Data Sharing Agreement

Last updated: 25th July 2025

This Data Sharing Agreement ("DSA") forms part of the Platform Terms (as defined below) and is entered into between:

  1. CooperHire GmbH, a company registered in Germany, with its business address at Rheinsberger Str. 76/77, 10115 Berlin, C/O FactoryWorks GmbH ("Cooper", "we", "us", or "our"); and
  2. The organisation that is a counterparty to the Platform Terms ("Hirer", "you", or "your").

This DSA prevails in the event of any conflict or inconsistency between this DSA and the Platform Terms. We may update this DSA from time to time where reasonably necessary to comply with applicable Data Protection Laws.

1. Definitions

In this DSA, the following definitions apply:

  • "Controller", "Data Subject", "Personal Data", "Personal Data Breach" and "Processing" have the meanings given in the General Data Protection Regulation (EU) 2016/679 ("GDPR").
  • "Data Protection Laws" means all applicable data protection, privacy, and security laws and regulations, including the GDPR and applicable German data protection legislation (including the Bundesdatenschutzgesetz – BDSG).
  • "Platform Terms" means the Platform Terms or any other applicable agreement entered into between you and us.
  • "Shared Personal Data" means any Personal Data provided or made available by us or on our behalf to you in connection with the Platform Terms, including data collected during intake calls, as further described in section 6.
  • "Job Seeker Terms" means the job seeker terms applicable to candidates using the Cooper Platform.
  • "Restricted Transfer" means a transfer of Shared Personal Data to a country outside the European Economic Area ("EEA") that is not subject to an adequacy decision by the European Commission and therefore requires appropriate safeguards under Chapter V GDPR.

Unless otherwise defined in this DSA, capitalised terms have the meanings given in the Platform Terms.

2. Purpose and Legal Basis of Data Sharing

Purpose

The sharing of Shared Personal Data by Cooper with you is necessary to facilitate candidate Introductions and hiring activities in accordance with the Platform Terms. This includes the use of voice data and transcripts from recorded intake calls with Job Seekers.

Legal Basis

Processing of Shared Personal Data under this DSA is based on:

  • the performance of contractual obligations owed to Job Seekers; and/or
  • the legitimate interests of Cooper, you, and Job Seekers in enabling efficient recruitment and hiring activities,

in each case in accordance with Article 6 GDPR.

Consent is also collected where required under Article 9 GDPR for any sensitive data shared voluntarily during intake calls.

3. Data Processing Roles

Independent Controllers

Each party acts as an independent Controller with respect to the Processing of Shared Personal Data and is individually responsible for compliance with Data Protection Laws.

Mutual Assistance

Each party agrees to reasonably assist the other in complying with Data Protection Laws, including responding to regulatory inquiries and Data Subject requests where relevant.

4. Your Additional Obligations

Data Subject Requests

You shall promptly assist Cooper where a Data Subject exercises their rights under GDPR (e.g., access, rectification, erasure, restriction), including with regard to any recordings or transcripts of intake calls shared with you.

Personal Data Breaches

You must notify us without undue delay upon becoming aware of any Personal Data Breach affecting Shared Personal Data (including any breach involving call recordings) and provide sufficient information to allow compliance with notification obligations.

Security Measures

You shall implement appropriate technical and organisational measures to protect Shared Personal Data, including recorded audio and transcribed content.

5. International Data Transfers

Where any transfer of Shared Personal Data constitutes a Restricted Transfer, the parties agree to implement appropriate safeguards in accordance with Chapter V GDPR, including the European Commission’s Standard Contractual Clauses ("SCCs") or equivalent lawful transfer mechanisms.

6. Data Sharing Details

Our Details

  • Name: CooperHire GmbH
  • Address: Rheinsberger Str. 76/77, 10115 Berlin, C/O FactoryWorks GmbH
  • Contact for data protection: [email protected]
  • Activities: Operation of an AI-powered recruitment platform facilitating candidate matching and Introductions, including recorded intake calls to understand a candidate's preferences and profile.
  • Role: Controller

Your Details

  • Name: The organisation registered on the Platform
  • Address: The address provided during registration
  • Contact for data protection: The contact details provided during registration
  • Activities: Hiring and recruitment of Job Seekers using the Platform
  • Role: Controller

Processing Description

Categories of Data Subjects

  • Job Seekers

Categories of Personal Data

Personal data relating to Job Seekers, including:

  • Name, title, contact details (e.g. address, email, phone)
  • Photograph, nationality, and professional documents (where provided)
  • Education, work history, skills, languages, and qualifications
  • References and referee contact details
  • Recorded intake call audio and transcripts capturing responses related to work experience, job preferences, and availability
  • CVs, LinkedIn profiles, application documents

Special Categories of Personal Data

Not intentionally collected, but Job Seekers may voluntarily share sensitive information (e.g., health, origin, union membership) during intake calls or through uploaded materials. You must ensure lawful Processing if such data is received.

Safeguards

We may use AI models and automated filters to identify and suppress sensitive data before sharing. However, you are responsible for ensuring lawful Processing under GDPR if sensitive information is received or retained.

Frequency of Transfer

  • Ongoing / continuous

Nature and Purpose of Processing

Evaluation and selection of candidates for potential employment under the Platform Terms. Intake calls are used to enhance context, matching accuracy, and transparency.

Retention Period

Shared Personal Data (including call recordings and transcripts) should be retained only as long as necessary for the fulfilment of hiring obligations and in accordance with applicable data retention policies under GDPR.

7. Precedence

In the event of any conflict between this DSA and the Platform Terms, this DSA shall prevail in respect of data protection matters.