• Name
• Age/Date of birth
• birth number
• Gender
• Photography
• Marital status
• Contact details
• Training details
• Career history
• Emergency contacts and details of dependants
• Contact details for a reference
• Immigration status (whether you need a work permit)
• Nationality/Citizenship/Place of birth
• A copy of your driving licence or passport/ID card
• Financial data (if we need to check your financial background)
• Social security number (or equivalent in your country) and other tax information
• Information on diversity, including any racial or ethnic origin, religion or similar beliefs, and physical and mental health, including any information related to disabilities.
• Details of any criminal history, if relevant to the post you are applying for
• Details of your current remuneration, pension and benefit arrangements
• Information about your interests and claims with respect to future employment, both directly collected and derived, for example from job offers or articles you read on our website.
• Additional information that you choose to provide us with
• Additional information that your contact person will provide about you for a reference
• Additional information that our customers voluntarily provide to us about you or that we receive from third parties, such as job portals
• IP address
• Date, time and frequency of your access to our services
• Video recordings when you enter our premises.
  Please note that this is not a complete list of personal information that we may collect.

Even if you access our website, we collect certain information about you. More information can be found here.

CUSTOMER DATA: We collect data about our customers only to a very limited extent. As a general rule, we only need your contact details or the contact details of individual contacts within your organisation (such as their names, telephone numbers and e-mail addresses) in order to ensure a smooth business relationship. We also store information about your online use of candidate profiles and other materials published by Ovation Group. We use this information to ensure that you receive appropriate promotional communications from us at the right time. We may also store additional information that someone from your organization has voluntarily provided to us. In certain circumstances, such as when you have contacted our finance or collection teams, our telephone calls with you may be recorded, subject to applicable local regulations and requirements. If, for any reason, we need additional personal information from you, we will let you know.

Even if you access our website, we may collect certain information about you. More information can be found here.

SUPPLIER DATA:We do not collect much information about suppliers. We only need to ensure a smooth business relationship. We collect information from our contacts within your organization, such as names, telephone numbers and e-mail addresses. We also collect bank information so that we can make payments to you. We may also store additional information that someone in your organization has voluntarily provided to us. In certain circumstances, such as when you have contacted our finance or collection teams, our telephone calls with you may be recorded, subject to applicable local regulations and requirements.

We also collect certain information about you when you access our website. More information can be found here.

Thanks to the emergency contact details, we have someone we can notify in case of an emergency. In order to ask someone for a reference, we naturally need the contact details of the contact person for references (such as name, e-mail address and telephone number). We also need these details if our candidate or one of our employees has indicated you as an emergency contact so that we can notify you in the event of an accident or emergency.

VISITORS OF OUR WEBSITE:  We collect and use a limited amount of information from visitors to our Website in order to make it easier for you to use our Web site and better manage the services we provide. This includes information such as how you use our site, how often you access our site, your browser type, the location from which you visit our site, the language selected, and the times when our site is most in demand. If you contact us through the website, for example by using the chat feature, we collect all information you provide to us, such as your name and contact information.

For more information about what information we collect about you when you visit our website, click here.

HOW IS YOUR PERSONAL DATA COLLECTED?

CANDIDATE DATA:We collect personal data from our candidates in three main ways:

• Personal data that you provide to us as a candidate
• Personal data that we receive from other sources
• Personal information that we collect automatically.
• Personal data that you communicate to us

Ovation Group requires certain information about you in order to provide you with a customized service. In this way, we can offer you optimal opportunities. You may also save time by not having to search through information about jobs and services that are not relevant to you.

You can provide us with information in a variety of ways, depending on what suits you best. This may include that you:

• Enter your information as part of the registration process on the Ovation Group website or on an application form;
• submit a printed CV at an Ovation Group recruitment event, job board or branch;
• Email or interview your resume to an Ovation Group consultant;
• Apply for jobs through a job search engine, which will then redirect you to the Ovation Group website;
• Enter your personal information on an Ovation Group microsite; or
• participate in a competition via a social network such as Xing, Facebook or Twitter.

Personal data that we receive from other sources

We also receive personal information about candidates from other sources. Depending on the relevant circumstances and applicable local laws and regulations, this may also include personal information received in the following situations:

Your reference contact may disclose personal information about you;
Our customers may disclose personal information about you to us;
We may learn about you when searching for potential candidates from external sources such as LinkedIn and other job networks;
When you click „Like“ on our Facebook page or „Follow“ us on Twitter, we receive personal information about you from these websites;
If you are referred to us by one of our partner vendors, they may share personal information about you with us.

Personal information automatically collected by us

If you access our website or read or click on an e-mail from us, we may also automatically collect your information in accordance with any local regulations and requirements or by providing it to us. You can find more information here.

CUSTOMER DATA: We collect personal data from customers in three ways:

Personal Information We Receive Directly From You
Personal data that we receive from other sources
Personal information that we collect automatically.
Personal data we receive directly from you
Our goal is the same: to make sure you find the best people for your organization. We receive data directly from you in two ways:

• if you contact us voluntarily, usually by telephone or e-mail, and/or
• if we contact you by telephone, e-mail or more generally as part of the business development activities of one of our consultants.

Personal Information We Obtain from Other Sources

We may attempt to obtain information about you and your colleagues, as appropriate and in accordance with any local laws and regulations, from other sources, usually through due diligence or market research, such as about you or your colleagues:

• Third-party market research and analysis of online and offline media (which we may conduct ourselves or hire other companies to do)
• Attendee lists for corresponding events
• Other limited sources and third parties (e.g. from candidates when they provide us with your data to give you a reference).

Personal Information We Collect Through Our Web Site

If you access our website or read or click on an e-mail from us, we may also automatically collect your information in accordance with any local regulations and requirements or by providing it to us. You can find more information here.

VISITORS OF OUR WEBSITE:  When you visit our website, we may automatically collect certain information about you, whether or not you use our services. This includes your IP address, the date, time, and frequency of your visits to the Site, and the way you browse the content. We also collect information from you when you contact us through the Site, such as when you use the chat feature.

We automatically collect your information using cookies according to the cookie settings in your browser. If you are also a candidate or customer of Ovation Group, we may use information about your use of the Site to improve other aspects of our communications with you or the service we provide to you. More information about cookies, such as how we use them and what choices you have, can be found here.

HOW IS YOUR PERSONAL DATA USED?

If we have data about you, we use it in different ways.
CANDIDATE DATA: In general, we use information about our candidates in four ways:

• Recruitment measures;
• Advertising
• Equal opportunities monitoring;
• Assertion, exercise or defence of legal claims.

Under appropriate circumstances in the future, we may also collect data from candidates for the purpose of creating a personality profile

Further details on the individual species:
Recruitment measures
Obviously, recruitment is the focus area of our work – we lead the right candidates to the right partners and jobs. We have listed below a number of ways in which we may use and process your personal information for this purpose in accordance with any local laws and regulations. Please note that this list is not exhaustive.
Collecting your data from you and other sources, e.g. LinkedIn, Xing
Store (and possibly update) your data in our database so that we can contact you in connection with the recruitment process.

• Providing recruitment services and facilitating the recruitment process
• Comparison of data about you with vacancies that we consider suitable
• Send your information to customers to apply for jobs or evaluate your suitability for jobs allow you to submit your resume, apply online for jobs, or receive notifications of jobs we think may be of interest to you enable you to participate in online expert training courses;
• Allow you, if you wish, to use the interactive features of our services;
• Fulfilling our obligations under contracts concluded between us;
• Fulfill our obligations under contracts entered into in connection with your recruitment between Ovation Group and third parties
• Facilitate our remuneration and invoicing processes
• Conduct customer satisfaction surveys
• Review information you have provided using external resources (e.g. psychometric assessments or skills testing) or requesting information (e.g. references, qualifications or possible criminal history, if appropriate and permitted by local law)
• Compliance with our legal obligations in connection with the detection of crimes or the collection of taxes or levies
• Process your data so that we can send you targeted, relevant promotional materials or other communications that we think may be of interest to you.

We may use your personal data for the purposes described above if we consider it necessary for our legitimate interests. More information about what this means can be found here. If you do not agree, you have the right to object under certain circumstances. You can find further information on this and how and when you can make use of it here.

Please note that in some jurisdictions in which we operate we are subject to additional local laws. Further information relating to your legal system can be found here.

Advertising activities

We may periodically send you information that we think may be of interest to you, or we may ask you to help us recruit other candidates. In particular, we may use your information for the purposes set out below if you so request and in accordance with local laws and regulations. Please note that this list is not exhaustive. For:

• Developing and promoting other products and services;
• Advertise our entire range of recruitment services (open-ended, temporary, work contracts, temporary employment, project contracts, service contracts, contracting, etc.);
• Send you details of reports, promotions, offers, networking and customer events, and general information about industries that we believe may be of interest to you;
• Display excerpts of your data as a success story for advertising purposes on the Ovation Group website(s) (only if we have your express consent to do so); and
• Inform you about certain discounts and offers you are entitled to as a result of your business relationship with Ovation Group.

For some aspects of these activities that are not covered by our legitimate interests (particularly data collection through cookies and direct marketing to you through our digital channels), we require your consent. Depending on the situation, we may ask you to give your consent explicitly by opt-in or tacitly by soft opt-in (see below). Please note that in some jurisdictions in which we operate we are subject to additional local laws. You can find more information about your legal system here.

Soft opt-in consent is a specific type of consent that applies if you have previously dealt with us (e.g. by submitting an application for a job or resume or by reporting a vacancy) and we advertise other recruitment services. For soft opt-in consent, we will consider your consent to be given as long as you do not withdraw it. For most people, this is helpful because it allows us to suggest jobs in addition to the job you have applied for. This greatly increases the likelihood that we will find you a new job. For other types of e-marketing, we are required to obtain your explicit consent.

More information on how we can obtain your consent can be found here. If you do not agree with our marketing approach, you can revoke your consent at any time. Further information can be found here. Nobody is perfect, even if we try hard. You should be aware that it is possible that your information may be collected again through public sources in the course of a separate advertising campaign, even if you have unsubscribed from our advertising communications through our recruitment centre. We try to avoid this, but unfortunately it can still happen. We would like to ask you to unsubscribe in these cases.

All our advertising is based on things that we believe will be particularly helpful to our clients and candidates. However, we are aware that we cannot always do everything right for everyone. We may use your information to display advertisements and other Ovation Group content on other websites such as Facebook. If you do not want us to use your information in this way, please disable the „Advertising Cookies“ option (please consult our cookie policy). Even if you have disabled advertising cookies, you may still see advertisements from Ovation Group. In this case, however, this is not targeted at you personally, but at an anonymous audience.

Equality monitoring and other sensitive personal data

We want to ensure that our recruitment processes are consistent with our approach to equality. Some of the information we may collect about you (under certain circumstances and in accordance with local laws and regulations) is „diversity information“. This may include information about your ethnic background, gender, disability, age, sexual orientation, religion or similar beliefs and/or socio-economic background. Where appropriate and in accordance with local regulations and requirements, we use this information in an anonymous form to monitor compliance with our Equality Policy. We may also provide this information (which may be made anonymous as appropriate) to customers if this is contractually agreed or the customer specifically requests this information in order to comply with their own employment processes.

This information is considered „sensitive“ personal information and is subject to stricter data protection regulations. Therefore, we need your explicit consent to use it. We ask for your consent by offering you an opt-in. This means that you must explicitly and unambiguously tell us that you consent to us collecting and using this information.

We may collect other sensitive personal information about you, such as health information, membership of a religious community, or details of any criminal history, if permitted by local law and required for the job you wish to apply for. We will never do this without your explicit consent.

More information on consent can be found here. Please note that in some jurisdictions in which we operate, different rules apply to this sensitive information. You can find more information about your legal system here.

If you do not agree, you can revoke your consent at any time. You can find more information here.

Assertion, exercise or defence of legal claims

In unusual cases, we may also use your personal information to enforce, exercise or defend legal claims.

Creation of a personality profile

Even though human decisions are currently involved in all our recruitment activities, we will in future use fully automated technologies, such as expert systems or machine learning, for the entire selection process of our candidates, if necessary and in accordance with all local laws and regulations.

If necessary, we will ask you for your consent to some or all of these measures. If you do not consent to profiling, your application will continue to be manually reviewed for positions for which you are applying, but your profile will not automatically be considered for alternative positions. This should reduce the likelihood that we can find a new job for you.

You have the right to revoke your consent at any time. You can find more information here.

CUSTOMER DATA: We use the information about our customers for the following purposes:

• Recruitment measures;
• Advertising;
• Assertion, exercise or defence of legal claims.

Further details on each species:

Recruitment measures

Obviously, recruitment is the focal point of our work. This is done via: (i) placement of candidates, (ii) RPO services; and (iii) MSP programs. Below are the different ways we can use your information to do this:

• Storing (and updating) your information in our database so that we can contact you in connection with recruitment activities
• Record conversations and meetings so that we can deliver targeted services to you
• Conduct customer satisfaction surveys
• Process your data in order to address appropriate advertising campaigns to you.

We may use your personal data for these purposes if this corresponds to our legitimate interests. Further information on what this means can be found here.

If you do not agree, you have the right to object under certain circumstances. You can find further information on this and how and when you can make use of it here.

Advertising activities

To the extent consistent with applicable local laws and regulations, we will not necessarily ask for your consent when we send promotional materials such as our Global Skills Index to a business mailing address or email address.

If you do not agree, you have the right to opt out of receiving promotional materials from us. You can find more information here.

Please note that in some jurisdictions in which we operate, we are subject to additional local advertising laws. Further information relating to your jurisdiction can be found here.

Enforcement, exercise or defence of legal rights

In unusual cases, we may also use your personal information to enforce, exercise or defend legal claims.

SUPPLIER DATA: We know that you are probably busy and do not want to bother you constantly. To strike a balance, we use your information only for the following purposes:

• Store (and possibly update) your data in our database so that we can contact you in connection with our agreements.
• Offer you services or receive support and services from you
• Fulfilling certain legal obligations;
• Develop appropriate targeted advertising campaigns; and
  in unusual cases, assertion, exercise or defence of legal claims.

We may use your personal data for these purposes if this is in accordance with our legitimate interests. Further information on what this means can be found here.

We will not necessarily ask you for your consent to send you promotional communications to a business mailing address or e-mail address.

If you do not agree, you have the right to object under certain circumstances. You can find further information on how to make use of this right here.

Please note that in some jurisdictions in which we operate, we are subject to additional local laws regarding the retention period of your data. Further information relating to your legal system can be found here.

WE MAY COLLECT PERSONAL INFORMATION FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE AND EMERGENCY CONTACTS:

We will only use the information our candidates provide about you for the following purposes:

• If candidates or employees have identified you as an emergency contact in our form, we will contact you if they become involved in an accident or emergency; or
• If the candidate or a future employee has indicated you as a contact person for a reference, we will contact you to obtain a reference. This is an important part of our quality assurance process for candidates. It can determine whether the person gets the job.
• If the candidate or a prospective employee has identified you as a contact for a reference, we may occasionally use your information to contact you in connection with recruitment activities that we believe may be of interest to you. In this case, we will use your information for the same purposes as we use customer information. More information about what this means can be found here.

We may use your personal information for these purposes if it is in our legitimate interests. More information about what this means can be found here.

If you do not agree, you have the right to object. Further information on how you can make use of it can be found here.

VISITORS ON OUR WEBSITE: We use your information to help you administer our site, for example, by analyzing your most recent job search criteria to better display jobs or candidates that we think may be of interest to you.

For more information about cookies, such as how we use them and what choices you have, click here.

TO WHOM IS YOUR PERSONAL DATA PASSED ON?

We may disclose your personal information to the following categories of people in a variety of ways and for a variety of purposes, as appropriate and in accordance with local laws and regulations:

• All Group Companies
• Individuals and organizations who have information associated with the reference or application to work with us, such as current, former or prospective employees, trainers and audit committees, employment and recruitment agencies.
• Tax, audit or other authorities if we believe in good faith that we are required by law or other regulation to disclose such information (for example, because of a request from a tax authority or in connection with a probable lawsuit)
• External service providers providing services on our behalf (including external consultants, business partners and professional consultants such as lawyers, auditors and accountants, technical support functions and IT consultants performing development and testing of our company’s technological systems)
• Providers of externally outsourced IT services and storage providers if a corresponding processing agreement (or comparable security) is in place
• Marketing technology platforms and suppliers
• In the case of candidates: potential employers and other recruitment agencies/organisations to improve your chances of finding employment.
• In case of candidates: external partners, job portals and job search engines, if we believe that this increases the chance to find the right job for you
• In the case of candidates: MSP providers within the MSP programs of our clients
• In the case of candidates and contact persons for references of our candidates and future employees: third parties whom we have engaged to provide services such as verification of references, qualifications and criminal records, where such verification is appropriate and permitted by local law.

Should Ovation Group merge with or be acquired by another company in the future (or there are meaningful discussions about such a possibility), we may share your personal information with the (future) new owners of the company or society.

HOW IS YOUR PERSONAL INFORMATION PROTECTED?

We will take all reasonable and appropriate measures to protect the personal information we hold from misuse, loss or unauthorized access. To this end, we have taken a number of technical and organisational measures. This includes measures to deal with any suspected data breaches.

If you suspect that your personal information has been misused, lost or accessed by unauthorized persons, please let us know as soon as possible. Details of how to contact us can be found here.

HOW LONG IS YOUR PERSONAL DATA STORED?

We will delete your personal information from our systems if we have had no relevant contact with you (or, as the case may be, with the company you work for or with) for two years (or longer if we believe in good faith that we are required by law or other regulation to retain your information). After that time, your information may no longer be relevant to the purpose for which it was collected.

For those candidates whose services are provided through a third party company or other entity, „relevant contact“ with you means relevant contact with the company or entity providing your services. If we are notified by that company or entity that there is no longer a business relationship with you, we will retain your information for a maximum of two years from that date or, if that date occurs later, two years from the date we had no relevant direct contact with you.

When we speak of „relevant contact“, we mean, for example, a communication (oral or written) between us or that you actively contact us through our online services. If you are a candidate, we will assume that there is a relevant contact when you upload your updated resume to our website or participate in one of our online training sessions. It is also considered a relevant contact if you communicate with us about possible jobs. This may take the form of verbal or written communication or clicks within one of our promotional communications. If you receive, open or read an e-mail or other digital message from us, it will not be considered a relevant contact. This is only the case if you click on something in it or reply directly.

HOW CAN YOU ACCESS, CHANGE OR WITHDRAW PERSONAL DATA THAT YOU HAVE PROVIDED TO US?

One of the main objectives of the GDPR (General Data Protection Regulation) is to protect and clarify the data protection rights of EU citizens and individuals within the EU. This means that you continue to have various rights with respect to your data, even if you have already provided it to us. These rights are described in more detail below.

If you wish to contact us in connection with these rights, please include us here. We will endeavour to respond to your request as quickly as possible, and in any case within one month (extensions may be applied which we are legally entitled to). Please note that we may keep records of our communications to better resolve any issues you may have raised.

Right of objection: On the basis of this right, you can object to the processing of your personal data by us if we do so for one of the following four reasons: (i) our legitimate interests; (ii) to perform a public service mission or exercise public authority; (iii) to send you direct mail; and (iv) for scientific, historical, statistical or research purposes.

The above „legitimate interests“ and „direct mail“ categories are the categories most likely to affect visitors to our website, candidates, customers and suppliers. If you object to our processing your personal data because we deem it necessary for your legitimate interests, we must cease such activities as a result of your objection, unless:

• we can demonstrate that we have priority legitimate reasons for processing that override your interests, or
• we process your data in order to assert, exercise or defend a legal claim.

If you object in connection with direct marketing, we must cease such activity. If you have given us your consent to process your personal data for certain activities (e.g. for our advertising arrangements or for automatic profiling), you can revoke this consent at any time. We will discontinue the activity you previously agreed to, unless we believe there is an alternative reason for us to further process your data for this purpose. If this is the case, we will inform you.

Request from Data Subjects for Information about Personal Data (DSAR): You may request confirmation from us at any time as to what information we hold about you and ask us to change, update or delete that information. We may ask you to confirm your identity or request further information about your request. If we grant you access to the information we hold about you, we will not charge a fee for doing so unless your request is „manifestly unfounded or excessive“. If you request further copies of this information from us, we may charge you reasonable administrative costs where permitted by law. We may decline your request if permitted by law. If we decline your request, we will always explain why.

Please note that in some jurisdictions in which we operate, we may be subject to additional local laws regarding access requests from data subjects and may refuse your request under those laws. Further information relating to your legal system can be found here.

Right to deletion: Under certain circumstances, you may request that we delete your personal information. In general, the information must meet one of the following criteria:

• The data is no longer required for the purpose for which we originally collected and/or processed it;
• You have withdrawn your previously given consent for us to process your data and there is no other valid reason to continue processing;
• The data has been processed unlawfully (i.e. in a way that is contrary to the GDPR);
• The data must be deleted so that we can fulfil our obligations as data controller; or
• You object to the processing and we cannot prove any overriding legitimate reasons for further processing by us if we process the data because we consider it necessary for our legitimate interests.

Please note that in some jurisdictions in which we operate, we may be subject to additional local laws regarding requests for deletion by data subjects and may refuse your request under those laws. Further information relating to your legal system can be found here.

We may refuse your request only for one of the following reasons:

• to exercise the right to freedom of expression and information;
• to comply with legal obligations, perform a task in the public interest or exercise public authority;
• if this is in the public interest for reasons of public health;
• for archival, research or statistical purposes; or
• to exercise or defend a legal right.
• If we comply with a valid request to delete data, we will take all reasonable or practicable steps to delete the data in question.

Right to Restrict Processing: In certain circumstances, you may request that we restrict the processing of your personal data. This means that we will only store your data in the future and will not be able to carry out any further processing activities until: (i) any of the conditions set out below have been removed, (ii) you give your consent or (iii) further processing is necessary to enforce, exercise or defend legal rights, protect the rights of others or if it is necessary in the legitimate public interest of the EU or any Member State.

In the following circumstances, you may request that we restrict the processing of your personal data:

• If you dispute the accuracy of the personal data we process about you. In this case, we will limit the processing of your personal data until the accuracy of the data has been verified.
• If you object to the processing of your personal data by us in the sense of our legitimate interests. In this case, you may request that the data be restricted while we review our reasons for processing your personal data.
• If the processing of your data by us is unlawful, but you prefer to limit the processing by us instead of having the data deleted.
• When there is no longer a need for us to process your personal data, but you need the data to enforce, exercise or defend your legal rights.
• If we have disclosed your personal data to third parties, we will inform them of the limited processing where this is possible and does not require disproportionate effort. We will of course inform you before we remove any restrictions on the processing of your personal data.
• Right to Correction: You may also request that we correct any inaccurate or incomplete personal data we hold about you. If we have passed on this personal data to third parties, we will inform them of the correction if this is possible and does not require any disproportionate effort. If necessary, we will inform you to which third parties we have passed on the incorrect or incomplete personal data. If we consider it inappropriate to comply with your request, we will explain the reasons for this decision.

Right to data transfer: If you wish, you are entitled to transfer your data from one person responsible to another. This means that you can transfer your account information to another online platform. For this purpose, we provide you with password-protected data in a standard machine-readable format so that you can transfer the data to another online platform. Alternatively, we can transfer the data directly for you. The right to data transfer applies to: (i) personal data which we process automatically (i.e. without human intervention), (ii) personal data which you have provided to us and (iii) personal data which we process on the basis of your consent or for the purpose of fulfilling a contract.

Right to complain to a regulatory body: You have the right to file a complaint with the appropriate local regulatory body. Details of how to contact them can be found here.

If you wish to exercise any of these rights or revoke your consent to the processing of your personal data (if your consent is the legal basis for the processing of your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues you may have raised.

You can unsubscribe from job notifications at any time. Details can be found here.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during the period in which we store it.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE OVATION GROUP WEBSITE?

If you would like to know which Ovation Group company is responsible for processing your personal data and where it is located, please follow this link.

If you have any comments or suggestions about this privacy policy, please follow this link. We take your privacy very seriously. We will therefore contact you as soon as possible.

HOW YOUR DATA IS STORED AND TRANSMITTED INTERNATIONALLY?

Would you like to learn more about how we store and transfer your data internationally? In order to provide you with the best possible service and to fulfil the purposes described in this data protection guideline, your data may be transmitted:

• between and within Ovation Group companies,
• to third parties (e.g. consultants or other suppliers of Ovation Group),
• to suppliers abroad,
• to suppliers in your country, who in turn can transmit your data internationally,
• to a cloud-based storage provider, and
• to other third parties described here.

We want to ensure that your information is stored and transmitted in a secure manner. Therefore, we will only transfer data outside the European Economic Area or EEA (i.e. the member states of the European Union as well as Norway, Iceland and Liechtenstein) if this complies with data protection law and the transfer method provides adequate protection for your data, for example:

by means of a data transfer agreement that includes the current standard contractual clauses that the European Commission provides for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws, or

• by signing the EU-U.S. Privacy Shield Framework for the transfer of personal data from EU companies to US companies or an equivalent agreement between other jurisdictions; or
• the transfer of your data to a country where there is a statutory level of data protection deemed appropriate by the European Commission, or
• if it is necessary for the conclusion or execution of a contract between us and a third party and the transfer for the purpose of this contract is in your interest (e.g. if we have to transfer data outside the EEA in order to fulfil our obligations under this contract, if you are a customer of us), or
• if you have given your consent for the data transfer.

To ensure that your personal data is adequately protected, we have implemented appropriate measures with third parties with whom we share your personal data to ensure that your personal data from these third parties is provided in a manner consistent with data protection rights and in compliance with data protection laws.

COOKIE POLICY

What’s a cookie?

A „cookie“ is information that is stored on your computer’s hard drive and records your navigation on a Web site. This allows you to be offered tailor-made options based on the information stored about your last visit. Cookies may also be used for traffic analysis, advertising and marketing purposes.

Cookies are used by almost all websites and do not harm your system. If you want to check or change what types of cookies are accepted, you can usually do this in your browser settings. We also provide you with information about this on the Advertising Settings page of the Ovation Group website.

How do we use cookies?

We use cookies to do two things:

To record your use of our website. This allows us to track how you use the site and record patterns that develop individually or with larger groups. This helps us to develop and improve our website and services based on visitors‘ wishes and needs; and

in order to be able to display jobs that we think might be of interest to you. We hope that you will spend less time searching through many pages and find the job you are looking for faster.

There are several types of cookies:

There are several types of cookies:

Session cookies: These are only stored on your computer during your Internet session and are automatically deleted when you close your browser. They typically store an anonymous session ID that allows you to use a website without having to log in to each page. However, you do not collect information from your computer.

Resident Cookies: A resident cookie is stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you return to that website. We use resident cookies for Google Analytics and personalization (see below).

Cookies can also be categorized as follows:

Required cookies: These cookies are necessary for you to use the site effectively, such as when you apply for a job. Therefore, they cannot be disabled. Without these cookies, we cannot provide the services we offer through our website. These cookies do not collect any information about you that could be used for advertising purposes or to identify which websites you have visited.

Performance cookies: These cookies help us monitor and improve the performance of our website. For example, we can use them to count visits, identify traffic sources, and identify which parts of the site are most in demand.

Functionality Cookies: These cookies allow our Web site to remember which options you have selected (such as your user name, language, or region of residence) and provide enhanced functionality. For example, we may provide you with news or updates about the services you use. These cookies can be used to store changes you have made to the text size, font, or other parts of the site that you can customize. They may also be used to provide services you have requested, such as playing a video or commenting on a blog. The information collected by these cookies is usually anonymized.

Personalization Cookies: These cookies allow us to advertise details of employment opportunities that we believe may be of interest to you. These are resident cookies that are stored permanently (as long as you are registered with us). Therefore, when you sign in or return to the Site, you will see ads for similar jobs to those you previously viewed.

The following table in Appendix 4 lists the cookies we use, the reason we use them, and their type.

OUR LEGAL BASIS FOR PROCESSING YOUR DATA

LEGITIMATE INTEREST

This is regulated in Article 6 (1) f) of the DSGVO: It states that we may process your data if this is „necessary to safeguard the legitimate interests [of us] or of a third party, unless the interests or fundamental rights and freedoms [of you] which require the protection of personal data prevail“.

We do not believe that the following activities affect any person in any way. Rather, they help us to provide more tailored and efficient services to you and are therefore beneficial to all concerned. However, you have the right to object to the processing of your personal data by us on this basis. Information on how you can do this can be found here.

Please note that in some jurisdictions in which we operate there may be a different legal basis for the processing of data in certain cases. You can find more information about your legal system here.

CANDIDATE DATA: We think we can assume that if you are looking for a job or have submitted the information from your resume to a job portal or professional networking site, you agree that we may collect or use your personal information to provide recruitment services to you or to provide them to you, that we may share that information with potential employers, and that we may match your skills with the job postings available to us. If you are being considered for a job, the potential employer may wish to review the information you have provided to us (e.g. the results of psychometric assessments or skills testing) or review your references, qualifications and police clearance where appropriate and permitted by local law. We must do this so that we can be commercially successful and help you and other candidates get the jobs you deserve.

We want to provide you with tailor-made job recommendations and relevant articles to help you find the job you are looking for. Therefore, we consider it appropriate that we process your data to ensure that we send you appropriate content.

We also think it may help you find a job if you attend one of our online expert training sessions or use some of our more interactive services when you have the time. These are part of our business and help us differentiate ourselves from our competitors in a competitive marketplace. Therefore, it is in our legitimate interest to use your information.

We must ensure that our business functions smoothly so that we can continue to provide services to candidates like you. Therefore, we may also need to use your information for internal administrative purposes such as compensation and, where appropriate, billing.

We have our own legal obligations and it is in our legitimate interest to insist on their fulfillment. Therefore, if we believe in good faith that this is necessary, we may disclose your information for the purposes of law enforcement or tax collection or to resolve actual or threatened disputes.

CUSTOMER DATA: In order to ensure that we provide you with the best possible service, we store your personal data and/or the personal data of individual contact persons within your organisation and keep records of conversations, meetings, notified bodies and job placement. Occasionally, we may also ask you to participate in a customer satisfaction survey. We consider this appropriate and believe that this use of your information is necessary for our legitimate interests as a company that provides various recruitment services to you.

SUPPLIER DATA: We use and store the personal information of individuals within your organization to obtain services from you as one of our suppliers. We also store your financial information so that we can pay for your services. We assume that all these activities fall within our legitimate interests as recipients of your services.

WE MAY COLLECT PERSONAL INFORMATION FROM CANDIDATES AND EMPLOYEES, SUCH AS CONTACT PERSONS FOR REFERENCES AND EMERGENCY CONTACTS:

If you have been identified by a candidate or prospective employee as one of their contacts for a reference, we will use your personal information to contact you about a reference. This is part of our quality assurance process, and we therefore consider it necessary for our legitimate interests as a recruitment service provider and employer.

If a candidate or employee has designated you as an emergency contact, we will use this information to contact you in the event of an accident or emergency. Surely you will agree that this is an important element for our organisation, which is primarily about people and therefore necessary for our legitimate interests.

CONSENT

Under certain circumstances, we may need your consent to process your personal data in connection with certain activities. Depending on exactly what your data is needed for, we may obtain your consent explicitly by opt-in or implicitly by soft opt-in.

According to Article 4(11) of the DSGVO, opt-in consent is „any voluntary, specific, informed and unambiguous expression of will in the form of a statement or other unambiguous affirmative act by which the data subject indicates his or her consent to the processing of his or her personal data“. Put simply, this means that:

• You must voluntarily give us your consent without us exerting any form of pressure on you;
• You need to know what you are consenting to – so we will make sure that we have provided you with sufficient information;
• You should have control over the processing activities to which you consent or disagree. We make these detailed controls available to you at our Privacy Settings Center; and
• You must give us your consent in the form of a positive, confirmatory act.

We will probably provide you with a field that you must mark to ensure that this requirement is clearly and unambiguously met.

We will keep a record of the consents you have given in this way.

As mentioned earlier, in some cases soft opt-in consent is sufficient. We may advertise products and services to you that are related to our recruitment services unless you have actively unsubscribed from those communications.

Please note that in some jurisdictions in which we operate, we may be subject to other local laws regarding consent to receive promotional materials. You can find more information about your legal system here.

As mentioned above, you have the right to revoke your consent for these activities. You can do so at any time. Details of the procedure can be found here.

ASSERTION, EXERCISE OR DEFENSE OF LEGAL CLAIMS

Sometimes it may be necessary for us to process personal information and, where appropriate and in accordance with local laws and regulations, sensitive personal information in connection with the exercise or defense of legal rights. Article 9(2)(f) of the DSGVO allows this if the processing „is necessary for the assertion, exercise and defence of legal claims or if the courts act in the course of their judicial activity“.

This may occur, for example, when we need legal advice in relation to legal proceedings or are required by law to retain or disclose certain information in the course of legal proceedings.

APPENDIXS

APPENDIX 1

Our contact details

Country in which you use Ovation Group services or provide services for Ovation Group: Germany

Ovation Group company responsible for processing the personal data of visitors to our website: Ovation Personal GmbH

The processing of the personal data of candidates, clients, suppliers and the emergency contacts and contacts for references of candidates and employees of Ovation Group depends on which of the following companies is the counterparty to the relevant arrangement.

• Ovation AG
• Ovation IKT GmbH
• Ovation Netcom Ltd.
• Ovation Personnel GmbH

This is how you can contact us:to access, modify or withdraw personal data you have provided us with if you suspect that your personal information has been misused, lost or accessed by unauthorised persons, to revoke your consent to the processing of your personal data (if the consent constitutes the legal basis for the processing of your personal data), to comment on or make suggestions about this Privacy Policy.

Postal address:
Ovation Group, Data Protection Officer, Am Seegraben 2, 99099 Erfurt, Germany
Alternatively, you can contact our data protection officer and the data protection team by e-mail at: datenschutz@ovation.de.

This is how you can contact us if you wish to update your advertising settings:

Or send us an email at: info@ovation.de or click the unsubscribe link in any promotional email you receive from us.

APPENDIX 2

Contact details of the competent local supervisory authority

Country in which you use Ovation Group services or provide services for Ovation Group: Germany

Contact details of the competent local supervisory authority:

For our companies based in Thuringia/Erfurt, Thüringer State Representative for Data Protection and Freedom of Information.

Post: P.O. Box 900455, 99107 Erfurt, Germany

Email: poststelle@datenschutz.thueringen.de

Phone: +49 (0) 361 / 57 311 29 00

Fax: +49 (0) 361 / 57 311 29 04

For our companies based in Baden-Württemberg/Mannheim, The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg.

Post: Postfach 10 29 32, 70025 Stuttgart, Germany

Email: poststelle@lfdi.bwl.de

Phone: (+49) 0711/61 55 41 – 10

Fax: +49 (0) 711/61 55 41 – 15

APPENDIX 3

Country-specific deviations from our data protection guidelines

Legal system: Germany

Country-specific legal regulation:

In Germany, we collect data on candidates‘ membership of a religious community in order to facilitate our remuneration processes. Because this is required by law, we do not ask for your express consent to the processing of this information.

DSAR applications

According to local laws, we are entitled to refuse your DSAR application if your data is only stored for the following reasons: (i) because we are required by law to store it or (ii) for the purposes of monitoring data protection or protecting data, when it would require a disproportionate effort to provide the information and when appropriate technical and organisational measures make processing for other purposes impossible.

Requests to delete your data

If your data is not processed automatically, we are not obliged to delete your data, unless your data is processed unlawfully, if the deletion would be impossible due to the storage method used or would require a disproportionately high effort, if we are of the opinion that your interest in the deletion is only minimal.
If your data is processed automatically, we may also refuse to delete your data if we have reason to believe that the deletion would be contrary to your legitimate interests or if the deletion would violate any legal obligation to store your data for a specified period of time. Instead, the processing of your data under these circumstances will be restricted in the manner provided for in the GDPR.

Candidates, customers and suppliers

As described in the main text of our Privacy Policy, we may require „soft opt-in“ consent with respect to certain promotional communications we wish to send you. The following conditions must be met for us to use soft opt-in consent: (i) We have received your email address in connection with the sale of goods or services, (ii) we only use this address to directly promote our own (or substantially similar) services, (iii) you have not objected to such use, and (iv) we clearly indicate your right to opt-out in each message.

For all other forms of electronic advertising, we must obtain your express opt-in consent and retain evidence that we have obtained such consent. To comply with our obligations under the Unfair Competition Act, we use a consent procedure commonly known as „double opt-in“. We first ask you for your consent to receive electronic advertising and then send you an e-mail asking you to confirm that you have given your consent. We may only add you to our marketing list if we have received this second confirmation by email.

Certain aspects of German law suggest that recruitment candidates and employees cannot be clearly distinguished. Even if we do not assume that this unclear delineation was intended in connection with the candidates of a personnel service provider, in case of doubt we follow the provisions of the DSGVO (as well as German law, i.e. the new Federal Data Protection Act), which apply to employment relationships, in order to ensure that we continue to process your data correctly and lawfully in the future.

The provisions applicable to employment allow the processing of employees‘ personal data for purposes related to the employment relationship if this is necessary for hiring decisions or, after hiring, to process or terminate the employment contract or to comply with and satisfy the rights and obligations of employee representatives as provided for by law or by collective agreements or other agreements between the employer and a works council. Further information can be found in Section 26 of the new Federal Data Protection Act.

Appendix 4 – Cookie List

Cookie names:

DoubleClick

AD Exchange Buyer

Google Analytics