Data Privacy Policy

We undertake to comply with all data protection regulations when handling the data of visitors to our website. We process data exclusively to the extent necessary and permitted by data protection law to make a visit to the website possible.

a. Informational Use of the Website

You can visit our website without providing any personal information. If you use our website for information purposes only, we do not collect any personal data other than data transmitted by your browser to enable you to visit the website and transmitted to us by the cookies we use.

aa. Technical Provision of the Website

To provide the website, we may need to process certain automatically submitted information from you for your browser to display our website and for you to use the website. This information is automatically collected each time you visit our website and stored in server log files. These log files contain, inter alia, the following information: IP address, date and time of the server request, pages accessed, referrer-URL (the previously visited page). Furthermore, we may use technically essential cookies to make our website available to you for use. Cookies are text files that are stored in the internet browser or by the internet browser when you visit a website on your computer system. A cookie contains a characteristic string of characters that enables a unique identification of the browser when the website is called up again. We use these cookies exclusively to provide you with our website and its technical functions. Some functions of our website may not be offered without the use of cookies.

The collection of this data is mandatory for the operation of the website. Consequently, there is no possibility of objection. Your information, collected by us through the aforementioned cookies and server log files will not be used by us to create user profiles or to evaluate your browsing behavior.

We process your personal data for the technical provision of our website (i) for the fulfillment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 lit. b GDPR, provided you visit our website to obtain information about our services; and (ii) to protect our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website.

bb. Statistical Analysis of Website Usage (Google Analytics)

If you have provided your consent, this website uses Google Analytics, a web analysis service of Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Scope of processing

Google Analytics uses cookies that enable an analysis of your use of our website. The information collected by the cookies about your use of this website is usually transferred to a Google server (EU and/or USA). We use the function ‘anonymizeIP’ (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.

During your website visit the following data may be collected:

• the pages you visit
  Achievement of “website goals”
• Your user behavior (for example clicks, dwell time, bounce rates)
• Your approximate location (region)
• Your IP address (in abbreviated form)
  technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
• Your internet provider
  the referrer URL (via which website/advertising medium you came to this website)

Purposes of processing

On our behalf, Google will use this information to evaluate your use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyze the performance of our website. As Google is used as a data processor, we have concluded a data processing contract with Google. A transfer of data to the USA cannot be excluded.

Duration of storage

The data sent by us and linked to cookies is automatically deleted after 14 months. Data deletion takes place once a month as soon as this storage period is reached.

Legal basis and right of withdrawal

Your consent is the legal basis for this data processing, Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by changing your selection in the cookie settings. For more information about Google Analytics terms of use and Google’s privacy policy, please visit the following websites:

https://marketingplatform.google.com/about/analytics/terms/gb/
https://policies.google.com/?hl=en.

cc. Statistical Analysis of Website Usage (Meta-Pixel)

If you have provided your consent, this website uses a meta-pixel (“Pixel”), a web analysis service of Meta Platforms, Inc. The responsible service provider in the EU is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (“Meta”). This allows us to display behavioral advertising (“Facebook Ads”) to you via the Facebook social network or other websites. We also use the Facebook service for campaign optimization.

Scope of processing

Your browser automatically establishes a connection to the Meta servers. We have no influence on the data processing at Meta. According to our knowledge, the following happens: Meta receives the information that you have called up a website from our offer, or clicked on one of our advertisements. If you are a user of the Facebook service, Facebook can also assign this visit to your account. If you do not have a Facebook account or are not logged in, it is still possible that Meta identifies and assigns you based on your IP address. The information collected via the Pixel can therefore be compiled by Meta and the information collected in this way can be used by Meta for its own advertising purposes as well as for advertising purposes of third parties. Thus, Meta can infer certain interests from your surfing behavior on this website and also use this information to advertise third-party offers. Meta may also combine the information collected via the Pixel with other information that Meta has collected about you via other websites and / or in connection with the use of the social network “Facebook”, so that a profile about you can be stored at Meta. This profile can be used for advertising purposes.

Purposes of processing

Through this data processing, we want to ensure that we only show you advertising that is appropriate to your interests. This also allows us to make our offer more appealing. Meta potentially transfers personal data to a third country in the context of providing its services. For more information about such transfers, scroll down to section 5.

Duration of storage

The data sent by us and linked to cookies is automatically deleted after 14 months. Data is automatically deleted once a month as soon as the storage period is reached.

Legal basis and right of withdrawal

Your consent is the legal basis for this data processing, Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by changing your selection in the cookie settings. For more information about Meta and the Pixel terms of use and Meta’s privacy policy, please visit the following websites:

https://www.facebook.com/help/568137493302217
https://www.facebook.com/about/privacy

b. Providing Information and Sending Queries

We offer the possibility for both employers and candidates to provide information through contact forms on our website. In case of employers the information essentially relates to company details, open positions and contact details. In case of candidates the information essentially relates education, work experience and other data relevant or potential employment. In addition, we may provide a short online questionnaire on our website for a preliminary assessment of the chances of candidates for a German work visa.

We process the above-mentioned data to be able to match potential employers in Germany with candidates. To this end and with consent of the candidates, we will show the profile of candidates we deem to have good prospects to potential employers and, possibly, facilitate their employment and visa process with an employer in Germany.

We process the above-mentioned data for the above purposes (questionnaire and contact requests) exclusively based on (i) your consent and Art. 6 para. 1 lit. a GDPR and (ii), in case of queries or contact requests, Art. 6 para. 1 lit. b GDPR to answer the individual queries (e.g. e-mails or telephone calls). Consent may be revoked at any time with effect for the future; we will no longer process the relevant data from receipt of the revocation.

The above-mentioned data is processed via (i) Restly, Inc., 1210 S Indiana Ave. Unit 1817 Chicago, IL 60605, United States and their service Fillout (hereinafter “Fillout”), (ii) Google and their service Google Workspace (hereinafter “Google Workspace”), (iii) Celonis, Inc. One World Trade Center 87th Floor New York, NY 10007 United States and their service make (hereinafter “Make”), (iv) Rewardly, Inc., d/b/a Streak, 2261 Market Street #4067, San Francisco, CA, 94114, United States (hereinafter “Streak”), (v) Sinch AB, Lindhagensgatan 112, 112 51 Stockholm, Sweden and their service Mailjet (hereinafter “Mailjet”), (vi) TYPEFORM S.L., Carrer Bac de Roda, 163, 08018 Barcelona, Spain (hereinafter “Typeform”) and (vii) Hostinger International Ltd. 61 Lordou Vironos Street, 6023 Larnaca, Cyprus (hereinafter “Hostinger”) as follows:

• The information you provide to us via the online forms on our website is processed by Fillout and will be stored on Fillout’s servers. Fillout is a service for creation of forms, surveys and quizzes.
• We use Google Workspace for email communications with you and to process other data you provide to us via Fillout forms and, potentially Typeform questionnaires. Google Workspace is a collection of productivity and collaboration tools.
• Make is a process automation service linking different applications to create an automated and efficient data flow. We use it to send emails to you once you have completed a Fillout form and, potentially, a Typeform questionnaire.
• The data you provide us via the Fillout forms and, potentially, the Typeform questionnaires is also processed by Streak. Streak offers a CRM system allowing us to manage workflows by means of Google Workspace.
• Mailjet is processing your data for the purposes of providing a collaborative deliverability tool taking care of getting emails to your inbox.
• The website itself is hosted by Hostinger International Ltd. 61 Lordou Vironos Street, 6023 Larnaca, Cyprus (hereinafter “Hostinger”). Hostinger is a service that makes our website available on the internet by providing a web server on which the files of our website are stored.
• We may have integrated Typeform into our website to enable us to create online questionnaires and integrate them into our website. The data you enter in our Typeform questionnaires may be stored on Typeform’s servers.

Some of these firms may be engaged by third parties with which we have concluded a corresponding data processing agreement (DPA). Some of the services provided by these firms entail data processing in third countries (see section 5 below).

4. Disclosure of Personal Data to Third Parties / Recipients of Data

For the provision of our services we may use technical service providers by way of third party processing in accordance with Art. 28 GDPR (see section 3 lit. a. and b.). In all other cases, we do not pass on your data to third parties unless (i) this is necessary to fulfill our business purposes (e.g. sharing profiles with potential employers), (ii) you have given your consent or (iii) we are required to do so by law, court order or governmental authority.

5. Transfer of Personal Data to a Third Country

We solely transfer your personal data to Third Countries within the meaning of the GDPR if the legal requirements pursuant to Art. 45, 46 GDPR are met (in particular if an adequacy decision pursuant to Article 45 para. 3 GDPR or appropriate safeguards pursuant to Article 46 GDPR exist) or based on your express consent (Art. 49 para. 1 lit. a GDPR).

6. Duration of Storage

a. Informational Use of the Website

Your data stored in logfiles will be deleted six months after your visit. In case we use SessionCookies, which are necessary for the technical provision of our website, these are usually deleted after leaving our website.

b. Providing Information and Sending Queries

If you choose to provide information via the online forms and, if available, online questionnaires, and/or enquire information (see section 3 .b.), we will store your data for the duration of our exchange with you and until six (6) months after our last exchange relating, in case of employers, to the filling of job openings or, in case of candidates, to job opportunities and visa processes. After expiry of these six (6) months, we will delete your data within three (3) months. If you submitted your data more than twelve (12) months ago and we have not contacted you to discuss further steps, we will delete your data. Legal obligations of data retention shall remain unaffected and might prohibit deletion of data, in particular in relation to a successful placement of candidates.

7. Rights of the Data Subjects and Supervisory Authority

Under the legal provisions you are entitled to the following rights as data subject, which you can assert against us:

• Right to information: You are entitled to request confirmation from us at any time within the scope of Art. 15 GDPR as to whether we are processing personal data relating to you; If this is the case, you are also entitled under Art. 15 GDPR to receive information about such personal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.
• Right to rectification: According to Art. 16 GDPR, you are entitled to demand correction of the personal data stored about you if it is inaccurate or incorrect.
• Right to erasure: You are entitled, under the conditions of Art. 17 GDPR, to request from us the deletion of personal data relating to you without delay. Among other things, there is no right of erasure if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfillment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defense of legal claims.
• Right to restriction of processing: Under the conditions of Art. 18 GDPR you are entitled to request from us the restriction of the processing of your personal data.
• Right to data portability: You are entitled, under the conditions of Art. 20 GDPR, to request from us the provision to you of the personal data relating to you that you have submitted to us in a structured, current and machine-readable format.
• Right of revocation: You have the right to revoke your consent to the processing of personal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.
• Right to object: You are entitled to object to the processing of your personal data under the conditions of Art. 21 GDPR, meaning that we have to terminate the processing of your personal data. The right of objection exists only within the limits provided for in Art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.
• Right of appeal to a supervisory authority: You are entitled to file a complaint with a supervisory authority, in particular in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of personal data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.

The supervisory authority responsible for us is:

Bavarian State Office for Data Protection Supervision
(Bayerisches Landesamt für Datenschutzaufsicht)
Promenade 18
91522 Ansbach, Germany
Phone: +49 (0) 981 180093-0
E-mail: poststelle@lda.bayern.de