Data protection information for applicants and talent management at Zühlke Engineering AG

1.    Purpose of this privacy policy

Zühlke operates a web-based platform for applicant- and talent-management (hereinafter the platform), which is based on the Wintrgarden software from Universum Group AB, Jakobsbergsgatan 22, 111 44 Stockholm, Sweden.

The platform enables people who are interested in Zühlke as an employer to create an applicant profile to apply for vacancies at Zühlke. The system also offers the means to create a talent profile. Based on the information stored in the talent profile, Zühlke can assess the suitability of a talent for vacancies at Zühlke and provide the talent with information on vacancies at Zühlke and/or general information about Zühlke as an employer.

Personal data is processed in connection with applicant- and talent-management. 

In this privacy policy we, the companies of the Zühlke Group (hereinafter referred to as Zühlke, we or us), explain how we collect and otherwise process personal data in connection with applicant- and talentmanagement.

When processing your personal data, the activities of the respective Zühlke Group company may be subject to the provisions of the European General Data Protection Regulation (GDPR). We have included several references in this privacy policy which are explicitly subject to the GDPR being applicable. Where we process your personal data outside the ambit of the GDPR, these references are not applicable.

2.    Information about the data controller

2.1    Name and contact details of the data controller

Zühlke is responsible for processing your personal data. The responsibility for processing your personal data rests with the Zühlke Group company that posted the job advertisement and which therefore processes your personal data via its services or via its communication with you and decides on the purposes and means of this data processing. The following companies are part of Zühlke:

  • Zühlke Engineering AG, Zürcherstrasse 39J, 8952 Schlieren, Switzerland
  • Zühlke Ventures AG, Zürcherstrasse 39j, 8952 Schlieren, Switzerland
  • Zühlke Engineering GmbH, Düsseldorfer Str. 38, 65760 Eschborn, Germany
  • Zühlke Engineering (Austria) GmbH, Rivergate, Handelskai 92, 1200 Wien, Austria
  • Zuhlke Engineering Ltd, 80 Great Eastern Street, London EC2A 3JL, United Kingdom
  • Zuhlke Engineering d.o.o., Bulevar Milutina Milankovića 1ž, 11070 Belgrad, Serbia
  • Zuhlke Engineering Pte Ltd, 140 Robinson Road #04-01, Singapur 068907, Singapore
  • Zuhlke Engineering Hong Kong Ltd, 511 Queen’s Road West, Sai Ying Pun, Hong Kong
  • Цюлке Инженеринг EООД – Zuhlke Engineering EOOD, Studentski District, 83 Nikola Gabrov-ski str., floor 5, Sofia, Bulgaria
  • Zühlke Engineering, Unipessoal, Lda., Rua Júlio Dinis 826, 4050-292 Porto, Portugal
  • Zuhlke Engineering Vietnam, SO006 – Floor 5, CJ Building, 2Bis-4-6 Le Thanh Ton, Ben Nghe Ward, District 1, Ho Chi Minh City


2.2    Contact details of the controller’s data protection officer

    Zühlke Engineering GmbH, Data Protection Office, Düsseldorfer Str.38, 65760 Eschborn, Germany; E-mail: dataprotection@zuehlke.com

3.    Basis of data processing

Zühlke processes your personal data based on various principles:

  • To safeguard Zühlke's legitimate interests (the legal basis under GDPR – where applicable – is section 6 para. 1 f);
  • To carry out pre-contractual measures (the legal basis under GDPR – where applicable – is section 6 para. 1 b of the General Data Protection Regulation) [does not apply to Hong Kong and Singapore];
  • To meet legal obligations (the legal basis under GDPR – where applicable – is section 6 para. 1 c);
  • Based on the user's express consent, insofar as this is legally required (the legal basis under GDPR – where applicable – is section 6 para. 1 a).

If you have any questions, please get in touch with the relevant contact referred to above.
 

4.    Purpose of data processing

Zühlke processes your personal data for the following purposes:

  • For the safe and stable operation of the platform; 
  • To provide the platform contents called up by the user;
  • For traceability regarding changes to the data stored in the system;
  • To carry out the application process, in particular examining applications, contacting the applicant and conducting job interviews to evaluate and select suitable applicants; 
  • For the administration of the applicant management;
  • To carry out the recruitment procedure after successful application, in particular the conclusion of an employment contract;
  • To carry out the talent management. For this purpose, we process the data stored in your talent profile in order to assess your suitability for vacancies at Zühlke and to provide you with information on vacancies at Zühlke and/or general information about Zühlke as an employer by e-mail and/or phone. If a talent who already has an applicant profile then creates a talent profile, we also transfer the data stored in the applicant profile to the talent profile;
  • To conduct cooperation with recruitment agencies appointed by applicants or talents.

5.    Collection, storage and use of personal data

5.1    When visiting the platform

When you visit our platform, your browser automatically sends information to our platform server. This information is temporarily stored in a log file. The following information is logged without your intervention and stored until it is automatically deleted:

  • name of the page or file you accessed;
  • date and time of the access;
  • transferred data volume;
  • indication whether the request was successful;
  • description of the web browser used;
  • operating system used;
  • page visited previously;
  • provider;
  • your IP address.

We process these data for the following purposes:

  • to ensure smooth platform connection;
  • to ensure user-friendly interaction with our platform;
  • evaluation of system security and stability; and
  • other administrative purposes.

The legal basis for data processing is our legitimate interest or your consent. Our legitimate interest follows from the data collection purposes listed above. Under no circumstances do we use the collected data for the purpose of drawing conclusions about you personally. In addition, we use cookies and analysis- and marketing-services when you visit our platform. Further information can be found in section 6 of this privacy policy. 
 

5.2    When registering on the platform

If you want to register on our platform, you will need to provide registration data to log in to our portal, and we will store this data (e-mail address, password, first name, surname). 

The legal basis for data processing is, with regard to the registration process, your consent, and with regard to the storage of data, our legitimate interest or your consent. Our legitimate interest lies in the guarantee of traceability regarding changes to the data stored in the system.

If the user deletes their applicant profile and there was no application, the data will be deleted immediately. Otherwise, the applicant profile data will be stored for a limited period of time from the date of the last application (see 5.3): 

  • In Germany and Austria: 6 months;
  • In Switzerland, Bulgaria, Serbia, UK, Singapore, Hong Kong and Portugal: 12 months;

If the user deletes their talent profile, the data is deleted immediately. Otherwise, the talent profile data will be stored for a limited period of time from the time of the last login to the platform (see 5.4): 

  • In Switzerland, Germany, Austria, UK, Serbia, Bulgaria and Portugal: 24 months;
  • In Singapore and Hong Kong: 36 months;
     

5.3    Applicant profile data

We store data that applicants themselves, or recruitment agencies commissioned by the applicant and on behalf of the applicant, submit in an applicant profile. We make a distinction between mandatory information (phone number, date of birth, previous employers, university/college, language and login data) and optional information (profile picture, CV, references).

The legal basis for data processing is the implementation of pre-contractual measures (preparation of the employment), our legitimate interest or your consent. Our legitimate interest lies in the protection against lawsuits (e.g. for alleged violation of applicable equal treatment laws) and the settlement of possible claims by recruitment agencies.

If an application is successful, we transfer the data to the personnel file. 

If an applicant withdraws the application they have submitted, or the application is unsuccessful, or the applicant deletes their applicant profile, we will continue to store the data for a certain period of time:

  • In Germany and Austria: 6 months (if the data was submitted by a recruitment agency, we will store the data for another 12 months);
  • In Bulgaria, Switzerland, UK, Serbia, Singapore,Hong Kong and Portugal: 12 months; 

If a talent who already has an applicant profile then creates a talent profile, we also transfer the data stored in the applicant profile to the talent profile.


5.4    Talent profile data

We store data that talents themselves, or recruitment agencies commissioned by the talent and on behalf of the talent, submit in a talent profile. We make a distinction between mandatory information (phone number, date of birth, previous employers, university/college, language and login data) and optional information (profile picture, CV, references).

The legal basis for data processing is your express consent.

If a user of the platform deletes their talent profile, the data is deleted immediately. Otherwise, the data will be stored for a certain period of time from the time of the last login to the platform:

  • In Switzerland, Germany, Austria, UK, Serbia, Bulgaria and Portugal: 24 months;
  • In Singapore and Hong Kong: 36 months;
     

5.5    Comments about applicants

We store any supplementary internal comments that Zuhlke adds to an applicant profile. These are notes from job interviews. These internal comments are not visible to applicants on the platform.

The legal basis for data processing is the implementation of pre-contractual measures (preparation of the employment), our legitimate interest or your consent. Our legitimate interest lies in the protection against lawsuits (e.g. for alleged violation of applicable equal treatment laws) and the settlement of possible claims by recruitment agencies.

If an application is successful, we transfer the data to the personnel file and store the data for another 12 months.

If an applicant withdraws the application they have submitted, or the application is unsuccessful, or the applicant deletes their applicant profile, we will continue to store the data for a certain period of time: 

  • In Germany and Austria: 6 months (if the data was submitted by a recruitment agency, we will store the data for 12 months);
  • In Bulgaria, Switzerland, Serbia, Hong Kong, Singapore,UK and Portugal: 12 months; 

If a talent who already has an applicant profile then creates a talent profile, we also transfer the data stored in the applicant profile to the talent profile. The legal basis for data processing within the scope of the GDPR is section 6 para. 1 a, your express consent. 
 

5.6    Comments about talent

We store any supplementary internal comments that Zühlke adds to a talent profile. These are notes on conversations with the talent. These internal comments are not visible to talents on the platform.

The legal basis for data processing is, the implementation of pre-contractual measures (Job-interviews) or your express consent.

If the user deletes their talent profile, the data is deleted immediately. Otherwise, the data will be stored for a certain period of time from the time of the last login to the platform:

  • In Switzerland, Germany, Austria, UK, Serbia, Bulgaria and Portugal: 24 months;
  • In Singapore and Hong Kong: 36 months. 

6.    Cookies

We typically use cookies and similar techniques on our platform to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored on your computer or mobile device by the web browser you use when you visit our platform. When you visit the platform again, we can recognise you, although we don't know who you are. In addition to cookies that are only used during a session and are deleted after your visit to the platform ("session cookies"), cookies can also be used to store user settings and other information for a certain period of time, e.g. two years ("permanent cookies"). However, you can set your browser to reject cookies, to save them only for one session or to delete them early. Most browsers are preset to accept cookies.

6.1    Necessary cookies

We use technically necessary cookies in some sections of our platform. Such file elements allow your computer to be identified as a technical unit during your visit to the platform in order to enable you to use our services. However, you usually have the option of setting your internet browser to inform you about the use of cookies so that you can allow or exclude them or delete existing cookies. Please use the Help function of your internet browser to obtain information on how to change these settings. Please note that certain functions of our platform may not work properly if you have deactivated technically necessary cookies. Cookies do not allow a server to read private data from your computer or the data stored by another server. They do not damage your computer and do not contain viruses.  Within the ambit of the GDPR, our use of technically necessary cookies is based on GDPR section 6 para. 1 f, i.e. the processing is carried out to enable the functioning of our platform. It is therefore necessary to protect our legitimate interests.

6.2    Additional cookies

In addition, we use the following cookies to understand how you use our services and to be able to present you with other marketing offers that may be of interest to you. The cookies described below are only used if you have given your prior consent (within the scope of the GDPR in accordance with section 6 para. 1 a).

6.2.1    Use of Google Tag Manager

We use Google Tag Manager. This is a management system that allows us to integrate the other services shown below into our platform. Google Tag Manager itself does not process any personal data. This is only done through the Google service described immediately below and in the manner described there.

6.2.2    Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies, which are text files stored on your computer that enable an analysis of your use of the platform. The information generated by the cookie about your use of this platform is usually transferred to a Google server in the USA and stored there. However, since IP anonymisation is enabled on our platform, your IP address will be shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there. Google uses this information on our behalf to evaluate your use of the platform, to compile reports on platform activities and to provide us with further services related to platform and internet use. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to benefit from the full functionality of our platform. You can also prevent the collection of data generated by the cookie and related to your use of the platform (including your IP address) by Google, and the processing of this data by Google by downloading and installing the browser plugin available via the following link (http://tools.google.com/dlpage/gaoptout?hl=en).

Please note that on this platform Google Analytics has been extended with the code "gat._anonymizeIp();" in order to guarantee anonymised collection of IP addresses (referred to as IP masking). In addition, you can prevent Google Analytics from collecting data by clicking this link. An opt-out cookie is then set to prevent further collection of your information when you visit this platform. This procedure is particularly recommended when accessing our site via mobile devices. For more information on terms of use and data protection, please visit https://marketingplatform.google.com/about/analytics/terms/us/ or https://policies.google.com/privacy?hl=en&gl=en. Our use of the a forementioned analysis tool is based on your consent (within the scope of GDPR section 6 para. 1 a).

6.2.3    Quantcast

We use the Quantcast service to optimise job advertisements placed online and to measure the success of these job advertisements. Quantcast is a service provided by Quantcast International Limited in Ireland. Quantcast collects and analyses anonymous browsing data using standard internet cookies. This anonymous data is never used to personally identify visitors to the website. The information generated by the cookie about your use of the platform is stored on a server in the USA. The IP address is anonymised immediately after processing and before it is saved.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to benefit from the full functionality of our platform. You can also prevent the collection of data generated by the cookie and related to your use of the platform by Quantcast, and the processing of this data by Quancast by using the opt-out option provided via the following link (https://www.quantcast.com/opt-out/). An opt-out cookie is then set to prevent further collection of your information when you visit this platform. This procedure is particularly recommended when accessing our site via mobile devices. For more information on Quantcast's terms of use and privacy policy, please visit https://www.quantcast.com/privacy/

Our use of the a forementioned analysis tool is based on your consent (within the scope of GDPR section 6 para. 1 a).

6.2.4    Use of Facebook pixel

Our platform also uses the remarketing function "Custom Audiences" from Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook“). This enables users of the platform to be presented with interest-related advertisements ("Facebook ads") when they visit the Facebook or other websites that also use the procedure. In doing so, we pursue the interest of displaying advertising that is of interest to you, in order to make our platform more interesting for you. Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server. We have no influence on the scope and further use of the data collected by Facebook through the use of this tool and therefore inform you according to our state of knowledge. Through the integration of Facebook Custom Audiences, Facebook receives the information that you have called up the platform or clicked on an advertisement from us. If you are registered for one of Facebook's services, Facebook can assign the visit to your account. Even if you are not registered with Facebook or have not logged in, it is possible that the provider will be able to identify and store your IP address and other identification features. The function "Facebook Custom Audiences" can be disabled here. Logged-in users can do this by clicking on https://www.facebook.com/settings/?tab=ads#_. The legal basis for this processing is your consent (within the scope of the GDPR section 6 para. 1 a). Further information on data processing by Facebook can be found at https://www.facebook.com/about/privacy

6.2.5    Use of LinkedIn Insight

Our platform uses LinkedIn Insight tag, an analysis and tracking tool from LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. LinkedIn Insight tag allows us to collect information about visits to our website, including URL, referrer URL, IP address, device and browser characteristics, timestamps and page views. This data is encrypted, anonymised within seven days and the anonymised data is deleted within 90 days. LinkedIn does not share any personally identifiable information with us, but only provides aggregate reports about the site's audience and advert performance. LinkedIn also provides retargeting for website visitors, which allows us to use this data to display targeted advertising outside our platform without identifying the member. LinkedIn members can control the use of their personal data for promotional purposes in their account settings. We use the LinkedIn Insight tag for the purpose of providing detailed campaign reporting and information about visitors to our website and thus our advertising and marketing interests. As a LinkedIn marketing solutions customer, we use the LinkedIn Insight tag to track conversions, retarget our site visitors, and gather additional information about the LinkedIn members who view our ads. The LinkedIn Insight tag feature can be disabled here. If you are a LinkedIn member and do not want LinkedIn to collect information about you through our platform and link it to your membership information held by LinkedIn, you must log out of LinkedIn before visiting our platform. You can also prevent participation in these tracking procedures by adjusting your browser software accordingly. By changing the settings in your internet browser, you can disable or restrict the execution of Java Script and thus prevent storage of data. Please note that in this case some of the features of our platform may no longer be available. To prevent the execution of Java Script code altogether, you can install a Java Script blocker, such as the NoScript browser plugin (e.g. https://noscript.net/ or https://www.ghostery.com/). The legal basis for this processing is your consent (within the scope of the GDPR section 6 para. 1 a). For further information on data processing by LinkedIn, please visit https://www.linkedin.com/legal/privacy-policy.

7.    Your rights

In connection with the processing of your personal data, you are entitled by law to various rights, but please note that their existence and scope may vary depending on the applicable data protection legislation. Within the ambit of the GDPR or Serbian Law on Personal Data Protection you have the following rights:

  • Information: You have the right to ask Zühlke which, if any, of your personal data it processes. If required, please submit a request for information. 
  • Rectification: Should your personal data be incorrect, you have a legal right to its correction.
  • Withdrawal of consent: Where our personal data processing activities are based on your consent you can revoke your consent at any time. The revocation is only valid for the future and does not affect any other basis for data processing. 
  • Objection: If the processing of your personal data is based on the legitimate interest of Zuhlke (not applicable for Hong Kong and Singapore), you may object to the use of your personal data. However, this is only the case if you are in such a special situation that your personal interest is in conflict with the use of your personal data. Zuhlke reserves the right to provide compelling, overriding reasons. Furthermore, you may at any time object to the use of your personal data for direct marketing purposes. Processing based on other factors remains unaffected by the objection.
  • Restriction: Under certain circumstances, you may request that the processing of your data be restricted. This may be the case if you doubt the accuracy of your data. Please note that any processing restriction may limit the scope of our services or make the service unavailable.
  • Data portability: If provided for under applicable data protection law, you may request the personal data you have provided us with in the form required by law and - subject to important conflicting interests - continue to use it.
  • Right of deletion: See section 10 below.
  • Complaints: Depending on the applicable data protection legislation, you may have a legal right of appeal to the relevant data protection authority; if processing takes place within the EU, this right may extend to the EU.

8.    Other recipients of your personal data

When processing your personal data, Zuhlke may use third parties (principally within the Zuhlke Group) to carry out the data processing on behalf of Zuhlke. In particular, this may be the case for handling commercial and administrative services and in connection with IT services such as in the context of the hosting and support of the platform by Wintrgarden. Your privacy is always ensured.

Please note that the passing on of anonymised data remains possible regardless of the above.

9.    Place of data processing

Your personal data will generally be processed in the host country of the Zuhlke company in which you are applying for a job or with regard to which you are creating the talent profile.

If your personal data is disclosed abroad, this will only take place in countries that have a recognised equivalent data protection standard or where specific guarantees have been given. 

In particular, you should expect your data to be transferred to all countries in which the Zuhlke Group is represented by Group companies (see section 2) and to other countries in Europe and the USA where the service providers we use are located (see sections 1 and 6.2). In case we should transfer personal data from EU or Serbia to Zuhlke Group companies outside the European Economic Area (EEA), the transfer will only be performed if it was confirmed by the respective authorities that this third party country has an adequate level of data protection or if standard data protection clauses exist.

If you have any questions, please get in touch with the relevant contact referred to above. 

10.    Storage duration / deletion of personal data

As a rule, we delete your data from the time at which the purpose for processing no longer applies. The duration of the data retention has been partly explained in detail above (see point 5). In the event of an objection to processing on the basis of a legitimate interest or consent, we will delete your data from this point in time, unless another permission for processing continues to exist, for example in the case of legal storage obligations, a legitimate interest to enforce our own legal positions, etc.

11.    Status of the privacy policy

This privacy policy is currently valid and was last updated on 13.01.2021.

It may become necessary to amend this privacy policy due to the further development of our platform or offers referred to above, or due to changes in legal or official requirements. The current privacy policy can be accessed at any time on our platform via https://www.zuehlke.com/en/data-protection-information-for-applicants-and-talent-management-at-zuhlke-engineering-ag.