Data Privacy Notice for imc's Career Page
Privacy Notice
This Privacy Notice informs you about the collection and processing of personal data during your application process, including the purposes for which your data will be used. Your data will be processed in compliance with this Privacy Notice and the relevant data protection regulations. This Privacy Notice applies to the career portal and applicant management system of imc information multimedia communication AG.
- Controller within the Meaning of Art. 4 Nr. 7 DSGVO
The controller within the meaning of the GDPR and other data protection laws is:
imc information multimedia communication AG
Scheer Tower
Uni-Campus Nord
D-66123 Saarbrücken
Authorised Representatives: Christian Wachter (CEO), Sven R. Becker, Dr. Wolfram Jost.
E-Mail: [email protected]
Telephone number: +49 681 9476 0
- Data Protection Officer
Roman Muth
- Data Processing
To facilitate the efficient management of application processes, we utilize the applicant management system provided by Softgarden e-Recruiting GmbH, located at Tauentzienstr. 14, 10789 Berlin (Contact: [email protected]). Softgarden e-Recruiting GmbH serves as a data processor in accordance with Art. 4(8) of the GDPR. We have established a data processing agreement with the provider pursuant to Art. 28 of the GDPR, ensuring adherence to data protection regulations.
For exercising your data subject rights and addressing any inquiries related to the application process, we remain your primary point of contact. You may reach out to us directly or, if applicable, contact the Data Protection Officer confidentially.
- Scope of Processing Activities
- Processing of Personal Data in Applicant Management
Personal data is processed as part of the applicant management process. According to Art. 4(1) of the GDPR, this data includes all information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”) that is necessary for conducting the application process and for establishing an employment relationship, in accordance with Art. 6(1)(b) of the GDPR.
- Collection of Usage Data
In addition to applicant data, usage data is also collected during the use of the applicant management system. This data is necessary for operating our websites and includes information about the start, end, and extent of the use of our website, as well as login details. Such processing is conducted in compliance with data protection and telemedia regulations.
- Additional Processing Activities
In the context of the application process and/or the use of the system, additional processing activities may occur based on the following legal grounds:
- Legitimate Interest: pursuant to Art. 6(1)(f) of the GDPR.
- Consent: pursuant to Art. 6(1)(a) of the GDPR.
- Legal Obligation or Public Interest: pursuant to Art. 6(1)(c) and (e) of the GDPR, such as for law enforcement or investigative purposes.
You can determine and control the extent of processing through individual settings in your web browser, the configuration of cookie settings, and your user behavior.
- Collection and Use of Your Data
- Visiting the Website
For operational and maintenance purposes, and in compliance with telemedia regulations, interactions are recorded ("system logs") that are necessary for the operation of the website or processed for system security purposes, such as analyzing attack patterns or illegal usage behavior ("evidence function").
When accessing the website, your internet browser automatically transmits the following data:
- Date and time of access,
- Browser type and version,
- Operating system used,
- Amount of data sent,
- IP address of the access.
This data is not used for immediate identification in the context of applicant management. It will be deleted in accordance with legitimate retention periods, unless a longer retention is required for legal reasons, such as for evidentiary purposes. In individual cases, extended retention for these purposes may be considered. The legal basis for the processing is Art. 6(1)(f) of the GDPR.
Use of Cloudflare by Softgarden
Softgarden employs the services of Cloudflare Inc., 101 Townsend St, San Francisco, USA, and its subsidiary Cloudflare Germany GmbH, Rosental 7, c/o Mindspace, 80331 Munich, Germany, to enhance the security of the platform, particularly to protect against DDoS attacks, and to improve delivery speed. Cloudflare provides a network of servers capable of delivering optimized content to end users and intercepting malicious traffic.
The services provided by Cloudflare include the "Data Localisation Suite" with components "Regional Services" and "Metadata Boundary for Customers." These components ensure that the transfer of personal data during the use of our platform occurs exclusively within the EU. The "Regional Services" guarantee that customer content traffic, i.e., end-user traffic, is securely transmitted to Cloudflare Points of Presence (PoPs) within the region selected by Softgarden and is reviewed within a PoP in that defined region. Softgarden has selected Germany as the region, so all traffic is exclusively processed on servers located in Germany. The "Metadata Boundary" ensures that Cloudflare does not transfer customer logs from the services used outside the European Union.
The personal data processed by Cloudflare includes all content transmitted by customers and applicants, including files (application documents) and multimedia data such as images, graphics, audio, or video, as well as any interactions between your browser and the Softgarden system. Cloudflare is a recipient of your personal data and acts as a data processor for Softgarden. This processing is conducted on the basis of legitimate interests in accordance with Art. 6(1)(f) of the GDPR to ensure the security and usability of the platform. Your personal data will be stored by Cloudflare for as long as necessary for the described purposes, typically up to 124 calendar days. For more information about Cloudflare, please refer to: Cloudflare DPA.
- Session Cookies
We use so-called "cookies" to provide you with comprehensive functionality and a more convenient experience on our website. Cookies are small files that are stored on your device by your internet browser. If you do not wish to have cookies stored on your device, you can prevent this by adjusting the settings in your browser. Please note that this may limit the functionality and scope of our services.
On our career page, we use the JSESSIONID cookie as a technically necessary session cookie. This cookie stores a session ID that allows requests from your browser to be associated with a single session. This enables your device to be recognized when you return to our website. This session cookie is deleted as soon as you log out or close your browser.
- Data Provided by Users: Application Process
As part of the application process, you have the opportunity to create and manage an account on our career portal after setting up a username and password. In addition to applying for positions individually, you can utilize additional features of the Softgarden applicant management system and make personal settings, such as being added to a talent pool.
For an efficient and successful application, we request that you provide the following information as part of your application:
- Contact details (address, phone number)
- Resume data, e.g.:
- Education
- Vocational training
- Professional experience
- Language skills
- Social network profiles (e.g., XING, LinkedIn, Facebook)
- Documents related to the application (application photos, cover letters, certificates, work references, work samples, etc.)
The legal basis for processing your data in the context of the application process and for initiating an employment relationship is Art. 6(1)(b) of the GDPR. Additionally, the use of the applicant management system by the data controller is based on legitimate interests pursuant to Art. 6(1)(f) of the GDPR. If specific processing activities require consent according to Art. 6(1)(a) of the GDPR, such consent will be obtained separately and transparently by the data controller, unless the consent is implied through clear and voluntary actions on your part, such as voluntarily participating in a video interview.
- Data Disclosure
Your data is handled confidentially within the scope of the applicant management process and is not disclosed to unauthorized third parties. The processing of your data is carried out solely for the purposes outlined in this privacy notice. Internal departments and responsible personnel of the data controller have access to your application data based on legitimate interests, provided it is necessary and permissible for the selection of candidates or internal administrative purposes of the company. For this purpose, your data may be forwarded to relevant individuals within the group of companies via email or within the management system. The legal bases for this processing may be Art. 6(1)(f) and (a) of the GDPR.
Data may also be shared with third parties as part of data processing agreements pursuant to Art. 28 of the GDPR. This involves outsourcing processing activities to third parties to efficiently perform specific tasks that the data controller would otherwise handle internally. The data controller ensures that all necessary data protection measures are implemented to comply with data protection regulations.
Disclosure to external third parties may also occur to defend legal claims or for investigations and disclosures to governmental authorities if required by law or necessary to fulfill a disclosure obligation. Information requirements under Art. 13 and 14 of the GDPR will be met prior to such disclosure, where applicable.
In the context of the application process, your personal data may also be shared within the group of companies and with affiliated companies in accordance with § 15 of the German Stock Corporation Act (AktG).
- Feedback Module
As part of your application process, we may request your feedback following an interview and up to three months after your hiring. To facilitate this, we will send you an invitation link directing you to our evaluation system where you can provide your feedback. The purpose of this processing is to further develop and optimize our recruiting and application processes, as well as to enhance our company image.
For these purposes, the following data is processed automatically:
- Contact details (name, email)
- Position title for which you applied
- Location of the position
- Job category
- Applicant ID
Your feedback is anonymized and stored in our database without linking it to personal identifiers. In addition to a star rating for individual questions, you have the option to leave comments. We expressly request that you do not include personal data in your comments. The collected information, along with your feedback, may be displayed on our evaluation page.
Participation in this feedback process is voluntary and requires your explicit consent. Feedback cannot be provided without your approval. The legal basis for processing your data is Art. 6(1)(a) of the GDPR.
- Job Subscription ("Job-Abo")
To stay informed about new job opportunities, you can subscribe to our job newsletter or receive relevant job postings through our career board (RSS feed). When subscribing to the newsletter, you can specify your preferences regarding the desired role and location.
Providing your email address is required to subscribe to the newsletter. The legal basis for this processing is your consent pursuant to Art. 6(1)(a) of the GDPR. You can withdraw your consent at any time via the unsubscribe link in the newsletter (opt-out).
The RSS feed for displaying new job offers does not process any personal data.
- Salary Statistics Module
During the application process, you have the opportunity to provide feedback on your salary expectations and the offers you receive.
The information submitted is processed anonymously, without reference to your name or contact details. Softgarden uses this anonymized data for its own purposes, such as statistics, analysis, and research, and is responsible for this processing in accordance with Art. 4(7) of the GDPR.
Participation in this feedback option is entirely voluntary and requires your consent. The legal basis for this processing is Art. 6(1)(a) of the GDPR.
- Social Share Buttons
You have the option to share our job postings on various social networks using available share buttons. These buttons direct you to the respective networks and their login pages after clicking. They do not function as plugins and do not transmit any personal data directly to the operators of the social networks.
Currently, job postings can be shared via the following social networks:
- Facebook (https://de-de.facebook.com/privacy/explanation)
- Twitter (https://twitter.com/de/privacy)
- LinkedIn (https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-join-privacy-policy)
- Xing ( https://privacy.xing.com/de/datenschutzerklaerung)
The legal basis for processing is Art. 6(1)(f) of the GDPR, which enables statistical analysis and reach measurement of job postings.
You can review how these social networks process your personal data by following the provided links. We have no control over the data processing practices of these social networks.
- Online Surveys ("Easyfeedback")
At the end of the application process, you may receive an invitation from Softgarden to participate in a survey via a provided link. This survey is conducted by easyfeedback GmbH and aims to capture your application experience. Softgarden acts as the data controller in accordance with Art. 4(7) of the GDPR and processes the collected data in an anonymized form for purposes such as statistics, analysis, studies, and further development of Softgarden products.
Survey data collection is conducted using SSL encryption, and Softgarden ensures that no personal identification is made during the analysis. You may terminate the survey at any time; however, data processed up to the point of termination may still be used for the aforementioned purposes.
Participation in the survey is voluntary. By participating, you consent to the processing of your data; without your consent, participation is not possible. The legal basis for processing your data is Art. 6(1)(a) of the GDPR. Data will be analyzed anonymously by Softgarden.
For more information on data protection with easyfeedback, please visit: https://easy-feedback.de/privacy/datenschutzerklaerung.
- Talent Pool
As part of your application or through the "Get in Touch" button, you have the option to recommend yourself for our talent pool. This processing is necessary to automatically consider you for future job postings, including similar or otherwise relevant positions.
When registering for the talent pool via the "Get in Touch" button, the following information will be requested:
- Academic title (optional)
- First name, last name, email address
- Job fields of interest
- Current career level
- Preferred location(s)
- XING profile or resume
Entry into the talent pool is entirely voluntary and requires your consent through an opt-in link. The legal basis for this processing is Art. 6(1)(a) of the GDPR. After six months, we will contact you to inquire if you wish to remain in the talent pool.
- Sharing Application Status with Job Boards
When you apply through a job board (e.g., Hellowork, Stepstone), the data you submit is automatically transferred to our recruiting system.
For some job boards, you have the option to track the status of your application in your account on the respective job board. In this context, our service provider, Softgarden e-recruiting GmbH, transmits the status of your application (receipt, processing, rejection) on our behalf to the job board. The display of the application status in your account on the job board may be delayed by up to four weeks, as we first wish to inform you personally about the status of your application.
The legal basis for this data transmission is Art. 6(1)(b) of the GDPR (initiation of an employment relationship).
For more information on data processing, please refer to the privacy notices of the respective job board through which you applied.
- Data Deletion
Your data is stored for the duration of the application process and retained according to applicable retention periods after the process concludes. In the event of a rejection, the data is kept for six months. In the case of a successful hire, the data is retained for three months following the hiring. After these retention periods expire, the data is fully anonymized.
Anonymized data sets are not subject to data protection regulations and may be used for statistical and analytical purposes, market research, or product development.
- Your Rights as a Data Subject
You have a variety of rights regarding the processing of your personal data within the scope of the respective regulations (especially Art. 15-21 GDPR):
- Right to information
- Right of rectification
- Right of deletion
- Right to restriction of processing
- Right to data portability
- You also have the right to be subject to an individual decision that is not exclusively automated
- Right to complain to a competent data protection supervisory authority
The right to information and the right of deletion are subject to legal restrictions, for example according to § 34, 35 Federal Data Protection Act. In such cases, please contact us at [email protected] or by mail at the address provided above.
For data processing based on your consent (Art. 6(1)(a) of the GDPR), you have the right to withdraw your consent at any time, without providing reasons, with effect for the future. The processing of your data will cease, but the legality of processing carried out prior to withdrawal remains unaffected. You also have the right to object to the processing of your data, particularly if the data has been processed incorrectly or if there are other legitimate reasons against further processing.
Please note that in the event of an objection or withdrawal, certain services or processing activities may no longer be feasible if the processing is necessary for those purposes.
- Automated Decision-Making
No automated decision-making occurs. Should such processing become necessary or occur in the future, we will obtain transparent consent in advance of the processing.
- Amendments to Privacy Notice
We reserve the right to amend or supplement this privacy notice at any time to comply with evolving legal, technical, and organizational requirements related to the processing of personal data. This may include corrections of translation errors and adjustments to meet national data protection standards.