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Privacy Policy

Date: July 2019
 
 

I. Controller

The Controller in the meaning of the General Data Protection Regulation (“GDPR” in the following) and other national data protection laws and provisions is

 

SKILLARY GmbH
Herzogparkstr. 3
81679 Munich
Germany

Telephone: +49 (0) 173 / 3529455

Email: info@skillary.de

 

Contact details of the DPO

Proliance GmbH / www.datenschutzexperte.de
Datenschutzbeauftragter

Leopoldstr. 21
80802 München

Email: datenschutzbeauftragter@datenschutzexperte.de

II. General Information on Data Processing

Data protection is of particular significance to us. Therefore, we only collect and use personal data of our users insofar as is required to provide our content and services and a functioning website. Personal data includes all information referring to an identified or identifiable natural person (“Person Concerned” in the following).

 

The collection and use of personal data of our users is always conducted in accordance with the GDPR and the applicable national data protection laws and provisions. If the processing of personal data is required, and such processing is not allowed by statutory regulations, we always seek the consent of the Person Concerned.

 

In general, we do not transfer personal data to third parties. A transfer only takes place, if you have given your express consent (Art. 6 Sec. 1 p. 1 lit. a GDPR); if a legitimate interest in such transfer exists and there is no reason to assume that you have an overriding and legitimate interest in you data not being transferred (Art. 6 Sec. 1 p. 1 lit. f GDPR); if a transfer is necessary for compliance with a legal obligation (Art. 6 Sec. 1 p. 1 lit. c GDPR); or if a transfer is necessary for the performance of a contract to which you are a party (Art. 6 Sec. 1 p. 1 lit. b GDPR).

III. Visits on our Website

When you visit our website www.skillary.de, the browser you use automatically sends information to the server on our website. The following information are collected and stored until automatic deletion:

  • IP adress,
  • Time of the server request,
  • Referrer URL,
  • Browser type and browser version,
  • Operating system used,
  • Host name of the accessing computer.

These data are only stored temporarily in a so-called log file. Not affected by this are the IP addresses of the user or other data that allow the assignment of the data to a user. A storage of this data together with other personal data of the user does not take place. When using this data, we draw no conclusions about the person concerned.

 

The legal basis for this processing is Art. 6 Sec. 1 p. 1 lit. f GDPR. The legitimate interest in the meaning of the GDPR is providing a working website with properly delivered content, optimizing our systems and providing law enforcement with the information needed to prosecute cyberattacks. As soon as there is no legitimate interest and there is no statutory retention requirement, these data will routinely deleted.

 

In addition, we use cookies and analytics and marketing services. Further information can be found under sections IV. and V. in this privacy policy.

IV. Cookies

On our website we use cookies. Cookies are small text files automatically generated by your browser which may be saved on your terminal device. This does not mean, though, that we directly become aware of your identity.

 

On the one hand, the use of cookies serves to make the use of our offer more pleasant for you. In addition, we use cookies to optimize usability and our offer and for statistical collection.

 

We use so-called session cookies to recognize that you have already visited individual pages on our website. These cookies are automatically deleted after leaving our site. In addition, we use temporary cookies that are stored on your device for a specific period of time. Visit our page again, it will automatically detect that you were with us already and what settings and adjustments they have made in order not to have to enter it again. The data collected includes the frequency of page views, search terms entered, and the use of website features.

 

The use of cookies for the statistical recording and evaluation of our offer is described in more detail in Section V. These cookies allow us to automatically recognize when you visit our site again that you have already been with us. These cookies are automatically deleted after the expiration of the storage period of one month.

 

If you click "ok" in the cookie note displayed on our website, you authorize us to set cookies. If you click "reject" only the technically necessary cookies are set.

 

The data processed by cookies are for the purposes mentioned in order to safeguard our legitimate interests as well as third parties according to Art. 6 Sec. 1 p. 1 lit. f GDPR required. Most browsers automatically accept cookies. However, you can set your browser in a way that it does not save cookies on your computer or always a hint appears before a new cookie is created. However, disabling cookies completely may mean that you can not use all features of our website.

V. Use of Analytical Services

Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“ in the following) for the purpose of designing and continually optimizing our pages.

 

The legal basis for using the analytic tools listed below is Art. 6 Sec. 1 p. 1 lit. f GDPR. We want to ensure a needs-based design and the continuous optimization of our website. On the other hand, we use the tracking measures to statistically record the use of our website and evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as justified within the meaning of the aforementioned legal basis.

 

In this context, pseudonymised usage profiles are created and cookies (see under IV.) are used.

 

The information generated by the cookie about your use of this website such as

  • browser type / version,
  • used operating system,
  • Referrer URL (the previously visited page),
  • host name of the accessing computer (IP address),
  • time of server request,

 

are usually transmitted to a Google server in the US and stored there.

 

This information may be transferred to third parties, if required by law or as far as third parties process this data in the order. In no case will the IP address transmitted by your browser be merged with any other data provided by Google. The IP addresses are anonymized, so that an assignment is not possible (IP masking). Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

 

Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to website usage and internet usage.

 

The customer may refuse the use of cookies by selecting the appropriate settings on the browser, however, the person responsible points out to the customer that in this case the customer may not be able to use all functions of this website. In addition, the customer can prevent data generated by the cookie and relating to their use of the website (including the IP address) from being collected and processed by Google, by downloading and installing a browser plug-in from the following link: https://tools.google.com/dlpage/gaoptout?hl=en. The customer can prevent Google Analytics from collecting data by clicking on the following. An opt-out cookie is set which prevents the collection of data on future visits to this website: Disable Google Analytics. An opt-out cookie will be set to prevent future collection of your information when you visit this site. The opt-out cookie is stored on your device and is only valid in this browser and only for our website. If you delete the cookies in this browser, you must set the opt-out cookie again.

 

For more information about privacy related to Google Analytics, see the Google Analytics Help Center: https://support.google.com/analytics/answer/6004245?hl=de

 

Facebook Pixel

This website uses Facebook Pixel, a service provided by Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA (in the following: “Facebook"). Facebook Pixel allows Facebook to identify the visitors of our online content as a target group for displaying advertisement (known as “Facebook ads”).

Facebook Pixel also allows to check whether a user has been redirected to our website following a click on our Facebook ads. Among other things, Facebook Pixel uses cookies, which are small text files that are stored locally in the cache of your web browser on your device. If you are logged in to Facebook with your user account, the visit to our online content will be stored in your user account. The data collected about you are anonymous to us, so no conclusions about the identity of the users are given. However, this data from Facebook can be linked to your local user account. If you have a Facebook user account and are registered, Facebook can associate the visit with your user account.

We use Facebook Pixel for marketing and optimisation purposes, especially to bring you relevant and interesting ads on Facebook, thus improving our offer, making it more interesting for you as a user and avoiding annoying ads. This also presents our legitimate interest in the processing pursuant to Art. 6 para. 1 lit. f GDPR.

You can object to the before mentioned collection of your data by Facebook Pixel and the use of your data by Facebook Ads. You can set which type of ads shall be displayed by Facebook on the following Facebook website: https://www.facebook.com/settings?

Furthermore has Facebook been certified under the Privacy Shield Agreement and therefore offers a guarantee of compliance with European data protection laws. Further information can be found in the following linked entry: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

 

Information about the third-party: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). For further information about the collection and use of data by Facebook and your privacy protection rights and options, please see the Facebook data protection policy at https://www.facebook.com/about/privacy/update. For specific information and details about Facebook Pixel and how it works, please visit the Facebook help section at https://www.facebook.com/business/help/651294705016616. You can disable this function as shown at https://de-de.facebook.com/business/help/1415256572060999?helpref=uf_permalink or at https://www.facebook.com/settings?tab=adsYou must be logged into Facebook to do this.

 

VI. Contact via our website

Due to legal regulations, our website contains information that enables us to contact our company quickly (in particular e-mail address). If you contact us by e-mail, your voluntarily transmitted personal data will be automatically stored for the purpose of processing or contacting you. A transfer of these data does not take place.

 

The data will be deleted if there is no statutory retention period and if they are no longer required to fulfill the contract or to initiate a contract. The legal basis for the processing of the data transmitted in the course of sending an e-mail is Art. 6 Sec. 1 p. 1 lit. f GDPR. The legitimate interest within the meaning of the GDPR is the processing and answering of your contact.

 

The data will be deleted as soon as it is for the purpose, this is the case when the respective conversation with the user is finished. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified.

 

You have the opportunity to object to the storage of your personal data at any time. For this purpose, please contact the person named in I. (in writing, by email or by telephone). The data from the previous communication is then deleted.

VII. Contact form

Users of our website have the opportunity to contact us via a contact form. If you take this option, the data given in the input screen will be transmitted to us and saved. These data are:

  • Name,
  • Email adress,
  • Company name,
  • personal data in the message.

The legal basis for this data processing is Art. 6 Sec. 1 p. 1 lit. a GDPR. For the processing of this data, your consent is obtained as part of the submission process and reference is made to this privacy policy. Sending the contact form without this declaration of consent is not possible. Alternatively, contact via the provided e-mail address is possible. In this case, the user's personal data transmitted by e-mail will be stored.

We only need the collected data to answer your contact request. Any further use or disclosure of this data will not take place.

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. For the personal data from the input form of the contact form, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified.

If the contract request results in a contract or contract initiation, the legal basis for further data processing is Art. 6 Sec. 1 p. 1 lit. b GDPR.

You have the opportunity to withdraw your consent to the processing and storage of your data at any time with effect for the future. For this purpose, please contact the controller named in I. (in writing, by e-mail or by telephone). The data from the previous communication is then deleted, another conversation is no longer possible without renewed consent.

VIII. Newsletter

By subscribing to our newsletter, you agree to the following notices regarding registration, sending and statistical evaluation procedures as well as your right of withdrawal.

 

If you sign up for our newsletter via our website, the data given in the input screen will be sent to us and saved. These data are:

  • Name,
  • Email address.

At the time of the registration, the following data are also stored

  • Date and time of the server request.

The legal basis for this data processing is Art. 6 Sec. 1 p. 1 lit. a GDPR. For the processing of this data, your consent is obtained as part of the submission process and reference is made to this privacy policy. Following the registration on our website, you will receive an Email confirming that you have to click on a link to confirm your subscription to the newsletter. If the link in this email is not clicked within 24 hours, your data will be deleted. This ensures that no one can sign up with an email address to which he has no access.

 

In accordance with the legal requirements, the newsletter registrations are logged by saving the registration and confirmation times. This data processing is based on Art. 6 Sec. 1 p. 1 lit. f GDPR instead. Our legitimate interests are the prevention of misuse of the registration form and the ability to prove registration.

 

These data will be forwarded to and processed by the platform “MailChimp” of the company Rocket Science Group, LLC, 675 Ponce De Leon Ave NE, Suite 5000. Atlanta, GA 30308, USA („MailChimp“ in the following). Through MailChimp’s certification in the US-EU Privacy Shield and the conclusion of a contract as a processor with us, MailChimp is committed to adhering to EU privacy standards and to providing the data in accordance with MailChimp’s Privacy Policy on our behalf to process.

 

To improve and understand our customers' interests, the newsletter includes a "web-beacon", a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. This retrieves technical data such as the IP address and information about the browser and system used. In addition, it is recorded if and at what time the newsletter is opened and which links are clicked on.

 

The aim of these analyzes is to better understand the reading habits of the users and to constantly improve the content of the newsletter and make it more interesting. The information can be technically assigned to individual subscribers, but it is neither in ours nor in the interest of MailChimp to monitor individual users. Our legitimate interest is exclusively collecting statistical values.

 

The logging of the registration procedure, the collection and evaluation of the statistical data as well as the use of MailChimp are carried out on the basis of our legitimate interests acc. Art. 6 Sec. 1 p. 1 lit. f GDPR. Our interest is a user-friendly and secure newsletter that meets the needs of users while serving our business interests, as well as preventing misuse of our offerings.

 

Users have the opportunity to withdraw their consent to the processing and storage of the data at any time with effect for the future. For this purpose, please contact the controller named in I.

 

(in writing, by email or by telephone) or use the "unsubscribe link", which you will find at the end of each newsletter.

IX. Registration - Creating a user account as a talent

You have the opportunity to register on our site and create a user profile in order to present your industry-specific skills and experience in a topic-oriented and precise manner. We collect and use the following personal data as part of the registration and setup process:

  • First name and surname
  • email address

Your user account gives you the opportunity to use other parts of our website and to log in for the offers you have subscribed to.

After the registration, information can be provided in the questionnaire voluntarily (e.g. about your personality; your professional background; objectives pursued).

Our aim is to develop your career in the long term and connect you with suitable companies. It does not matter whether you are currently looking for a job or not. Furthermore, the SKILLARY platform keeps you up to date when companies are looking for new profiles. For this purpose, Skillary GmbH may contact the talents by telephone or e-mail to suggest companies to the talents that match their profile. Searching companies only see your skill set in case of a match. In the event of a match, you remain free to pass on further data to the requesting company. 

The legal basis for the data processing is Art. 6 para. 1 lit. b GDPR, as the processing is necessary for the performance of a contract.

 

Your data will be deleted as soon as the user account on our website is deleted and as long as there are no legal storage obligations. As a rule, you can change and/or delete your user account, including the data you have entered, directly in your user account after logging in or by sending a corresponding message to the controller named in the introduction. The user account will be deleted at the latest 2 years after inactivity of your profile.

 

X. External links

Social networks (Facebook, Instagram and LinkedIn) are only included on our website as links to the corresponding services. After clicking on the integrated text/image link, you will be redirected to the page of the respective provider. User information will only be transferred to the respective provider after forwarding. For information on how to handle your personal data when using these websites, please refer to the respective data protection regulations of the providers you are using.

 

XI. Rights of the data subject

As the Person Concerned (= data subject) you have the following rights against the Controller. If you wish to assert any of such rights, please contact the Controller under the contact details mentioned in I.

1. Right of access (Art. 15 GDPR)

You have the right to obtain information from the Controller on whether or not personal data concerning you are being processed.

 

Where that is the case, you may obtain from the Controller access to the personal data and information on the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from you, any available information as to their source; the existence of automated decision-making, including profiling, referred to in Art. 22, Sec. 1 and 4 GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing to you; information on the transfer of personal data to a third country or to an international organization, and the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer.

2. Right to Rectification (Art. 16 GDPR)

You have the right to obtain from the Controller without undue delay the rectification and/or completion of personal data concerning you that is incorrect or incomplete.

3. Right to Erasure (Art. 17 GDPR)

You have the right to obtain from the Controller the erasure of personal data stored by us, if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; if you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; if you object to the processing pursuant to Art. 21, Sec. 1 and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21, Sec. 2; if the personal data have been unlawfully processed; if the personal data have to be erased for compliance with a legal obligation; or if the personal data have been collected in relation to the offer of information society services referred to in Art. 8, Sec. 1 GDPR.

 

This right to erasure does not apply to the extent that processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; for reasons of public interest; or for the establishment, exercise or defence of legal claims.

4. Right to Restriction of Processing (Art. 18 GDPR)

You have the right to obtain from the Controller restriction of processing, if the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data; if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; if the Controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or if you have objected to processing pursuant to Art. 21 Sec. 1 GDPR, pending the verification whether the legitimate grounds of the Controller override those of you.

 

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

 

If you have obtained restriction of processing, you shall be informed by the Controller before the restriction of processing is lifted.

5. Right to Data Portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

6. Right to Object

Insofar as your personal data are processed on the basis of legitimate interests in accordance with Art. 6 Sec. 1 p. 1 lit. f GDPR, you have the right to object such processing of your personal data on grounds relating to your particular situation. If your objection is directed against direct marketing, you have a general right to object which we will implement without you being required to submit grounds relating to your particular situation

7. Right to Withdraw Consent (Art. 7 Sec. 3 GDPR)

You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

8. Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

You have the right to lodge a complaint with a supervisory authority. You may address the supervisory authority of your habitual residence or place of work, or the supervisory authority concerned with us.

XII. Data Security

To protect your data, we use the SSL (Secure Socket Layer) method on our website, combined with the highest level of encryption supported by your browser. Whether a single page of our website is transmitted in encrypted form is indicated by the closed presentation of the key or lock symbol in the status bar of your browser.

 

Incidentally, we use appropriate technical and organizational security measures to protect your data against manipulation, loss, destruction or against unauthorized access by third parties.

XIII. Currency and Amendment of this Privacy Policy

This Privacy Policy is currently applicable in its version from July 2019. A further development of our services and website or amended statutory regulations may make it necessary to amend this Privacy Statement in the future.