Data Protection Disclaimer for Participants

Thank you for taking part in an Assessment Center, Development Center, and Survey solution from atrain. We take the protection of your personal data very seriously and would like to provide you with the following information in accordance with the General Data Protection Regulation (GDPR).

1. Data Controller and Contact

The responsible controller for the processing of your data is:
atrain GmbH
Unterer Kaulberg 3
96049 Bamberg

If you have any questions about data protection, please contact us at: datasecurity@atrain.com

2. Purpose of Data Processing

Your personal data will be processed solely for:

• Conducting and evaluating Assessment Centers and Development Centers.
• Administering surveys to support individual and organizational development.
• Providing structured feedback to you and to our client (your employer or prospective employer).

3. Categories of Data Processed

We process the following types of personal data:

• Identification data (e.g., name, email address).
• Assessment data (e.g., performance in exercises, facilitator observations, survey responses).
• Feedback and evaluation results.

4. Legal Basis of Processing

Processing of your personal data is based on:

• Article 6(1)(b) GDPR: Processing is necessary for the performance of a contract (e.g., the talent management/development process with your employer).
• Article 6(1)(f) GDPR: Processing is necessary for the legitimate interests pursued by your employer and by us (ensuring fair, structured, and evidence-based talent and development processes).

5. Use of External Tools

We use specialized software providers to deliver our services:

• Applysia by Applysia GmbH (Assessment Centers and Development Centers)
  Address: Marsstraße 14, 80335 Munich, Germany
  A signed Data Processing Agreement (DPA) is in place to ensure compliance with GDPR.
• Qualtrics by Qualtrics LLC (Surveys)
  Address: 333 West River Park Drive, Provo, UT 84604, USA
  A signed Data Processing Agreement (DPA) is in place. Potential data transfers outside the EU are safeguarded by Standard Contractual Clauses (SCCs) in accordance with GDPR.
• Zoho Survey by Zoho Corporation B.V.
  Address: Hoogoorddreef 15, 1101 BA Amsterdam, The Netherlands
  A signed Data Processing Agreement (DPA) is in place to ensure GDPR compliance.

All providers act as data processors on our behalf and are contractually bound to handle your data securely and in compliance with GDPR.

6. Data Access and Recipients

Your data will only be accessed on a per-need basis by:

• Our trained employees and carefully selected external facilitators are contractually bound to confidentiality and data protection obligations.
• Your (potential) employer (the commissioning organization), who will receive aggregated results, reports, or feedback as defined in the project agreement.

We do not share your personal data with unauthorised third parties.

7. Storage and Retention

Your personal data will be stored for as long as necessary to fulfil the stated purposes and in accordance with applicable legal retention obligations. After this period, your data will be securely deleted or anonymized.

8. Your Rights

As a participant, you have the following rights under GDPR:

• Right of access to Your Personal Data.
• Right to rectification or erasure.
• Right to restriction of processing.
• Right to object to processing.
• Right to data portability.
• Right to lodge a complaint with a supervisory authority.

To exercise your rights, please contact us at datasecurity@atrain.com.

9. Voluntary Participation

Your participation is voluntary. However, please note that opting out of certain assessments or surveys may affect the ability to complete the process or provide full feedback.