Privacy Policy — Private Capital Performance Study

The protection of your personal data is very important to us. This study involves two clearly separated data flows:

  • A recruitment side, on which the scientific lead invites potential participants by email using their professional contact information. Recipients can opt out of further emails at any time.
  • A survey side, which is designed to be structurally anonymous: no contact information, name, IP address, or other directly identifying data is collected or stored when you submit a response. There is no link between the recruitment list and submitted responses.

All processing is carried out in accordance with the EU General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection (revDSG).

1. Controller

The controller within the meaning of Art. 4 (7) GDPR is:

Hochschule Schaffhausen AG (HSSH)
Rheinstrasse 10
CH-8200 Schaffhausen
Switzerland
info@hochschule-schaffhausen.ch

The scientific lead of the study is Jan Veder (PhD Candidate at HSSH), supervised by Prof. Dr. Marcus Riekeberg.

The study, including all data processing described in this notice, is conducted exclusively within the framework of this PhD research. It is independent of any other professional, advisory, or commercial activity of the scientific lead, and no other organization is a controller, sponsor, or recipient of study data.

2. Data Protection Officer

For this study, the scientific lead has personally engaged the following external data protection officer to provide independent privacy oversight and advice:

DSBOK GmbH
Untergasse 2
65474 Bischofsheim, Germany
Managing Director: Oliver Krause
Phone: +49 6144 402197
info@dsbok.de
https://www.dsbok.de/

DSBOK acts in an advisory and oversight capacity for this study. DSBOK does not process participant data, does not maintain identifiers used by the study, and is not involved in distributing the survey link.

3. Purpose of data processing

All data processing is carried out exclusively for the scientific research project Beyond IQ — Private Capital Performance Study. Specifically, processing serves to:

  • send personalized invitations to potential participants identified as professionals in the private capital industry,
  • might send a small number of reminder emails to recipients (invitations may also be sent as personal LinkedIn messages, connection requests, or InMails),
  • determine the country of origin of completions (country level only) for the purpose of describing the geographic distribution of the sample,
  • respond to study-related inquiries, if and when participants choose to contact the scientific lead.

4. Categories of data processed

  • Recipient contact data (recruitment side): first name, last name, and email address of professionals working at private capital firms, sourced from public business profiles (e.g., LinkedIn, corporate websites) for the sole purpose of inviting them to participate in the study. This data is held in the scientific lead’s own self-hosted recruitment system (see Section 8) and at no point linked to any submitted survey response.
  • Pre-filled invitation links (recruitment side): to shorten the career-history section, some invitation links carry a small set of pre-selected answer codes (for example country, private capital segment, role type, or start year). These codes are derived from professional background information held in the scientific lead’s recruitment system (such as public LinkedIn profile data) and are generated partly by fixed rules and partly with the help of a language model (Anthropic Claude Haiku, see Sections 9 and 10). The codes are coarse categories and contain no name, email address, or other identifier. Every pre-filled value is displayed to you for review and can be changed or removed before submission. The prepared codes are kept in the recruitment system only to build your link and can be deleted on request at any time (see Section 11); they are deleted at the latest at the close of data collection.
  • Survey responses (survey side): demographic information, career data, cognitive ability scores (ICAR-16), personality and emotional-intelligence measures, and self-reported performance indicators. Responses are collected in LimeSurvey's anonymous-response mode — no email address, name, token, or other identifying attribute is stored alongside the response.
  • Country of origin (country code only): upon successful completion of the survey, your IP address is briefly held in server memory and resolved against a local copy of the MaxMind GeoLite2-Country database to derive a two-letter ISO country code (e.g., DE, CH, US). The IP address is never written to any database, application log, or file, and is discarded the instant the lookup completes. Only the resolved country code, a timestamp, and the lookup status are persisted, alongside the anonymous response. Standard webserver access logs — which retain IP addresses for routine security and operational diagnostics, rotated and deleted after the usual retention period — are unaffected and are not used for research purposes, with one narrow exception: aggregate, non-personal visit counts per recruitment entry page (for example, the number of visitors arriving via the peer-referral address hssh.janveder.de/peer, resolved to country level using the same locally hosted GeoLite2 database) may be derived from these logs to describe how participants were reached. No IP address or other personal data from these logs is ever persisted or reported as part of the research data; only anonymous aggregate counts are retained.
  • Participant feedback identifier: when you reach the final page of the survey, a numerical identifier is displayed to you. It is computed deterministically from an internal sequential response number combined with a constant offset and contains no information about you personally. This identifier exists solely to allow you to refer to your own response if you later choose to request personal feedback. The controller cannot use this identifier to identify, locate, or contact you in any way unless you yourself voluntarily disclose it.
  • Optional LinkedIn experience paste (opt-in only): if — and only if — you actively choose the optional pre-fill helper described in Section 5, the text you paste into the dedicated field is processed once for field suggestion. The paste itself is cleared from the form before submission and is not stored in our database; only the structured answers you review and submit are retained. If you choose the manual entry option instead, no such text is collected.

5. Optional pre-fill via LinkedIn paste (opt-in)

At the beginning of the career-history section of the survey, you may choose between two ways of entering your professional background:

  • “Fill in manually” — answer the career-history questions one by one. No additional processing beyond what is described in Sections 4, 7, and 8 takes place. You can skip the rest of this section.
  • “Pre-fill via LinkedIn paste” — an optional helper that lets you copy your LinkedIn “Experience” text into a single text field, has it analyzed once by a language model, and pre-fills approximately ten career-history fields (private capital segment, role, employer classifications, year dates, etc.) for your review. You retain full control: every pre-filled value is displayed to you for verification and can be edited before submission; fields below the classifier’s confidence threshold are deliberately left blank for manual completion; and you may switch back to manual entry at any time.

If you choose the pre-fill helper, processing proceeds as follows:

  • Explicit, separate consent. Before the helper runs, you tick a dedicated checkbox confirming that you understand and agree that the pasted text will be sent once to Anthropic for classification. Without this checkbox the helper does not run and no transfer takes place. The remainder of the survey can be completed without this step.
  • Single transient API call. The pasted text is transmitted once over an encrypted HTTPS connection to the Anthropic Claude Haiku API. The model returns structured field suggestions together with per-field confidence scores. Only suggestions at or above the configured confidence threshold are pre-filled; lower-confidence suggestions are discarded and the corresponding fields remain blank for you to complete manually.
  • No use for model training. Anthropic’s commercial API terms exclude the use of inputs and outputs for model training. Neither the pasted text nor the model output is written to our application logs.
  • No company-derived database is built from the paste. Company names extracted from the paste are not persisted to any reference database, recruitment list, or contact list. No lead, prospect record, or company entry is created or augmented from your paste.
  • The pasted text is not retained in our database. Immediately before your survey response is submitted to the server, the pasted text is cleared from the form by a client-side script. Only the structured answers you review and possibly edit (private capital segment, role, employer classifications, year dates, etc.) are stored as part of your anonymous response. The raw paste itself is never written to the survey response database, and the per-field classifier suggestions are not persisted as a separate record. The pasted text is therefore held only transiently in your own browser and, for the duration of the single API call, on the processor side — it does not survive the submission of your response.
  • Sub-processor. Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA, acts as a processor under Art. 28 GDPR for the duration of the single API call. A data processing agreement with appropriate technical and organizational safeguards is in place. The use of Anthropic for this specific opt-in feature has been reviewed and approved by the external Data Protection Officer named in Section 2.
  • International transfer to the United States. The single API call constitutes a transfer of the pasted text to the United States. The transfer is safeguarded by Standard Contractual Clauses (Art. 46 (2) (c) GDPR, EU Commission Implementing Decision (EU) 2021/914) concluded with Anthropic, supplemented by additional measures: encryption in transit (TLS), exclusion of the data from model training, and strict limitation of the transfer to the single classification call you have explicitly authorized.

6. Legal basis

Recruitment side (invitation and reminder emails). The sending of invitation and reminder emails to professionals in the private capital industry is based on Art. 6 (1) (f) GDPR (legitimate interest of the scientific lead in recruiting an appropriate professional sample for the study) in conjunction with Art. 89 GDPR (scientific research). Recipients are contacted exclusively in their professional capacity; the volume is limited to one initial invitation plus a small number of reminders; the message clearly identifies its academic purpose; and recipients can opt out of further emails at any time via the unsubscribe link contained in every email.

Survey side (anonymous responses). Participation in the survey, and the storage of your anonymous responses and country code, is based on your voluntary participation, indicating consent in accordance with Art. 6 (1) (a) GDPR and Art. 31 revDSG.

The brief, in-memory processing of your IP address solely for the country-level lookup, as well as the long-term storage of anonymous responses and aggregate country statistics for scientific evaluation, is additionally based on Art. 6 (1) (f) GDPR (legitimate interests in scientific research and in describing the geographic distribution of the sample) in conjunction with Art. 89 GDPR (processing for scientific research purposes under appropriate safeguards).

7. Anonymity architecture

The study has been designed from the ground up to be structurally anonymous. Specifically:

  • Single open survey link. The survey is publicly accessible through one URL. No tokens are issued. Invitation links may carry pre-filled answer codes (Section 4), but never a name, email address, or other identifier. No name, email address, or other contact data is requested at any point during participation.
  • LimeSurvey anonymous-response mode. The survey platform is operated in the configuration that explicitly disables any link between submitted responses and identifiers. The internal response identifier is sequential and not associated with any personal attribute.
  • Country-level geographic lookup, IP never persisted. When your submission is received, the server-side endpoint reads your IP address from the HTTP request, performs an offline lookup against a locally hosted copy of the MaxMind GeoLite2-Country database, writes only the resulting two-letter country code (together with the anonymous response identifier and a timestamp) to the database, and immediately discards the IP address. No external request is made to MaxMind or any third party during the lookup. No copy of the IP address is created in any application log or file used by the research project.
  • Self-referential participant identifier. After submission, you are shown a numerical identifier derived from the internal response number. The identifier allows you, and only you, to point to your own response if you later choose to request personal feedback. Because the identifier is purely numerical and contains no contact information, the controller has no means to use it to identify, contact, or locate you. It functions as a one-way reference: from you to your data, never the reverse.
  • Self-hosted, single-operator infrastructure. The survey platform, the geographic lookup endpoint, and the underlying database are operated personally by the scientific lead, Jan Veder, on infrastructure he hosts under his own domains hssh.janveder.de and janveder.de. No commercial survey-platform vendor, no analytics provider, and no third-party processor has access to participant data on the survey side. Sole administrative access (root) lies with the scientific lead.
  • Separation of recruitment from response. The recruitment side and the survey side run in two completely separate systems. The recipient list is held in the scientific lead’s own self-hosted recruitment system; individual invitation and reminder emails are dispatched via the email service provider IONOS and, from 10 July to 8 October 2026, additionally via Instantly (see Section 9). The survey platform never receives the recipient list. No mapping, token, or other technical connection is created or stored between an email recipient and any survey response. Even with full simultaneous access to both data sets, it is structurally impossible to determine whether a given invited person responded to the survey, and if so, with which response.

As a consequence, no party — including the controller, the data protection officer, or any third party — holds both identifying information and survey responses, because no identifying information is ever collected on the survey side.

8. Storage period

  • Recipient contact data (name and email address) is retained in the scientific lead’s own self-hosted recruitment system for the active recruitment phase of the study and deleted no later than 3 months after the close of data collection. Opt-out requests are honored immediately: the corresponding email address is added to an internal suppression list so that no further emails are sent. Suppression entries are retained as long as needed to honor the opt-out.
  • Anonymous survey responses and the associated country code are retained for up to 24 months after completion of the study, in accordance with the principles of good scientific practice (reproducibility, verification, replication). After this period, the data is either deleted or archived in fully anonymized form in a recognized research repository.
  • IP addresses are not stored as part of the research data. Standard webserver access logs follow the operational retention policy of the hosting infrastructure (typically a few weeks). The only research-related use of these logs is the derivation of aggregate, non-personal visit counts per recruitment entry page (country level only; no IP addresses are persisted or reported) to describe how participants were reached.

9. Recipients of the data

Survey side. The survey platform, the geographic lookup endpoint, and the underlying database are hosted personally by the scientific lead, Jan Veder, on infrastructure operated under his own domains hssh.janveder.de and janveder.de. There is no commercial survey-platform vendor, no external analytics service, and no third-party processor handling survey responses on our behalf. The MaxMind GeoLite2-Country database used for the country-level lookup runs locally on the same server; no requests are made to MaxMind during participation, and no participant data is transmitted to MaxMind. The underlying physical server is leased from an EU-based hosting provider for the sole purpose of providing virtualized hardware; the hosting provider has no role in determining the purposes or means of processing and does not, in the normal course of operations, access the data stored on the server.

Recruitment side. Invitation and reminder emails are dispatched via IONOS SE (Elgendorfer Straße 57, 56410 Montabaur, Germany) as processor under Art. 28 GDPR. IONOS is established in the European Union and operates EU-based email infrastructure. A data processing agreement is in place. The recipient list itself is held in the scientific lead’s own self-hosted recruitment system; IONOS processes only the individual email messages transmitted for dispatch (containing the recipient’s name and email address) and does not receive any survey responses, the participant feedback identifier, country data, or other study data.

Additional dispatch service (10 July to 8 October 2026). In this period, part of the invitation and reminder emails was dispatched from separate sending domains via Instantly (Foo Monk LLC, 30 N. Gould St., Ste. R, Sheridan, WY 82801, USA) as processor under Art. 28 GDPR, under its data processing addendum. Instantly received the recipient’s name, email address, company, and the invitation link with its pre-fill codes. It does not receive any survey responses, the participant feedback identifier, or country data. Use of this service ends on 8 October 2026.

Reachability check page. Invitation links first open a small entry page hosted on Cloudflare Pages (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA) as processor under Art. 28 GDPR. This page checks whether the survey server is reachable from your browser and then forwards you to the survey; if a corporate web filter blocks the survey server, it shows alternative ways to open your link. Cloudflare processes the technical request data (IP address, browser type, and the invitation URL with its pre-fill codes) transiently to deliver the page. The entry page does not set cookies. If the survey server is blocked, the page reports the event (time, country, device type, error type, and the pre-fill codes of the invitation, but no IP address) to the scientific lead so that affected participants can be offered another way to take part. If you use the optional “send the link to my address” function, the address you enter is used once to send the link via IONOS (see above) and is not stored. Cloudflare’s global network may process the request outside the EEA; see Section 10.

Optional pre-fill helper (opt-in only). If — and only if — you actively enable the optional pre-fill helper described in Section 5, the text you paste is transmitted once to Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA as processor under Art. 28 GDPR, under Anthropic’s commercial API terms exclude the use of inputs and outputs for model training. A data processing agreement is in place. In this context Anthropic does not receive any other study data — no other survey responses, no country code, and no participant feedback identifier. The use of Anthropic for this specific opt-in feature has been reviewed and approved by the external Data Protection Officer named in Section 2.

Pre-filled invitation links (recruitment side). To derive the pre-filled answer codes described in Section 4, professional background text from the recruitment system is transmitted to Anthropic PBC (address above) as processor under Art. 28 GDPR, under Anthropic’s commercial API terms, which exclude the use of inputs and outputs for model training. Anthropic returns only coarse answer codes; it does not receive any survey responses, country data, or participant feedback identifier.

Outbound emails (invitations, reminders, and replies) may be dispatched from any personal email account of the scientific lead. The host of such an account is not a controller, sponsor, processor, or recipient of study data; the responsibilities and data flows described in this notice apply regardless of the dispatching account.

Beyond the parties named above, data is not disclosed to third parties with the exception of competent authorities, if and insofar as there is a legal obligation to disclose.

10. International data transfers

As a default, personal data is processed within the European Economic Area (EEA) and Switzerland. Switzerland is recognized by the European Commission as providing an adequate level of data protection (Commission Decision 2000/518/EC, reviewed under the GDPR regime).

One exception, exclusively triggered by your opt-in: if you actively choose the optional pre-fill helper described in Section 5, the text you paste is transmitted once to Anthropic PBC in the United States. Apart from the exceptions described below, this is the only transfer of personal data to a third country outside the EEA and Switzerland in the context of this study. The transfer is safeguarded by Standard Contractual Clauses (Art. 46 (2) (c) GDPR, EU Commission Implementing Decision (EU) 2021/914) concluded with Anthropic, supplemented by additional measures: encryption in transit (TLS), exclusion of the data from model training, and strict limitation of the transfer to the single classification call you have explicitly authorized.

A second, technical exception concerns the entry page hosted on Cloudflare Pages (Section 9): request data may be processed on Cloudflare’s global network, including in the United States. Cloudflare, Inc. is certified under the EU-U.S. Data Privacy Framework and the transfer is additionally safeguarded by Standard Contractual Clauses in Cloudflare’s data processing addendum. No survey responses and no recruitment list are ever transmitted to Cloudflare.

A fourth exception concerns the additional dispatch service Instantly (Section 9), used from 10 July to 8 October 2026: the data needed to send an invitation (name, email address, company, invitation link) was transmitted to Foo Monk LLC in the United States. This transfer is safeguarded by the Standard Contractual Clauses (EU Commission Implementing Decision (EU) 2021/914) incorporated in Instantly’s data processing addendum.

11. Your rights

Under the GDPR and the revDSG, you have the following rights with respect to your personal data:

  • Right of access (Art. 15 GDPR).
  • Right to rectification (Art. 16 GDPR).
  • Right to erasure (Art. 17 GDPR).
  • Right to restriction of processing (Art. 18 GDPR).
  • Right to data portability (Art. 20 GDPR).
  • Right to object (Art. 21 GDPR), in particular to processing based on legitimate interests (Art. 6 (1) (f)).
  • Right to withdraw consent (Art. 7 (3) GDPR) at any time with effect for the future. Withdrawal does not affect the lawfulness of processing based on consent prior to its withdrawal.

Recruitment side — how to exercise these rights. If you have received an invitation or reminder email and do not wish to receive further communications, you can opt out at any time via the unsubscribe link that is automatically included in every email. Opt-out takes effect immediately: your email address is added to an internal suppression list so that no further messages are sent. In addition, you may request access to, rectification of, or deletion of your contact data on the recruitment list at any time by writing to the scientific lead at jan.veder@edu.hochschule-schaffhausen.ch or to the data protection officer at info@dsbok.de. None of these actions has any effect on already-submitted, anonymous survey responses, because no link between the two data sets exists.

Survey side — an important note on the practical exercise of these rights. Because the study processes no personally identifying information when you submit a response, and the data we store cannot be linked back to your person by us (see Section 6), the survey responses and country code held in our database constitute anonymous data within the meaning of Recital 26 GDPR. The rights of access, rectification, erasure, restriction, and portability presuppose that the controller is able to identify the data subject. In the design of this study we have made identification structurally impossible. As a result, we are technically unable to access, modify, or delete individual responses upon request. This is not a refusal of your rights — it is a consequence of the strongest form of data protection: data that does not exist as personal data cannot be retrieved or removed.

The right to object (Art. 21 GDPR) on the survey side remains meaningful with respect to the brief, in-memory processing of your IP address for the country lookup at the moment of submission. If you wish to object to this processing, please do not complete the survey: the geographic lookup is triggered only upon successful completion. The right to withdraw consent (Art. 7 (3) GDPR) can be exercised by simply not completing the survey or by closing the browser before final submission.

For general questions about this privacy notice or the study, you may contact the scientific lead at jan.veder@edu.hochschule-schaffhausen.ch or the data protection officer at info@dsbok.de.

12. Right to lodge a complaint

You have the right to lodge a complaint with a competent supervisory authority (Art. 77 GDPR, Art. 49 revDSG). The competent authorities are:

For HSSH (Switzerland):
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Feldeggweg 1, CH-3003 Bern
https://www.edoeb.admin.ch
For the data protection officer (Germany):
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany
https://datenschutz.hessen.de

13. Automated decision-making

The study does not involve automated decision-making or profiling within the meaning of Art. 22 GDPR. Test scores and configurational profiles generated in the course of the scientific analysis are not used to make decisions affecting individual participants.

14. Voluntariness

Participation in the study is entirely voluntary. Declining to participate or closing the browser before final submission does not result in any disadvantage and does not trigger any data processing on our side beyond what occurs in the standard course of an HTTPS connection.

15. Cookies and saving your progress

This survey sets a single strictly necessary cookie that remembers your current session, so that you can pause and continue the survey later from the same browser via your invitation link. This cookie stores no personal data, is never used for tracking or advertising, and expires automatically when your session ends. Because it is strictly necessary for the survey to function, no separate consent is required for it.

Impressum

Jan Veder
PhD Candidate at Hochschule Schaffhausen AG
Rheinstrasse 10
CH-8200 Schaffhausen
jan.veder@edu.hochschule-schaffhausen.ch

Last updated: 4 October 2026