Privacy policy

1. Controller

The controller is Santifaller Growth Consulting LLC, 1209 Mountain Road PI NE, Albuquerque, NM 87110, USA, represented by Marvin Santifaller. Contact: kontakt@grow-with-us.com. Further details are given in the legal notice.

2. Hosting, server log files and audience measurement

This website is hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. When the pages are accessed, the server automatically records access data in log files: IP address, date and time of access, page requested, volume of data transferred, browser type and operating system. This data serves the technical provision and security of the service. The legal basis is our legitimate interest in a secure, functioning service (Art. 6(1)(f) GDPR). The data is not combined with other data sources.

From the same log files we compile our own, purely statistical overview: page views, approximate visitor numbers, referring page, browser and device type, and the approximate origin at country and city level. The location is determined on our own server using a locally stored database; no request is made to any third party. The IP address is shortened in the process, so the statistics cannot be attributed to a particular person. No cookies are set, no measurement script is loaded and no data is passed to third parties. Log files are deleted automatically after 30 days; only the aggregated overview remains. The legal basis is our legitimate interest in data-minimising audience measurement (Art. 6(1)(f) GDPR).

3. No cookies, no tracking, no third-party resources

This website sets no cookies, uses no analytics or tracking services, and loads no fonts, images or other resources from external servers. Everything is served from the same server as the page itself. No data is therefore transferred to third parties.

4. Contact by email

If you write to us by email, we process the details you provide — such as your name, email address, company and the content of your message — solely in order to deal with your enquiry (Art. 6(1)(b) GDPR where a contract or its preparation is concerned, otherwise Art. 6(1)(f) GDPR; our legitimate interest is answering your enquiry). Our mailboxes are hosted by our domain's mail provider, checkdomain GmbH in Germany, which operates them on our behalf (section 11). Beyond that, we do not pass your data on to third parties. For emails to jobs@grow-with-us.com, section 7 applies in addition; for emails to kontakt@grow-with-us.com, section 5 (“Contact enquiries”).

5. Contact and application form

When you submit the form on the contact page, the details you enter — your name and email address and, where you provide them, company, phone number, the support you are looking for, languages, preferred start, scope, tools in use, budget and your message — are transmitted to our own server and stored there as a contact enquiry (see “Contact enquiries” below). With the application form on the page for freelancers, your name, email address and — where you provide them — phone number, place of residence, availability, a link to your online profile and your message are transmitted to our own server and forwarded from there by email. The application goes to jobs@grow-with-us.com; at the same time we create it as an application in our applicant portal (section 7) — with your name, email address and, where provided, phone number. The other details are in the email, which we assign to the same application. If an application is already in progress under your email address, we do not create a second one but assign the new details to it. We use the application solely to assess a possible collaboration.

Confirmation and applicant profile. After submitting, you receive an email confirming receipt. It contains a link with which you can complete your applicant profile at jobs.grow-with-us.com without a password (for example experience, skills, availability, CV); this is voluntary. The link is valid for 14 days; after that we may invite you again. If no collaboration comes about — including if the invitation expires unused — we delete the application including emails and documents six months after the process has ended.

Contact enquiries. We store your enquiry in our own application, which only our management can access. You receive an email confirming receipt, and we receive a notification about the new enquiry. We use your details solely to answer your enquiry and to prepare a possible collaboration. We send our replies from kontakt@grow-with-us.com. Emails you write to this address are fetched automatically into the same application and assigned to your enquiry so that the whole conversation is in one place; the mailbox itself is hosted by our domain's mail provider. If no collaboration comes about, we delete the enquiry including its messages automatically 24 months after the last contact, and obviously unwanted submissions (spam) after 30 days. If the enquiry leads to a collaboration, we keep it for the duration of that collaboration and thereafter within the scope of statutory retention obligations. You can request earlier deletion by email at any time. The application runs on our own servers (section 10). If it is unavailable, our server forwards your enquiry by email to kontakt@grow-with-us.com instead; you then do not receive an automatic confirmation, and we record the enquiry manually.

Mandatory details. We need your name and email address to handle your enquiry or application and to reply to you; without them this is not possible. All other details are voluntary.

Talent pool. The form does not add you to our talent pool (section 6). We may offer it to you later, for example during or after your application process; you are only added if you then consent yourself at jobs.grow-with-us.com.

Handling your enquiry or application — including creating the application in the applicant portal and the confirmation email — is based on Art. 6(1)(b) GDPR (preparing a collaboration at your request), general enquiries on Art. 6(1)(f) GDPR (our legitimate interest is answering your enquiry). To fend off automated submissions, the form contains an additional field that is invisible to you, and the number of submissions per IP address is limited; no permanently stored profiles are created in the process (Art. 6(1)(f) GDPR, protection against abuse). The emails are sent via our domain's mail provider. Should transmission to our server fail, the page offers to send the message with your own email program instead; in that case you do not receive an automatic confirmation, and we take over your enquiry or application manually.

6. Talent pool

Purpose. Our talent pool is a register of freelancers we would like to approach for suitable assignments. We use it solely to approach you for such assignments and to manage your replies; a request does not create a contract. You only join it if you wish to: by signing up at jobs.grow-with-us.com, after an application process or at our invitation. In every case your profile only becomes active once you have confirmed your consent yourself at jobs.grow-with-us.com. We store which version of the consent text you agreed to and when. Unconfirmed invitations are deleted after 30 days.

What data. In the talent pool we process:

• basic details: name, email address, phone number, city, country, time zone, languages and your expectations on day rate and type of assignment;
• skills with your own self-assessment and an internal assessment by the recruiting team; in addition, the team's internal ratings, notes and tags;
• documents you upload yourself: CV, certificates and other documents. We expressly do not accept copies of ID documents; please do not upload any;
• your availability (time periods) and references you provide;
• messages you send to jobs@grow-with-us.com or that we send you from there (section 7);
• our requests for assignments and your replies to them.

Legal basis and duration. The legal basis is your consent (Art. 6(1)(a) GDPR). It is voluntary. It is valid for twelve months and can be renewed: 30 days before it expires we ask by email whether you would like to stay; one click renews it for another twelve months. Without renewal your profile becomes inactive on expiry and is deleted 30 days later, including documents.

Withdrawal. You can withdraw your consent at any time with effect for the future — at jobs.grow-with-us.com using the “Withdraw consent” button, or informally by email to jobs@grow-with-us.com. With the button we delete your profile including documents immediately; with an email, without undue delay once we have read it. This does not affect the lawfulness of processing carried out before the withdrawal. An ongoing application is not affected; sections 5 and 7 apply to it.

Who has access. Only the grow with us recruiting team has access, currently three people. Clients and other third parties cannot see the talent pool; the technical service providers listed in section 11 process data only on our behalf. If you start working with us, we transfer the details required for that into our freelancer administration; from then on the contractual relationship is the legal basis (Art. 6(1)(b) GDPR), and the transferred profile is no longer deleted under the periods above.

Where the data is stored. See section 10.

7. Applicant portal and the jobs@ mailbox

Application processes and the talent pool run in our own application at jobs.grow-with-us.com. There we process the details you provide in the process (profile, answers to questions, uploaded documents, tasks) as well as the recruiting team's assessments. We invite you to an application process by email; the invitation is valid for 14 days. If you apply via the form on this website, the confirmation of receipt is also this invitation (section 5). You sign in without a password: the link in the invitation signs you in directly once within that period. After that, we send a sign-in link to your email address on request; it can be used once and is valid for 60 minutes. If no collaboration comes about or you withdraw your application, we automatically delete the process including documents, messages, appointments and access six months after it has ended. You can request earlier deletion at any time at jobs.grow-with-us.com or by email. The legal basis is Art. 6(1)(b) GDPR (preparing a collaboration).

Emails you send to jobs@grow-with-us.com, or that we send you from there, are fetched automatically into this application, assigned to your application or profile and stored there including attachments, so the recruiting team can see the conversation; you see the same messages at jobs.grow-with-us.com. The mailbox itself is hosted by our domain's mail provider. Assigned messages are deleted together with the application or profile. Emails that we do not assign to any application or profile and discard are deleted 30 days after being discarded; all other emails not assigned to anyone are deleted no later than six months after receipt. The legal basis is Art. 6(1)(b) GDPR (application process), your consent (talent pool) or, for other emails, Art. 6(1)(f) GDPR (handling your message).

AI-assisted pre-selection. When your application reaches the first stage (pre-selection), we have an AI service summarise the details in your applicant profile and your CV and compare them with the requirements of the role (Claude by Anthropic, see below). We do not pass on the name, email address and phone number from your profile; where they appear in your CV, they are contained in it. The result — a short assessment listing the points that speak for or against a fit and the details that are still missing — is seen only by the recruiting team, and expressly as a pointer. Whether your application moves forward is always decided by a person who reviews your documents themselves. Characteristics such as age, gender, origin, religion, health or appearance are not part of the assessment. We store the assessment with your application and delete it together with the application (periods above). The legal basis is Art. 6(1)(b) GDPR (steps prior to a collaboration) and our legitimate interest in a prompt and consistent pre-selection (Art. 6(1)(f) GDPR).

Provider of the AI service. For the assessment we use Anthropic's programming interface (API): our contracting party is Anthropic Ireland, Limited, Dublin, Ireland; the data is processed by Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA. Anthropic processes the data on our behalf (Art. 28 GDPR) and, under its terms, may not use it to train its AI models. According to Anthropic, inputs and results are generally deleted within 30 days; they are kept longer only if they are flagged for a breach of Anthropic's usage policies or where the law requires it. Transfers to the USA are covered by the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR), which form part of Anthropic's data processing addendum. More information: anthropic.com/legal/privacy.

No automated decisions. Applications and requests are decided by people. There is no automated decision-making, including profiling, within the meaning of Art. 22 GDPR; the AI assessment is only a pointer. Talent pool documents are not analysed by AI services.

8. Booking appointments via Calendly

Provider and purpose. For interviews in the application process we use the scheduling service Calendly, provided by Calendly LLC, 115 E Main St, Ste A1B, Buford, GA 30518, USA. Its sole purpose is booking, rescheduling and cancelling interview appointments. Calendly processes the data on our behalf; the data processing agreement forms part of Calendly's terms.

Only after your click. On jobs.grow-with-us.com, Calendly is only loaded once you tap “Load calendar” or open the booking link in a new window. Before that, no Calendly script is loaded and no connection to Calendly is made. When it loads, we pass on your name and email address so you do not have to type them.

What data. Calendly processes your name, email address, the chosen time and your answers in the booking form, as well as technical data of your access. Calendly informs us of bookings, rescheduling and cancellations so that we can match the appointment to your application. The legal basis is Art. 6(1)(b) GDPR (conducting the application process).

Transfer to the USA. The data is transferred to Calendly in the USA. This is based on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework (Art. 45 GDPR), under which Calendly LLC is certified.

Retention. Calendly does not delete booking data on its own. We cancel open appointments as soon as the application process ends, and we delete the booking data of your application at Calendly together with the application, no later than six months after the process has ended. The appointment record stored on our side is deleted together with the application.

No recording. We do not use an AI note-taking assistant (notetaker) from Calendly or any other provider; calls are neither recorded nor transcribed. More information: calendly.com/privacy.

9. Video calls with Google Meet and calendar

Provider. The interviews themselves are held as video conferences via Google Meet. For this we use the Google account of our applications mailbox jobs@grow-with-us.com. The provider for us is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you use Google Meet with your own Google account and are based in the European Economic Area or Switzerland, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, is responsible for your account. You do not need a Google account to take part; the link to the call is enough. You receive it in the booking confirmation.

Which data. During the call, video and audio, your display name, where applicable your email address and technical connection data (such as IP address, device and browser details, time and duration of participation) are processed. We do not record calls or have them transcribed.

Calendar. Calendly (section 8) enters booked appointments in the Google Calendar of the jobs@grow-with-us.com account; this is also where the Meet link is created. The calendar entry contains your name, your email address, the date and time of the call and, where applicable, your answers in the booking form. If you cancel or reschedule, Calendly updates the entry accordingly.

Transfer to the USA and legal basis. Processing by Google LLC in the USA cannot be ruled out. Google LLC is certified under the EU-US Data Privacy Framework (adequacy decision of the European Commission of 10 July 2023, Art. 45 GDPR); the certification also covers the UK Extension and the Swiss-U.S. framework. The legal basis is Art. 6(1)(b) GDPR (conducting the application process). More information: policies.google.com/privacy.

10. Where the data is stored

The applicant portal, the talent pool, the related documents and the messages via jobs@, as well as contact enquiries and the messages via kontakt@, run on servers of Hetzner Online GmbH in Germany, which we operate ourselves and which only the recruiting team — or, for contact enquiries, our management — can access. No data is transferred to countries outside the EU in the process; the exceptions are AI-assisted pre-selection at Anthropic (section 7), appointment booking via Calendly (section 8) and video calls and calendar at Google (section 9).

For the USA (Anthropic, Calendly, Google), see sections 7, 8 and 9.

11. Recipients and service providers

We only pass personal data to the following service providers, who process it on our behalf (Art. 28 GDPR):

• Hetzner Online GmbH, Gunzenhausen, Germany — hosting of the website, access server, backup copies;
• checkdomain GmbH, Lübeck, Germany — email mailboxes of the grow-with-us.com domain;
• Anthropic Ireland, Limited, Dublin, Ireland, and Anthropic PBC, San Francisco, CA, USA — AI-assisted pre-selection of applications (section 7);
• Calendly LLC, Buford, GA, USA — appointment booking (section 8).

In addition, Google LLC, Mountain View, CA, USA, receives the data listed in section 9: for video calls via Google Meet and for the Google Calendar of our jobs@ mailbox, in which booked appointments are kept.

Beyond that, we do not pass on or sell data unless we are legally obliged to do so.

12. Freelancer login

The “Freelancer login” link leads to the separate application at portal.grow-with-us.com. It is a closed area for freelancers we work with. It is only called up when you click the link yourself; merely visiting this website transfers no data to that application. The notices provided there apply to processing inside the login area.

13. Retention and backup copies

Server log files are deleted automatically after 30 days. Email enquiries are kept for as long as is necessary to deal with them and any follow-up questions, and beyond that within the scope of statutory retention obligations. For contact enquiries and messages via kontakt@, for applications, the talent pool and messages via jobs@, the periods set out in sections 5 to 8 apply.

To protect against data loss we back up the database every night; the backup copies are likewise kept on our servers in Germany. Backups are overwritten after 14 days. Deleted data may therefore remain in backup copies for up to 14 days; it is not used there.

14. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You may withdraw consent you have given — for example for the talent pool — at any time with effect for the future (Art. 7(3)).

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR).

15. Contact for data protection matters

For questions about data protection and to exercise your rights, you can reach us at kontakt@grow-with-us.com, for the talent pool and applications also at jobs@grow-with-us.com, or via our representative in the EU (section 1).