Privacy Policy

Privacy Policy

Status: September 2019 This Privacy Policy contains information about how we process your personal data in the context of the website and  (the “Website”).

1. General

Controller for the purposes of the General Data Protection Regulation (“GDPR”) regarding the processing of personal data in the context of the Services is True Node GmbH, Christburger Straße 39, 10405 Berlin, Germany („TrueNode“, “we”, “us” or “our”). By means of this Policy, we explain to you which data we collect in the context of our Services, for which purposes and how we use (“Use”) those data, and which rights you have. Please note that our Services may contain links to other providers’ websites whose content we do not control, and which are not subject to this Privacy Policy

How we use your personal data:

We process your personal data only if it is necessary for providing a functional website, our contents, and our services.

2. Visiting our Website

The use of our Services is possible without providing your personal data to us. Regarding the Website: As is the case with most websites, our systems, however, do automatically register every access to or visit of our Website and temporarily store this information in a “log file.” Among the data saved in this context are in particular:

  • IP-address of the accessing computer
  • Name and URL of the accessed file
  • Date and time of the access
  • Access status/HTTP status code
  • Amount of data transferred for each transmission
  • Browser identification data.

2.2 Contact / Enquiries

If you contact us about our services, the emails you send may include information about you, such as your name, address, age, gender, email address and your enquiry. We use this information to carry out the following: In line with the legitimate interest we have in promoting our business, we will process your enquiries to provide you with information about the services we offer. This might include replying to your enquiry, or sending you invites to our events. We use Copper CRM to process your email address and information supplied by you in the course of an enquiry through the website, and to send you invitations and marketing materials. The legal basis for the processing of the aforementioned personal data is: Article 6 (1) sentence 1 (f) GDPR (legitimate interests). Our legitimate interest is based on the fact that we can only perform the action the user asked for (e.g. answering an enquiry) if we process his/her personal data. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services. You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.

2.3 Marketing

We might use your information to send you marketing emails, in accordance with our legitimate interests, about our services or events which are similar or related to those which you have previously received (or attended, in the case of events). We may also disclose your name and contact information to our relevant affiliates who provide the same services, to enable them to market their services and/or events to you.

In order to be removed from this mailing list, please contact us at or click unsubscribe at the bottom of each marketing email.

2.4 Recruitment

When you apply for a job on this site or via, the personal data contained in your application will be collected by us. Your personal data was either provided by yourself or obtained from publicly available sources (e.g. LinkedIn) or provided to us by someone who referred you for potential employment.

Your personal data will be processed for the purposes of managing our recruitment related activities in line with our legitimate interests, which include evaluating your candidacy/application for employment with us, setting up and conducting interviews and test for applicants, evaluating and assessing the results thereto, and as in otherwise needed in the recruitment and hiring processes.

2.5 Analytics / Cookies

Our website uses cookies. Cookies are small text files that are stored in your Internet browser for the purpose of technical session control. They allow us to analyze anonymous user behavior which helps optimize our Website design. Cookie data cannot be associated with a specific individual. The Services use cookies to the following extent: Transient / Session cookies, Persistent / Setting cookies, and Analysis cookies. Transient cookies are automatically deleted when you close your browser. This includes, in particular, the session cookies. These store a so-called session ID, which identifies user sessions in the browser. Session cookies are deleted when you log out or close your browser. Persistent cookies help the Services remember your information and settings when you visit them in the future. They are automatically deleted after a specified period, which may differ depending on the cookie. We also use cookies on our Services which enable an analysis of the user’s surfing behavior. The legal basis for the processing personal data related to cookies is: Article 6 (1) sentence 1 (f) (legitimate interest). Our legitimate interest is based on the above-mentioned purposes, to optimize Services use and to improve your user experience.

2.6 Analytic Tools

2.6.1 Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how you use the Services. The information generated by the cookie about your use of the Services will normally be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on the Services, your IP address will be truncated within the area of member states of the European Union or within other contracting states to the Agreement on the European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of the Website for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services for the website operator relating to website activity and internet usage. The IP address that your browser transfers within the scope of Google Analytics will not be associated 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 all functions of the Services. You can also opt-out from the storage by Google of the data that is created by the cookie and is related to the use of the Services (including your IP address) and the processing of such data by Google by downloading and installing the Google Analytics opt-out Browser add-on available under here.
The legal basis for the processing of the data described in this section 2.6 (to the extent such data is to be considered personal data) is Article 6 (1) sentence 1 lit. f GDPR (legitimate interests). The legitimate interests to use such data is that we use and analyze the respective data to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services and to help personalize your user experience. Google is committed (to the best of our knowledge) to the EU-US Privacy Shield Agreement published by the US Department of Commerce on the collection, use, and retention of personal data from EU member states. Google has declared through certification that it will comply with the relevant privacy shield principles. The European Commission expects the US to provide adequate legal protection for personal data transferred from the EU to self-certified organisations in the US under the Privacy Shield. Further information can be found here.

2.6.4 Legal Basis

The legal basis for the processing of the data described in this section 2.6 (to the extent such data is to be considered personal data) is Article 6 (1) sentence 1 lit. f GDPR (legitimate interests). The legitimate interests to Use such data is that we use and analyze the respective data to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services and to help personalize your user experience.


Your personal data on our website is used and shared by all our offices around the world. We keep your information confidential but may share it with our shareholders, affiliates and business partners. Whenever we transfer your personal data outside of the European Economic Area (EEA) we ensure that we have standard contractual clauses in place as a safeguard for this transaction.

We may also disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy, provided that they do not make independent use of the information and have agreed to adhere to the rules set out in this privacy statement.

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

4. How long do we store your Personal Data

As far as the other stipulations of this Policy do not prescribe a certain amount of time that we need to retain your personal data, we only store personal data generated in the context of using our Services for as long as is necessary to process your requests or enquiries, and after that only to the extent of and if required by statutory storage obligations. If we no longer need your personal data for the above-mentioned purposes, it will only be stored for the legal retention period and they will not be processed for other purposes.

5. Your rights

You have the right to request information from us at any time about your personal data stored by us. If the legal requirements are met, you also have rights vis-à-vis us to request from us access to and rectification or erasure or restriction of processing concerning your personal data or to object the processing of your personal data. If you have given your consent to the use of personal data, you can revoke such consent at any time (for the future). If you believe that the processing of your personal data by us is in breach of the applicable data protection laws, you can issue a complaint with the competent supervisory authority for data protection.

6 Contact

For all data privacy questions (incl. assertion of your rights as per Section 5 of this Privacy Policy), you can contact us at You can also contact our data protection officer directly. The contact details of the data protection officer are:

Datenschutzbeauftragter der True Node GmbH


True Node GmbH

Schönhauser Allee 149,

10435, Berlin


7. Data Security

We maintain current technical measures to ensure data security protection, especially to protect your personal data against risks during transmission and against third-party access. These measures will be updated according to the latest technical developments.

8. Changes

This policy may be updated from time to time. We will notify you of any changes by posting the new policy here and, where feasible, by letting you know by email.