Data protection declaration

INTRODUCTION

• This Privacy Policy explains how we handle your personal data when we introduce ourselves to you, assist you in your job search, maintain a relationship with you after we have found a job for you, provide a service to you, or you provide a service to us, use your data to ask you for assistance in connection with one of our candidates or when you visit our website.
• This Privacy Policy describes how we collect, use and process your personal data and how we comply with our legal obligations to you. The protection of your data is very important to us and we have made it our mission to protect and uphold your data protection rights.
• This Privacy Policy applies to the personal data of visitors to our website, temporary workers, potential candidates, candidates, customers, suppliers and other persons with whom we will contact to learn more about our candidates or who have indicated them as emergency contacts.  In addition, it applies to the emergency contacts of our employees. For clarification: If you are an employee of allectio, please note the allectio employee privacy policy, which can be found on the allectio intranet.
• For the purposes of applicable data protection laws (including, but not limited to, the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), you can find the company responsible for your personal data ("allectio" or "us") here.
• Important: This Privacy Policy may change from time to time. Please use this page to inform yourself, as we will post any changes here.
• If you do not agree with any aspect of our Privacy Policy, you may have legal rights, which are also described here.
• This Privacy Policy applies in the relevant countries within our international network. Different countries may have slightly different approaches to data protection, so this Privacy Policy includes country-specific parts. You can find country-specific terms for your jurisdiction here. This allows us to ensure that we comply with all applicable data protection regulations, regardless of your location.

HOW TO USE THIS PRIVACY POLICY

• This Privacy Policy gives you some information about how we use your personal data and, perhaps more importantly, what your rights are in this regard (for example, you always have the right to request erasure from us or confirmation of what information we hold about you, withdraw consents you have given and/or lodge a complaint with the supervisory authority; if you are not satisfied with something we have done).
• The Privacy Policy is divided into an abridged version, called a "summary", and a long version.
• The "Summary" section is limited to a few pages, where you will be given an overview under the following headings:
  • What types of personal data are collected?
  • How is your personal data collected?
  • How is your personal data used?
  • To whom will your personal data be disclosed?
  • How is your personal data protected?
  • How long will your personal data be stored?
  • How can you access, modify or withdraw personal data that you have provided to us?
  • How is your data stored and transferred internationally?
  • Who is responsible for the processing of your personal data on the allectio website?
  • What are cookies and how are they used?
  • How to refuse cookies.
• Below there is a long version, where all these questions are discussed in more detail. If you want to know more about a specific question, you can simply click on the hyperlinks in this document that we have integrated in the "Summary" to get to the corresponding part in the long version.
• If you want to go back to the "Summary" section, you can simply scroll up: both the "Summary" and the long version are in the same document.
• This Privacy Policy also includes some defined terms, which is why we have included a glossary at the end of this document. If you are unsure about the meaning of any of these defined terms, you can simply click on the term and you will be redirected via a hyperlink to the appropriate part of the glossary.

This Privacy Policy is divided into different subsections for each different group of people who need to understand it (for example, in the section "What types of personal data are collected?" there are subsections for "Candidates" and "Visitors to our website", as well as for the other individuals to whom this Privacy Policy applies). The Privacy Policy contains different information depending on the section, so make sure you are in the right section. EXECUTIVE SUMMARY – "Summary" What types of personal data are collected? 

• CANDIDATE DATA: We need to process certain information about you in order to provide you with optimal, tailor-made employment opportunities. We only ask for information that we think will actually help us better serve you, such as your name, age, contact details, education details, employment history, emergency contacts, residency status, financial information (if we need to check your financial background) and social security number (of course, you are welcome to provide us with further information voluntarily). Where appropriate and permitted by local laws and regulations, we will also collect information about your health, diversity information or details of any criminal record.
• A more detailed description of the personal data we collect about you can be found here.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• DATA OF POTENTIAL CANDIDATES: If we take note of your information online and believe that you may be interested in or benefit from our services, we will collect and use this information about you to evaluate how we could help and contact you.
• A more detailed description of the personal data we collect about you can be found here.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• TEMPORARY WORKER DATA: If we employ you directly as a temporary worker, we need to process certain additional information (in addition to the information collected from candidates) to ensure a smooth temporary employment relationship. We only collect important information such as personnel numbers or other identifiers, start dates, bank details and details of previous compensation, pension and benefit arrangements. Consequently, in accordance with local laws and regulations, we may also collect information about union membership, sexual orientation and childcare or caring arrangements when you provide us with information about salary deductions for union membership or childcare groups or details of your emergency contact.
• A more detailed description of the personal data we collect in this way can be found here.
• Even when you access our website, we collect certain information about you. More information can be found here.
• CUSTOMER: If you are a customer of allectio, we need to collect and use information about you or persons within your organization to provide or offer you services, e.g.: (i) finding candidates who are a good fit for you or your organization, (ii) providing you with (or assisting another organization) with a managed service provider ("MSP") program, (iii) providing recruitment process outsourcing ("RPO") services (or assisting another organization in doing so) (iv) providing services to your employees, such as training teachers working for our education clients, and/or (v) notifying you of allectio published content that is likely to be important and useful to you.
• A more detailed description of the personal data we collect in this way can be found here.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• SUPPLIER DATA: We need a little information from our suppliers to ensure a smooth process. We need the contact details of the responsible persons within your organisation in order to be able to communicate with you. We also need further information, such as your bank details, so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
• A more detailed description of the personal data we collect about you can be found here.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: In order to be able to offer candidates suitable employment opportunities, to be prepared for certain eventualities with regard to them and our employees, and to provide employees with access to certain benefits or employment rights, we need some basic background information. We ask for very basic contact details so that we can contact you for a reference or contact you because you have been identified as an emergency contact or relative of one of our candidates or employees.
• A more detailed description of the personal data we collect about you can be found here.
• VISITORS TO OUR WEBSITE: We collect a limited amount of information from visitors to our website and use it to make it easier for you to use our website and to better manage the services we offer. This includes, but is not limited to, information about how you use our website and how often you access the website, as well as the times when our website is particularly in demand.
• For more information about what information we collect about you when you visit our website, click here.

We need some elements of the personal data we collect from you to fulfil our contractual obligations to you or others. Some information, such as candidates' social security number, may be required by law in certain jurisdictions. Others are only needed to ensure a smooth business relationship. Depending on the nature of the personal data in question and the reasons for its processing by us, we may not be able to fulfil our contractual obligations or, in extreme cases, continue to maintain the business relationship if you refuse to provide us with this data or ask us to stop the processing. Details of the legal bases to which we are subject when using and processing your personal data can be found here. How is your personal data collected? 

• CANDIDATE DATA: We collect your personal data either:

1. From you or
2. from third parties.

• More information about how we collect your personal data can be found here
• Furthermore, if you access our website or read or click on an email from us, we will also collect certain data automatically or by providing it to us. Further information can be found here.
• DATA OF POTENTIAL CANDIDATES: We collect personal information about you from third parties (for example, through social media, professional networks, job search engines and online job posting providers and RPO or MSP providers when they refer you to us.)
• More information about how we collect your personal data can be found here
• Furthermore, if you access our website or read or click on an email from us, we will also collect certain data automatically or by providing it to us. Further information can be found here
• TEMPORARY WORKER DATA: We collect your personal data either:

1. From you or
2. from third parties.

• More information about how we collect your personal data can be found here
• Furthermore, if you access our website or read or click on an email from us, we may also collect certain data automatically or by providing it to us. Further information can be found here.
• CUSTOMER: We collect your personal data either:

1. From you or
2. from third parties (e.g. our candidates or temporary workers) and other restricted sources (e.g. online and offline media).

• More information about how we collect your personal data can be found here
• Furthermore, if you access our website or read or click on an email from us, we will also collect certain data automatically or by providing it to us. Further information can be found here.
• SUPPLIER DATA: We collect your personal data in the course of working with you.
• Furthermore, if you access our website or read or click on an email from us, we will also collect certain data automatically or by providing it to us. Further information can be found here
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: We only collect your contact details if a candidate or one of our employees identifies you as an emergency contact or dependent, or if a candidate names you as a reference contact.
• VISITORS TO OUR WEBSITE AND RECIPIENTS OF E-MAILS: We collect your data automatically using cookies in accordance with the cookie settings in your browser when you visit our website. For more information about cookies, such as how we use them and the choices you have, click here. We also collect information from you when you contact us through the Site. Some of our emails contain code snippets that are not visible. With this so-called tracking pixel, we can find out which of our messages are opened. If you do not want this information to be collected, please disable the automatic download of images in your email software or from your email provider.

How is your personal data used? 

• CANDIDATE DATA: The main reason for using your personal information is to help you find employment or other suitable employment. The more information we have about you, your skills and your goals, the better we can tailor our performance to you. Where appropriate and permitted by local laws and regulations, we will also use your personal data to advertise our services to you, profiling and diversity monitoring, etc. We may ask for your consent for some of these actions.
• More information about how we use your personal data can be found here.
• DATA OF POTENTIAL CANDIDATES: We use information about potential candidates to determine whether you are interested in our services or whether they may be of use to you. If this is the case, we will evaluate whether and how we could help you. If we think we can help you, we will use your information to contact you about our services.
• More information about how we use your personal data can be found here.
• TEMPORARY WORKER DATA If we employ you as a temporary worker, we use your personal data primarily to ensure a smooth temporary employment relationship and to fulfil our contractual and other obligations to each other and to our customers in the context of our temporary employment relationship, as well as our obligations to third parties such as tax authorities and government agencies.
• More information about how we use your personal data can be found here.
• CUSTOMER: The main reason why we use information about customers is to be able to introduce ourselves to you and ensure that the contractual arrangements between us can be properly implemented to ensure a smooth business relationship. This will include: (i) identifying candidates we believe are a good fit for you or your organization, (ii) providing you with an MSP program (or assisting another organization in doing so), (iii) providing RPO services to you (or assisting another organization in doing so), and/or (iv) providing benefits to your employees. The more information we have, the better we can tailor our services to you.
• More information about how we use your personal data can be found here.
• SUPPLIER DATA: We use your personal data mainly for two reasons: on the one hand, to ensure that the contractual agreements between us can be properly implemented and thus a smooth business relationship is possible, and on the other hand, to ensure compliance with legal requirements.
• More information about how we use your personal data can be found here.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: We use the personal data of reference contacts to help our candidates find a suitable position. If we can verify their information and qualifications, we can ensure that they are a good fit for potential employers. If a reference representative is required based on a candidate's professional experience and we believe they may be interested in becoming our client, we may also use their information to contact them through this alternative option. We use the personal information of the emergency contacts of candidates or employees in case the candidate or employee should be involved in an accident or emergency.We use the personal information of dependents or other beneficiaries of employees to provide that employee with access to certain benefits or employment rights.
• More information about how we use your personal data can be found here.
• VISITORS TO OUR WEBSITE: We use your information to make it easier for you to use our website, for example by analysing your most recent job search criteria so that we can better show you jobs that we think may be of interest to you. If you are also a candidate or client of Allectio, we will use data about your use of the Website to improve other aspects of communication with you or the service we provide to you.
• For more information about cookies, such as how we use them and the choices you have, click here.
• Please note that communications to and from Allectio employees, including emails, will be reviewed as part of internal or external investigations or disputes.

To whom will your personal data be disclosed? 

• CANDIDATE DATA: We will share your personal data with different recipients in different ways and for different reasons. First and foremost, we share your information with potential employers to increase your chances of getting the job you want. Unless you have indicated otherwise, we will also share your information with each of our group companies and related third parties, such as service providers we use and selected job search engines, if we believe this will help us provide you with the best possible service and maximise your chances of finding the job you seek.
• A more detailed list of possible recipient groups with whom we may share your personal data in appropriate circumstances can be found here.
• DATA OF POTENTIAL CANDIDATES: If you have been identified as a potential candidate, we may share your information with any group companies and related third parties, such as service providers we use, in order to contact you about our services.
• A more detailed list of possible recipient groups with whom we share your personal data in appropriate circumstances can be found here.
• TEMPORARY WORKER DATA: If we employ you directly as a temporary worker, we may share your personal data with some additional parties to ensure a smooth temporary employment relationship. For example, we may share your personal data with relevant colleagues at allectio (this may include colleagues in offices abroad), a client and, if applicable, with healthcare professionals such as your GP or an occupational health expert.
• A more detailed list of possible recipient groups with whom we share your personal data in appropriate circumstances can be found here.
• CUSTOMER: We share your information for the following purposes: (i) primarily to ensure that we can provide you with access to an appropriate pool of candidates, (ii) to provide you with an MSP program (or to assist another organization in doing so), (iii) to provide RPO services to you (or to assist another organization in doing so), and/or (iv) to provide benefits to your employees, to be provided. Unless you have indicated otherwise, we will share your information with each of our group companies and related third parties, such as service providers we use, in order to better achieve these objectives.
• A more detailed list of possible recipient groups with whom we may share your personal data in appropriate circumstances can be found here.
• SUPPLIER DATA: Unless you have indicated otherwise, we will share your information with each of our group companies as well as affiliated third parties, such as service providers we use and organisations for whom we provide services.
• A more detailed list of possible recipient groups with whom we may share your personal data in appropriate circumstances can be found here.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: Unless you have indicated otherwise, we will share your information with each of our group companies as well as affiliated third parties, such as service providers we use and organisations for whom we provide services.
• A more detailed list of possible recipient groups with whom we may share your personal data in appropriate circumstances can be found here.
• VISITORS TO OUR WEBSITE: Unless you indicate otherwise, we will share your information with providers of web analytics services, marketing automation platforms and social media services to ensure that you only receive targeted advertising from us.

How is your personal data protected? 

• Your privacy is important to us. Therefore, we take appropriate measures to prevent unauthorized access to and misuse of your personal data.
• More information about the procedures we have put in place can be found here.

How long will your personal data be stored?

• If you are a customer or a supplier, we store your personal data in order to provide services to you or to receive services from you or to provide you with information about our services that we consider to be of interest to you. If you have expressly indicated that you do not want us to retain your personal information, we will delete it from our systems unless we believe in good faith that we are required to retain it by law or otherwise (for example, because of a request from a tax authority or a connection with a foreseeable litigation).
• If you are a potential candidate or candidate and we have not had any relevant contact with you (or, if applicable, the organisation you work for or with) for two years, we will delete your personal data from our systems unless we believe in good faith that we are required by law or otherwise: retain them (for example, because of a request from a tax authority or in connection with an anticipated litigation). As with customers and suppliers, if you, as a potential candidate or candidate, have expressly indicated that you are not interested in our services, we will delete your personal data from our systems unless we believe in good faith that we are required to retain it by law or otherwise (for example, because a request from a tax authority or a connection with an anticipated litigation).
• If we employ you directly as a temporary worker, we will process your data normally during our temporary employment relationship and then (further) process it in accordance with the procedure we apply to candidates after the termination of our relationship.
• Further information on our policy regarding the storage of personal data can be found here.

How can you access, modify or withdraw personal data that you have provided to us? 

• Even if we already have your personal data, you have various rights with regard to this data. If you would like to contact us in this context, please contact us. We will endeavour to process your request as soon as possible and in any case in accordance with the applicable legal provisions. Please note that we may keep records of our communications in order to better resolve any issues you raise.
• Right to object: If we use your data because we believe it is in our legitimate interests and you do not agree to this, you have the right to object. We will respond to your request within 30 days (although in certain cases we may be entitled to extend this period). As a rule, we will only object to you in certain, narrowly defined circumstances.
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in certain jurisdictions to use cookies) or your consent to send advertising to you, you may withdraw your consent at any time.
• Data subject request for access to personal data (DSAR): For the avoidance of doubt, you have the right at any time to request confirmation from us as to what information we hold about you and to ask us to change, update or delete that information. We can then comply with your request. In addition, we have the following options:
  • ask you to confirm your identity or ask you for more information about your request; and
  • if permitted by law, reject your request. (In this case, however, we will explain the reasons for the refusal.)
• Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to ask us to "delete" your personal data. We will respond to your request within 30 days (although in certain cases we may be entitled to extend this period) and will only object to you in certain narrowly defined circumstances. If we agree to your request, we will delete your data.
• Right to data portability: If you wish, you are entitled to transfer your data from us to another controller. We will support you in this by transmitting your data directly for you or by providing you with a copy in a commonly used machine-readable format.
• Right to lodge a complaint with a supervisory authority: You also have the right to complain to the competent local supervisory authority. Details can be found here.
• If your interests or requirements change, you can unsubscribe from some or all of our promotional content (for example, email notifications about vacancies or newsletters from allectio) by clicking on the unsubscribe link in the email or by sending an email to info@allectio-consulting.com
• More information about your rights in relation to the personal data we hold about you can be found here.

How is your data stored and transferred internationally? 

• allectio is an internationally active company – this is the only way we can offer you this level of service. In order for us to continue to work in this way, we may need to transfer or store your data internationally in certain circumstances.

More information about the measures we take when we transfer and store your data internationally can be found here. Who is responsible for the processing of your personal data when you visit the Allectio website?  

• allectio controls the processing of personal data when you visit our website(s).

If you have further questions or would like more details, click here. What are cookies and how are they used? 

• A "cookie" is a small data file that is stored on your computer's hard drive. Cookies are used by almost all websites. They do not harm your system. We use them to track your activities and ensure that you can enjoy a pleasant customer experience when visiting our website. We may use the information from cookies to ensure that we can present you with options tailored to your preferences on your next visit. We may also use cookies for traffic analysis and advertising purposes.
• If you want to check or change what types of cookies are accepted, you can usually do so in your browser settings. We also provide you with information on this on the advertising settings page on the allectio website.

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

• If you do not wish to receive cookies that are not strictly necessary to perform basic functions of our website, you can change your browser settings so that cookies are no longer accepted.
• Most web browsers accept cookies. However, if you prefer us not to collect data in this way, you can choose to accept all or some cookies or refuse all cookies in your browser's privacy settings. However, if you reject all cookies, you may not be able to take full advantage of the features of our website. Every browser is different. Therefore, check the help menu of your browser to find out how to change your cookie settings.
• For more general information about cookies, including how to disable them, see aboutcookies.org. You can also find out how to delete cookies from your computer.

   DETAILED SECTIONS IN DETAILED FORM WHAT TYPES OF PERSONAL INFORMATION ARE COLLECTED?   Would you like to know more about what data we collect about you? Here is a more detailed description of the information we collect. The information described below is, of course, in addition to the personal data that we are legally obliged to process in the respective situations.

• CANDIDATE DATA: Depending on the applicable conditions and applicable local laws and regulations, we will collect some or all of the information listed below in order to provide you with employment opportunities tailored to your situation and interests. In some jurisdictions, we are restricted in the processing of the following data. In these cases, we do not process the data in these jurisdictions:
  • Name
  • Age/Date of birth
  • Birth number
  • Sex
  • Photography (application photo, etc.)
  • Marital status
  • Contact
  • Details of the training incl. certificates/certificates or similar
  • Professional career
  • Emergency contacts and dependents
  • Details of the contact person for a reference
  • Immigration status (whether you need a work permit)
  • Nationality/citizenship/place of birth
  • Start date or availability date
  • A copy of your driver's license or passport/ID card
  • Bank account
  • Financial data (if we need to check your financial background)
  • Social security number (or equivalent in your country) and other tax information
  • Information about diversity (any racial or ethnic origin, religious affiliation or similar beliefs, as well as physical and mental health, including any information related to disabilities)
  • Details of any criminal record, if relevant to a job you are applying for
  • Details of your previous and current compensation, annuity and benefit arrangements
  • Childcare or caregiver agreements (for example, if you allow a wage deduction for childcare cups or voluntarily provide this information)
  • Sexual orientation (for example, if you disclose this by providing details about loved ones)
  • Information about your interests and aspirations with regard to future employment; these are both collected directly and derived, for example from the job vacancies or articles you read on our website or from the links you have clicked on in emails we send
  • Additional information you voluntarily provide to us
  • Additional information that your reference contacts voluntarily provide to us about you
  • Additional information that our clients voluntarily share with 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 an exhaustive list of the personal information we collect.

Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.

• POTENTIAL CANDIDATE DATA: If we believe that our services may interest you or be of use to you, we will collect limited information about you to evaluate how we could help you. This information is likely to include your name and contact details so that we can contact you. We may also collect additional information about you, for example, if we found you during our searches on LinkedIn or other job listing sites. In this case, we collect information such as your professional career, education, qualifications, skills and interests, as well as additional information that you have provided in a profile or resume that you have uploaded to one of these websites.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• TEMPORARY WORKER DATA: If we employ you directly as a temporary worker, depending on the circumstances and applicable local laws and regulations, we will collect some or all of the information listed below (in addition to the data collected about candidates) in order to ensure a smooth temporary employment relationship and to fulfil our contractual and other obligations to each other and to our clients in the context of our temporary employment relationship and our obligations. to third parties such as tax authorities and government agencies. In some jurisdictions, we are not allowed to process certain of the data listed below. In these cases, we will not process the data in these jurisdictions.
  • Personnel number/other identifier
  • Place of your employment or the place of work at the customer
  • Membership of a trade union
  • Details of complaints or disciplinary cases brought by or against you or in which you are or have otherwise been involved
  • Details of any leave you take or request during our temporary employment relationship or sick leave, including health information
  • Information about your performance in your position during our temporary employment relationship, including details of bonuses or promotions you have received, performance evaluations and other information relating to your employment, interaction with colleagues and work-related issues
  • Details of trips undertaken.
• Please note that the above list of categories of personal data we collect is not exhaustive.
• Some of the items listed above are necessary for us to perform our contractual obligations to you or others. Certain, such as your Social Security number (or equivalent), are required by law or other laws. Other elements may only be needed for our temporary employment relationship to run smoothly or to run our business.
• Depending on the nature of the personal data concerned and the reasons why we may process it, we will not be able to fulfil our contractual obligations or, in extreme cases, continue our temporary employment relationship if you do not provide us with this data.
• CUSTOMER DATA: We only collect very limited data about our customers. Typically, we only need your contact details or the contact details of individual contacts within your organisation (such as their names, telephone numbers and email addresses) to contact you about our services, to ensure a smooth business relationship and, in certain circumstances, to provide services to your employees. We also store information about your online use of candidates' profiles and other materials published by allectio. We use these to ensure that you receive appropriate advertising communications from us at the right time. 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 phone calls with you may be recorded, depending on applicable local regulations and requirements. If for any reason we require further personal data from you, we will let you know.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• SUPPLIER DATA: We don't collect a lot of data about suppliers. We just need to ensure a smooth business relationship. We collect information from our contacts within your organization, such as names, phone numbers, and email addresses. We also collect bank details in order to be able to 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 phone calls with you may be recorded, depending on applicable local regulations and requirements.
• Also, when you access our website or click on a link in an email we send, we collect certain information about you. More information can be found here.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: From reference contacts, we only need confirmation of the information about the candidate or future employee that you already have, so that they can get the job they want. 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 reference person (such as name, e-mail address and telephone number). We also need these details if our candidate or one of our employees has provided you as an emergency contact so that we can notify you in the event of an accident or emergency.
• We collect your date of birth, contact details and, if applicable, certain information about your health if one of our employees has designated you as a dependant or other beneficiary for a benefit related to their employment, or if one of our employees exercises certain employment rights. We may also receive limited information about your sexual orientation (based on inferences) if one of our employees identifies you as a spouse or partner by identifying you as a dependent, dependent, or emergency contact.
• VISITORS TO OUR WEBSITE We collect a limited amount of information from visitors to our website and use it to make it easier for you to use our website and to better manage the services we offer. This includes information such as how you use our website, how often you access our website, your browser type, the location from which you access our website, the language selected and the times when our website is particularly in demand. If you contact us via the Website, for example by using the chat function, we collect any information you provide to us, such as your name and contact details.
• 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 the following ways:

1. Personal data that you provide to us as a candidate
2. Personal data we receive from other sources
3. Personal Information We Collect Automatically.

Personal data you provide to us

• allectio needs certain information about you in order to be able to provide you with a tailor-made service. In this way, we can offer you optimal possibilities. Plus, you'll probably save time because you don't have to search through information about jobs and benefits that aren't relevant to you.
• You can share information with us in a variety of ways, depending on what suits you best. This may include that you:
  • enter your data as part of the registration process on the allectio website or in an application form;
  • submit a printed curriculum vitae at an allectio recruitment event, a job board or a branch;
  • send your CV or other information by e-mail to an allectio consultant or conduct an interview with him;
  • apply for jobs via a job search engine, which then redirects you to the allectio website;
  • enter your personal information on an allectio microsite; or
  • enter a contest via a social network such as Facebook or Twitter (or similar).

Personal data we receive from other sources

• We also receive personal data about candidates from other sources. Depending on the relevant circumstances and applicable local laws and regulations, these may also include personal data received in the following situations:
  • Your reference contact may disclose personal information about you;
  • Our customers, suppliers and other candidates may share personal information about you with us;
  • If you "like" our Facebook page or "follow" us on Twitter, we receive personal information about you from these websites;
  • If you are referred to us by an RPO or MSP provider, they may provide us with personal information about you.

Personal Information We Collect Automatically

• If you access our website or read or click on an email from us, we will also collect your information automatically in accordance with any local regulations and requirements or by providing it to us. Further information can be found here.
• DATA OF POTENTIAL CANDIDATES: We receive personal data about potential candidates from third parties when we:
  • Search for potential candidates through third-party sources such as LinkedIn and other job listing sites from which we receive your personal information
  • receive your personal data from Facebook or Twitter when you like our Facebook page or 'follow' us on Twitter (or have a similar interaction with us on social media); and
  • receive your personal data from an RPO or MSP provider when they refer you to us.
• TEMPORARY WORKER DATA: If we employ you directly as a temporary worker, we collect your data (in addition to the data already collected about candidates) in the following ways:
  • Personal data you provide to us
    • 1. Personal data that you provide to us and
    • 2. Personal data we receive from other sources.

See below for more details on each of these methods.

• allectio needs certain information about you in order to fulfil our obligations towards you, to ensure that you properly fulfil your obligations towards us and to ensure that we both fulfil our obligations towards others. With this information, we will be able to have an ordinary temporary employment relationship, with all that entails.
• There are many ways in which you can submit your information to us, in addition to the information you have submitted as a candidate. This includes, where applicable and in accordance with local laws and regulations:
• If you fill out registration forms at the beginning of our temporary employment relationship, or
• In meetings or communications with your consultant, our HR team or other colleagues.

• Personal data we receive from other sources
• We also receive personal data about you from other sources. Depending on the circumstances and applicable local laws and regulations, this may include personal data obtained in the following situations:
  • If you are referred to us by recruitment agencies or other employment agencies who have shared personal information about you with us
  • Information about you that we have received from third-party service providers who have checked your background on our invoice at the beginning of our temporary employment relationship
  • Your colleagues may share personal information about you with us
  • Healthcare professionals may (in reasonable and limited circumstances) share personal information about you with us
  • The providers of your pension and benefits may share relevant personal data about you with us; and
  • Other third parties, such as your local tax authority, may share your personal information with us.
• CUSTOMER We collect personal information from customers in the following ways:

1. Personal data we receive from you
2. Personal data we collect or receive from other sources
3. Personal Information We Collect Automatically.

Personal data we receive directly from you

• We share the same goal: we want to make sure you find and have the best people for your organization. We receive data directly from you in two ways:
  • when you contact us on your own initiative, usually by telephone or e-mail, and/or
  • when we contact you by phone, email or more generally in the course of the business development activities of one of our consultants.

Personal data we receive from other sources

• We will attempt to obtain information about you and your colleagues from other sources, usually through due diligence or market research, where appropriate and in accordance with any local laws and regulations, about:
  • Third party market research and analysis of online and offline media (we will carry out these ourselves or commission other companies to do so)
  • Lists of participants at corresponding events
  • Other restricted sources and third parties (e.g. from the candidates, if they share your data with us so that you can provide you with a reference or if they give us feedback on a specific task).

Personal data we collect through our website or links in emails

• If you access our website or read or click on an email from us, we may also collect your information automatically in accordance with any local regulations and requirements or by providing it to us. Further information can be found here.
• VISITORS TO OUR WEBSITE: When you visit our website, we automatically collect certain information about you, regardless of whether you use our services, namely your IP address, the date, time and frequency of your access to the website, how you browse the content and other technical information. We also collect information from you when you contact us through the Site, for example when you use the chat feature.
• We collect your data automatically using cookies in accordance with the cookie settings in your browser. If you are also a candidate, potential candidate or customer of allectio, we will use data about your use of the website to improve other aspects of communication with you or the service we provide to you. For more information about cookies, such as how we use them and the choices you have, click here.

HOW IS YOUR PERSONAL DATA USED? When we have information about you, we use it in different ways.

• CANDIDATE DATA: In general, we use data about our candidates in five ways:
  • recruitment activities;
  • Promotional activities
  • equal opportunities monitoring; and
  • Establishment, exercise or defence of legal claims.
  • In appropriate circumstances, we also use data from candidates to create a personality profile.

Further details on each species: Recruitment activities

• Obviously, recruitment is the focus area of our work – we lead the right candidates to the right jobs. We have listed below the different ways in which we may use and process your personal data for this purpose and in accordance with any local laws and regulations. Please note that this list is not exhaustive.
  • Collecting your information from you and from other sources, such as LinkedIn
  • Storing (and possibly updating) your data in our database so that we can contact you in connection with recruitment
  • Providing recruitment services and facilitating the recruitment process
  • Matching data about you with vacancies that we consider suitable
  • Sending your information to clients to apply for jobs or assess your suitability for jobs
  • Allow you to submit your resume, apply for jobs online, or receive alerts about jobs we think you'll be interested in
  • Enable you to participate in online expert training
  • Allow you, if you choose, to use the interactive features of our Services
  • Performing our obligations arising from contracts entered into between us
  • Fulfilling our obligations arising from contracts concluded between allectio and third parties in connection with your recruitment
  • Facilitate our compensation and invoicing processes
  • Conducting customer satisfaction surveys
  • Verifying information you have provided or requesting information (e.g., references, qualifications, or possible criminal record, where appropriate and permitted by local law)
  • Comply with our legal obligations in connection with the detection of crimes or the collection of taxes or duties
  • Process your data so that we can send you targeted, relevant promotional materials or other communications that we think may interest you
  • Carrying out assessment and development activities (e.g. psychometric assessments or skills testing) in some jurisdictions where we operate. More information related to your jurisdiction can be found here.
• We will use your personal data for the purposes described above where we consider it necessary for our legitimate interests. More information on what this means can be found here. If you do not agree, you have the right to object under certain circumstances. More information about this and how and when you can use it can be found here.
• Please note that in some jurisdictions in which we operate, we are subject to additional local legal requirements. More information related to your jurisdiction can be found here.

Promotional activities

• We may periodically send you information that we think may be of interest to you or ask you for help in placing other candidates. In particular, we may, upon request and in accordance with local laws and regulations, use your data for the purposes set out below. Please note that this list is not exhaustive. To:
  • Developing and promoting other products and services;
  • advertise to you for our full range of recruitment services (permanent, temporary, work contracts, temporary employment, MSP programmes and RPO services);
  • send you details of reports, promotions, offers, networking and customer events and, more generally, information about industries that we believe may be of interest to you;
  • Display excerpts of your data for advertising purposes on allectio's website(s) as a success story (only if we have your express consent to do so); and
  • inform you about certain discounts and offers to which you are entitled on the basis of your business relationship with allectio.
• For some aspects of these activities that are not covered by our legitimate interests (in particular for data collection using cookies and direct marketing of our services to you via our digital channels), we need your consent. Depending on the situation, we will ask you to provide them 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 legal requirements. More information related to your jurisdiction can be found here.
• "Soft opt-in" consent is a specific type of consent that applies when we have received your contact details when you have previously dealt with us (for example, by submitting an application for a job or resume or reporting a vacancy to be filled) and we advertise other of our recruitment services online. In the case of "soft opt-in" consent, we consider your consent to have been given as long as you do not object or withdraw it (and we will remind you of your right to do so in any e-marketing message we send you). For most people, this is helpful because it allows us to provide you with information that we think you might be interested in, as well as suggest other jobs in addition to the job you applied for. This significantly increases the likelihood that we will find a new job for you.
• For other types of e-marketing, we are obliged to obtain your express consent. For more information on how we may obtain your consent, please click here. If you do not agree with our marketing approach, you can withdraw or withdraw your consent at any time. More information can be found here. No one is perfect, even if we try very hard. You should be aware that it is possible that your data may be collected again through public sources as part of a separate advertising campaign, even if you have opted out of receiving our promotional communications through our Settings Centre. We try to avoid this, but unfortunately it can still happen. We kindly ask you to unsubscribe again in these cases.
• All of 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 each individual. We will use your data to show you advertisements and other content from allectio on other websites such as Facebook. If you do not want us to use your data in this way, disable the "advertising cookies" option (please consult our Cookie Policy). Even if you have deactivated advertising cookies, it is possible that advertisements from allectio will be displayed to you. In this case, however, this is not done specifically for you personally, but for an anonymous target group.

Gender monitoring and other sensitive personal data

• We want to ensure that our recruitment processes are in line with our approach to equality. Some of the information we collect about you (in certain circumstances and in accordance with local laws and regulations) falls within the scope of "diversity information". This may include information about your ethnic background, gender, disability, age, sexual orientation, religion or similar beliefs and/or your socio-economic background. This diversity information is considered "sensitive" or "specially categorized" personal information and is subject to stricter data protection regulations.
• Where appropriate and in accordance with local regulations and requirements, we use this information in an anonymised form to monitor our compliance with our Equality Policy. We will also provide this data (appropriately anonymised) to clients (including their internal or external auditors) if this is contractually agreed or if the client expressly requests this information in order to comply with its own employment processes.
• We may collect other sensitive/special category personal information about you, such as health or religious affiliation information, where permitted by local law. In these circumstances, we will use this information to comply with labour rights and obligations, such as calculating entitlement to annual leave or making appropriate adjustments for candidates or part-time workers. If you would like to know more about the legal basis under which we process this "sensitive" or specially categorised personal data, please click here.
• We may also collect details of any criminal record where permitted by local law. In these circumstances, we need your explicit consent to use them. We ask for this consent by offering you an "opt-in". This means that you must explicitly and unequivocally tell us that you consent to us collecting and using this information.
• Further information on consent can be found here.
• If you do not agree, you can withdraw your consent at any time. Information can be found here.
• Please note that some jurisdictions in which we operate have different rules for this sensitive/special category data. More information related to your jurisdiction can be found here.

Establishment, exercise or defence of legal claims

• In more unusual cases, we will also use your personal data to establish, exercise or defend legal claims.

Creation of a personality profile

• Creating a personality profile is a type of processing that uses information we collect about you to create your "personality profile". This allows us to better assess your personality and your interests, likes and dislikes and then offer you the best possible service.

Creation of a personality profile

• Creating a personality profile is a type of processing that uses information we collect about you to create your "personality profile". This allows us to better assess your personality and your interests, likes and dislikes and then offer you the best possible service.

This is how we use the personality profile:

• A. Personalization

We want to ensure that we communicate with you in the best possible way and optimize the information you receive through our services, our website and our online presence. For this purpose, we use methods to create personality profiles, in which we analyze your personal data in order to better know your personality and your interests, habits and preferences. (An example of this: When you click on an element on our website, we consider this a possible sign of what you are looking for.) We use personality profiling methods to place you and your candidate in groups or segments with other candidates based on your interests, habits, traits and/or preferences to:

• Send you personalized emails (reflecting, for example, what we have identified as your possible preferences)
• Provide recommendations for editorial content that we think may be of interest to you (e.g., reports on developments in your industry)
• Send you tailored or more relevant advertisements (the content of which, for example, reflects how you have responded to or interacted with our previous advertisements).
• B. Shortlisting and ranking

We may use personality profiling methods that analyse your personal data and/or place you and your candidate profile in groups or segments based on your interests, habits, characteristics and/or preferences so that our consultants can make decisions. For example, we may run your personal data through our systems in order to find out as efficiently as possible how suitable you are for a vacancy. In this way, we optimize the match of candidate profiles with the positions and improve the effectiveness and efficiency of the recruitment cycle.

• More specifically, we can use these personality profiling methods to:
  • Shortlist you and other suitable candidates for specific positions based on prescribed criteria so that our consultants can more efficiently identify the most suitable candidates for positions and recommend positions to you based on how your interests, habits, characteristics and/or preferences are ranked compared to other candidates.
  • Recommend positions to you based on how your interests, habits, traits and/or preferences are ranked compared to other candidates.
• We will use personal profiling methods in connection with your personal data where we consider it necessary for our legitimate interests. If you would like to know more, please click here. If you do not agree to this, you have the right to object in certain circumstances and can find more information on how and when possible here.
• C. Automated decision-making

As new and better technologies come to market, we will use them to help you as efficiently and effectively as possible.

• We use automated or artificial intelligence systems, which may include systems provided by third parties, to analyze data about you and other candidates and make decisions about you based on this data. This includes applying machine learning technology to candidates' personal data in order to obtain the best possible shortlist for a particular position. This technology should significantly reduce the time it takes to consider when a candidate is best suited for relevant positions. This should make the recruitment process far more efficient and effective, which we hope will improve your overall experience with us.
• We use automated decision-making in relation to your personal data when we deem it necessary to complete the pre-contractual steps taken at your request. If you would like to know more, please click here.
• DATA OF POTENTIAL CANDIDATES: We use data about potential candidates to determine whether you are interested in our services or whether they may be of use to you and evaluate whether and how we could help you. If we think we can help you, we will use your contact details to contact you about our services (usually by email).
• To do this, we can:
  • Collect your personal data
  • Store (and update (and update) your information in our database to contact you about our services
  • review your information to determine if and how our services may help you; and
  • Contact you about our services.
• TEMPORARY WORKER DATA: If we employ you directly as a temporary worker, we collect your data in five main ways:
  • To ensure the smooth running of our temporary employment relationship, including all activities that must be carried out in an ordinary relationship of this nature, such as:
    • Facilitate payroll and invoicing, if applicable to your legal system
    • Determining the conditions under which you work during your temporary employment relationship
    • Document promotions, raises, or bonuses awarded to you
  • Evaluation of your performance
  • If necessary, via equal opportunities monitoring
  • To help us establish, exercise or defend legal claims; and
  • To help us, help you and understand our legal obligations if you have an illness or disability.
• More detailed information about how your data is processed under the last three categories can be found in the internal privacy policy for recruitment at Allectio. For example, during the onboarding process with allectio, temporary workers for positions at allectio are treated similarly to internal applicants and their personal data during the recruitment process for these positions is processed as described in the internal privacy policy for recruitment at allectio (https://www.allectiocareer.net/datenschutz). We know that you are not an 'internal candidate' within the meaning of this policy, but since we use the data in a similar way and for the same purposes, we thought you wouldn't mind taking a quick look at this policy if you were interested in detailed details.
• CUSTOMER: We use information about our customers for the following purposes:
  • recruitment activities;
  • Promotional activities: and
  • Establishment, exercise or defence of legal claims.

Recruitment measures

• Obviously, recruitment is the focus area of our work. This is done through: (i) placement of candidates, (ii) RPO services; and (iii) MSP programs. Below we have listed the different ways in which we may use your data for this purpose:
  • Storing (and possibly updating) your data in our database so that we can contact you in connection with recruitment activities
  • Make recordings of conversations and meetings so that we can provide targeted services for you
  • Conducting customer satisfaction surveys
  • Processing your data in order to be able to target appropriate advertising campaigns for our services to you
• We also provide services for your employees, such as training for teachers working for our clients in education. Here we need to use your personal data to give you access to these services.
• We will use your personal data for these purposes where it is in our legitimate interests to do so. More information on what this means can be found here.
• If you do not agree, you have the right to object under certain circumstances. More information about this and how and when you can use it can be found here.

Promotional activities

• Where consistent with applicable local laws and regulations, we will not necessarily ask for your consent when we send you 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. Information can be found here.
• Please note that in some jurisdictions in which we operate, we are subject to additional local laws regarding advertising. More information related to your jurisdiction can be found here.

Establishment, exercise or defence of legal claims

• In more unusual cases, we will also use your personal data to establish, exercise or defend legal claims.
• SUPPLIER DATA: We know you're probably busy, and we don't want to bother you all the time. In order to strike a balance, we will only use your information for the following purposes:
  • Storing (and, if necessary, updating) your information in our database so that we can contact you in connection with our agreements
  • Provide services to you or receive support and services from you
  • Comply with certain legal obligations;
  • Develop appropriate targeted advertising campaigns; and
  • in more unusual cases, assertion, exercise or defence of legal claims.
• We will use your personal data for these purposes where it is in our legitimate interests to do so. More information on what this means can be found here.
• We will not necessarily ask for your consent to send you promotional communications to a business mailing address or email address.
• If you do not agree, you have the right to object under certain circumstances. More information on how to use it can be found here.
• Please note that in some jurisdictions in which we operate, we are subject to additional local legal requirements regarding the retention period of your data. More information related to your jurisdiction can be found here.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS: We will only use the information that our candidates or employees provide to us about you for the following purposes:
  • If candidates or employees have indicated you as an emergency contact in our form, we will contact you if they become involved in an accident or emergency; or
  • If you have been identified by an employee or temporary worker as a dependent, dependent, or other beneficiary, we will retain your personal data to ensure that that that employee's or temporary employee's human resources data is accurate and will use your personal data where necessary to provide employee benefits and pay remuneration and provide your data to the appropriate Service providers.
  • If a candidate or prospective employee has designated you as a contact person for a reference, we will contact you to obtain a reference or give your information to a third party so that they can do so on our behalf. If you are asked to provide a reference based on a candidate's professional experience and we think you may be interested in becoming our client, we may also use your information to contact you through this alternative option.
  • We will use your personal data for these purposes where it is in accordance with our legitimate interests or applicable labour law. More information on what this means can be found here.
  • If you do not agree, you have the right to object. More information on how to use it can be found here.
• VISITORS TO OUR WEBSITE: We use your information to make it easier for you to use our website, for example by analysing your most recent job search criteria in order to better show you jobs or candidates that we think may be of interest to you.
• For more information about cookies, such as how we use them and the choices you have, click here.

TO WHOM WILL YOUR PERSONAL DATA BE SHARED?

• We may share your personal information with the following categories of individuals in a variety of ways and for a variety of purposes in accordance with local laws and regulations:
  • All Group companies
  • Suitable colleagues at Allectio (this may include colleagues in offices abroad)
  • In the case of temporary workers and, where applicable, in limited circumstances, healthcare professionals such as your GP or an occupational health expert
  • In the case of temporary workers, the customer for whom you (will) work as a temporary worker
  • In the case of temporary workers, potential employers (for example, if a reference is provided, insofar as this is compatible with local laws and regulations)
  • Individuals and organisations who, in order to work with us, have information associated with the reference or application, such as current, previous or future employees, trainers and examination boards, and employment and recruitment agencies
  • Tax, auditing 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 an anticipated litigation)
  • Service providers (whether third parties or our group companies) who perform services on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, administrative functions, technical support functions and IT consultants who perform development and testing work on our company's technological systems)
  • Providers of outsourced IT services and storage providers, if a corresponding data processing agreement (or comparable protection) 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 the case of candidates: external partners, job portals, job platforms, job search engines, software developers and cloud-based databases, if we believe this increases the chance of finding the right job for you or improves the recruitment process in general
  • In the case of candidates: MSP vendors as part of our clients' MSP programs
  • In the case of candidates and reference contacts for our candidates and prospective employees: third parties whom we have engaged to provide services such as verification of references, qualifications and criminal records, where such checks are appropriate and permitted by local laws
  • In the case of candidates and the contact persons for candidate references: internal and external auditors of our clients, if we need to share this data with them upon request in order to comply with our contractual or regulatory obligations
  • In the case of candidates: third parties who help us by developing services and procedures to optimize the selection process of candidates and thus improve the quality and efficiency of recruitment services
  • Should allectio merge with or be acquired by another company or company in the future (or if there are meaningful discussions about such a possibility), we may pass on your personal data to the (future) new owners of the company or company.

HOW IS YOUR PERSONAL DATA 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 organizational measures. This includes measures to deal with any suspected data breaches.
• If you suspect that your personal information has been misused, lost or accessed without authorisation, please let us know as soon as possible. Details on how to contact us can be found here.

HOW LONG WILL YOUR PERSONAL DATA BE STORED?

• If you are a customer or a supplier, we store your personal data in order to provide services to you or to receive services from you or to provide you with information about our services that we consider to be of interest to you. If you have expressly indicated that you do not want us to process your personal data, we will delete it from our systems unless we believe in good faith that we are required to retain it by law or otherwise (for example, because of a request from a tax authority or a connection with a foreseeable legal dispute).
• If you are a potential candidate or candidate and we will delete your personal data from our systems if we do not have any relevant contact with you (or, where applicable, with the Company) for two years (or for a longer period if we believe in good faith that we are required by law or otherwise to retain your data). for or with which you work). At the end of this period, your data is probably no longer relevant to the purpose for which it was collected.
• As with customers and suppliers, if you, as a potential candidate or candidate, have expressly indicated that you are not interested in our services, we will delete your personal data from our systems unless we believe in good faith that we are required to retain it by law or otherwise (for example, because a request from a tax authority or a connection with an anticipated litigation).
• For the candidates whose services are provided through a third-party company or other entity, "relevant contact" with you means the relevant contact with the company or entity providing your services. If we are notified by that company or entity that we no longer have a business relationship with you, we will retain your data for a maximum of two years from that date or, if later, two years from which we have not had any 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 potential candidate, we will assume that there is a relevant contact when we first contact you in connection with our services. If you are a candidate, we will assume that there is a relevant contact when you upload your updated CV to our website or attend one of our online training courses. It is also considered a relevant contact if you communicate with us regarding 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 email or other digital message from us, this will not be considered a relevant contact. This is only the case if you click on something in it or reply directly.
• If we employ you directly as a temporary worker, we will process your data normally during our temporary employment relationship and then keep it after our relationship has ended. The exact retention period depends on the type of data, our legitimate business needs and other legal or regulatory rules that impose certain minimum retention periods on us. For example, we may be required to retain certain information for the purpose of filing tax returns or answering tax questions. We may also retain the data if this is relevant to potential litigation. In jurisdictions where this is permitted, we will generally retain personal data about you where necessary to provide a reference to you or a prospective employee.
• In determining the appropriate retention period for different types of personal data, we consider the amount, nature and sensitivity of the personal data concerned, the potential risk of harm due to unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can fulfil those purposes in other ways (ensuring, of course, that we comply with our legal, regulatory and risk management obligations as described above). For the avoidance of doubt, if you are a temporary worker, we will also process your personal data as a candidate for the duration of your temporary employment relationship and thereafter.

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

• One of the main objectives of the GDPR is to protect and clarify the data protection rights of EU citizens as well as individuals within the EU. This means that you continue to have various rights with regard 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 relation to these rights, please contact us. We will endeavour to respond to your request as soon as possible, and in any event within one month (extensions to which we are entitled by law may apply). Please note that we may keep records of our communications in order to better resolve any issues you raise.
• Right to object: On the basis of this right, you can object to our processing of your personal data if we do so for one of the following four reasons: (i) our legitimate interests, (ii) to perform a task in the public interest or to exercise official authority, (iii) to send you direct marketing materials and (iv) for scientific, historical, statistical or research purposes.
• The above categories of "legitimate interests" and "direct marketing" are the categories most likely to apply to visitors to our website, candidates, temporary workers, customers and suppliers. If you object to us processing your personal data because we consider it necessary for your legitimate interests, we will need to stop the relevant activities as a result of your objection, unless:
  • we can demonstrate that we have overriding legitimate grounds for the processing which 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 then stop this activity.
• Right to withdraw consent: If you have given us your consent to process your personal data for certain activities (e.g. to use cookies in certain jurisdictions), you can withdraw that consent at any time. We will cease the activity to which you had previously consented unless we believe there is an alternative reason justifying our continued processing of your data for this purpose. If this is the case, we will inform you.
• Data subject request for access to personal data (DSAR): You can always request confirmation from us 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 ask you for more information about your request. If we give you access to the information we hold about you, we will not charge for it 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 refuse your request where permitted by law. If we reject your request, we will justify this in any case.
• Please note that in some jurisdictions in which we operate, we are subject to additional local legal requirements regarding data subject access requests and may refuse your request under those laws. More information related to your jurisdiction can be found here.
• Right to erasure: In certain circumstances, you can request that we delete your personal data. Typically, the information must meet one of the following criteria:
  • The data is no longer needed for the purpose for which we originally collected and/or processed it;
  • You have withdrawn your previously given consent to the processing of your data by us and there is no other valid reason to continue the processing;
  • the data has been unlawfully processed (i.e. in a manner contrary to the GDPR);
  • the data must be erased so that we can fulfil our obligations as a data controller; or
  • You object to the processing and we cannot demonstrate overriding legitimate grounds 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 are subject to additional local legal requirements regarding data subject erasure requests and may refuse your request under those laws. More information related to your jurisdiction can be found here.
• We may only refuse your request 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 official authority;
  • where it is in the public interest for reasons of public health;
  • for archiving, research and statistical purposes; or
  • to exercise or defend a legal claim.
• If we comply with a valid request to delete data, we will delete the data in question.
• Right to restriction of processing: In certain circumstances, you can request that we restrict the processing of your personal data. This means that in the future we will only store your data and will not be able to carry out any further processing activities until: (i) one of the conditions listed below has been eliminated, (ii) you give your consent or (iii) further processing is necessary to establish, exercise or defend legal claims, to protect the rights of other persons or if it is necessary due to the legitimate public interest of the EU or a member state.
• You can request that we restrict the processing of your personal data in the following circumstances:
  • If you dispute the accuracy of the personal data we process about you. In this case, the processing of your personal data will be restricted by us 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 can request that the data be restricted while we verify our reasons for processing your personal data.
  • If the processing of your data by us is unlawful, but you prefer to restrict the processing by us instead of having the data deleted.
  • If there is no longer a need for us to process your personal data, but you need the data to establish, exercise or defend legal claims.
• If we have disclosed your personal data to third parties, we will inform them of the restriction of processing where this is possible and does not require disproportionate effort. We will of course inform you before we lift any restrictions on the processing of your personal data.
• Right to rectification: You may also request that we rectify any inaccurate or incomplete personal data we hold about you. If we have disclosed this personal data to third parties, we will inform them of the correction if this is possible and does not require disproportionate effort. If necessary, we will inform you to which third parties we have disclosed the inaccurate or incomplete personal data. If we deem it inappropriate to comply with your request, we will explain to you the reasons for this decision.
• Right to data portability: If you wish, you are entitled to transfer your data from one controller to another. This ultimately means that you can transfer the data of your account with Allectio to another online platform. For this purpose, we provide you with the data in a standard machine-readable format password-protected so that you can transmit the data to another online platform. Alternatively, we will transfer the data directly for you. The right to data portability applies to: (i) personal data that we process automatically (i.e. without human intervention), (ii) personal data that you have provided to us and (iii) personal data that we process on the basis of your consent or for the performance of a contract.
• Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the competent local supervisory authority. Details on how to contact them can be found here.
• If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data (where your consent is the legal basis for processing your personal data), here are details of how to contact us. Please note that we may keep records of your communications to better resolve any issues you raise.
• You can opt out of receiving notifications about open jobs or other of our promotional communications 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 data includes changes during the period in which we store data.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA WHEN YOU VISIT THE ALLECTIO WEBSITE?

• If you would like to know which Allectio company is responsible for the processing of your personal data and where it is located, follow this link.
• If you have any comments or suggestions about this Privacy Policy, please follow this link. We take data protection very seriously. Therefore, we will contact you as soon as possible.

HOW IS YOUR DATA STORED AND TRANSFERRED INTERNATIONALLY?

• Would you like to know more about how we store and transfer your data internationally? In order to provide you with the best possible service and to fulfill the purposes described in this Privacy Policy, your data will be transferred:
  • between the individual companies of allectio as well as within these companies,
  • to third parties (e.g. consultants or other suppliers of allectio),
  • to customers abroad, if applicable
  • to customers in their country, if applicable, who may transfer your data internationally,
  • to a cloud-based storage provider, and
  • to other third parties described herein.
• We want to ensure that your data is stored and transmitted in a secure manner. Therefore, we 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 way of transfer provides adequate protection for your data, for example:
  • by means of a data transfer agreement incorporating the current Standard Contractual Clauses provided by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection law, or
  • by signing the EU-U.S. Privacy Shield Framework for transfers of personal data from companies in the EU to companies in the United States or an equivalent agreement between other jurisdictions, or
  • the transfer of your data to a country in which there is a legally required level of data protection that has been assessed as adequate by the European Commission, or
  • where it is necessary for the conclusion or performance of a contract between us and a third party and the transfer for the purposes of that contract is in your interest (for example, where we need to transfer data outside the EEA to fulfil our obligations under that contract if you are a customer of ours), or
  • if you have given your consent for the transfer of data.
• To ensure that your personal data receives an adequate level of protection, we have implemented appropriate measures with third parties with whom we share your personal data to ensure that your personal data is processed by these third parties in a manner consistent with data protection laws and in accordance with data protection laws.

COOKIE POLICY What is a cookie?

• A "cookie" is information that is stored on your computer's hard drive and records your navigation on a website. This allows you to be offered tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for 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 so in your browser settings. We also provide you with information on this on the advertising preferences page on Allectio's website.

How do we use cookies?

• We use cookies to do two things:
  • To record your use of our website. This allows us to understand how you use the website and record patterns that develop individually or in larger groups. This helps us to develop and improve our website and services based on the wishes and needs of visitors; and
  • to show you jobs that we think will interest you. We hope you will spend less time searching through a lot of pages and find the job you want faster.
• 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 consume a website without having to log in to each individual page. However, they do not collect any information from your computer.
  • Persistent cookies: A persistent 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 visit that website again. We use persistent cookies for Google Analytics and personalization (see below).
• Cookies can also be categorized as follows:
  • Strictly necessary cookies: These cookies are necessary for you to use the website effectively, for example 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 information about you that could be used for advertising purposes or to identify which websites you have visited.
  • Performance cookies: These cookies allow us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources, and identify which parts of the site are particularly in demand.
  • Functionality cookies: These cookies allow our website to remember which options you have selected (e.g. Your username, language, or region you are in) and advanced features. For example, we may provide you with news or updates about the Services you use. These cookies can be used to remember changes you have made to the text size, font or other parts of the website that you can customize. They may also be used to provide services that 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 persistent cookies that are stored permanently (as long as you are registered with us). Therefore, you will see ads for jobs similar to the ones you looked at before when you log in or return to the site.

In the table below in Appendix 4 you will find the cookies we use, the reason why we use them and their type. OUR LEGAL BASES FOR PROCESSING YOUR DATA LEGITIMATE INTEREST

• This is regulated in Article 6 (1) f) of the GDPR: it states that we may process your data if this is "necessary for the purposes of the legitimate interests [of us] or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms [of you] which require the protection of personal data."
• We do not believe that the following activities affect any person in any way. Rather, they help us provide tailored and more efficient services to you (for example, by using personality profiling methods to personalise your experience with us and our communications with you) and are therefore beneficial to everyone involved. However, you have the right to object to the processing of your personal data by us on this basis. Information on how to do this can be found here.
• Please note that in some jurisdictions in which we operate, in certain cases, a different legal basis may apply to the processing of data. More information related to your jurisdiction can be found here.
• CANDIDATE DATA:
• We believe we can assume that you, as a candidate, consent to us collecting and/or using your personal data to provide or provide recruitment services to you, to share this information with potential employers and to match your skills with the job postings we have. If you are considered for a job, the prospective employer may wish to verify the information you have provided to us (such as the results of psychometric assessments or skills testing) or check your credentials, qualifications and police clearance certificate, where appropriate and permitted by local law. We need to do this so that we can be economically 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 in your job search. Therefore, we consider it appropriate that we process your data and use personality profiling methods to ensure that we send you appropriate content and uncover the best job opportunities for you.
• We also think that taking one of our online expert training courses or using some of our more interactive services when you have the time can help you find a job. These are part of our company's range of services and help us to stand out from our competitors in a competitive market. Therefore, it is in our legitimate interest to use your data.
• We need to ensure that our business runs smoothly so that we can continue to deliver services to candidates like you. Therefore, we must also use your data for internal administrative purposes such as remuneration and, if applicable, invoicing.
• We have our own legal obligations and it is in our legitimate interest to insist on their fulfilment. Therefore, if we believe in good faith that this is necessary, we will share your information for law enforcement or tax collection or actual or threatened disputes.
• DATA OF POTENTIAL CANDIDATES:
• We think we can assume that you are looking for job opportunities if you have posted your professional CV on a job portal or professional networking website and therefore consent to us collecting or using your personal data to assess whether we can offer or provide recruitment services to you and to contact you about these services.
• TEMPORARY WORKER DATA:
• If we employ you directly as a temporary worker, we consider that the following non-exhaustive examples of processing activities are in our legitimate interests to build a successful temporary employment relationship:
  • For our internal administrative purposes, such as facilitating payroll and invoicing procedures, if applicable to your legal system
  • Determining the conditions under which you work during your temporary employment relationship
  • Record the start and duration of the assignment, working hours during the assignment and (in certain jurisdictions) promotions, salary increases or bonuses awarded to you
  • Provide or receive feedback in connection with your use, and
  • Where applicable, to help us establish, exercise or defend legal claims.
• CUSTOMER:
• To ensure that we provide you with the best possible service, we store your personal data and/or the personal data of individual contacts within your organisation and keep records of conversations, meetings, reported jobs and job placement. Occasionally, we will also ask you to participate in a customer satisfaction survey. We believe this is appropriate and believe that this use of your information is necessary for our legitimate interests as a company providing various recruitment services to you.
• SUPPLIER DATA:
• We use and store the personal data of individuals within your organisation in order to receive services from you as one of our suppliers. We also store your financial data so that we can pay for your services. We assume that all these activities fall within the scope of our legitimate interests as recipients of your services.
• INDIVIDUALS WHOSE DATA WE RECEIVE FROM CANDIDATES AND EMPLOYEES, SUCH AS REFERENCE CONTACTS, EMERGENCY CONTACTS AND DEPENDANTS:
• If you have been designated by a candidate or prospective employee as one of their contacts for a reference, we will use your personal data to contact you for a reference. This is part of our quality assurance process, which is why we consider it necessary for our legitimate interests as a company providing recruitment services and as an employer.
• If you are asked to provide a reference based on a candidate's professional experience and we think you may be interested in becoming our client, we may also use your information to contact you through this alternative option.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. I am sure you will agree with us that this is an important element for our organisation, which is first and foremost about people, and is therefore necessary for our legitimate interests.

CONSENT

• In certain circumstances, we may need to obtain your consent to process your personal data in connection with certain activities. Depending on what exactly your data is needed for, we obtain this consent explicitly via "opt-in" or tacitly via "soft opt-in".
• Article 4(11). According to the GDPR, consent (opt-in) is "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her." Put simply, this means that:
  • you need to give us your consent voluntarily without us putting any form of pressure on you;
  • You need to know what you are giving consent to – so we will ensure that we have given you sufficient information;
  • You should have control over the processing activities to which you consent or do not consent. We provide you with these detailed controls in our Privacy Settings Center; and
  • You need to give us your consent in the form of a positive, affirmative action. We will probably provide you with a box that you will need to mark so that this requirement is clearly and unambiguously met.
• As already mentioned, in some cases consent via soft opt-in is sufficient. We may advertise products and services to you that are related to the recruitment services we provide to you, provided that you have not actively opted out of these communications.
• Please note that in some jurisdictions in which we operate, we are subject to additional local legal requirements regarding consent to receive marketing materials. More information related to your jurisdiction can be found here.
• As mentioned above, you have the right to withdraw your consent for these activities. You can do this at any time. Details on how to do this can be found here.

ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS

• Sometimes it is necessary for us to process personal data and, where appropriate and in accordance with local laws and regulations, sensitive personal data in connection with the exercise or defence of legal claims. Article 9(2)(f) of the GDPR allows this if the processing is "necessary for the establishment, exercise and defence of legal claims or if courts act in the context of their judicial activity".
• This will occur, for example, if we need legal advice in relation to legal proceedings or are required by law to retain or disclose certain information as part of the legal process.

EXERCISING OUR RIGHTS OR FULFILLING OUR OBLIGATIONS UNDER LABOUR LAW AND SOCIAL SECURITY LAW

• For some candidates, temporary workers and individuals whose personal data is provided by candidates and employees, it may be necessary for us to process your sensitive/specially categorized personal data. Article 9(2)(b) of the GDPR entitles us to do so if the processing is "necessary for … the rights [us or you] deriving from labour law and social security and social protection law can be exercised and the obligations relating thereto can be fulfilled', to the extent permitted by law.
• We process sensitive/specially categorised personal data of candidates to ensure compliance with our equality obligations where appropriate and compatible with local laws (e.g. for some candidates during the recruitment process). We will also process sensitive/specially categorised personal data of individuals who are associated with candidates or employees for other reasons, e.g. to provide the respective employee with access to certain benefits or employment rights. For more information about how we process your sensitive/special category personal data, please see "What types of personal information are collected?".
• Where we employ temporary workers directly, we process your specially categorised personal data to ensure that we comply with our equal opportunity obligations, insofar as this is in accordance with local laws. However, we may also process other parts of your specially categorised personal data for other reasons during our temporary employment relationship. For example, we may also process your medical data where appropriate and in accordance with local laws and regulations to provide you with appropriate support if you suffer from illness or disability. For example, we may share medical information about you with an occupational health professional to make a prognosis and determine reintegration arrangements, as well as to assess your ability to work more generally. We may also process certain health-related data so that we or our customers can make appropriate adjustments during the temporary employment relationship.
• Please note that certain jurisdictions in which we operate have additional rules governing our processing of your specially categorised personal data. For more information on these additional requirements in your jurisdiction, please click here.

WHERE THE PROCESSING OF YOUR PERSONAL DATA IS NECESSARY FOR US TO PERFORM OUR OBLIGATIONS UNDER OUR CONTRACT WITH YOU, TO ENSURE THAT YOU PROPERLY PERFORM YOUR OBLIGATIONS TO US AND TO ENSURE THAT WE FULFIL OUR OBLIGATIONS TO OTHERS

• The relevant basis for this is Article 6 (1) b) of the GDPR, which applies where the processing of personal data "is necessary for the performance of a contract to which [you are a party] or for the implementation of pre-contractual measures taken at [your] request".
• CANDIDATE DATA
• We may use automated decision-making to make decisions about you based on your personal data. We will only do this if it is necessary to perform a contract that you have entered into with us or one of our customers, or if it is necessary to take action that must be taken prior to entering into such a contract.
• We think we can assume that you, as a candidate, hope to enter into an employment contract and that by using our services, you will instruct us to take the necessary measures in this regard. This includes, for example, checking whether you meet certain requirements for a particular position. If the position is in high demand, we may need to check the eligibility of numerous potential candidates – so we could use automatic decision-making to reduce this pool of candidates to a more manageable number.
• Please note that in certain jurisdictions in which we operate, a different legal basis for data processing may apply in certain cases. For more information about your jurisdiction, please click here.
• TEMPORARY WORKERS
• Where we employ temporary agency workers directly, we rely on this legal basis before and during our temporary employment relationship to collect and use your personal data to perform our part of our contract with you and to fulfil our obligations to third parties and to ensure that you properly fulfil your obligations to us.
• By way of example, we may process your bank account details and name (and other verification information) through the payroll account in order to pay you under your contract. Another example is data processing for fulfillment or behavioral management in the context of our temporary employment relationship.

WHEN THE PROCESSING OF YOUR PERSONAL DATA IS NECESSARY FOR US TO COMPLY WITH OUR LEGAL OBLIGATIONS

• If we employ temporary workers directly and in relation to our obligations to you under our contract, we are also subject to other legal obligations that we must fulfil. Article 6 (1) c) of the GDPR states that we may process your personal data where such processing is "necessary for compliance with a legal obligation to which [we are subject]".
• An example of a legal obligation we need to comply with is our duty to cooperate with tax authorities, including providing details of your refund and taxes paid.

hide APPENDIX 1 Our contact details Country in which you use allectio services or provide services for allectio: Germany, Austria, Switzerland and Bulgaria allectio company responsible for the processing of personal data of visitors to our website: allectio group GmbH The processing of the personal data of candidates, customers, suppliers and the emergency contacts and contact persons for references of the candidates and employees of allectio depends on which of the following companies is the counterparty for the relevant arrangement.

• allectio group GmbH, Munich – trade register data and business information
• allectio consulting GmbH, Munich – trade register data and business information
• allectio consulting Bulgarid Ltd, Bulgaria

How to reach us:

• to access, modify or withdraw personal data that you have provided to us;
• if you suspect that your personal information has been misused, lost or accessed without authorisation;
• to withdraw your consent to the processing of your personal data (where consent is the legal basis for processing your personal data),
• comments or suggestions regarding this Privacy Policy.

Postal address: allectio consulting GmbH, Datenschutzbeauftragter/DPO, Hanns-Schwindt-Str. 8, 81829 Munich, Germany. Alternatively, you can contact our Data Protection Officer and the Data Protection Team by e-mail at: info@allectio-consulting.com. To contact us if you want to update your advertising preferences: Send us an email to: info@allectio-consulting.com or click on the unsubscribe link in any promotional email you receive from us. ANNEX 2 Contact details of the competent local supervisory authority Country in which you use Allectio services or provide services to Allectio: Germany Contact details of the competent local and international supervisory authorities: For our companies based in Bavaria, The State Commissioner for Data Protection and Freedom of Information Bavaria:

• Post: P.O. Box 22 12 19, 80502 Munich
• Email: poststelle@datenschutz-bayern.de
• Phone: (+49) 089 212672-0
• fax: (+49) 089 212672-50

For our companies based in Bulgaria.

• Post: Sofia 1592, 2 Prof. Tsvetan Lazarov blvd.
• Email: kzld@cpdp.bg
• Website: www.cpdp.bg

APPENDIX 3 Country-Specific Deviations from Our Privacy Policy Legal System : Germany Country-Specific Legal Regulation: In Germany, we collect data on candidates' religious affiliation to facilitate our compensation processes. Because required by law, we do not ask for your explicit consent to process this information. DSAR requests Under local law, we are entitled to refuse your DSAR request if your data is retained only for the following reasons: (i) because we are required by law to retain it or (ii) for the purpose of monitoring or protecting data, where it would require a disproportionate effort to provide the information and where appropriate technical and organisational measures make processing for other purposes impossible. Requests to delete your data If your data is not processed automatically, unless your data is processed unlawfully, we are not obliged to delete your data if deletion would be impossible due to the storage method used or would require a disproportionate effort, provided that we consider that your interest in deletion is minimal. If your data is processed automatically, we are also entitled to refuse the deletion of your data if we have reason to believe that the deletion is contrary to your legitimate interests, or if the deletion would violate legal obligations to store your data for a certain period of time. Instead, the processing of your data in 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 for certain marketing communications we choose to send you. The following conditions must be met in order 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 will only use this address to directly promote our own (or substantially comparable) services, (iii) you have not objected to this use, and (iv) we will clearly inform you of your right to unsubscribe in each message. For all other forms of electronic advertising, we must obtain your explicit consent via "opt-in" and keep proof that we have received that consent. In order to comply with our obligations under the Unfair Competition Act, we use a consent procedure commonly known as a "double opt-in". In doing so, we first ask for your consent to receive electronic advertising and then send you an e-mail in which we ask 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 from each other. Even if we do not assume that this unclear demarcation was intended in connection with the candidates of a personnel service provider, in case of doubt we comply with the provisions of the GDPR (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 relationships allow the processing of personal data of employees for purposes related to the employment relationship, if this is necessary for recruitment decisions or, after recruitment, for the execution or termination of the employment contract or for the rights and obligations of employees' representatives provided for by law or by collective agreements or other agreements between the employer and a staff delegation. is necessary to comply and to satisfy. Further information can be found in Section 26 of the new Federal Data Protection Act. Appendix 4 – Cookie List Cookie Name: Google Analytics The full list of cookies, which shows the purpose, the data collected and the disclosure of data, can be downloaded here. GLOSSARY

• Candidates: This term describes applicants for all positions advertised or supported by allectio or persons whom allectio reasonably considers to be interested parties for jobs, including temporary and permanent positions as well as part-time positions and freelance work with allectio's customers (including persons who wish to become temporary workers or whom allectio reasonably regards as persons who wish to do so), as well as persons who consider an unsolicited application to allectio without applying for a specific position. Individual contractors, freelancers or employees of suppliers or other third parties who are proposed for positions with customers of allectio, for example as part of an MSP offer, are also considered candidates within the meaning of this data protection policy.
• Customers: This category includes, as the term suggests, our customers, clients, clients and other parties for whom allectio provides services in the course of its business activities or whom allectio reasonably regards as persons who may be interested in our services. In certain circumstances, allectio provides services to individual employees working for client organisations, such as training for teachers working for clients in the education sector. In this context, please note that allectio requires customers to transmit the corresponding parts of this privacy policy (in particular the sections for customers) to their employees.
• Delete: In today's world, it is almost impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, as set out in this Privacy Policy, we are required by law or regulation or for risk management reasons to maintain the ability to access certain elements of personal data. However, we undertake to you that at the end of the nominal retention period of your personal data, or if we are reasonably requested by you to delete it, we will implement specific operational and system measures to ensure that your data is rendered unusable. This means that although the data is technically still available in an archive system, we ensure that neither our operating systems, nor our processes or employees can easily access it. Only an extremely (i.e. extraordinarily) small number of senior staff will be able to recover your personal data in extremely (again, extraordinarily) limited and carefully prescribed situations so that it can be accessed for such lawful purposes. Once we are satisfied that all relevant legally required retention periods have expired (although we currently expect this to be the case after a seven-year period), we move on to the next and final step and carry out a so-called "hard" deletion, after which even this extremely small number of senior staff will not be able to recover your personal data.
• General Data Protection Regulation (GDPR): A legal regulation of the European Union harmonizing European data protection law. It shall enter into force on 25 May 2018 and all references to it should be construed in such a way as to take into account related national data protection laws.
• Managed Service Provider (MSP) programs: Engaging a third-party staffing service provider to manage external employees (including freelancers, independent contractors and temporary staff) by clients.
• Other persons with whom allectio can contact: These can be emergency contacts as well as contact persons for references of candidates and employees of allectio. We will only contact these persons if this is appropriate in the circumstances.
• Potential candidates: Persons with whom allectio had not previously contacted, but considers allectio appropriately interested in its services and in particular as applicants for positions advertised or promoted by allectio, including temporary and permanent positions as well as part-time positions and freelance work with allectio's customers.
• Recruitment Process Outsourcing (RPO) Services: Entrusting a recruitment service provider with the entire recruitment process for permanent employees or part of this process.
• Colleague: This term describes current and former employees and interns who are directly involved in allectio's business (or who have accepted an offer to involve) as well as certain other workers who are or were involved in the business by providing services to allectio (even if they are not classified as employees). For these purposes, we also involve employees of allectio who work on the premises of customers under the conditions of the RPO or MSP agreements. For the avoidance of doubt, "employees" does not include private individuals who have been employed by allectio for the purpose of temporary work at the customer outside the RPO/MSP agreements. These individuals are treated in the same way as the candidates of allectio and are covered by the Privacy Policy. Similarly, independent contractors and consultants who provide services to allectio fall under the term "supplier" for the purposes of this Privacy Policy.
• Suppliers: The term refers to partnerships and companies (including sole proprietors) as well as atypical employees such as independent contractors and freelancers who provide services to allectio. Under certain circumstances, allectio subcontracts for services that the company provides to its customers to external suppliers who provide the services on behalf of allectio. In this context, suppliers who are individual contractors, freelancers or employees of suppliers are treated as candidates for data protection purposes. Please note that allectio requires suppliers to inform their employees about the relevant components of this Privacy Policy (in particular the sections on candidates).
• Systems: This term describes telephone, computer, Internet and WLAN systems, software and portals, accounts and/or networks that belong to allectio or are controlled or used by allectio to transmit, create and/or receive messages, or are otherwise used in the course of allectio's business activities, including software of candidate portals and CRM systems.
• Temporary employment relationship: Our contractual relationship with temporary workers while they are directly employed by us.
• Temporary workers: Describes a person employed by allectio to carry out temporary work for a customer. If you are a temporary worker, we will also process your personal data as a candidate during the duration of your temporary work and thereafter in accordance with the provisions of this Privacy Policy.
• Visitors to our website: All persons who access an allectio website.

Note: In order to simplify the reading flow, we have deliberately chosen certain terms such as "employment", "employer", "job", etc. and have refrained from mentioning the equivalent for project assignments of our specialists at the same time. Responsible bodies where we act as processors can be found here by our sub-processors.