Here at Talent Diverse, the privacy of users is important to us. We take personal data protection very seriously and make sure to comply with Regulation (EU) 2016/679 on the protection of personal data (the “GDPR”) as well as any other applicable national law or regulation regarding the processing of personal data. Therefore, in this privacy notice, we would like to inform you about the nature, scope and purpose of the collection and processing of your personal data when you use our website and services, or otherwise interact with us.
Who we are - Controller
The responsible body for operating this website and processing your personal data is:
mcp MyCareerPath UG (haftungsbeschränkt)
Who this privacy notice relates to - Data Subjects
This privacy notice relates in great part, to the users of this website, in particular the candidates who submit their personal profile and curriculum vitae, or otherwise use our platform, for the purpose of being connected or introduced to employers. The privacy notice also applies where the representatives of potential employers have provided their personal data to us.
Furthermore, this privacy notice applies in other situations where individual natural persons provide us with their personal data e.g. persons who register for our events or newsletters, or persons whom we engage with in the framework of our purpose and activities, so long as we solely and autonomously determine the purposes and means of the processing of the personal data.
What are personal data?
Personal data are any information relating to an identified or identifiable natural person. Personal data include name, email address or telephone number. Personal data also includes information about websites viewed. Our policy is to only collect and process personal data if the processing is permitted by law or if you consent to it.
How are your data collected and used?
In the course of our interaction with you, we obtain various personal data.
We may collect your personal data:
- when you register on our website by creating an account;
- when you access our website whether as a registered or unregistered user;
- when you seek/obtain advisory, training and other services from us;
- when you represent your organization in the recruitment of candidates;
- when you or your organization provides services as our vendor;
- when you contact us via telephone, email or our social media platforms;
- when you subscribe to our newsletter or any of our other services; and
- when you work with us or apply to work with us, as our own employee.
The personal data that we collect, and process may include:
- basic information such as name, title, date of birth, age, designation, educational and professional qualifications, physical address, email address, phone numbers, and other contact information;
- information that you provide when filling in forms on our website, creating an account on our platform, posting material on our website, subscribing to our service, reporting a problem on our website or requesting further services;
- information contained in your curriculum vitae when you choose to upload one, including any sensitive personal data such as details of criminal convictions or ethnic origin;
- background information such as those provided by you or collected by us as part of our recruitment processes;
- information that you provide when completing surveys requested by us for research purposes;
- information that is contained in correspondence between you and us;
- IP address, log files, session records, type/version of the browser, referrer URL, hostname of the computer/device and other technical information obtained when you visit our website;
- any other information which is provided to us, or which we generate in the course of providing our services.
The personal data can be either provided directly by yourself or potentially gathered from other sources.
On which legal basis and for what purposes do we process your data?
We obtain and process your personal data for the following purposes:
- providing contracted services to you or your organization;
- managing our business relationship with you or your organization, whether in connection with the delivery of services, or as your employer or former employer, including processing payments, accounting, billing and collection and related services;
- acting in compliance with our legal obligations;
- supervision of access to our offices, systems and online platforms;
- complying with court orders and other legal requirements;
- statistical analysis for the purpose of operation, security and optimization of our website, social media and other digital platforms; and
- communicating with you with respect to legal developments, announcements, events and our services which may be of interest to you.
We always process your personal data within the boundaries of the legal bases laid down under applicable law. We also ensure to limit the processing of your personal data to what is strictly necessary for the achievement and performance of these purposes.
Performance of legal, statutory or contractual duties - We may process your personal data where this is necessary for the performance of our legal/statutory duties or the performance of our contractual obligation towards you. In such a case, we limit the processing of your personal data to the extent of what is strictly necessary.
Consent - When we process your personal data for specific purposes beyond the usual contractual obligation or relationship, we strive to rely on your consent to put you in control of your personal data. Your prior informed, explicit consent will be requested for registering to our marketing communications. Your consent will also be sought in case you are photographed or filmed at meetings or events that we organise. You always have the right to withdraw your consent at any time by sending an email to us via email@example.com.
Legitimate interests - We may also process personal data for other purposes falling under the achievement and realisation of our legitimate interests. In such cases, we strive to maintain a fair balance between the need to process your data and the preservation of your rights and freedoms, including the protection of your privacy.
If you are a candidate using our platform for the purpose of being connected or introduced to employers, we may - in the course of interaction with you - collect the following information about you: first name, last name, maiden name, other names, title, date of birth, place of birth, nationality, age, designation, educational and professional qualifications, physical address, email address, phone numbers, and other contact information. Depending on your location or residence, we may also collect and process information such as your passport/ID details and travel itinerary. This is done for the purpose of providing you a service (Art. 6 (1) b. GDPR).
If you are the representative of an employer, using our platform for the purpose of being connected or introduced to candidates, we may - in the course of interaction with you - collect the following information about you: first name, last name, title, designation, physical address, email address, phone numbers, and other contact information. This is done for the purpose of providing you a service (Art. 6 (1) b. GDPR).
If we obtain information about you from sources such as corporate websites, job board websites, social media (e.g. LinkedIn or Xing), online CV libraries, your business card, personal recommendations, and others, for the purpose of inviting you to our platform or discussing a job vacancy, this is done in line with our legitimate interests (Art. 6 (1) f. GDPR).
If you sign up for one of our email communications, we will collect and process your personal data to follow up on your request and handle any feedback or query from you. This is done on the basis of your consent (Art. 6 (1) a. GDPR) or for the purpose of processing your enquiry (Art. 6 (1) b. GDPR). You can unsubscribe at any time by using the ‘unsubscribe button’ in the email or by sending an email to the originator.
If you represent/work for a company having a business or contractual relationship with us (e.g. service supplier), we will collect your name and professional contact details for the purposes of the business relation or contract, general administrative management, compliance with laws and regulations, and the protection of our rights. This is done for the purpose of providing you a service (Art. 6 (1) b. GDPR), and/or for the purpose of fulfilling our legal obligation (Art. 6 (1) c. GDPR).
With whom and how do we share your data?
After candidates provide their information to us, potential employers are then able to view the profile of these candidates on our website, but the candidate profiles are pseudonymised, meaning that employers would ordinarily not know the actual identity of a candidate until the employer requests to interview the candidate and the candidate indicates to us that they wish to move forward with the said employer.
We often rely on contractually bound third-party companies and external service providers to provide our services. These service providers may need to process personal data to perform their contractual obligations. When this is the case, processors are permitted to use the data only for the purposes and duration specified by us. Furthermore, they are contractually obligated to handle your data exclusively in line with the applicable data protection laws.
We use a Digital Ocean LLC of 101 6th Avenue, New York, USA (server in Frankfurt, Germany, EU) to provide hosting and administration for services some of the services on the webapp. Some of the information that you provide to us is processed by Digital Ocean and stored, in large part, in its servers and on other media. While Digital Ocean does not solicit this information from you, it does passively collect your information due to its hosting activities and may, in certain circumstances, make use of it. More information on how Digital Ocean collects, processes and stores data can be found at https://www.digitalocean.com/legal/privacy-policy/.
The disclosure of personal data to service providers is based on Art. 28 (1) GDPR or, alternatively, on the basis of our legitimate interests in the economic and technical advantages associated with the use of specialised processors and on the basis of circumstances in which your rights and interests in the protection of your personal data are not overridden (see Art. 6 (1) f. GDPR).
Where required to investigate the unlawful use of our services or for the purposes of prosecution, personal data will be disclosed to the relevant law enforcement authorities and, where applicable, to any third-party claimants. However, such a course of action will only take place if there is concrete evidence of unlawful conduct or misuse. In such cases, your data may also be shared if doing so is required for the fulfilment of terms and conditions of use or other agreements. If requested, we are also legally obligated to disclose such data to certain public authorities, such as law enforcement bodies, authorities that penalise offences with financial penalties, and financial authorities. In these cases, data is disclosed on the basis of our legitimate interest in combating misuse, aiding the prosecution of criminal offences, and aiding the establishment, assertion and enforcement of claims, in line with Article 6 (1) c. & f. GDPR.
Beyond the circumstances mentioned above, candidates’ personal data are not shared with third parties without the candidates’ express prior consent in accordance with Art. 6 (1) a. GDPR
How are your data stored and retained?
Personal data may be stored on our own technology systems or those of our vendors or in paper files. As a rule, we only store your personal data for as long as it is necessary for the execution of the contract or the respective purpose and limit the storage period to an absolutely necessary minimum. Therefore, we delete your personal data, if your use of our services ends, and you have not agreed to a further use. An extended storage will only occur, if there is a legal obligation.
Automated Decision Making (“Profiling”)
Profiling means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person. Examples of such profiling include the analysis of data (e.g. based on statistical methods) with the aim of displaying personalized advertising to the user or giving shopping tips.
We do not process any data via “profiling” or in the form of automated decision making.
What are your rights?
As a data subject you have the right:
- to withdraw your consent to us at any time. As a result, we are no longer allowed to continue the processing of data based on this consent in the future;
- to object to the processing of your personal data, if your personal data are processed on the basis of legitimate interests insofar as there are reasons for this arising from your particular situation;
- to obtain from us access to your personal data. In particular, you may request access to the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored;
- to demand a correction of any incorrect personal data;
- to obtain from us without undue delay the rectification of inaccurate personal data concerning you;
- to obtain the erasure of your personal data stored with us, unless the processing is necessary to exercise the right to free expression of opinion and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
- to demand the restriction of the processing of your personal data, if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have filed an objection against the processing; and
- to receive your personal data, which you have provided to us, in a structured, current and machine-readable format or to request the transmission to another controller.
In the case of a request for information, you must provide sufficient information about your identity and provide proof that it is your personal data. The information relates to data that has been stored regarding your person, the origin of the data, the recipient or the categories of recipients to which data has been transmitted and the purpose of the storage. To exercise these rights, please send an email to us at firstname.lastname@example.org
If you have given your consent to the processing of your data, you can revoke it at any time by sending us an email at email@example.com. Such revocation will affect the admissibility of processing your personal data by us. Insofar as we base the processing of your personal data on the weighting of interests, you may object to the processing. This is the case if processing your data is not required to fulfil a contract with you.
In the case of your justified objection, we will examine the situation and will either stop processing your data, adapt the data processing or point out to you our compelling legitimate reasons on which we continue the processing.
What safety measures are in place for protection of your data?
We have installed technical and organizational measures in order to safeguard our website and/or products against loss, destruction, access, changes or the distribution of your data by unauthorized persons. However, we cannot guarantee a complete protection for data transmitted to us against all dangers at all times, because transmission of information via the internet is not completely secure.
Enforcement of Privacy Notice
We make every effort to ensure that your personal information is used in accordance with this privacy notice. If you have any concerns regarding our adherence to this privacy notice or the manner in which your personal information is used, kindly send us an email via firstname.lastname@example.org
Changes to this Privacy Notice
This privacy notice is accessible via our website, and may be downloaded and printed anytime. We reserve the right to amend and modify this notice from time to time, taking into account currently applicable data protection provisions. So, please review it frequently.
For any inquiries and additional questions about the processing of your personal data, please contact us at email@example.com