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Privacy Policy

Last update: 30.05.2024

The confidentiality and safety of the information you entrust to us are of utmost importance. Please refer to this notice on the processing of personal data to find out more details about the personal data processing activities carried out by Startup Refugees (Phoenix ry) when accessing the platform available at the (“Startup Refugee Platform”).



The personal data Controller is Startup Refugees (Phoenix ry) (hereinafter referred to as "Controller" or "Startup Refugees"), a public institution headquartered in Helsinki. Business ID: 2765975-3, Sturenkatu 4, 00510 Helsinki- Finland



    • Personal data refers to any information about an identified or identifiable natural person; an identifiable natural person is a person who can be identified, directly or indirectly, particularly by referring to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more elements specific to their physical, physiological, genetic, mental, economic, cultural, or social identity. In the context of the Match CV, it refers to any information that can be used to identify an individual. This includes a wide range of details that are provided when registering into the Match, including:
      • Name and Contact Information:
      • Full name
      • Address
      • Phone number
      • Email address
      • Professional Details:
      • Work history (including company names, job titles, and employment dates)
      • Education history (including institutions attended and qualifications earned)
      • Certifications and licenses
      • Personal Details:
      • Date of birth
      • Nationality
      • Photograph:
      • A photo
      • Social Media Profiles:
      • Links to professional social media profiles such as LinkedIn
      • Links to personal blogs or portfolios that contain further personal details
      • Additional Information:
      • Hobbies and interests, if they reveal personal details
      • References who can attest to the applicant’s qualifications and character
  • Special category Data:
    • Racial or ethnic origin

  • Processing refers to any operation or set of operations that are performed on personal data or sets of personal data, with or without the use of automated means.
  • Data Subject refers to any natural person whose personal data is processed.



Startup Refugees shall take all measures necessary to ensure that the processing of data is carried out in accordance with the principles set out in (EU) 2016/679 (General Data Protection Regulation (GDPR)). Thus, the following principles are fundamental in the processing of your personal data by Startup Refugees:

  • Legality, equity, and transparency - we collect and process personal data only when we have a legal basis, and we use it exclusively for the purposes and under the conditions set out in this Privacy Policy. At the time of collecting and processing personal data, you will receive all necessary information related to the processing activities.
  • Purpose limitations - personal data is collected for well-defined, explicit and legitimate purposes, and further processing will not be incompatible with these purposes.
  • Data minimization - we collect only adequate, relevant, and necessary data in relation to the processing purposes.
  • Data accuracy - we take the necessary steps to ensure that personal data is accurate and that inaccurate data, given the purposes for which it is processed, is deleted or rectified.
  • Storage limitations - personal data is stored in a manner that allows identifying the person only for the time necessary to fulfill the purposes for which the data is gathered/ collected (processed).
  • Ensuring integrity and confidentiality – personal data is processed in a manner that ensures its adequate safety, including protection against unauthorized or illegal processing against accidental loss, destruction, or damage, by taking appropriate technical or organizational measures.




When you register on the Startup Refugees Platform, Startup Refugees will process personal data about you.

The personal data we process includes the categories mentioned below.

  • Information provided directly by the data subject on their own initiation:

This refers to your e-mail address, name, profile picture, billing address, home address, online identifiers, test results, candidates' skills, professional experience, studies, qualifications etc. - all this personal data is generally incorporated in the information necessary to deliver a product/service or to improve the relationship between us and our clients. The personal data collected directly is stored to ensure the possibility of performing other activities on our website.

  • Automatically collected information about you:

This is personal data, such as online identifiers, that is automatically stored by cookies and other session tools. For example, information about your IP address,etc. is part of this category of personal data. 

At the same time, for the purpose of responding to you as quickly as possible and for remembering the preferences expressed by you in previous browsing sessions on any of our pages, for making our websites as intuitive as possible and adapted to the device you are using while browsing, but also for preventing and solving any problems you may encounter while browsing, we may process your personal data such as: IP address, cookies, other online identifiers, UIDD (Unique Universal ID), browsing history, browsing searches, browsing dates and times, the device from which the browsing is performed, the type of Internet browser used for browsing, information about events occurring on your device (for example, navigation errors), information about the hardware settings of the browsing device, information about the location from which the browsing is performed.



We process your personal data for the following purposes and on the following grounds:


4.2.1 Execution of a contract to which the Data Subject is a party (GDPR - art. 6 paragraph 1 letter b)

By registering into our match system, you are entering into a contractual relationship with us, under which we agree to provide our services to you. These services include job matching and training opportunities, aimed to assist you in your career development. While our services are provided free of charge, the submission of your personal data and the subsequent processing of this data is necessary for us to fulfill our service commitment to you. In order to carry out the contractual relationship between you and Startup Refugees, we process your data for the following purposes:

- providing our services. This includes, for example, your identification, account registration, offering other free (or paid if relevant and provided by other providers) services you have requested, promotional items that will be sent to you as a result of a request made by you in this regard, communication with you about such services, as well as to notify you about changes to any services;

- informing the Users regarding their Account situation, including the validation, solving cancellations or problems of any nature related to the services.

- evaluation of the Users’ skills and aptitudes during tests and games;

- creating personalized CVs for Users;

- to communicate with you for opportunities, services and evaluating your skills and competences.


4.2.2 Consent of the Data Subject (GDPR - Art. 6 Paragraph 1 Letter a)

Once you create an account in the Match and make a CV, you will actively and willingly enter different types of personal data (including name, phone number, email address, date of birth, etc.) into the system. It is essentially your personal CV/Profile that you create on your own initiation and consent. We ensure that all the personal data will be secured in the Match, and we won’t share it with anyone unless specifically requested by you, while the sharing will 100% serve the purpose for which you created the profile and provided the data.

Based on your express consent, we process your data for the following purposes:

  • Communication of the results of the skills and aptitudes assessments, as well as of the CVs to the Clients (employers, if relevant mentors, trainers, coaches) - if you consent to the communication of this data to the Startup Refugees Clients, the data will be transmitted to them, who will then process this data as operators, in compliance with their own personal data processing policies and procedures.
  • Sending relevant opportunities, information, communications, and/or periodic alerts, using electronic services (e-mail, SMS, WhatsApp, or via direct phone calls).

The data subject has the right to update, edit, download, and remove the data. By downloading your profile, you can transfer your data. We strongly advise you to keep your profile and contact details updated, or contact us to do it for you. Please note that, in case staff of Startup Refugees directly make your profile/CV into the Match system (still with your own initiation and consent), you won’t be able to access your profile to edit, download, and remove; however, you are always welcome to contact and request from us.

4.2.3 Fulfillment of the Legitimate Interests Pursued by Startup Refugees (GDPR - Art. 6 Paragraph 1 Letter F)


To achieve the legitimate interests pursued by Startup Refugees, we process your data for the following non-commercial purposes:


Enhancing Service Delivery: To improve the effectiveness and efficiency of the services we provide to you, ensuring they meet the needs of the communities we serve.

Supporting and Managing Community Relationships: To maintain and enhance our relationship with you, ensuring that we can continue to support your needs effectively.

Program Evaluation and Impact Analysis: For statistical purposes and to analyze the impact of our programs, helping us to understand trends, outcomes, and areas for improvement in our service offerings.

Client Base Analysis: Managing and analyzing data on service usage to better understand the needs and behaviors of those we serve. This helps us to improve the quality, relevance, and reach of our services.

Feedback and Development: Using feedback and data to develop new programs and services that respond to the changing needs of our community and to enhance existing services.


4.2.4 Fulfillment of a legal obligation incumbent on Startup Refugees (GDPR - art. 6 paragraph 1 letter c)

We may process some of your data for the purpose of providing services on the basis of legal obligations or obligations imposed to the Startup Refugees Platform through the applicable law. For instance:

Contractual obligations: (reporting and accountability), as an NGOs we often need to report on our activities to funders to demonstrate that funds have been used appropriately and effectively. This may involve processing personal data to provide detailed reports on the outcomes of funded programs. Besides, we may need to do evaluation and Impact assessment, as funders may require evidence of the impact of their investments. NGOs might need to process data to assess and demonstrate the success and reach of their initiatives.




We do not use your personal data in the relationship with third-party companies, partners, or other persons outside of our organization. Our policy is to not disclose, share, sell or rent data to third parties, other than as set forth in this Privacy Policy.

The personal data regarding the candidates registered on the Startup Refugees Platform will be communicated to the Startup Refugees Network (employers, partners, coaches, training providers, mentors) only based on the express consent of the respective candidate.

We will not disclose your personal data to third parties or public institutions unless we are legally obliged to do so, the provisions of the previous paragraph of this section being applicable. We may disclose your personal data to third parties if you have given your consent or if there are other legal reasons for doing so.



Startup Refugees has implemented reasonable security policies and procedures to protect personal data against loss, misuse, alteration or unauthorized destruction.

To protect your data, we have taken technical and organizational measures, in particular against the loss, alteration or unauthorized access. The measures adopted shall be checked regularly and shall be constantly adapted to the latest applicable technical standards.

We use secure protocols for communication and data transfer (such as HTTPS), we use anonymization and pseudonymization, monitoring our systems for possible vulnerabilities and attacks.

Even if we try our best, we cannot guarantee the security of the information. We commit to notifying the competent authorities of any breaches of data protection, and we will notify you immediately if there is a threat to your rights or interests. We will do everything reasonably available to prevent the breach of security and to assist the authorities in the event that violations will occur.

Access to your personal data is limited to those who have a real need to know it. The persons who have access to the data have the obligation to maintain its confidentiality.

If you have an account on the Startup Refugees Platform, bear in mind that you must keep your username and password secret.



In relation to the processing activities carried out by Startup Refugees that concern you, you have the following rights:

- Withdrawal of consent. If you have been asked for express consent for particular processing, you may withdraw your consent at any time without the withdrawal affecting the lawfulness of the processing carried out on the basis of your consent before it was withdrawn (Which means any actions we took with your personal data before you withdraw your consent, remain lawful and valid.). Generally speaking, as the basic rule, you have the right to request deleting all types of data that we keep from you. We try to immediately, max within 3 weeks, erase all types of your personal data in our system (except situations when we have legal obligations to keep partially your data).

- Access. You may request access to your personal data. If you send us such a request, we will provide you with all the information about the purposes of the processing, the categories of data processed, the categories of recipients, the data retention period, your rights to rectify, delete or restrict the data accessed, if applicable. As the sole owner of your data, you also have the right and ability to directly extract, transfer, edit and delete your profile on the Match. Please note that once you are creating a profile the Match asks for more details from you, not all of them will be published on the downloaded CV. 

- Portability. If technically feasible, you may obtain a copy of the personal information we have registered about you. You can download your Match CV and use it independently. Please note that we may have other information from you, apart from what is shown on a downloaded CV, if technically possible, we can provide you with them too.

- Restriction. You may request a restriction on the processing (1) if you challenge the accuracy of the data, for the period necessary to verify the correctness of the data, (2) if the processing is illegal and you choose to restrict personal information, and not to delete it, (3) if you wish for us to retain your personal data, when you need such data to defend a right in court, or (4) if you objected to the processing, for the time period in which it is verified whether the legitimate rights of the operator prevail over those of that person.

- Amendment. You may request the amendment of inaccurate data concerning you or the completion of data insofar as it is incomplete. In most of the cases, you are also able to amend your data directly into the Match system.

- Removal. You may request the removal of your data if one of the following reasons applies: (1) if your personal data is no longer necessary for the purpose of the processing; (2) if you have withdrawn your consent to the processing of data, in the case of processing based on consent and there is no other legal basis for the processing. in situations where we provided you with a concrete service, like when you are hired with our help, or established a business with our support, we may have some legal obligations to keep some part of your data for reporting purposes; (3) if you have objected to the processing of the data and there are no legitimate reasons prevailing with regard to the processing; (4) if the data must be deleted in order to fulfill an applicable legal obligation; (5) if the personal data has been processed illegally. In most of the cases you are also able to delete your profile on your own.

- Opposition. You may oppose the processing of your personal data for reasons related to your particular situation, within the limits and under the conditions established by law.

- Automatic processing. You have the right to object to any automatic processing of your personal data, including profiling, as well as the possibility to oppose a decision based solely on automatic data processing, which may be exercised whenever there is a result of the profiling that produces legal effects that affect or may significantly affect the Data Subject..

- Complaint. You have the right to submit a notification or complaint to the National Authority for the Supervision of Personal Data Processing (

In order to exercise your aforementioned rights, please send us your request by e-mail to




Personal data processed for the purposes outlined will be retained for a period of two years. After this period, we will reach out to you to confirm whether you would like us to continue storing your data. You may withdraw your consent and request data deletion at any time prior to the mentioned period, you could also delete your data from the Match on your own. Other information (non-personal data) collected about you, will be stored for as long as necessary for accounting purposes or other obligations arising out of legal terms but not more than 10 years. Please be aware that if we provide you with a specific service, such as employment or entrepreneurship opportunities, certifications, or training, we are legally required to document, keep and report certain information. Consequently, we may need to retain some of your personal data, typically your name, surname, phone number, email address, type of employment and the contract, employer,  and in some instances, your home address and ID number. Depending on the duration of the project, we may hold this information for up to a maximum of 10 years.


At the end of the storage period we will remove/delete your personal data from Startup Refugees systems and records, and/or we will take steps to anonymize it so that you can no longer be identified based on it.



Occasionally, this notice on the processing of personal data may be updated. The changes are displayed on our website so that you may have permanent access to updated details on the processing activities related to the use of the Startup Refugees Platform. The current version will always be the one displayed on the website.



If you have any questions or need additional information about this privacy policy, please contact us at and we will do our best to answer as soon as possible.