Employee Privacy Notice

Employee Privacy Notice

kyu Creative Community Platform

Thank you for being a part of the kyu Collective (“we”,”us”).

kyu is a collective of individuals that have come together to invent, design, prototype, and make. kyu’s potential lies in Creative Communities that value Creative Intelligence – which we define as how we exercise our collective curiosity and imagination to acquire, generate and apply knowledge and insights that create new value out to the world. As kyu explores new forms of communities, we are currently in the process of setting up a platform to bring together new communities, potentially linked by geographies, beliefs, professional practice and common interests.

For this purpose, we’ve gathered specific personal data about you as described below and this privacy notice serves to inform you of what data we process about you as employees, to what extent this data could be shared and what rights you may have in regard to our processing of your data.

Provision of the Creative Community and sharing of Employee Data: We will provide a platform for our Creative Community that allows centralized gathering of Employee Data. All kyu group entities have provided employee name, business level, tenure, work history, discipline, skills, office location and past client projects (“kyu Employee Data”) to the Creative Community Platform. Additional information, such as digital images and likenesses, personal biography, place of residence, passions, interests, and other details (“Voluntary Employee Data”), may be provided voluntarily to the Creative Community Platform by kyu entity employees through a series of questions relating to their own unique characteristics and experiences (“Profile Builder”).

With the help of a service provider, the kyu Employee Data and Voluntary Employee Data (together “Employee Data”) is mapped to graphically display common employee characteristics and to create respective employee clusters. All kyu Collective entities will have access to the Employee Data of their own.

The provision of Employee Data to the Creative Community Platform is compatible with the original purpose of the data collection of the kyu Collective entities’ data processing for the employment relationship. The Creative Community serves to foster community and new opportunities among kyu Collective entities, which involves the administration of Employee Data/on a group level. Respective Talent/HR administration is also a main purpose of the Employee Data processing by individual kyu Collective entities. We do not expect any adverse effects for the employees, taking into account the non-sensitive nature of the Employee Data. Rather, you will be able to benefit from the community and opportunities enabled by the Creative Community Platform. Further, we have legitimate interests to provide the Creative Community Platform and allow access to the Employee Data for all kyu Collective entities. The Creative Community Platform facilitates communication and community among the kyu group entities. Further, every kyu Collective entity providing Employee Data has legitimate interests to become aware of ongoing or envisaged projects where their employees can provide support with their knowledge and experience.

We jointly decide on the purposes described above as well as the means of the processing in the Creative Community Platform. We concluded an agreement laying down our respective responsibilities for compliance with data protection obligations. According to this agreement, we will use the personal data in the context of the purpose of the collaboration only, unless processing would be permitted otherwise by the applicable data protection law. Further, it is the responsibility of each kyu Collective entity engaging in the Creative Community Platform to comply with the applicable data protection law requirements, particularly to answer a data subject request directed to it in an appropriate and legal manner. We will mutually assist each other with reasonable means in complying with the data protection law obligations.

Engagement of service providers: We will share Employee Data/Voluntary Employee Data with the following:

Graph Commons, 63 Flushing Ave. (Brooklyn Navy Yard), New Lab, Building 128, Brooklyn, New York 11205, US, a cloud vendor that serves to graphically display common employee characteristics and to create respective employee clusters.

Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, U.S., a vendor where Employee Data will be stored.

Heroku, 415 Mission Street, Suite 300, San Francisco, CA 94105, US, a service provided by Salesforce that allows us to operate applications in the cloud.

These service providers process the Employee Data exclusively on our behalf upon our instructions. They are prohibited from using the information for their own individual purposes. The obligations are laid out in respective data processing agreements.

Cross-border transfers: The use of the Creative Community Platform and the engagement of the service providers above involves that Employee Data of EU employees is shared with kyu Collective entities and/or service providers located outside the EU. We’ve implemented adequate safeguards to ensure that the Employee Data is subject to an appropriate level of data protection.

Storage period: When Employee Data is no longer needed for the purposes indicated above, it will be deleted, unless we are legally obliged or permitted to further retention.

Your rights: Depending on the circumstances of the specific case, you may have the following data protection rights:

  • to request information about and access to your personal data and/or copies of this data, in a structured, accessible, and machine-readable format when applicable, as well as the direct transfer of your personal data to another controller, as far as this is technologically possible;
  • to request the rectification, erasure or limitation of processing of your personal data as far as its use is not permitted under applicable data protection law; in cases in which the data is processed by third parties, we will forward your request for rectification, erasure, or restriction of the processing to these third parties unless this proves impossible or involves disproportionate effort;
  • to not be subject to a decision that is exclusively based on automated processing if this decision has a legal effect against you or materially affects you in a similar manner;
  • to take legal action or call on the competent supervisory authorities if it is your opinion that your rights have been violated because the processing of your personal data did not comply with the provisions of data protection law;
  • In addition, you have the right to object to the processing of your personal data at any time, if we are processing your personal data for the purpose of pursuing our legitimate interests and there are reasons arising from your particular situation.

If you have any questions regarding this privacy notice or your data protection rights, you may contact Talent/Human Resources at your employing kyu entity, or kyu directly at datainquiries@kyu.com