Untitled Document
Data protection policy
Thank you for visiting our website. The protection and confidentiality of your personal data is of particular importance for jobs.lu.
In this document we will inform you about the processing of personal data in connection with the services we offer at www.Jobs.lu. and other websites or apps (collectively referred to as “Platforms”) that incorporate this Data Protection Policy. Personal data comprises all information that relates to an identified or identifiable natural person (Article 4 (1) GDPR). This includes information such as your name, e-mail address, postal address, or telephone number. Information that is not directly associated with your identity, e.g. the number of users of an Internet site, does not fall within this scope.
1. Who is responsible for the processing of your personal data?
The data controller (hereinafter referred to as “jobs.lu” or “we”) in the sense of the GDPR and other national data protection laws of the member states as well as other data protection regulations is:
Branch office of jobs.lu Limited,
5 rue des Mérovingiens, L-8070 Bertrange
Tel.: (+352) 27 99 27 98
Mail: info@jobs.lu
2. Contact details of the data protection officer
You can contact our data protection as follows:
Branch office of jobs.lu Limited,
5 rue des Mérovingiens, L-8070 Bertrange
Tel.: (+352) 27 99 27 98
E-Mail datenschutz@jobs.lu
3. Purposes and legal basis of the data processing and period for which data will be stored
In the following we inform you about the different purposes for which we process personal data, on which legal basis such processing takes place, and for how long we store the data.
Insofar as we obtain the consent of the data subject for processing personal data, Art. 6 (1) (a) EU General Data Protection Regulation (GDPR) is the legal basis for the processing of personal data. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) GDPR will be the legal basis. This also applies to processing operations required to carry out pre-contractual actions. If processing of personal data is required to fulfill a legal obligation that our company is subject to, Art. 6 (1) (c) GDPR is the legal basis. If processing is necessary to safeguard the legitimate interests of our company or a third party, and if the interests, fundamental rights, and freedoms of the data subject do not prevail over the first interest, Art. 6 (1) (f) GDPR is the legal basis for processing.
The personal data of the data subject will be stored for as long as the purpose continues.
3.1 Data processing in the context of a general use of our Platforms and services
3.1.1 General access to our Platforms
With each access to our Platforms, we automatically collect data and information from the accessing device and store this data and information in the log files of the server. We may collect (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (known as referrers), (4) the sub-web pages that are accessed on our website (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used to defend any attacks against our IT systems.
For security purposes, i.e. to be able to reconstruct an eventual attack against our Platforms, we store such data including the IP address for 14 days and then anonymize or delete such data. The IP address is required during the connection to transfer the contents of our Platform to your device. The legal basis for the processing and storage of the IP address is a legitimate interest as per Article 6 (1) (f) GDPR. The legitimate interest for the transmission of the IP address is that it is required to display the contents of the website; without transmission of the IP address it is not possible to display the content of the Platform. The legimtiate interest for the temporary storage are our security interests.
3.1.2 Optimization of search and recommendation functions
We may also store information about your usage patterns on our Platforms in order to create statistical models to make our Platforms more user-friendly and, in particular, to optimize the functionalities to search for and recommend suitable job advertisements. In this context we also save your IP address in a pseudonymized form (that means that a natural person can no longer be identified based purely on the information in the statistical model) to exclude automated accesses (bots) to our Platforms when creating the statistical models. Legal basis for this purpose is Art. 6 (1) GDPR. Our legitimate interest is to ensure the functionality of the statistical model to improve our services. The IP address is deleted after one year.
3.1.3 Application form
If we provide an application form on our Platforms for job advertisements that are posted on our Platforms, and you complete this without being logged in to a Jobs.lu account (see clause 3.2.2 below) and click the button to submit the application, we will submit the information you provide in the application form to the provider who posted the advertisement on our Platform. The legal basis here is your consent in accordance with Art. 6 (1) sentence 1 GDPR.
3.1.4 Newsletter
If you register for a newsletter, we use your e-mail address to send you the respective newsletter, in which we regularly inform you about interesting topics. To ensure that you are properly registered for the newsletter, that is, to prevent unauthorized subscriptions on behalf of third parties, we will use a double-opt-in process and send you a confirmation e-mail after your first newsletter subscription; this e-mail will request you to confirm the subscription. The legal basis here is your consent in accordance with Art. 6 (1) sentence 1 a GDPR. In connection with your newsletter registration, we also store your IP address plus the date and time of registration and confirmation, so that we can trace and prove the registration at a later date. The legal basis for this storage is a legitimate interest within the meaning of Art. 6 (1) (f) GDPR, where the legitimate interest is in being able to prove the registration. We will store your email address for sending you the newsletter until you unsubscribe or we stop sending the newsletter to you.
The newsletters contain what are known as tracking pixels tor the statistical evaluation of our newsletter campaigns. This is a miniature graphic embedded in HTML-formatted e-mails that lets us know if and when you opened an e-mail and which links in the e-mail were accessed. In this context your IP address will be transmitted to our servers, but we will not store the IP address or any other personal data. The legal basis for the use of these tracking pixels is a legitimate interest within the meaning of Art. 6 (1) (f) GDPR, where the legitimate interest is in being able to evaluate and optimize our newsletters.
You may object to all types of Jobs.lu newsletters at any time.
3.1.5 Objections to marketing
If you raise an objection with us against marketing purposes, we may put your personal contact information (name, address, telephone number, fax number, e-mail address) on a blacklist to ensure that we no longer send you any unwanted marketing material. The legal basis is a legitimate interest within the meaning of Art. 6 (1) (f) GDPR, where the legitimate interest is that we can meet our obligations from your objection against marketing. The data will be stored for this purpose until you expressly withdraw the objection to marketing in writing.
3.1.6 Contact form and e-mail contact
Our Platforms provide contact forms that can be used to contact us electronically. By clicking the “Send” button, you consent to the transmission to us of the data entered in the input form. In addition, we save the date and time of your contact. Alternatively, contact via the e-mail address provided is possible. In this case, the user’s personal data transmitted along with e-mail and our response will be stored. The personal data voluntarily transmitted to us in this context is used to process your inquiry and to contact you as needed. The legal basis for the transmission of the data is Art. 6 (1) (a) GDPR. The data will be used for this purpose until the specific conversation with you has ended. The conversation will be deemed ended when it can be inferred from the circumstances that the relevant facts have been conclusively clarified.
3.1.7 Jobs.lu surveys
Jobs.lu organizes market surveys from time to time. As part of such surveys we will not collect any personal data, but in connection with such survey we might offer you the opportunity to participate in a competition. In order to participate in the competition you will have to provide us with your e-mail address, which we will only use for the purpose of the competition to notify you if you have won a prize. In particular, the e-mail address will be stored completely separately from your answers to the survey. The legal basis for the storage of your email address is your consent under Art. 6 (1) (a) GDPR. We will store your email address for this purpose until the end of the respective competition.
3.1.8 Use of data processors for hosting and securing our platforms, administrative, troubleshooting, and support services
We use data processors, which we list below, to provide our services. The legal basis for using these data processors is legitimate interest under Art. 6 (1) (f) GDPR. The legitimate interest lies in the execution of our business activities, particularly to provide the services described elsewhere in this Data Protection Policy. No conflicting interest is apparent because we have entered into a data processing agreement with the respective processors under Art. 28 GDPR.
3.1.8.1 Hosting
We use data processors to host our Platforms and for back-up services, meaning that personal data that is stored on our platforms is transferred to these data processors. These data processors are Amazon Webservices, Inc., 410 Terry Drive Ave North, WA 98109-5210 Seattle, USA (who processes data solely in the EU), StepStone GmbH, Axel-Springer-Str. 65, 10969 Berlin, Germany, StepStone Continental Europe GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany and StepStone N.V., Koningsstraat 47 Rue Royale, 1000 Brussels Belgium. These data processors will store the data for the same duration as it is stored on our Platforms for the various purposes defined in this Data Protection Policy.
3.1.8.2 Administrative, troubleshooting, and support services
For administrative (particularly including certain functionalities or processes described in this data protection policy), troubleshooting, and support services we use services provided by The Stepstone Group Ireland Recruit Ltd, Waterways House, Grand Canal Quay, Dublin 2, D02 NF40, Ireland, Jobs.ie Limited, Waterways House, Grand Canal Quay, Dublin 2, D02 NF40, Ireland, and StepStone Services sp. z o.o., ul. Domaniewska 50, 02-672 Warsaw, Poland, which may consequently also have access to your personal data. Generally these should not store any personal data. This will only be done in exceptional cases, e.g. if needed to rectify technical issues. In such cases personal data will only be stored to the extent and for the duration that is necessary.
3.1.8.3 Sending of e-mails and other messages
For the sending of e-mails and messages through other electronic channels we use the services of Selligent GmbH, Atelierstraße 12, 81671 Munich, Germany, as a data processor, who in turn uses the following subcontractors
- Selligent Benelux NV, Kempische Steenweg, 305 box 401 Belgium
- Selligent International, Avenue de Finlande 2 box 2, 1420 Braine-L'Alleud, Belgium
- Selligent France SA, 20 Place des Vins de France RCS, 75012 Paris, France
- Selligent SA, 1420 Braine-l'Alleud, 2 avenue de Finlande, Belgium
- Selligent Iberica S.L.U, Caille Enrique Granados 86-88, Planta 3 °, 0008 Barcelona, Spain
- Selligent Ltd, Second Floor, 45 Folgate Street, London E1 6GL, United Kingdom
Accordingly, these parties may also be provided with your personal data in the course of data processing commissioned by us. It will be stored there for a period that is otherwise lawful for purposes under this Data Protection Policy, i.e. in particular for the contractual communications in the course of contracts with you or otherwise for promotional communications.
The legal basis for our use of Selligent is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely the execution of our business purposes in the course of the processes described elsewhere in this Data Protection Policy. No conflicting interest is apparent in this respect, in particular due to the fact that we have entered into a data processing agreement with Selligent.
3.1.8.4 Proxy caching and web application firewall
We use Akamai Technologies GmbH, Parkring 20-22, 85748 Garching, Germany and Akamai Technologies, Inc., 150 Broadway, Cambridge, 02142 MA, USA as data processors for the purposes of proxy caching and web application firewall services. That means that any visit to our websites is routed through the servers of Akamai, meaning that the user will not be connected directly to our servers but to those of Akamai and Akamai will then request the content from our servers and will deliver it to the user. Proxy caching in this context means that Akamai will cache selected content (but not personal data) for a period of 24 hours, so that this can be delivered faster to you. The web application firewall means that Akamai will try to identify malicious web traffic and will prevent it from accessing our websites. Akamai does not store any personal data, but any dataflows between our servers and the user will be routed through Akamai, so that this can also include personal data. Data transferred to Akamai Technologies, Inc is transferred outside the EU and the EEA. This is permissible under Art. 45 GDPR because Akamai Technologies, Inc is Privacy Shield certified and thus an adequate level of protection exists according to the Implementing Decision of the Commission (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016D1250&from=DE). The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000Gn4RAAS&status=Active.
With respect to Akamai, the additional legitimate interest in the context of the legal basis is that we thereby are also implementing technical and organizational measures to protect our Platforms and the personal data stored on them.
3.1.9 Google Re-Captcha
In specific cases we use the reCAPTCHA service https://www.google.com/recaptcha/intro/ by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (“Google”) based on a legitimate interest (i.e. the interest to ensure the correctness of data, avoidance of automatic registrations / orders by so-called bots, and economical operation of our online offering within the meaning of Art. 6 (1) f) GDPR).
Google is certified under the Privacy Shield Agreement and thus warrants that it complies with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use re-Captcha to distinguish whether an input is made by a human or abusively by automated, mechanical processing. The query in this context includes the sending of the IP address and any other data required by Google for the reCAPTCHA service to Google. Your input will be transmitted to Google and analyzed for this purpose.
For more information about Google reCAPTCHA and Google’s Data Protection Policy, please visit the following links: https://www.google.com/intl/en/policies/privacy/ and https://www.google.com/recaptcha/intro/android. html.
3.1.10 Cookies and similar technology
We use cookies on our websites. Cookies are text files that are stored on a computer system via an Internet browser. We use such cookies both as a technical means of providing services on our Platforms as well as for analyzing the website behavior of our visitors and on that basis developing a more user-friendly design of our offerings. For this purpose, we may also use other techniques, such as tracking pixels or code in apps. In addition, we may use these cookies or other techniques to target you with interesting job advertisements and other content. For the sake of clarity, we have moved the information on cookies and similar techniques in section 4. of this Data Protection Policy. More details can be found there.
3.2 Data processing if you register for a JobAlert or a Jobs.lu account
Jobs.lu offers a variety of services for your career development. Jobs.lu aims to support you at all stages of your professional life. In particular, you can subscribe to a JobAlert and can create a Jobs.lu account in which we process personal data. In this section 3.2, we inform you about the purpose, the respective legal basis as well as the storage duration of these processing operations.
3.2.1 JobAlert
First we offer you the opportunity to enter into a contract to receive a JobAlert. The purpose of data processing in the context of a JobAlert is for us to send you regular e-mails about job vacancies that correspond to a predefined profile or are recommended to you based on your user behavior. Details of the JobAlert can be found in our Terms of Use. The legal basis is Art. 6 (1) (b) GDPR. We store the data under a contract for the use of the JobAlert for the duration of the contractual term, i.e. until you or we terminate your JobAlert.
3.2.2 Jobs.lu account
Second we offer you the opportunity to enter into a contract for a Jobs.lu account, where you can use additional functions and correspondingly define the scope of the contractual use. The purposes of the data processing under this contract are that:
- We store the applications you make through our Platforms in your Jobs.lu account for you until you delete a stored application.
- You can save individual job advertisements in your Jobs.lu account,
- You can use additional functionalities of a JobAlert (see 3.2.1)
- You can administer the Jobs.lu e-mail newsletters
- You can follow a company
- You can create a profile under the contract for your Jobs.lu account. Which personal data is transmitted to us in this context depends on your uploads or your input into the relevant fields. We will analyze the content and structure of any uploaded documents in an automated process in order to improve the services we provide to you. You can define the scope of the contractual use of this profile. You can either use it to apply to vacant positions only, see below; or you can make the profile accessible to potential employers who are Jobs.lu customers and use the Jobs.lu CV database or similar products. In the context of profiles made fully available, we may also use your profile data to find publicly available, business-related social media profiles and link these to your profile. Your profile will be stored until you delete it or the contract for your Jobs.lu account is terminated. Please be informed that, as far as you make your profile accessible to recruiters, a recruiter could also be located outside of the EU/EEA. That means that as part of the contract between you and us, it might be necessary, that your profile is accessed from a country that does not have the same level of data protection as the EU or EEA.
- If you have created a profile and access a job application form made available on our Platforms for job advertisements published on our Platforms, we will use your profile data to complete this form and, when you click the button to submit the application, we will send the data recorded with the form and make your profile accessible to the recruiter who published the respective job advertisement with us. Again, Please be informed that the respective recruiter might not be located in the EU or EEA, so that as part of the contract between you and us, it might be necessary, that the data is transmitted to or accessed from a country that does not have the same level of data protection as the EU or EEA.
Further details about the Jobs.lu account can be found in our Terms of Use. In connection with the registration of a Jobs.lu account and the setting of the various functions, we will also store your respective IP address and the date and time of registration or setting of functions. The legal basis for the storage and use of your personal data in connection with your Jobs.lu account is Art. 6 (1) (b) GDPR.
We store your personal data for as long as necessary to provide the contractually agreed service. The personal data stored by you in your “Jobs.lu” account is available to you for the duration of the contract and will be stored by us for this period. The personal data will be erased if you do so in relation to individual data or ask us to do so or if the contract ends, that is, if you or we terminate the contract, further details are available in the terms of use.
Additionally, we use information provided by you as part of a profile in order to optimize the job search and job recommendations for you and other users of our Platforms using the statistical model described in clause 3.1.2 In this context we store certain parts of your profile which by themselves or in combination with each other cannot be used to identify you along with a pseudonymized user ID in the statistical model. Based solely on this pseudonymized ID you are not identifiable from within the statistical model: an identification would theoretically only be possible by externally pseudonymizing the user ID assigned to your Jobs.lu account and then comparing the outcome with all pseudonymized user IDs stored in the statistical model. If we optimize the job search and the job recommendations for you with the statistical model, this is done in the context of your contract via the Jobs.lu account on the legal basis of Art. 6 (1) (b) GDPR. If we use the data to generally improve our statistical model and thus also services for other users, this is done on the basis of a legitimate interest under Art. 6 (1) (f) GDPR. By deleting your Jobs.lu account, your data will be completely anonymized in the statistical model, as the pseudonymized user ID stored in it will no longer allow any reference to your Jobs.lu account. Our legitimate interest is in pursuing our business interests to improve our services. No conflicting interest is apparent, since the data is required during the contract period for achieving the purpose of the contract for the Jobs.lu account and identification is no longer possible after the end of the contract.
3.3 Data processing about businesses and their employees
Our services for recruiters aim to provide businesses with a wide selection of suitable candidates. In doing so, we process personal data of businesses (data relating to businesses is only personal data if the business is operated by one or more natural person/s) or employees of such businesses. The respective businesses may be in a contractual or pre-contractual relationship with us, but in some cases we may also process data about businesses and their employees if there is no such pre-contractual relationship. In this section 3.3 we inform you about the purpose, the respective legal basis as well as the retention period of such processing about businesses or their employees as well as the data categories, provided we do not collect the personal data from the data subject. The data will be deleted as soon as it is no longer necessary for the achievement of the purpose, that is, no contract with the customer exists and we no longer intend to enter into a contract with the respective customer and a legitimate interest no longer exists and, moreover, we are no longer obliged to keep records that may contain personal data.
3.3.1 Data processing for contract management and pre-contractual purposes
We process personal data for the purpose of contract management, that is, so that we can provide our customers with the contractual services and also for associated pre-contractual purposes. If the customer is a natural person, the legal basis is that the processing is required for the performance of a contract or for the performance of pre-contractual measures pursuant to Art. 6 (1) sentence 1 b GDPR. If we process personal data of employees of the customer, the legal basis is a legitimate interest pursuant to Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the conduct of our business and that of the customer. There is no conflicting interest of the data subject because, from the point of view of our customer, we are required to perform the processing in the context of the existing employment relationship with the data subject or there is a legitimate interest. We store personal data for this purpose for the term of the contract.
Furthermore, we store accounting records for the duration of ten years and business correspondence, i.e. every message that is used to prepare, execute, or revoke a business transaction, for the duration of six years, in order to comply with statutory retention periods for business correspondence. The legal basis for this purpose is Art. 6 (1) (c) GDPR.
3.3.2 Customer services
We process the personal data of a business or its employees (as a contact person) obtained in connection with a contract with or a request from a prospective customer, including after the end of the contract and, if no contract is entered into, for the purpose of customer services and particularly, in case of a new request of the customer or prospective customer, to be able to recommend suitable services on the basis of the previous contracts or inquiries. The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the execution of our business activities. We store personal data for this purpose for as long as we believe the respective customer might enter into an initial or further contract with us in future, which is the case as long as the customer does not specifically inform us that he or she does not intend to enter into any contract with us under any circumstances.
3.3.3 Jobs.lu Recruiter Space
In order to use and manage their contractual services, our customers or their employees can use the Jobs.lu Recruiter Space. In this context, we process such personal data of the respective customer or its employees as was provided by them, as well as the respective contractually agreed or offered services and the manner in which they are utilized. When using our CV database we also collect and save when which CVs were accessed. In order to prevent abuse and thereby guarantee proper billing and to ensure and verify that the Jobs.lu Recruiter Space and the contractual services are functioning correctly at all times, and in particular to allow our customer service team to solve problems that may arise for specific customers, we will, upon every use of the Jobs.lu Recruiter space, additionally collect and store the Corporate User ID (i.e. the user’s username) and the Company ID (i.e. the name of this customer based on the specific user's affiliation with a specific Jobs.lu customer).
If the customer is a natural person, the legal basis is that the processing is required for the performance of a contract or for the performance of pre-contractual measures pursuant to Art. 6 (1) sentence 1 b GDPR. If we process personal data of the customer's employees, the legal basis is a legitimate interest pursuant to Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the conduct of our business and that of the customer. There is no conflicting interest of the data subject because, from the point of view of our customer, we are already required to perform the data processing in the context of the existing employment relationship with the data subject or there is a legitimate interest. Personal data will be stored for this purpose for the term of the contract for the use of the Jobs.lu Recruiter Space.
Additionally, we use the data collected under this section in anonymous form to produce statistics about the general behavior of the customers of the CV Database. This allows us to make the services more customer-friendly. The legal basis is a legitimate interest pursuant to Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the execution of our business activities.
3.3.4 Data processing when publishing advertisement products
If our customers publish advertising products or company portraits on our Platform, we process personal data of the customer where the customer is a natural person. If our customer specifies an employee’s contact data in an advertisement product, we process this employee’s personal data to provide the relevant data to our users as part of the advertisement on our Platform and to ensure that the advertisement can be found via the search functionality on our Platforms. To increase the reach of the advertisement by submitting it to our co-operation partners, we may, in whole or in part, submit the advertisement content to our co-operation partners who provide the advertisement or a preview on their web site. If the customer is a natural person, the legal basis is that the processing is necessary for the performance of a contract pursuant to Art. 6 (1) sentence 1 b GDPR. If the advertisement contains contact details of employees of the customer, the legal basis is a legitimate interest pursuant to Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the conduct of our business and that of the customer. There is no conflicting interest of the data subject because, from the point of view of our customer, we are required to perform the processing in the context of the existing employment relationship with the data subject or there is a legitimate interest. We will store the data for this purpose for the contractual term during which the job advertisement is available on our Platforms.
3.3.5 Data processing for general marketing purposes
We process personal data about our customers as well as other companies and companies that are not in a business relationship with us and in this context, if necessary, also from the respective contact persons for the purpose of direct marketing, as far as legally permitted. If we did not collect this data directly from the respective data subject, we may also collect contact data about the data subject from publicly available sources, in particular the website of the respective company, classified directories, or advertisements of the respective business. In connection with these direct marketing purposes, we can also process information about the previous contracts of our customers and specifics about the business such as industry or size of the business in order to make the advertising as appropriate as possible. The legal basis is a legitimate interest in accordance with Art. 6 (1) sentence 1 f GDPR. The legitimate interest lies in the processing of personal data for the purpose of direct advertising itself (see recital 47 GDPR). The data subjects have the right to object at any time to the processing of personal data concerning them for the purpose of such advertising. You object at any time under the contact details set out in clause 1; in the case of advertising by e-mail, you will also find an opt-out link directly in the respective e-mail. We will store personal data for this purpose as long as we are still interested in entering into a contract with the respective business or until the business objects.
3.4 Facebook Fanpage
We use a Facebook fanpage at jobs.lu. Facebook provides Page-Insights for that fanpage to us. Page-Insights are aggregated data, which allow us to understand how users interact with our fanpage. Page Insights can be based on personal data which is collected in relation to a visit of or an interaction with our fanpage and its content by users. Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland („Facebook Ireland“) and we are joint controllers in the sense of Art 26 GDPR for the processing of Insights data and we have entered into an arrangement with Facebook Ireland which you can find at www.facebook.com/legal/terms/page_controller_addendum. Legal basis for our use of the fanpage and Page-Insights is a legitimate interest in the sense of Art. 6 para 1 f GDPR, in relation to the fanpage that means the use of Facebook as channel of communication about our company and in relation to Page Insights the better understanding of the interests of visitors of our fanpage so that we can specifically serve these interests.
4. Cookies and similar technology
We use cookies on our websites. Cookies are text files that are stored on a computer system via an Internet browser. We use such cookies both as a technical means of providing services on our Platforms, for enabling e.g. certain functions, as well as for analyzing the website behavior of our visitors and on that basis developing a more user-friendly design of our offerings. For this purpose, we can also use other techniques, such as tracking pixels or code in apps. In addition, we may use these cookies or other techniques to target you with interesting job advertisements and other content.
Some of the cookies we use are deleted at the end of the browser session, i.e. when you close your browser (known as session cookies). Other cookies are kept on your end device and enable us or our partner companies to recognize your browser on the next visit (persistent cookies).
If not specifically stated below, you can view the exact retention period of a given cookie by displaying the cookie in your browser.
You can set your browser up such that you are notified when a cookie is set and can decide individually whether to accept them or whether you opt out of accepting cookies for specific cases or generally. If you opt out of accepting cookies, the functionality of our website may be limited.
When you visit the Website, we check if you have provided consent in the last 6 months. If you have not provided consent in the last 6 months, then we display a cookie consent banner and ask for your consent and only trigger necessary cookies and similar tracking technologies until consent is provided. If you provide consent for all cookies and similar technologies in the last 6 months, then we trigger all cookies and similar tracking technologies for 6 months from when this consent was provided. If you only provide consent for necessary cookies and similar technologies in the last 6 months, then we only trigger necessary cookies and similar tracking technologies for 6 months from when this consent was provided.
The following list describes these consent options:
If you have provided no consent in the last 6 months, only necessary cookies and similar tracking technologies being triggered.
If you choose 'I accept' from the cookie banner, you consent to all cookies and similar tracking technologies being triggered for 6 months from when this consent was provided.
If you choose the 'Settings' option from the cookie consent banner, the cookie preferences dialog is displayed and allows you to provide more granular consent to only necessary cookies and similar tracking technologies for 6 months.
If you choose 'Accept All' from the cookie preferences dialog, you consent to all cookies and similar tracking technologies being triggered for 6 months from when this consent was provided.
If you choose 'Confirm' from the cookie preferences dialog with the option 'Adverts for other goods and services on this website as well as job adverts on other websites' turned off, you consent to only necessary cookies and similar tracking technologies being triggered for 6 months from when this consent was provided.
If you choose 'Confirm' from the cookie preferences dialog with the option 'Adverts for other goods and services on this website as well as job adverts on other websites' turned on, you consent to all cookies and similar tracking technologies being triggered for 6 months from when this consent was provided.
We deal with specific cookies below.
4.1 Technically necessary cookies
We use technical cookies. These are cookies that are merely required to collect certain information on our Platforms to provide a service required or wanted by you as user. This extends to navigation or session cookies that enable smooth navigation and use of the website (and for instance permit access to the restricted area); analysis cookies that are set directly by us to collect aggregated information about the number of users and their behavior; functional cookies that provide you with navigation by certain selected criteria as part of a service optimization (e.g. selected language, purchase of selected products).
The legal basis for these cookies is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes.
4.2 Cookies and technologies that we use via third party providers
We also use cookies or other technology provided to us by external providers in various areas. In the following, we inform you about the respective providers and how you can object to the cookie or the corresponding technology. You can control the types of cookies here.
In addition, you can opt out using the following links from companies that adhere to the self-regulatory principles for online behavioral advertising and participate in the opt-out programs established by the Digital Advertising Alliance or the European Interactive Digital Advertising Alliance.
4.2.1 Criteo
On our website we use services by Criteo SA, 32 Rue Blanche, 75009 Paris in the framework of our common responsibility as defined under Art. 26 GDPR.
The purpose of the processing is retargeting, which means that when you have viewed certain offers on the website, we may show you advertising for similar offers from us on websites or other third-party platforms. We designate the scope of the respective advertising campaign in line with the contract with Criteo. The implementation of this advertising campaign, including the decision on which advertisements are delivered where is then the responsibility of Criteo. To that end a code from Criteo is executed on our pages directly by Criteo and what are known as (re)marketing tags (invisible graphics or code, also known as web beacons) are integrated into the website. These are used to store an individual cookie, i.e. a small file on your device (comparable technologies may also be used instead of cookies). This file records which websites the user locates, the content he or she is interested in and which offers he or she has clicked. It also stores technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offering. Criteo may also combine the above information with information from other sources. If the user subsequently visits other websites, tailored advertisements can be displayed depending on his or her interests.
Further information and means of objecting to this data recording by Criteo can be found in Criteo’s privacy policy: http://www.criteo.com/en/privacy .
Criteo stores the data for 13 months and the cookies set by Criteo expire automatically after 13 months.
Within the scope of the joint responsibility for the data processing described in this clause 4.1, you can assert your rights under the GDPR against us and Criteo either with us or with Criteo.
The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes.
4.2.2 Security analysis techniques from Akamai
Our websites use web and security analysis techniques from Akamai Technologies, Inc. (“Akamai”). These techniques use cookies, text files and beacons that are stored on your computer and that enable Akamai (i) to perform security analyses and thus prevent unauthorized access to our websites and (ii) to analyze the use of the websites by you. The information generated by the cookies or beacons about the access to our websites, including your IP address and other data from log files, is transferred to Akamai's servers, some of which are located in the USA, where it is stored and processed. This is permissible under Art. 45 GDPR because Akamai is Privacy Shield certified and thus an adequate level of protection exists according to the Implementing Decision of the Commission (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016D1250&from=DE). The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000TSUAAA4&status=Active .
Akamai will use this information to prevent unauthorized access to the websites, to produce reports about website activity for us, to perform further services associated with the website use and Internet use, and to analyze your use of our websites. Akamai may also pass this data to third parties if Akamai is required to do so by law or if these third parties are processing this data on behalf of Akamai. Akamai will not use the data to identify natural persons. You can prevent the storage of cookies or beacons by making a corresponding setting in your browser software; however, note that if you do so you may not be able to use the full functionality of this website. You can view the precise storage duration of the cookies for yourself by accessing this information via your respective browser.
For further information on terms of use for the processing of personal data by Akamai and on Akamai’s data protection policy, see https://www.akamai.com/de/de/privacy-policies/ .
The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes and the protection of our websites.
4.2.3 Hotjar
We use Hotjar, a web analytics service of Hotjar Ltd, Level 2, St Julian's Business Center, 3, Elia Zammit Street, St Julian's STJ 1000, Malta ("Hotjar") in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on https://www.hotjar.com/privacy.
You can opt-out from the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this link https://www.hotjar.com/opt-out.
We have a contract processing agreement with Hotjar. The use of Hotjar is based based on a legitimate interest according to Art. 6 para. 1 p. 1 f DSGVO. Our legitimate interest is the user-friendly design of our websites.
4.2.4 AppSee
To analyze the usage of our apps, we use the app analysis service AppSee of Shift 6 Ltd. Menorat Hamaor 3, Tel Aviv, Israel.
The user behavior within the apps is analyzed in order to identify causes of errors and to constantly improve the user experience. Only anonymous data is collected and stored, details of the stored information can be found at https://support.appsee.com/customer/en/portal/articles/2686233-what-types-of-data-does-appsee-capture. A storage of personal data does not take place. To create the anonymized data, your IP address may be processed by Shift 6 and its affiliate US company AppSee Inc. Such processing can also take place in the US or Israel. A transfer of personal data to Israel is allowed under the Adequacy Decision 2011/61 / EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061), as Israel is therefore has a level of data protection that is adequate compared to the EU’ and in the US Appsee Inc is certified under Privacy Shield, and thus in accordance with Commission Implementing Decision (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/? uri = CELEX: 32016D1250 & from = DE) there is an adequate level of data protection. The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000TSUAAA4&status=Active
You will find further information about the privacy of Appsee at: http://www.appsee.com/legal/privacypolicy.
The legal basis for the use of Appsee is a legitimate interest under Art. 6 para. 1 sentence 1 f DSGVO. Our legitimate interest is the user-friendly design of our offers.
You can object to the use of Appsee at any time by changing the setting of the slider for anonymous statistics in the app under "Settings".
4.2.5 Fabric Crashlytics
We use the Fabric Crashlytics service offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland to better address technical issues related to our mobile apps. Fabric Crashlytics is an analytics service that collects technical information about the device (such as the operating system and model) and app usage data, specifically related to system crashes and errors. We use this information to collect data on app usage specifically related to system crashes and errors, and to better understand how our users use the app to improve the app. The information collected is available only in anonymous form. A storage of personal data does not take place. Google Ireland Limited may use Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, as a subcontractor. Google Inc. is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. Other subcontractors that Google can use can be found here: https://fabric.io/terms/subprocessors.
For more information, see the Fabric Crashlytics Terms of Use at: https://fabric.io/terms.
The legal basis for the use of Fabric Craslytics is a legitimate interest under Art. 6 para. 1 sentence 1 f DSGVO. Our legitimate interest is the user-friendly design of our apps.
You can opt out of using Fabric Crashlytics at any time by changing the setting of the slider for anonymous statistics in the app under "Settings".
4.2.6 Adjust
We also use the app analysis service Adjust (adjust GmbH, Saarbruecker Str. 38a, 10405 Berlin) to analyze the usage of our apps. The Adjust service has been tested and certified according to the ePrivacyseal (European Privacy Seal) (see https://www.eprivacy.eu/en/customers/awarded-seals/).
When using the app, Adjust collects installation and usage data on our behalf. We use this anonymous information to understand how our users interact with our app. Adjust uses your anonymized IDFA or Android ID as well as your anonymized IP and MAC address. It is not possible to identify you. A storage of personal data does not take place accordingly.
For more information, see Adjust's Privacy Policy: https://www.adjust.com/privacy-policy/.
The legal basis for the data analysis and use of Adjust is a legitimate interest (ie interest in the analysis, optimization and economic operation of our apps) in the sense of Art. 6 (1) (f) GDPR for the purposes of our own Market research, advertising purposes and the optimization and user friendly design of the apps. There is no apparent conflicting interest, especially since we have concluded a data processing agreement with Adjust.
You can opt out of using Adjust at any time by changing the setting of the slider for anonymous statistics in the app under "Settings”.
4.2.7 Firebase
In our apps we use technology from Google Firebase (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, "Google") with various functionalities.
Firebase Analytics enables the analysis of the use of our apps. This completely aonymized information about the use of our app is collected and transmitted to Google and stored there. Google uses the advertising ID of the device. Google will use this information to evaluate the use of our app and to provide us with other services related to the use of apps. In Device Settings, you can restrict the use of the Advertising ID (iOS: Privacy / Advertising / No Ad Tracking, Android: Account / Google / View). Google Analytics for Firebase (Google Inc.). We also use Firebase Remote Config, which allows us to run A / B tests and customize the behavior and appearance of the app without having to download a new version. Personal data is not stored.
Google Inc. is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Subcontractors that Google can use can be found here: https://firebase.google.com/terms/subprocessors.
The legal basis for the use of data analysis and the use of Firebase is a legitimate interest (ie interest in the analysis, optimization and economic operation of our apps) within the meaning of Art. 6 (1) (f) GDPR).
You can opt-out of using Firebase at any time by changing the setting of the slider for anonymous statistics in the app under "Settings”.
4.2.8 Google Tag Manager
On our websites we use the Google Tag Manager. Google Tag Manager is a solution that lets us manage website tags from one interface. The Tag Manager tool itself (which implements the tags) does not use cookies and does not collect personally identifiable information. The tool triggers other tags, which may collect data. Google Tag Manager does not access this data. If disabled at the domain or cookie level, the deactivation will remain in effect for all tracking tags implemented with Google Tag Manager. Legal basis is a legitimate interest under Art. 6 para. 1 f DSGVO. The legitimate interest lies in optimizing the management of the website tags used by us.
4.2.9 AddThis
We use plug-ins from the AddThis service operated by Oracle America, Inc. ("Oracle") located at 500 Oracle Parkway, Redwood Shores, CA 94065 ("AddThis"). AddThis provides web site creation and design tools (www.addthis.com) designed to make it easier for website visitors to share their current page with other internet users via email or social media. You can identify the pludins by the "Tweet", "E-Mail", "LinkedIn" and "g + 1" buttons integrated on parts of our website. AddThis also provides tools for website operators to help analyze and improve the use of their own website or to provide a direct user approach. AddThis also uses cookies and web beacons (small graphics, "counting pixels" that enable log file recording and log file analysis). If you use an AddThis plug-in, your Internet browser establishes a direct connection with the AddThis servers and, if applicable, the selected social network. The generated data (such as time of use or browser language) are transferred to AddThis and processed there. Personal data is not stored by Addthis. When you send content from our website to social networks, a link can be made between visiting the website and your user profile on the appropriate social network. For more information about data processing and privacy through AddThis, visit http://www.addthis.com/privacy/privacy-policy.
AddThis is certified under Privacy Shield, which provides an adequate leverl with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt00000000181AAA&status=Active).
Legal basis is a legitimate interest under Art. 6 para. 1 DSGVO. The legitimate interest is that we want to offer our users the ability to share content they consider interesting.
4.2.10 Revive Adserver Hosted edition
On our website we use services by Revive Software and Services BV, Jonkersvaart 36, 9366 TC Jonkersvaart, The Netherlands.
The purpose of the processing is to display job related content sections within our website using the Revive Adserver Hosted edition. For more details see: https://www.revive-adserver.net/privacy/4.2.11
4.2.11 Facebook Pixel
The “Facebook Pixel” from the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA, is used within our website. This means that what are termed tracking pixels are integrated into our pages. When you visit our pages, the tracking pixel creates a direct link between your browser and the Facebook server.
This provides Facebook with the information from your browser for instance that our page was accessed by your device. If you are a Facebook user, Facebook can allocate the visit to our pages to your user account. Please note that as the provider of the pages we are not informed about the content of the data transferred or its use by Facebook. We can merely choose which segments of Facebook users (age, interests) our advertising is to be shown to.
By accessing the pixel on your browser, Facebook can also identify whether displaying an advertisement on Facebook was successful, e.g. if it resulted in an online sale being completed. This enables us to record the effectiveness of Facebook advertisements for statistical and market-research purposes.
Please click here if you wish to opt out of data recording via Facebook Pixel: https://www.facebook.com/settings?tab=advertisements#_=_. Alternatively, you can deactivate the Facebook Pixel on the Digital Advertising Alliance page via the following link: http://www.aboutads.info/choices/ .
Transfer of data to the USA is permissible under Art. 45 GDPR because Facebook is Privacy Shield certified and thus an adequate level of protection exists according to the Implementing Decision of the Commission (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016D1250&from=DE). The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes and the targeted marketing of our services.
4.2.12 Google Remarketing
Our websites use the remarketing or “similar audiences” function from Google Inc. (“Google”). This enables us to target the visitors to our websites with advertising by displaying personalized, interest-driven advertisements to the users of the website when they visit other websites in the Google Display network. Google uses cookies to perform the analysis of the website use, on the basis of which the interest-driven advertisements are generated. No personal data of the website visitors is stored. If you then visit another website in the Google Display network, you will be shown advertisements that are highly likely to relate to product and information areas you have previously accessed.
You can permanently deactivate the use of cookies by Google by clicking the following link and downloading and installing the plug-in provided there: https://www.google.com/settings/advertisements/plugin. Alternatively, you can deactivate the use of cookies from third-party providers by accessing the deactivation page of the Network Advertising Initiative at http://www.networkadvertising.org/choices/ and the implementing the additional information about opting out as set out there. For further information on Google Remarketing and Google's data protection policy, click: http://www.google.com/privacy/advertisements/ .
The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes and the targeted marketing of our services.
4.2.13 Google Conversion Tracking
On the grounds of our legitimate interests (i.e. interest in the analysis, optimization, and economical operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we use the marketing and remarketing services (for short: “Google Marketing Services”) of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thus warrants that it complies with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
The Google Marketing Services enable us to display advertisements for and on our website in a more targeted manner to so that users are only shown advertisements that they may be interested in. If a user sees e.g. advertisements for products that he or she was interested in on other websites, this is referred to as “remarketing”. For this purpose, when our websites and other websites are accessed on which Google Marketing Services are active, Google directly executes a Google code and what are termed (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. These are used to store an individual cookie, i.e. a small file on the user’s device (comparable technologies may also be used instead of cookies). The cookies may be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com, or googleadservices.com. This file records which websites the user searches for, the content he or she is interested in and which offers he or she has clicked. It also stores technical information on the browser and operating system, referring websites, time of visit, and other information on the use of the online offering. Similarly, the user’s IP address is recorded, whereby in the context of Google Analytics we state that the IP address is shortened in within Member States of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases is it transferred in full to a Google server in the USA and shortened there. The IP address is not merged with the user’s data within other Google offerings. Google may also combine the above information with information from other sources. If the user subsequently visits other websites, tailored advertisements can be displayed depending on his or her interests.
The user’s data is processed in a pseudonimyzed form as part of the Google Marketing Services. This means that Google stores and processes e.g. not the user’s name or e-mail address, but instead processes the relevant data based on the cookie within pseudonymized user profiles. This means that, from Google’s perspective, the advertisements are not managed and displayed for a specifically identifiable person, but for the holder of the cookie, irrespective of who the holder of this cookie is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information about the user collected by Google Marketing Services is transferred to Google and stored on Google’s servers in the USA.
The Google Marketing Services deployed by us include the “Google AdWords” online advertising program. Google AdWords supplies every AdWords customer with a different “conversion cookie”. This means that cookies cannot be traced via the websites of AdWords customers. The information obtained using the cookie enables conversion statistics for AdWords customers to be produced who have opted for conversion tracking. The AdWords customers are notified of the total number of users who clicked their advertisement and were forwarded to a page containing a conversion tracking tag. However, they are not given any information that could be used to personally identify users.
We may involve third parties on the basis of the “DoubleClick” Google marketing services. DoubleClick uses cookies that enable Google and its partner websites to place advertisements on the basis of users’ visits to this website and other websites on the Internet.
Additionally, we may deploy the “Google Tag Manager” to integrate and manage the Google analytics and marketing service within our website.
For further information on data usage for marketing purposes by Google, refer to the overview page: https://www.google.com/policies/technologies/advertisements; Google’s privacy policy can be accessed at https://www.google.com/policies/privacy.
If you would like to opt out of interest-driven advertising from Google Marketing Services, you can use the settings and opt-out options provided by Google: http://www.google.com/advertisements/preferences.
4.2.14 AppDynamics
We use the services of Firma AppDynamics LLC, 303 Second Street, 8th Floor, North Tower, San Francisco, CA 94107, for the purpose of performance monitoring. To this end, AppDynamics places a cookie that is only valid during your visit to our website.
No personal data is stored.
Transfer of data to the USA is permissible under Art. 45 GDPR because AppDynamics is Privacy Shield certified and thus an adequate level of protection exists according to the Implementing Decision of the Commission (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016D1250&from=DE). The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000GnJ2AAK .
The legal basis is a legitimate interest under Art. 6 (1) sentence 1 f GDPR, namely pursuance of our business purposes.
4.2.15 Google Analytics
Our website use Google Analytics to collect aggregated visitor usage data to help us understand the overall performance of our website. This analytics tool provides valuable insights that help guide our business. For more information see: https://support.google.com/analytics/answer/6004245?hl=en-GB.
4.2.16 Adobe Analytics
We use SiteCatalyst, a web-analytics tool from Adobe Systems Software Ireland Limited, that enables us to optimize our services in line with your requirements.
Adobe Analytics uses cookies that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of this website (including your IP address) is transferred to servers of the service in Ireland where it is anonymized. It is then transferred to servers in the USA for further processing, where it is stored. Adobe uses this information to evaluate your use of the website to compile reports on website activities for the website operators and to provide further services connected with the use of the website and the Internet.
No personal data is stored because of the anonymization.
As a user of our websites you of course have the option to block cookies at any time in your browser settings. You can opt out of any future recording of your user behavior on the Platform at any time; click the following link for instructions on how to deactivate cookies on your computer: https://www.adobe.com/privacy/opt-out.html .
The legal basis for processing this data is a legitimate interest under Art. 6 (1) (f) GDPR. The legitimate interest as defined by Art. 6 (1) (f) GDPR that we are pursuing by processing the data described above is our interest in structuring our offerings in a user- and demand-driven manner. No conflicting interest is apparent, especially because you may opt out at any time.
4.2.17 Intercom
We use a support tool provided by Intercom, Inc. (INTERCOM, INC., 55 2nd St, 4th Fl., San Francisco, CA 94105 USA). It is a communication platform for direct interaction via chat between website visitors and us. If questions arise, we can provide you prompt assistance by means of this tool.
The transmission of your IP address to Intercom takes place into the USA and thus into a state outside the EU or the EEA. This transfer is permitted under Art. 45 GDPR, as Intercom is Privacy Shield certified and therefore, according to Commission Implementing Decision (EU) 2016/1250 (http://eur-lex.europa.eu/legal-content/EN/TXT/ HTML /? Uri = CELEX: 32016D1250 & from = DE) an adequate level of protection of personal data exists. The certification can be viewed at https://www.privacyshield.gov/participant?id=a2zt0000000TNQvAAO&status=Active.
Legal basis is a legitimate interest under Art. 6 para. 1 f of the GDPR, namely to offer our users a fast support service.
5. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the data controller:
5.1 Right of access
You may request confirmation from us as to whether we process personal data relating you.
If such processing is taking place, you can request the following information from us:
(1) the purposes for which the personal data is being processed;
(2) the categories of personal data that are being processed;
(3) the recipient or categories of recipient to whom the personal data concerning you has been or will be disclosed;
(4) the envisaged period for which the personal data concerning you will be stored or, if no concrete information about this is possible, criteria used to determine that period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right restrict the processing of the data by the controller or a right to object to this processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information about the origin of the data if the personal data was not collected from the data subject;
(8) the existence automated decision-making including profiling in accordance with Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved and the scope and the intended effects of such processing for the data subject.
You have the right to request information about whether the personal data in question will be transferred to a third country or an international organization. In this context you can ask to be notified of the suitable safeguards in accordance with Art. 46 GDPR in the context of the transfer.
This right to information may be limited if it is likely to render impossible or seriously impair the achievements of the statistical purposes and the limitation is necessary for satisfying the statistical purposes.
5.2 Right to rectification
You have a right to rectification and/or completion vis-à-vis the data controller if the personal data concerning you that is being processed is incorrect or incomplete. The data controller must perform the rectification without undue delay.
Your right to rectification may be limited if it is likely to render impossible or seriously impair the achievements of the statistical purposes and the limitation is necessary for satisfying the statistical purposes.
5.3 Right to restriction of processing
If the following conditions are met, you can demand that the processing of the personal data concerning you is restricted:
(1) if you contest the accuracy of the personal data relating for you for a that enables us to review the accuracy of the personal data;
(2) the processing is unlawful and you oppose the erasure of the personal data and instead request a restriction of the use of the personal data;
(3) we no longer require the personal data for the purposes of the processing, but you need it to establish, exercise, or defend legal claims, or
(4) if you have objected to the processing in accordance with Art. 21 (1) GDPR and it has not yet been verified whether our legitimate reasons override yours.
If the processing of the personal data concerning you has been limited, this data – with the exception of being stored by you – may only be processed with your consent or for the purpose of establishing, exercising, or defending legal claims or to protect the rights of another natural or legal or on grounds of a compelling public interest of the EU or a Member State.
If a restriction of processing has been imposed in accordance with the above conditions, we will notify you before the restriction is lifted.
Your right to restrict processing may be limited if it is likely to render impossible or seriously impair the achievements of the statistical purposes and the limitation is necessary for satisfying the statistical purposes.
5.4 Right to erasure
5.4.1 Erasure obligation
You may request that we erase the personal data concerning you without undue delay, and we are obliged to erase this data without undue delay where one of the following grounds applies:
(1) The personal data concerning you is no longer needed for the purposes for which it was collected or otherwise processed.
(2) You withdraw your consent upon which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and no other legal ground for the processing applies.
(3) You object to the processing in accordance with Art. 21 (1) GDPR and no overriding legitimate grounds for the processing apply, or you raise an objection to the processing under Art. 21 (2) GDPR.
(4) The personal data concerning you has been processed unlawfully.
(5) The erasure of the personal data concerning you is required in order to comply with a legal obligation under EU law or the law of the Member States to which we are subject.
(6) The personal data concerning you is collected in the context of information society services pursuant to Art. 8 (1 ).
5.4.2 Information to third parties
If we have published the personal data concerning you and we are obliged to delete it under Art. 17 (1) GDPR, we will take reasonable steps (including in terms of technical feasibility), taking account of the available technology and implementation costs, in order to notify the responsible data controller who is processing the data that you as a data subject have requested from them the erasure of all links to this personal data or copies or replications of this personal data.
5.4.3 Exceptions
There is no right to erasure if the processing is necessary
(1) for the exercise of the right to the freedom of expression and information;
(2) to satisfy a legal obligation that requires the data to be processed under the law of the EU or the Member States to which the data controller is subject, or to perform a task that is carried out in the public interest or in the exercise of official authority vested in the data controller;
(3) on grounds of the public interest in the area of public health in accordance with Art. 9 (2) (h) and (i) as well as Art. 9 (3) GDPR;
(4) for archiving purposes in the public interest, academic or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, provided the right specified under section a) is likely to render impossible or seriously impair the achievements of the objectives of this processing or
(5) to establish, exercise, or defend legal claims.
5.5 Right to data portability
You have the right to the receive the personal data concerning you that you have provided to us in structured, commonly used, and machine-readable format. Further, you have the right to transmit this data to a different data controller without hindrance from us, provided
(1) the data processing is based on consent under Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and
(2) the processing is being performed using automated means.
Further, in exercising this right you also have the right to have the personal data concerning you transferred directly from one data controller to another data controller, where technically feasible. This must not adversely affect other people’s rights and freedoms.
The right to data portability does not apply to the processing of personal data that is required for a task that is performed in the public interest or the exercise of official authority vested in us.
5.6 Right to object
You have the right to object, on grounds relating to your specific situation to object, at any time to the processing of the personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to any profiling based on those provisions.
In this case we will stop processing the personal data concerning you unless we can provide compelling and legitimate grounds for the processing that override your interests, rights and freedoms, or the data is being processed for the purpose of establishing, exercising, or defending legal claims.
If the personal data concerning you is being processed for the purpose of conducting direct marketing, you have the right to object at any time to the processing of the personal data concerning you for such marketing; this also applies to any profiling connected to such direct marketing.
If you object to the data processing for the purposes of direct advertising, the personal data concerning you will no longer be processed for these purposes.
In the context of the use of information society services and Directive 2002/58/EC notwithstanding, you may exercise your right to object using automated means using technical specifications.
Where personal data is processed for statistical purposes pursuant to Art. 89 (1) GDPR, you, on grounds relating to your specific situation, have the right to object to personal data concerning your being processed.
Your right to object may be limited if it is likely to render impossible or seriously impair the achievements of the statistical purposes and the limitation is necessary for satisfying statistical purposes.
5.7 Right to withdraw the declaration of consent under data-processing law
You have the right to withdraw your declaration of consent under data-processing law at any time. Withdrawing the consent has no bearing on the lawfulness of any processing performed up to the point of the revocation.
5.8 Automated decision in individual cases including profiling
You have the right not to be subject to a decision that is based solely on automated processing – including profiling – that produces legal effects on you or is similarly significantly affects you. This does not apply if the decision
(1) is necessary for the entering into or performing a contract between you and the data controller,
(2) is authorized under legal provisions of the EU or the Member States to which the data controller is subject and these legal provisions contain adequate measures for safeguarding your rights and freedoms as well as your legitimate interests or
(3) is made with your explicit consent.
However, these decisions must not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (g) applies and adequate safeguards to protect the rights and freedoms as well as your legitimate interests are in place.
As regards the cases stated in (1) and (3), we take adequate measures to your rights and freedoms as well as your legitimate interests, which include at least the right to have a person intervene on the data controller’s side, to present your own point of view, and to challenge a decision.
5.9 Right to lodge a complaint with a supervisory authority
Notwithstanding any other administrative or judicial legal remedy, you have the right to lodge a complaint with a supervisory authority in the Member State of your place of residence, your workplace, or the place of the alleged breach if you are of the opinion that the processing of the personal data concerning you breaches the GDPR.
The supervisory body to which the complaint was submitted will notify the complainant of the status and outcomes of the complaint including the option of a judicial remedy under Art. 78 GDPR.
6 Amendment of the data protection policy; amendment of purpose
We reserve the right to amend this Data Protection Policy in consideration of stipulations under data-protection law. You will always be able to locate the current version here or another corresponding, easily locatable point of our website or app. If we are intending to process your data for other purposes, i.e. those for which it was collected, we will notify you about this in advance in compliance with the statutory provisions.
