Privacy Policy

This policy explains how personal data is handled when you use this website or contact us. It is a working skeleton and must be reviewed by a qualified data protection adviser before launch.

Last updated: {{DATE}}

1. Controller

The controller responsible for data processing on this website is the provider named in the Impressum.

{{CONFIRM whether a data protection officer must be appointed; if so, add name and contact here.}}

2. Hosting

This website is hosted on Cloudflare Pages. Cloudflare, Inc. may process server log data (including IP address, request time, browser and operating system) as a processor on our behalf to deliver and secure the site.

{{CONFIRM the Cloudflare data processing agreement is in place and reference it here. Confirm whether Cloudflare Web Analytics is enabled and, if so, describe it.}}

3. Server log files

When you access the site, technical access data is processed automatically. The legal basis is our legitimate interest in the secure and stable operation of the website (Art. 6 (1)(f) GDPR).

4. Contact by email

If you contact us by email, the data you provide is processed to handle your enquiry. Email routing is handled through Cloudflare Email Routing and delivered to a mailbox hosted by Zoho.

The legal basis is Art. 6 (1)(b) GDPR where your enquiry relates to a contract or pre-contractual steps, and Art. 6 (1)(f) GDPR otherwise. Data is deleted once it is no longer required and no retention obligations apply.

5. Applicant and candidate data

If you send us a CV or candidate information, we process it to assess a possible placement. {{DESCRIBE at a high level the categories of data processed for candidates, retention period, and whether and how data is shared with client employers. Do NOT describe verification method here.}}

The legal basis is Art. 6 (1)(b) GDPR and, for verification of information relevant to a placement, Art. 6 (1)(f) GDPR. {{CONFIRM lawful basis and any consent text with legal review.}}

6. Transfers outside the EU/EEA

Some processors may be located outside the EU/EEA. {{LIST processors and the transfer mechanism relied on, e.g. EU Standard Contractual Clauses. Confirm with legal review.}}

7. Your rights

You have the right to access, rectification, erasure, restriction of processing, data portability, and to object to processing. Where processing is based on consent, you may withdraw it at any time with future effect.

You also have the right to lodge a complaint with a supervisory authority. {{ADD the competent supervisory authority once the registered address is known.}}

8. Changes to this policy

We update this policy when our processing changes or when required by law. The current version is always available on this page.

Skeleton, not legal advice. Have it reviewed by a qualified data protection adviser before launch.