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Processing of (personal) data by the entity in charge of the online application process

1. Introduction

In the following, we inform you about the processing of personal data during the use of our website.

● our website https://www.botsandpeople.com/

● our profiles on social media.

Personal data is any data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details

The responsible party pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Bots and People Product GmbH, Schlesische Str. 29, 10997 Berlin, Germany, email: info@botsandpeople.com.We are represented by Nico Bitzer, Oliver Nagel.

Our data protection officer is heyData GmbH, Kantstr.99, 10627 Berlin, www.heydata.eu, E-Mail:datenschutz@heydata.eu.

1.2 Scope of data processing, processing purposes and legal basis

The scope of data processing, processing purposes and legal bases are explained in detail below. The following are possible legal bases for data processing:

Article 6 (1) sentence 1 it. a DSGVO serves as the legal basis for processing operations for which we obtain consent.

Art. 6 para. 1 p. 1 lit. b DS GVO is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of enquiries about our products or services.

Art. 6 (1) sentence 1 lit. c DSGVO applies if we fulfil a legal obligation with the processing of personal data, as may be the case in tax law, for example.

Article 6 (1) sentence 1 lit. f DSGVO serves as the legal basis if we can invoke legitimate interests for the processing of personal data, e.g. for cookies that are required for the technical operation of our website.

1.3 Data processing outside the EEA

Where we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed, where available (e.g. for the UK, Canada and Israel), by adequacy decisions of the EU Commission (Article 45(3) of the GDPR).

If there is no adequacy decision (e.g. for the USA), the legal basis for the data transfer is usually standard contractual clauses, unless we indicate otherwise. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Article 46 (2) (b) of the GDPR, they guarantee the security of the data transfer. Many of the providers have issued contractual guarantees that go beyond the standard contractual clauses to protect the data. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies want to access the data.

1.4 Storage period

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion is not contrary to any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted, i.e. the data is blocked and not processed for other purposes. This applies, for example, to data that we must retain for reasons of commercial or tax law.

1.5 Rights of the persons concerned

Data subjects have the following rights with respect to personal data concerning them:

● Right to information,

● Right to rectification or erasure,

● Right to restriction of processing,

Right to object to processing,

● Right to data portability,

Right to revoke the consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6 Obligation to provide data

Within the framework of a business relationship or other relationship, customers, interested parties or third parties only have to provide us with the personal data that is required for the establishment, implementation and termination of the business relationship or for the other relationship or which we are legally obliged to collect. Without this data, we will usually have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automatic decision-making in individual cases

For the establishment and implementation of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 of the GDPR. Should we use these procedures in individual cases, we will inform you separately if this is required by law.

1.8 Contacting

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) are stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f DSGVO) in answering enquiries directed at us. We delete the data accrued in this context after the storage is no longer necessary or restrict the processing if there are statutory retention obligations.

1.9 Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better so that the legal basis for the associated data processing is Art. 6 para. 1 p. 1 lit f DSGVO. We delete the data when the results of the surveys have been evaluated.

2. newsletter

We reserve the right to inform customers who have already used our services or purchased goods about our offers from time to time by e-mail or other electronic means, unless they have objected to this. The legal basis for this data processing is Article 6 (1) sentence 1 lit. f DSGVO. Our legitimate interest lies in direct advertising (recital 47 DSGVO). Customers can object to the use of their email address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each email or by sending an email to our above-mentioned email address.

Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a DSGVO. Consent can be revoked at any time, e.g. by clicking on the relevant link in the newsletter or by sending a message to our e-mail address given above. The processing of the data until the revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1S. 1 lit. a DSGVO), we also measure the opening and click-through rate of our newsletters in order to understand which content is relevant to our recipients.

We send newsletters using the HubSpot tool from the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy:https://legal.hubspot.com/de/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the USA.

3. data processing on our website

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3.1 Informational use of the website

During the informative use of the website, i.e. when visitors to the website do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest so the legal basis is Art. 6 para. 1 p. 1 lit. fDSGVO.

These data are:

● IP address

● Date and time of the request

Time zone difference from Greenwich Mean Time (GMT)

Content of the request (concrete page)

● Access status/HTTP status code

Volume of data transferred in each case

● Website from which the request comes

Browser

Operating system and its interface

● Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.2 Web hosting and provision of the website

Our website is hosted by Webflow, Inc. 208 Utah, Suite 210, SanFrancisco, CA 94103, USA (privacy policy: https://webflow.com/legal/eu-privacy-policy)and webgo GmbH, Heidenkampsweg 81, 20097 Hamburg. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO.

3.3 Contact form

When contact is made via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering enquiries directed at us. The legal basis for the processing is therefore Art. 6 para. 1 p. 1 lit. f DSGVO.
We delete the data generated in this context after storage is no longer necessary or restrict processing if there are legal obligations to retain data.

3.4 Job advertisements

We publish vacancies in our company on our website, on pages linked to the website or on websites of third parties.
The data provided as part of the application is processed for the purpose of carrying out the application procedure. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Article 88 (1) DSGVO in conjunction with Section 26 (1) BDSG. We have marked the data required for the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 Para. 1S. 1 lit. a DSGVO).

We ask applicants to refrain from disclosing political opinions, religious beliefs and similar sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing in the context of the processing of the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9(2)(a) DSGVO).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.

We pass on the applicants' data to the responsible employees in the HR department, to our order processors in the area of recruiting and to the other employees involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures, we will delete their data only one year after receipt of the application.

3.5 Booking appointments

Visitors to our website can book appointments with us. For this purpose, we process metadata or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly option for making appointments, which is why the legal basis for data processing is Article 6 (1) sentence 1 lit. fDSGVO. Insofar as we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.6. customer area

Site visitors can open a customer account on our website. We process the data requested in this context to fulfil the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b DSGVO.

3.7 Offer of goods or services

We offer goods or services via our website. The processing of the data collected in this context is carried out for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 p. 1 lit. b DSGVO).

3.8 Payment service provider

For the processing of payments, we use payment processors who are themselves data protection controllers within the meaning of Art. 4 No. 7 DSGVO. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfil the contract concluded with our customers (Art. 6 para. 1 p. 1 lit. b DSGVO).

These payment service providers are:

● giropay GmbH

● Klarna Bank AB (publ), Sweden

● Mastercard Europe SA, Belgium

● PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg

Stripe Payments Europe, Ltd, Ireland

● Visa Europe Services Inc, Great Britain

3.9 Third party providers
3.9.1 HubSpot

We use HubSpot for the management of customer relationships. The provider is HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. f DSGVO. We have a legitimate interest in managing data in a simple and convenient way.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://legal.hubspot.com/privacy-policy.

3.9.2 Weglot

We use Weglot for translations. The provider is Weglot, 138, rue Pierre Joigneaux in BOIS-COLOMBES (92270), France. The provider processes meta/communication data (e.g. device information,IP addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. f DSGVO. We have a legitimate interest in automatically translating information on our website.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://weglot.com/de/privacy/abrufbar.

3.9.3 Google Web Fonts

We use Google Web Fonts for fonts on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. a DSGVO. Data subjects may withdraw their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of the processing until the withdrawal.

The legal basis for transfers to a country outside the EEA is consent.

Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.9.4 Google Tag Manager

We use Google Tag Manager for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. a DSGVO. Data subjects may withdraw their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of the processing until the withdrawal.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.9.5 Google Conversion Tag

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. a DSGVO. Data subjects may withdraw their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of the processing until the withdrawal.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information can be found in the provider's data protection declaration at https://policies.google.com/privacy?hl=dehttps://support.google.com/tagmanager/answer/9323295?hl=de&ref_topic=3441532abrufbar.

3.9.6 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis of the processing is Art. 6 para. 1 p. 1lit. a DSGVO. Data subjects may withdraw their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The withdrawal does not affect the lawfulness of the processing until the withdrawal.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93(2) of the GDPR (Article 46(2)(c) of the GDPR), which we have agreed with the provider.

The data is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

4. data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behaviour, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the operators of the networks store information on user behaviour in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators will merge this information with other data. Users can find further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This can result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies have access to the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the enquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO.

4.1 Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The data protection declaration is available here: https://www.facebook.com/policy.php. One way to object to data processing is via settings for advertisements:https://www.facebook.com/settings?tab=ads.
We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 DSGVO with Facebook. Facebook explains exactly what data is processed a thttps://www.facebook.com/legal/terms/information_about_page_insights_data. Affected people can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a quicker response if they contact Facebook directly.

4.2 Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here:https://help.instagram.com/519522125107875.

4.3 YouTube

We maintain a profile on YouTube. The operator is GoogleIreland Limited Gordon House, Barrow Street Dublin 4. Ireland. The data protection declaration is available here: https://policies.google.com/privacy?hl=de.

4.4 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The data protection declaration is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. You have the option to object to data processing via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

4.5 Xing

We maintain a profile on Xing. The operator is New WorkSE, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here: https://privacy.xing.com/de/datenschutzerklaerung.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect in the future. A current version is available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please contact us using the details above.

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.