Project Firefly Privacy Policy

 

Last updated on August 22, 2018.

This Privacy Policy (the “Privacy Policy”) describes the principles based on which Project Firefly (hereinafter “Project Firefly”, “we” or “us”) processes personal data collected through this website (the “Website”). It informs you in particular about what personal data we collect, for which purposes it is processed, with whom it may be shared, for how long we retain it and which rights and options relating to the use of your personal data you may have. “Personal data" or “Personal information” means any and all information relating to an identified or identifiable natural person, for example name, address, e-mail address, an online identifier or the phone number.

This Privacy Policy applies as far as the processing activities are not subject to other privacy policies or are provided for by applicable law.  Moreover, this Privacy Policy forms an integral part of the Terms and Conditions of Project Firefly.

Please read this Privacy Policy carefully. By signing up for an account or otherwise by using the services of our Website you consent to the collection and processing of your personal information as set forth in this Privacy Policy.

1. Controller of Personal Data and Contact Details

Controller of your personal data collected through this Website is:

Project Firefly

Rorschacherstrasse 43

9000 St. Gallen, Switzerland

Email:      info@project-firefly.com

Telefon:   +41 71 534 14 07

Project Firefly determines the purposes and means of the processing of your personal data and is therefore responsible for the processing and use of your personal data as described in this Privacy Policy. If you have any questions or concerns regarding privacy or how we handle your personal data, kindly contact us at any time by sending an email to info@project-firefly.com.

2. How do we process personal data

Any personal data collected through the Website is processed in accordance with the provisions of applicable data protection and privacy laws. We collect and process personal data carefully and for the purposes described in this Privacy Policy. In accordance with applicable law, we may also use your personal data in other ways as described in this Privacy Policy. In such event, we will provide specific privacy policies or notices at the time of collection and obtain your consent where necessary. We always seek, to the extent reasonably possible, to collect information on an anonymized or pseudonymized basis so we cannot recognize your identity.

3. What kind of personal data is collected?

Project Firefly seeks to create a vibrant sustainable community among driven, emerging Thought Leaders. In order to fully participate, join discussions on our Website and submit essays’s for review, you must create a personal account.

a. Information provided by you

When you sign up for a personal account as Contributor on the Website, we may ask you for the following different kinds of personal information: (i) basic information, (ii) account information, (iii) educational background, (iv) career history and (v) additional information. Such personal information includes the following personal data:

  1. Basic information includes: first, middle and last name, username, date of birth, gender, country of residence, nationality, email address, University, most recent degree and expected graduation date.
  2. Account information includes: profile picture, CV/Resume, short biography.
  3. Educational background information includes: University, most recent degree, subject of study, expected graduation date, advanced qualifications, language skills, extracurricular activities.
  4. Career history information includes: places of work, positions, preferred area of work, career aspirations, organization memberships.
  5. Additional information includes: social media profiles (e.g. Linked In, Facebook, Twitter, how you did hear about us, topic of interest.

    Additional personal data might be collected in case of a participant winning a competition or challenge (e.g. for travelling to an event such as World Economic Forum). Such additional personal information includes the following personal data:

  6. Scan of university matriculation, scan of passport (e.g. for winners travelling), contact details, home address, phone number, any visa restrictions, health and food restrictions and accommodation restrictions, team Bio, up to date resumé, university name, team member names, degrees studied, languages spoken, industry experience, indicate team member locations during a consulting project and Skype ID

Moreover, each Contributor will be assigned a User ID - Number to better anonymize information (e.g. if necessary for providing information for grading or restricted information to corporate partners).

During the registration process, you are not required to provide all the above mentioned data and you may choose to leave some of the registration fields blank and not to provide certain information to Project Firefly. Some of the personal data, however, needs to be provided and such data is specifically marked (*).

The providing of such personal data will always be voluntary based on your consent. Without providing such information you may, however, not be able to use the services or purposes for which the information is requested.

b. Information automatically collected

Project Firefly collects and stores information that your browser automatically transmits to us in "server log files" when visiting our Website. These may include the following data:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address
  • These data will not be combined with data from other sources.

This data is collected automatically and cannot be deactivated. It is stored by us until it is automatically deleted within three months at the latest.

4. For what purposes and on which legal basis is the personal data processed?

a. Purposes of processing for information provided by you

The personal data collected during the registration process, by interacting on the Website, and uploading Submissions is used for the lawful purposes which were evident from the circumstances or indicated at the time of collection which may include the following purposes:

  • for building a community among driven, emerging Thought Leaders by bringing together employers and students and recent graduates (who graduated within the last three years) and young professionals (who graduated more than 3 years ago) from universities around the world;
  • to publish and share a limited version of your profile on the Website; it details your personal bio and limited education history such as most recent degree and university;
  • to publish and share your profile with other contributors which can see all that the public profile displays and when signed in, they can additionally see further education information as well as your career history information. Project Firefly therefore recommends not to post and/or disclose sensitive Personal Data on these publicly accessible areas;
  • to enable you to build your unique network, to discuss challenging topics, debate and contribute to get ahead in your career;
  • to provide you with exclusive opportunities to earn interviews, projects, internships and jobs with leading companies around the world;
  • to publish and share Submissions, e.g. essay’s or videos, with the community on our Website. If your Submission is published, then it will be displayed together with your first and family names, including a limited version of your profile, on the Website and will then be publicly accessible;
  • for communicating with you (e.g. via email) and sending you with your agreement information we think may interest you, e.g. about new competitions and challenges;
  • for market research purposes and for sending you surveys and other questionnaires for receiving your opinion;
  • for statistical or analytical purposes in pseudonymized or anonymized summary form (e.g. to find out how many people from which countries participate in our competitions);
  • to provide examples of success stories to potential new corporate partners;
  • to inform universities and professors of their students’ progress and success (e.g. if they win a competition or a challenge);
  • for other lawful purposes where such processing was evident from the circumstances or indicated at the time when the personal data was collected.

 

b. Purposes of processing for information automatically collected

The data automatically collected as described above is processed for the purposes of proper functioning of our Website, e.g. for establishing a connection, ensuring stability and uninterrupted system security, to improve our services, for statistical analysis, e.g. in the event of attacks on the network infrastructure on which the Website is made available.

c. Legal basis for processing

The legal basis for processing your personal data for the purposes described above (see para. 4 lit. a and b) may be based on the following legal grounds:

  • your consent, only if it may be withdrawn at any time;
  • for the performance of a contract with you or for the intention to enter into a contract;
  • to comply with a legal obligation (e.g. for purposes of legal investigations or proceedings), or
  • for the purposes of our legitimate interests, including:
    • efficient and effective support, maintenance of contact and other communication with you outside of the processing of contracts;
    • advertising and marketing activities;
    • efficient and effective improvement of existing services and development of new services;
    • efficient and effective protection of data, secrets and assets of or entrusted to us including the protection and safety of our IT systems;
    • maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further development of the Websites and other IT systems;
    • compliance with legal and regulatory requirements and internal rules;
    • concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of claims and actions against Project Firefly, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defense against legal actions.

Should the processing be based on your consent or our legitimate interests, you may withdraw consent or object to that processing at any time by contacting us directly at info@project-firefly.com. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal.

5. Who has access to your personal data and with whom do we share your data?

We take necessary measures to ensure only authorized people will have access to your personal data to fulfill the purposes for which your personal data was collected.

In accordance with applicable laws, we may share your personal data with the following categories of recipients for the purposes of processing as described in this Privacy Policy on our behalf or for their own purposes:

  • our corporate partners, contributors (see point 6) and other partners (e.g. universities or professors);
  • our trusted third-party service providers, including processors;
  • providers of technical services;
  • website designers and developers;
  • the public, including social media sites of Project Firefly, industry organizations, associations, organizations and other committees;
  • professional advisors and auditors;
  • acquires or parties interested in acquiring business units, companies or other parts of Project Firefly;
  • governmental administrations, courts and other competent authorities;
  • other parties in potential or actual legal proceedings.

We choose our partners and data processors carefully and only upon sufficient guarantees they have appropriate technical and organizational measures in place. Our partners are subject to confidentiality requirements and may use your personal data solely to the extent necessary to fulfill the purpose for which your personal data was collected, except as otherwise required by law.

6. Personal data disclosed to Corporate Partners and other Contributors

The Corporate Partners will be informed of all relevant new Submissions. If a Submission is made in connection with a competition, the Corporate Partner sponsoring the competition chooses what personal data they would like to be made available to them. This normally includes the following personal data:

  • Names (e.g. of top performers), email addresses, submissions, university, residence, nationality, degree and education status e.g. graduate or student.

This may result in the Corporate Partner, in the first instance contacting the Contributor directly. All other Corporate Partners only have access to limited personal data such as your place of study, subject of study, your university degree, language skills and other data which do not allow conclusions concerning the identity of the individual Contributor ("Limited Personal Data").

In any event, the Corporate Partners may use the personal data solely for recruitment and career development purposes. For example, a Corporate Sponsor may contact a Contributor for an internship or for a special recruiting event. If the Contributor has agreed, then the Corporate Sponsor may also use the personal data of a Contributor for market research purposes, for example for surveys. The Corporate Partner is not allowed to use personal data for commercial purposes nor to sell personal data to any third party.

Since the Website is accessible for Corporate Partners all over the world, your personal data might also be transferred to or accessed by a Corporate Partner domiciled outside Switzerland (see para. 7). Project Firefly has entered into an agreement with each Corporate Sponsor in order to afford an adequate protection of your personal data. However, by making your respective Submissions over the Website, you acknowledge and agree that your personal data is accessible by Corporate Partners domiciled outside Switzerland.

Based on your published Submissions other registered Contributors can send a request directly to you to connect with you. It is then in your sole discretion whether you want to connect with other Contributors and disclose further personal information.

After the contact between you and Corporate Partners/other Contributors has been established, you may interact directly with Corporate Partners/other Contributors. For personal data or any other data that is disclosed to a Corporate Partner/another Contributor directly by you and not through the Website, these data protection regulations will not apply. We take no responsibility with respect to such personal data or other data that is directly disclosed from you to a Corporate Partner/another Contributor and we therefore recommend being cautious when providing Corporate Partners/other Contributors with sensitive Personal Data.

7. Where will your personal data be stored and international data transfers?

We may transfer, store and process your personal data in data locations around the world, where our partners or our third-party providers are located, for example in the US where your data will be stored on Armor servers, located in Richardson, Texas. Therefore, we may transfer your personal data outside the EEA and Switzerland if it is required for the data processing described in this Privacy Policy in accordance with applicable data protection and privacy laws. 

If personal data is disclosed to countries that do not guarantee an adequate level of protection, we will ensure adequate protection of data disclosed by putting appropriate safeguards in place, e.g. on the basis of EU standard clauses adopted by the EU-Commission, binding corporate rules, on the basis of the EU-U.S. and the Swiss-U.S. Privacy Shield Framework for transfers to third parties based in the U.S., or transferring data pursuant to consent, conclusion or performance of a contract, or in connection with the determination, exercise or enforcement of legal claims according to applicable data protection laws.

8. For how long will your personal data be stored?

We retain your personal data for as long as necessary to fulfill the purposes for which your personal data was collected. For this reason, we will delete or anonymize personal data (or equivalent) once they are no longer necessary to achieve the purposes, subject however (i) to any applicable legal or regulatory requirements to store personal data for a longer period (e.g. for tax or accounting reasons), or (ii) to establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal holds, which we may enforce to preserve relevant information.

On that basis, we normally process personal data subject to the following rules and obligations:

  • As a rule for contract related personal data (including business records and communication), we retain personal data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship;  
  • As a rule for operational data containing data (e.g. protocols, logs), we retain personal data for a period of 3 - 12 months;
  • Personal data relating to your user account will be stored for as long as you have a personal account with Project Firefly. Once you have deleted your user account, all your personal information will be deleted, and your Submissions will be taken off the Website unless we have received your consent to continue to publish your Submission(s) on our Website.  
9. Cookies

When you access or use the Website, we may place so called cookies – small text files – or similar tools on your computer. We use these cookies to recognize you as a user of the Website, to customize content, to improve the Website's performance and to enhance your user experience.

a. Categories of cookies we use

Depending on their function and intended purpose, cookies we may use can be divided into the following categories: functional cookies, performance cookies, and advertising cookies.

  • Functional cookies: These cookies serve a variety of purposes to the presentation, functionality and performance of a website and in particular to enhance visitors’ experience and enjoyment of the Website. They enable a website to save details that have already been provided (e.g. user name, your location or language choices) and offer the visitors improved, more personal functions. Functional cookies are used, for example, to remember things like your log-in information. These cookies cannot track your movement on other websites.
  • Performance cookies: These cookies are used to collect information how a website is used – for example how visitors came to our website, which pages a visitor opens most frequently, how they navigated around our website during their visit and whether they receive error messages from a page. We also may use these cookies to provide us with certain statistical and analytics information, such as how many visitors came to our website. These cookies are used to monitor the level of activities of the Website and to improve the performance of the Website.
  • Advertising cookies enable the website owner or a third party service provider to place ads on the website of the website owner or on websites of third parties with products that the user may like, so that the advertisement the user see can be more relevant to the user’s preferences or interests (sometimes referred to as "targeting cookies"). They may also be used to evaluate effectiveness of advertising and promotion.

These cookies may be placed by us or a third party on our behalf. To learn more about cookies and how they are used, please visit: http://www.allaboutcookies.org/.

b. Google Analytics

On your computer, we store the cookies of Google Analytics. Google Analytics is a web analytics service that is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The cookies of Google Analytics allow an analysis of the use of the website by you and other website users that Google provides to us. The information generated by the cookie about your use of our Website is usually transmitted to a Google server in the USA and stored there. This information may include number of times a user visits the website, dates of the first and last visit, duration of the visits, the page from where the user accessed the website, the search engine the user used to access the website or the link they clicked on, the place in the world from where the user accesses, etc. Google will use this information on our behalf to evaluate your use of the website, to compile reports on your website activity, and to provide other services regarding website activity and internet usage for us.

We have activated the IP anonymization feature on our website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this Website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under this link (https://tools.google.com/dlpage/gaoptout?hl=en).

In addition, Google may monitor the use of the Website by the user and combine this data with data from other websites monitored my Google which the user has visited and Google may use these findings for its own benefits (e.g. to control advertisement), under their responsibility and based on their own privacy policies that can be found here (https://policies.google/).You can learn more about Google Analytics and how they process personal data here ( https://policies.google.com/technologies/partner-sites). 

c. Social Network Plug-ins

Our Website provides the user with social plug-ins from various social networks, e.g. Facebook, Twitter, Youtube or LinkedIn. In the default setting of the website plug-ins are deactivated and, as a result, do not send any data. The user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during his or her visit on the Website, which allows the provider to be aware of the user's visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the social media provider according to data protection and privacy laws and according to its data protection policies published on its website (such as www.facebook.com, www.twitter.com., www.youtube.com or www.linkedin.com). Please read carefully the privacy policies of your social networks for detailed information about their collection and transfer of personal data, your rights, and how you can achieve satisfactory privacy settings.

d. List of Cookies we use

Please find hereafter a complete list of the cookies currently used on this Website including the information about their purposes and their expiration.

Provider Name Category Purpose and expiration
JavaScript has_js Functional cookie used to indicate whether or not the visitor’s browser has JavaScript enabled so that content can be delivered in a suitable way. They expire when you close the browser.
Google Analytics _gat Performance cookie business performance monitoring. Used to throttle request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.
Google Analytics _gid Performance cookie Google Analytics for business performance monitoring. Used to distinguish users and to track how they navigate the website to improve the website ‘s usability. It expires after 24 hours.
Google Analytics _ga Performance cookie Google Analytics for business performance monitoring. Used to distinguish users and to track how they navigate the website to improve the website ‘s usability. It expires after 2 years.

 

e. Management of Cookies

If you do not want to accept these cookies you can change your browser settings to delete or prevent certain cookies from being stored on your computer or device without your consent. Each browser is different in the type, how it manages the cookie-settings. This is normally described in the «Help» menu of each browser. You will find this information for the most popular browsers under the following links:

Please note, however, that by disabling the cookies function in your browser settings, you may no longer be able to use all the functions of the Website.

f. Legal basis

The legal basis for the processing of personal data by using cookies or social network plug-ins are our legitimate interests in operating, protecting, analyzing, optimizing, and improving our Website.

10. Email mailing and other business communication

We will use your email address for sending you information about new challenges and other commercial communications that may be of interest for you as long as you will be subscribed to the email mailing list. You can unsubscribe from such emails at any time, by clicking the highlighted link “unsubscribe from this list” at the end of each email or by contacting us directly via email at info@project-firefly.com.

Moreover, we use the email service of MailChimp, a third-party data processor, operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States. MailChim manages our email subscriber list and send emails to our subscribers on our behalf. MailChimp stores your data in the US and may collect and process your data in accordance with their Privacy Policy. You can find out more about how MailChip collets and processes your personal data in the Privacy Policy available here (https://mailchimp.com/legal/privacy/).

In addition, MailChimp provide us with information such as clicking rates, bounce rates, countries, and states. This information is not used to identify a specific individual, and therefore they are used pseudonymously.

MailChimp has certified  to the EU-U.S. and Swiss-U.S. Privacy Shield Framework to ensure an adequate level of protection (see their certification here). When you sign up to our email mailings, you agree to your data being stored and processed in this way.

11. Security of your Personal Data

In order to protect your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure or access, we have implemented technical and organizational security measures. We adapt these measures from time to time and try to provide a high level of security at all times.

We may use third party data processors to collect and process your personal data on our behalf. Any data processors commissioned by us will only process your personal data in accordance with our instructions and are legally obliged to adhere to strict security procedures when handling personal data.

Nevertheless, you have to be aware that, despite our best efforts, transmission of information via the internet is not whole secure and no security measures are perfect or impenetrable. In addition, and in order to help maintain a high level of security, we kindly ask you to keep your username and password confidential and not to disclose it to third parties. Although we do our utmost to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is done so at your own risk.

12. Third-party privacy policies

Please note that if you click on the link to a third-party website (e.g. google or social media websites), you will be taken to a website we do not control, and our Privacy Policy will no longer be in effect. Your browsing and interaction on any other website is subject to the terms of use and privacy policies and notices of such third-party websites. We strongly encourage you to read the terms of use and privacy policies and notices of other websites carefully before providing personal data through that website. We are not responsible or liable for the information or content on such third-party websites.

13. What are Your Rights

You can contact Project Firefly anytime and request that we inform you about all personal data that we have collected and stored about you. In addition, you may request that we correct, restrict or delete such personal data as well as to object to the processing of personal data. Please note, that if you request us to delete your personal data, you will no longer be able to use the Website and the services offered therein. By accessing your account on the Website, you have at any time the opportunity to correct, amend or delete your personal data. Of course, you may delete your personal account at any time. Please note, however, that upon deletion of your user account, you will not be able to use the services for which the information was collected and also Corporate Partners and other Contributors will no longer have access to your personal data.

Should the processing of personal data be based on your consent, you may withdraw consent at any time. However, please note that a withdrawal does not affect the legitimacy of the processing activities that took place before you withdrew your consent. Moreover, if you withdraw consent, you will no longer be able to use the Website and the services offered for the purposes the personal data was collected. In countries of the EEA you may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer.

Requests in this respect shall be submitted to us via the following email address: info@project-firefly.com. Project Firefly reserves the right to restrict the rights of the affected user in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data. 

If we refuse your request or if you are not satisfied with our processing, you are also entitled to lodge a complaint with the competent supervisory authority and seek a judicial remedy. For users located in Switzerland, the competent authority is the Federal Data Protection and Information Commissioner in Switzerland (http://www.edoeb.admin.ch). For the users located in the EU Countries, a list of the supervisory authorities can be found here.

14. Where to contact

If you have any questions regarding this Privacy Policy, the handling of your personal data or would like to exercise your rights, please contact:

Project Firefly, Rorschacherstrasse 43, 9000 St. Gallen, Switzerland by sending an email to info@project-firefly.com.

We take your concerns seriously and we will try to resolve any issue relating to your personal data for you as soon as possible in accordance with applicable laws.

15. Changes to this Privacy Policy

Project Firefly may change this Privacy Policy from time to time and without prior notice or announcement. All changes to this Privacy Policy are effective when they are posted on the website unless indicated otherwise. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our website or in another appropriate manner prior to the change becoming effective and update the ‘effective date’ at the top of this page.

We recommend that you regularly check this Privacy Policy when you access your personal account.

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