§1 – INFORMATION ABOUT THE COLLECTION OF PERSONAL DATA
(1) Below, we provide information about the collection of personal data when using our website. Personal data is all data that can be related to you personally, e.g. name, address, email addresses, user behaviour.
(2) The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is medicruiter GmbH, Johannisplatz 1, 04103 Leipzig, Germany. You can contact our data protection officer, Dr Volker Wodianka, LL.M., at volker.wodianka@privacy-legal.de or at our postal address with the addition ‘the data protection officer’.
(3) If we use contracted service providers for individual functions of our offering or wish to use your data for advertising purposes, we will inform you in detail about the respective processes below. We will also specify the criteria for the storage period.
(4) Wir verarbeiten Ihre Daten grundsätzlich innerhalb der Europäischen Union bzw. des Europäischen Wirtschaftsraums. Sollte eine Übermittlung Ihrer Daten in sogenannte Drittländer erfolgen, haben wir die nach Art. 44 ff. DSGVO erforderlichen Maßnahmen getroffen, um ein geeignetes Schutzniveau zu gewährleisten.
§2 – ERHEBUNG PERSONENBEZOGENER DATEN BEI BESUCH UNSERER WEBSITE
(1) When using the website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR):
(2) In addition to the aforementioned data, if you have given us your consent, cookies will be stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and assigned to the browser you are using, and through which certain information flows to the entity that sets the cookie (in this case, us). Cookies cannot execute programmes or transfer viruses to your computer. They serve to make the Internet offering more user-friendly and effective overall.
(3) We use cookies from various providers on our website, provided that you have given your express consent to the setting of the respective cookies (legal basis: Art. 6(1)(a) GDPR). Your data will not be processed by cookies without your consent. You can give your consent via our cookie banner, which is displayed when you first visit our website. You can revoke your consent at any time with future effect. In the following, we would like to provide you with comprehensive information about cookie-based data processing.
(a) Google Analytics 4
(1) This website uses Google Analytics, a web tracking service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (‘Google’). The purpose of our use of this tool is to enable the analysis of your user interactions on websites and in apps and to improve our offering and make it more interesting for you as a user based on the statistics and reports obtained.
(2) We primarily collect information about interactions between you as a user of the website and our website using cookies, device/browser data, IP addresses and website or app activity. Google Analytics also collects your IP addresses to ensure the security of the service and to provide us, as website operators, with information about the country, region or location from which the respective user originates (so-called ‘IP location determination’). For your protection, we naturally use the anonymisation function (‘IP masking’), which means that Google truncates the IP addresses within the EU/EEA by the last octet.
(3) Google acts as a processor and we have concluded a corresponding contract with Google. The information generated by the cookie and the (usually truncated) IP addresses about your use of this website are usually transferred to a Google server in the USA and processed there. In such cases, Google has stated that it has imposed a standard that corresponds to the former EU-US Privacy Shield and has undertaken to comply with applicable data protection laws when transferring data internationally. We have also agreed so-called standard contractual clauses with Google, the purpose of which is to ensure an adequate level of data protection in third countries.
(4) The legal basis for the collection and further processing of the information (which takes place for a maximum of 14 months) is your consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time without affecting the lawfulness of the processing prior to withdrawal. The easiest way to withdraw your consent is to use our consent manager or to install the Google browser add-on, which is available at the following link: tools.google.com/dlpage/gaoptout?hl=en/
(5) For more information about the scope of Google Analytics services, please visit marketingplatform.google.com/about/analytics/terms/en/. Google provides information on data processing when using Google Analytics at the following link: support.google.com/analytics/answer/6004245?hl=en/. General information on data processing, which according to Google also applies to Google Analytics, can be found in Google’s privacy policy at www.google.de/intl/de/policies/privacy/.
b) Google Adwords Conversion
On this website, we use Google AdWords from Google LLC. to draw attention to our offers on external websites with the help of advertising material (known as Google AdWords). We can determine how successful the individual advertising measures are in relation to the data from the advertising campaigns. Our goal is to show you advertising that is of interest to you, to make our website more appealing to you and to achieve optimal calculation of advertising costs.
These advertising materials are delivered by Google via so-called ‘ad servers’. For this purpose, we use ad server cookies, which allow certain parameters for measuring success, such as the display of advertisements or clicks by users, to be measured.
If you access our website via a Google advertisement, Google Adwords will store a cookie on your computer. These cookies usually expire after 30 days and are not intended to identify you personally. The unique cookie ID, the number of ad impressions per placement (frequency), the last impression and opt-out information (indicating that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie.
These cookies enable Google to recognise your internet browser. If a user visits certain pages of an AdWords customer’s website and the cookie stored on their computer has not yet expired, Google and the customer can recognise that the user clicked on the ad and was redirected to this page. Each AdWords customer is assigned a different cookie. Cookies cannot therefore be tracked across the websites of AdWords customers. Ad server cookies usually expire after 30 days and are not intended to identify you personally.
We ourselves do not collect or process any personal data in the advertising measures mentioned. We only receive statistical evaluations provided by Google. Based on these evaluations, we can identify which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users based on this information.
Due to the marketing tools used, your browser automatically establishes a direct connection to Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: By integrating Adwords Conversion, Google receives the information that you have accessed the corresponding part of our website or clicked on our advertisement. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged into a Google service, it is possible that the provider may find out and store your IP address.
You can prevent participation in this tracking process in various ways, e.g. by adjusting your browser software settings or by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com (https://www.google.de/settings/ads), although this setting will be deleted when you delete your cookies. Furthermore, you can deactivate interest-based ads from providers that are part of the ‘About Ads’ self-regulation campaign via the link https://www.aboutads.info/choices. This setting will also be deleted when you delete your cookies. Finally, you can permanently deactivate this feature in your Firefox, Internet Explorer or Google Chrome browsers by clicking on the link https://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to use all the functions of this website to their full extent. The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as the data processor.
The transfer of data to the United States cannot be ruled out.
c) Google Dynamic Remarketing
We use ‘Google Dynamic Remarketing’ on our website, a service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland. Google Dynamic Remarketing enables us to display our advertisements to you when you continue to use the internet after visiting our website. This is done using cookies stored in your browser, which Google uses to record and evaluate your usage behaviour when visiting various websites. This allows Google to detect your previous visit to our website. According to Google, the data collected in the context of remarketing is not merged with your personal data that may be stored by Google. In particular, according to Google, pseudonymisation is used in remarketing.
We use Google Dynamic Remarketing for marketing and optimisation purposes, in particular to display relevant and interesting advertisements for you, to improve campaign performance reports and to achieve a fair calculation of advertising costs.
You can prevent cookies from being installed by deleting existing cookies and disabling the storage of cookies in your web browser settings. Please note that in this case you may not be able to use all the functions of our website to their full extent.
You can also prevent cookies from being stored by setting your web browser to block cookies from the domain ‘www.googleadservices.com’ (https://www.google.de/settings/ads). Please note that this setting will be deleted when you delete your cookies. You can also deactivate interest-based advertising via the link https://optout.aboutads.info/?c=2&lang=EN. Please note that this setting will also be deleted when you delete your cookies.
The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acting as a data processor. The transfer of data to the United States cannot be ruled out.
Further information on data usage by Google, settings and objection options, and data protection can be found on the following Google web pages:
Data Policy: https://policies.google.com/privacy?hl=de&gl=de
Google Website-Statistics: https://services.google.com/sitestats/de.html
d) DoubleClick
This website uses the online marketing tool DoubleClick from Google LLC. DoubleClick uses cookies to display relevant ads to users, improve campaign performance reports, or prevent a user from seeing the same ads multiple times. Google uses a cookie ID to track which ads are displayed in which browser and can thus prevent them from being displayed multiple times.
In addition, DoubleClick can use cookie IDs to track conversions related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later visits the advertiser’s website using the same browser and makes a purchase there. According to Google, DoubleClick cookies do not contain any personal information.
Due to the marketing tools used, your browser automatically establishes a direct connection to Google’s server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: By integrating DoubleClick, Google receives the information that you have accessed the corresponding part of our website or clicked on our advertisement. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may find out and store your IP address.
You can prevent participation in this tracking process in various ways by adjusting your browser software settings to suppress third-party cookies or by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com (https://www.google.de/settings/ads), although this setting will be deleted when you delete your cookies. In addition, you can deactivate interest-based ads from providers who are part of the ‘About Ads’ self-regulation campaign via the link https://www.aboutads.info/choices, although this setting will also be deleted when you delete your cookies. Finally, you can prevent the processing of your data by permanently deactivating it in your Firefox, Internet Explorer or Google Chrome browsers at https://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to use all the functions of this website to their full extent.
The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acting as a data processor. The transfer of data to the United States cannot be ruled out.
For more information about DoubleClick by Google, please visit https://www.google.de/doubleclick and https:/support.google.com/adsense/answer/2839090, as well as Google’s privacy policy in general: https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at https://www.networkadvertising.org.
d) Facebook Custom Audience
With your consent, we use the ‘visitor action pixel’ from Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA.
The ‘visitor action pixel’ can be used to track user actions as soon as they are redirected to a provider’s website by clicking on a Facebook advertisement.
This enables us to measure the effectiveness of Facebook advertisements for statistical and market research purposes and to optimise our marketing measures accordingly.
The data collected is anonymous to us; we cannot view any personal data relating to individual users or draw any conclusions about them.
Facebook stores and processes this data. Facebook can therefore assign this data to your Facebook account. You can enable Facebook and its partners to place advertisements on and outside of Facebook. A cookie may also be stored on your computer for these purposes.
For more information about Facebook’s collection and use of data, as well as your rights and options for protecting your privacy, please refer to Facebook’s data policy: https://www.facebook.com/about/privacy/.
You can revoke your consent. In addition, you can prevent the Facebook pixel from collecting and using your data to display Facebook ads. To set which types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions on settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
e) Hubspot
We use the inbound marketing tool ‘HubSpot’ on our website, which is provided by HubSpot Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 United States. HubSpot is a web-based all-in-one marketing software that is used to implement and manage inbound marketing.
These include, among others:
Content management (website & blog)
Email marketing (newsletters and automated mailings, e.g. to provide downloads)
Social media publishing & reporting
Reporting (e.g. traffic sources, hits)
Contact management (e.g. user segmentation & CRM)
Landing pages and contact forms
The central element of HubSpot is user-related personal profiles. A personal contact within HubSpot is created as soon as a previously anonymous website visitor fills out a form. At this point, a contact is created based on your email address. You will only be contacted if you explicitly confirm that you wish to be contacted.
Translated with DeepL.com (free version)
HubSpot is used for the purposes of individualising advertising and for market research. We have also concluded a contract with HubSpot for order processing and fully implement the strict requirements of the German data protection authorities when using HubSpot.
HubSpot’s privacy policy can be found here: https://legal.hubspot.com/de/privacy-policy.
§4 – OTHER FUNCTIONS AND SERVICES OF OUR WEBSITE
(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. To do so, you will usually need to provide additional personal data, which we will use to provide the respective service and to which the aforementioned principles for data processing apply.
(2) We sometimes use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly monitored.
(3) Furthermore, we may pass on your personal data to third parties if contracts or similar services are offered by us in conjunction with partners. You will receive more detailed information on this when you provide your personal data or in the description of the offer below.
(4) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.
(5) Google Web Fonts
This website uses so-called web fonts from Google to ensure a uniform display of fonts. When you visit a page, the required web fonts are loaded into your browser’s cache to display text and fonts correctly. We have decided to use the offline version, in which the Google fonts are stored locally on our web server. The fonts are then managed via CSS, as with any other font family. No IP addresses or other data are transferred to Google.
Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offerings, taking into account efficiency and cost-saving considerations. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the General Data Protection Regulation (GDPR). If your browser does not support web fonts, a standard font from your computer will be used.
Further information on Google Web Fonts can be found in Google’s privacy policy: https://www.google.com/policies/privacy/
§5 – USE OF SOCIAL MEDIA PLUGINS
(1) We currently use the following social media plug-ins: Facebook, Instagram, LinkedIn and YouTube.
(2) We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the providers of the plug-ins. You can recognise the provider of the plug-in by the marking on the box above its initial letter or the logo. We offer you the option of communicating directly with the plug-in provider via the button. Only when you click on the marked field and thereby activate it and agree to the use of cookies will the plug-in provider receive the information that you have accessed the corresponding website of our online offer. In addition, the data mentioned in § 3 (1) of this declaration will be transmitted.
(3) In the case of Facebook, according to the respective providers in Germany, the IP address is anonymised immediately after collection. By activating the plug-in, your personal data is therefore transmitted to the respective plug-in provider and stored there (in the case of US providers, in the USA).
(4) We have no influence on the data collected and data processing operations, nor are we aware of the full scope of data collection, the purposes of processing, or the storage periods. We also have no information about the deletion of the collected data by the plug-in provider.
(5) The plug-in provider stores the data collected about you as usage profiles and uses them for the purposes of advertising, market research and/or the needs-based design of its website. Such evaluation is carried out in particular to display needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. The plug-ins offer you the opportunity to interact with social networks and other users, enabling us to improve our offering and make it more interesting for you as a user. The legal basis for the use of the plug-ins is your consent in accordance with Art. 6 (1) (a) GDPR.
(6) Data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, the data we collect will be directly associated with your existing account with the plug-in provider. If you click on the activated button and, for example, link the page, the plug-in provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this will prevent your profile from being assigned to the plug-in provider.
(7) Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers, which are provided below. There you will also find further information on your rights in this regard and settings options for protecting your privacy.
Addresses of the respective plug-in providers and URLs with their privacy policies:
Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; https://www.facebook.com/policy.php; further information on data collection: https://www.facebook.com/help/568137493302217
Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA; https://help.instagram.com/155833707900388
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland: https://de.linkedin.com/legal/cookie-policy?
YouTube, Google Ireland Limited, Gordon House Barrow Street, Dublin 4 Irland; https://policies.google.com/privacy?hl=en
§6 – USE OF YOUTUBE
(1) This website uses the YouTube embedding function to display and play videos from YouTube. We use the extended data protection mode, which, according to the provider, only starts storing user information when the video is played. As soon as the embedded video is played, YouTube uses cookies to collect information about user behaviour.
(2) According to YouTube, these serve, among other things, to collect video statistics, improve user-friendliness and prevent abusive behaviour.
(3) Regardless of whether the embedded videos are played, a connection to the Google network ‘DoubleClick’ is established each time this website is accessed, which may trigger further data processing operations beyond our control.
§7 – CONTACT AND INITIAL CONSULTATION
(1) When you contact us by e-mail or telephone, we will store the data you provide (your e-mail address, your name and telephone number, if applicable) in order to respond to your enquiry.
(2) If you contact us via the contact form or the application questionnaire to arrange an initial consultation appointment, we collect the following data:
Interest in specific qualifications,
Information on whether nursing qualifications are available,
First and last name,
Gender,
Contact details (e-mail address and telephone number),
(3) The legal basis for this is your explicit consent to the processing of your data for the aforementioned purpose, Art. 6(1)(a) GDPR.
(4) If we arrange an initial consultation with you, we will process the above data along with the consultation date (date and time) and the content of the conversation. In doing so, we process your data to check whether the conditions for entering into an agency relationship with you are met.
Die Verarbeitung Ihrer Daten erfolgt damit zur Durchführung vorvertraglicher Maßnahmen gem. Art.6 Abs.1 S.1 lit.b) DSGVO.
(5) If the initial consultation does not result in the conclusion of a contract (agency relationship), we will continue to store your data in our applicant pool, provided you have expressly consented to this (§ 9).
§8 – USE OF APPLICANT DATA
(1) We collect and process information in both paper and digital form in order to process your application.
a) This data mainly includes:
Contact details (home address, email, telephone number),
Master data (name, academic titles, address, date and place of birth, gender, personnel number),
Marital status, children, religious affiliation and nationality,
Performance data and references (assessments),
profile data, certifications, information on school and vocational training, completed training courses for further education and training and qualifications, language skills, other qualifications such as first aid, disaster, fire and evacuation assistants,
other applicant data (application, CV, references, evidence of school and vocational training, diplomas),
Previous values of the aforementioned data (historical data).
b) In rare cases, information on health status, severe disability status and other workplace-relevant health data may also be included, insofar as this is relevant to the employment relationship.
(2) We collect, process and use your personal data exclusively for the purposes of the application process and for permissible business purposes within the scope of our business activities that are related to your application.
a) These include:
Processing applications,
Performance assessment and performance management,
Personnel administration, personnel planning, personnel management, personnel development and training,
Training, education and further training,
Professional recognition in Germany,
Compliance with legal requirements, e.g. in accordance with labour law, tax law and social security law principles,
Internal administrative and organisational purposes.
b) The legal basis for the processing of your data is Art. 6(1)(b) and Art. 88 GDPR in conjunction with Section 26 of the Federal Data Protection Act (BDSG).
c) Your data will only be processed for purposes other than those mentioned above if such processing is compatible with the purposes of the employment relationship. We will inform you of any such further processing of your data and, where necessary, obtain your consent.
(3) Your personal data will only be transferred or disclosed to external parties to the extent required by law or necessary for the fulfilment of a training contract or agency contract concluded with you (e.g. to tax and social security authorities, recognition and immigration authorities, banks, auditors, hospitals or clinics).
(4) If you are recruited, your application data will be stored for the duration of your contract with us. If no contract is concluded with us, we will retain your data in our applicant pool, provided you have given your express consent to this (§ 9).
§9 – APPLICANT POOL
At the time of your initial contact or application, you may lack certain qualifications required for our placement services. In such a case, you have the option of obtaining the relevant qualifications and then re-entering the application process.
In order to facilitate this entry and to remain in contact with you, we would like to store the above-mentioned applicant data in an applicant pool.
The legal basis for this storage is your active and informed consent in accordance with Art. 6 (1) (a) GDPR.
You can revoke your consent at any time with future effect. We will then delete your data from the applicant pool.
No data from the applicant pool will be passed on to third parties. It serves solely to make our application process more efficient and to facilitate contact with you.
We will store your data for as long as it is necessary for the above-mentioned purpose or until you revoke your consent to its storage.
§10 – PLACEMENT
(1) If the initial consultation was successful and you have the necessary qualifications for professional recognition in Germany, we will be happy to refer you to one of our many contractual partners (potential employers).
(2) For this purpose, we process the application data listed in § 8.
(3) In addition, we prepare you for everyday working life in Germany and help you obtain the necessary qualifications through training programmes provided by qualified contractual partners. As part of this programme, we collect the following information from you
Performance and examination data as well as
document attendance.
(4) Your data is processed for the purpose of providing our contractual consulting or brokerage services, Art. 6(1)(b) GDPR.
(5) For this purpose, we transfer your data to
Educational institutions whose training courses you attend (German Language Institute in the case of learning German language skills (data categories: personal details and language qualifications),
as well as to our contractual partners within the scope of our placement activities, namely clinics and hospitals (data categories: CV, evaluation summary = personality traits (motivation, performance data and examination data)).
(6) We store your data for the duration of the existing consulting or agency relationship and, in the case of data subject to statutory retention periods, beyond that.
§11 – YOUR RIGHTS
(1) You have the following rights with regard to your personal data:
Right to information,
Right to rectification or erasure,
Right to restriction of processing,
Right to object to processing,
Right to data portability.
(2) If you have given your consent to the processing of your data, you may revoke this consent at any time. Such revocation affects the permissibility of processing your personal data after you have notified us of your revocation.
(3) Insofar as we base the processing of your personal data on the balancing of interests, you may object to the processing. This is the case if the processing is not necessary to fulfil a contract with you, which is explained by us in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either cease or adapt the data processing or point out to you our compelling legitimate reasons for continuing the processing.
(4) If you have any questions regarding the processing of your data or wish to exercise your rights, you can contact us at the following email address: kontakt@privacy-legal.de.
(5) You also have the right to complain to a data protection supervisory authority about our processing of your personal data.
Status of the privacy policy: 13 January 2023
Data protection measures are subject to technical innovations. For this reason, we ask you to inform yourself about our data protection measures at regular intervals by reviewing our privacy policy.
