Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting

We are hosting the content of our website at the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host(s):

maxcluster GmbH
Lise-Meitner-Str. 1b
D-33104 Paderborn

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Sport-Thieme GmbH
Helmstedter Straße 40
38368 Grasleben

Phone: 05357/18190
E-mail: info@sport-thieme.de

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer.

Sport-Thieme GmbH
z.Hd. Abteilung Datenschutz
Helmstedter Straße 40
38368 Grasleben

Phone: 05357/18190
E-mail: datenschutz@sport-thieme.de

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Real Cookie Banner

Our website uses Real Cookie Banner’s consent technology to obtain your consent for the storage of certain cookies on your device or for the use of specific technologies and to document the former in a data protection compliant manner. The provider of this technology is devowl.io GmbH, Tannet 12, 94539 Grafling, Germany (hereinafter referred to as “Real Cookie Banner”).

Real Cookie Banner is installed locally on our servers, which ensures that a connection with Real Cookie Banner provider’s servers is not established. Real Cookie Banner stores a cookie in your browser to be able to allocate the consent you have granted or revoked. The data recorded in this manner will be stored until you ask us to delete them, revoke your consent to the archiving of your data or until the purpose of archiving the data no longer exists (e.g., upon completion of the processing of your inquiry). This does not affect mandatory statutory provisions – in particular those governing retention periods.

We use Real Cookie Banner to obtain the consent required by law for the use of cookies from site visitors. The legal basis for this is Art. 6(1)(c) GDPR.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

5. Analysis tools and advertising

Matomo

This website uses the open-source web analysis service Matomo.

Through Matomo, we are able to collect and analyze data on the use of our website-by-website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser, and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

IP anonymization

For analysis with Matomo we use IP anonymization. Your IP address is shortened before the analysis, so that it is no longer clearly assignable to you.

Analysis without cookies

We have configured Matomo in such a way that Matomo will not store cookies in your browser.

Hosting

We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.

6. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.

Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

7. Plug-ins and Tools

YouTube with expanded data protection integration

This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user’s browser, which contain personal data similar to cookies and can be used for recognition. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing operations may be triggered over which we have no influence.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

8. Privacy information for job applications

We offer you the opportunity to apply for a position with us (for example by email, post or via our online application form). Below, we explain the scope, purpose and use of the personal data collected during the application process. We assure you that all data is collected, processed and used in accordance with applicable data protection laws and other legal requirements, and that your information is treated with strict confidentiality.
Thank you for your interest in our company and for applying, or having applied, for a position with us.

Who is responsible for data processing?

The data controller within the meaning of data protection law is:

Sport-Thieme GmbH
Helmstedter Straße 40
38368 Grasleben
Germany

Further information about our company, details of authorised representatives and additional contact options can be found in the legal notice on our website:
View legal notice

Scope and purpose of data collection

When you submit an application, we process the personal data associated with it (such as contact and communication details, application documents and notes taken during interviews) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this processing is Section 26 (1) of the German Federal Data Protection Act (BDSG) (initiation of an employment relationship) and Article 6 (1) (b) GDPR (pre-contractual measures), and – where consent has been given – Article 6 (1) (a) GDPR. Consent may be withdrawn at any time.

Within our company, your personal data is shared only with those individuals involved in processing your application.

If your application is successful, the data you submit will be stored in our data processing systems for the purpose of carrying out the employment relationship, based on Section 26 (1) BDSG and Article 6 (1) (b) GDPR.

If, after completion of the application process, data is required for legal enforcement purposes, processing may take place on the basis of Article 6 GDPR, in particular Article 6 (1) (f) GDPR (legitimate interests). Our legitimate interest in this case is the assertion or defence of legal claims.

Where you have consented to the collection, processing or transfer of certain personal data, such processing is carried out on the basis of your consent in accordance with Article 6 (1) sentence 1 (a) GDPR in conjunction with Section 26 (2) BDSG.

How long is the data stored?

If we are unable to offer you a position, if you decline an offer or if you withdraw your application, we reserve the right to retain the data you have provided for up to six months after the end of the application process (rejection or withdrawal), based on our legitimate interests under Article 6 (1) (f) GDPR. After this period, the data will be deleted and any physical application documents destroyed. This retention period primarily serves evidentiary purposes in the event of legal disputes.

If it is evident that the data will be required beyond the six-month period (for example due to an impending or ongoing legal dispute), deletion will take place only once the purpose for continued retention no longer applies.

Data may be stored for a longer period if you have given your consent (Article 6 (1) (a) GDPR) or if statutory retention obligations prevent deletion.

To whom is the data disclosed?

We use a specialised service provider for applicant management, softgarden e-recruiting. This provider acts as a processor on our behalf and may, in connection with the services offered (such as system maintenance and support), gain access to personal data. We have concluded the necessary data protection agreements to ensure that processing is carried out lawfully.

After receipt of your application, your data is reviewed and assessed internally by the managers responsible for the respective position. The further process is then coordinated with the HR department. Within the company, only those persons who require access for the proper conduct of the application process are granted access to your data.

Applications via softgarden e-recruiting

If you apply to Sport-Thieme via the online application tool softgarden e-recruiting, the following additional information applies:

We use the softgarden e-recruiting online tool to facilitate the digital application process. By clicking on a job posting, you leave the Sport-Thieme website and are redirected to the website of softgarden e-recruiting GmbH, Tauentzienstr. 14, 10789 Berlin, Germany.

softgarden e-recruiting GmbH provides the software used to process application data and processes personal data on behalf of Sport-Thieme GmbH within the meaning of Article 4 (8) GDPR.

softgarden processes and analyses uploaded documents in order to extract CV data. This processing takes place within softgarden’s infrastructure and is not transferred to third parties. The primary legal basis is Article 6 (1) (b) GDPR.

Where you have given consent for the processing or transfer of certain personal data, this is carried out on the basis of Article 6 (1) sentence 1 (a) GDPR in conjunction with Section 26 (2) BDSG.

During the application process, you may optionally create an account in the softgarden career portal to view and manage your application. You will receive an automatically generated email with instructions to create the account. You can access your account at
Sign in to the softgarden career portal.
Creating an account is optional and not required to apply to Sport-Thieme.

Further information on data processing by softgarden can be found here:
softgarden privacy policy

CV analysis using Textkernel

Our applicant management system softgarden uses AI technology to process and analyse uploaded documents in order to extract CV data and convert it into a structured format (“CV parsing”).

To safeguard data subject rights and security standards, softgarden has concluded a data processing agreement with the service provider Textkernel B.V., Nieuwendammerkade 26 A 5, 1022AB Amsterdam, Netherlands, which is ISO 27001 certified. Processing takes place on a server located in Germany within a secure environment.

The legal basis is Article 6 (1) (b) GDPR and Article 6 (1) (f) GDPR, to initiate an employment relationship and make the application process as efficient as possible. No personal data is transferred to unsafe third countries. Your data is deleted from Textkernel’s temporary storage after processing.

Subscription to job listings (“job alerts”)

To stay informed about new vacancies, you may subscribe to job alerts via softgarden or view suitable positions on our career board (RSS feed). You can specify preferences such as role and location.

An email address is required to subscribe. The legal basis is your consent to receive the newsletter under Article 6 (1) (a) GDPR. You can withdraw your consent at any time using the unsubscribe link included in each email.

No personal data is processed via the RSS feed itself.

Social share buttons

You may share job postings from softgarden on various social networks using the available share buttons. Clicking a button redirects you to the respective network’s login page. These buttons are not plug-ins and do not automatically transmit personal data to social network operators.

Job postings can currently be shared on the following platforms:

• Facebook – Facebook privacy information
• X – X privacy policy
• LinkedIn – LinkedIn privacy policy
• Xing – Xing privacy policy

The legal basis is Article 6 (1) (f) GDPR for statistical analysis and reach measurement of job postings. We have no influence on how these social networks process your personal data.

Online surveys (“easyfeedback”)

At the end of the application process, you may receive an invitation via softgarden to participate in a survey conducted using a service provided by easyfeedback GmbH. The purpose is to gather feedback on the application experience.

softgarden acts as the data controller within the meaning of Article 4 (7) GDPR and processes the survey data anonymously for its own purposes (statistics, analysis and product development). Data transmission is secured using SSL encryption, and no personal reference is established during evaluation.

Participation is voluntary and may be discontinued at any time. By participating, you consent to the processing under Article 6 (1) (a) GDPR. Further information can be found here:
easyfeedback privacy policy

Talent pool

As part of your application or via the “Get in touch” option, you may choose to join our talent pool. This allows us to consider you automatically for future vacancies that match your profile.

When registering via “Get in touch”, the following information may be requested:

• Salutation, academic title (optional)
• First and last name, email address
• Areas of professional interest
• Current career level
• Preferred location(s)
• XING profile or CV

Inclusion in the talent pool is voluntary and requires your explicit consent via an opt-in link. The legal basis is Article 6 (1) (a) GDPR.

Appointment scheduling (“Cronofy”)

We use an integrated service provided by Cronofy Limited, 9a Beck Street, Nottingham, NG1 1EQ, UK, for appointment scheduling and invitations.

If we invite you to an interview using this function, you will receive a calendar invitation generated via Cronofy. Your email address, appointment title, description and location will be transmitted. No further personal data is shared.

Processing is based on Article 6 (1) (f) GDPR, reflecting our legitimate interest in efficient appointment coordination. Data processing takes place on encrypted servers in Germany. Appropriate security standards have been contractually agreed and verified. Further details are available here: https://cronofy.com

If you do not wish to use Cronofy, you may object in advance of scheduling.

Transfer of application status information

If you apply via a job board (for example Hellowork or StepStone), the data you submit is automatically transferred to our recruiting system.

Some job boards allow you to track your application status in your account. In such cases, our service provider softgarden e-recruiting GmbH transmits the status of your application (receipt, processing, rejection) to the job board on our behalf. This information is displayed with a delay of up to four weeks to ensure we can inform you personally first.

The legal basis is Article 6 (1) (b) GDPR. Further details can be found in the privacy notices of the respective job board.

Recruiting via instant messaging

You may also submit your application via WhatsApp. If you choose this option, the data you enter and all messages sent during the chat are processed by WhatsApp.

Details on data processing can be found in WhatsApp’s privacy policy. We have no influence over how messaging services process data. Messaging services are technically connected to our recruiting system via specialised providers.

During a transitional technical phase until the end of May 2026, applications submitted via WhatsApp may be processed via either MessengerPeople GmbH or 360dialog GmbH. From 1 June 2026 onwards, processing will be handled exclusively by 360dialog GmbH.

360dialog does not store message content or media files. Only technical message logs (such as message ID, sender, recipient and delivery status) may be processed for operational purposes.

Please avoid sending special categories of personal data within the meaning of Article 9 GDPR (for example health data or information on severe disability) or extensive application documents via WhatsApp. Use alternative application channels instead.

The legal basis for using WhatsApp as an additional communication channel is your consent under Article 6 (1) (a) GDPR. You may withdraw consent at any time by notifying us.

Application data transferred to our recruiting system is processed to initiate an employment relationship under Article 6 (1) (b) GDPR in conjunction with Section 26 (1) BDSG. If you do not wish your data to be transmitted to WhatsApp, please use alternative application options.

Personal data may be transferred to locations outside the EU where legally permitted. If no adequacy decision exists, EU standard contractual clauses are used as appropriate safeguards.

You may cancel the application process at any time by entering “/cancel” in the chat. All data entered up to that point will be deleted. Deletion of messenger application data can also be requested via the link provided during the application process.

If your application has been successfully transferred to our recruiting system, interview data will be deleted by MessengerPeople after 180 days, where applicable. The general retention rules in section 8.3 apply to data stored in our recruiting system.

Automated application matching

After submission, your application is automatically evaluated using AI technology. This involves checking how closely your profile matches the requirements of the advertised position.

If a high level of match is identified, your application is highlighted as a “KI-Match” in our recruiting software softgarden. This classification does not result in automated decisions or rejections. Applications without a KI-Match remain fully visible and are reviewed as usual. The function is intended solely to support recruiters by providing a clearer overview.

The legal basis is our legitimate interest in an efficient recruiting process under Article 6 (1) (f) GDPR. The AI system is operated and developed by our processor softgarden e-recruiting GmbH. No personal data is shared with additional recipients. Deletion follows the standard retention periods described in section 8.3.

Where is the data processed?

All data is processed exclusively in data centres located in the Federal Republic of Germany.

Your rights as a data subject

You have the right to request information about the personal data we process about you. If a request is not made in writing, we may ask for proof of identity.

You also have the right to rectification, deletion or restriction of processing, insofar as permitted by law. In addition, you have the right to object to processing within the statutory framework and the right to data portability.

Our data protection officer

We have appointed an external data protection officer. You can contact them at:

Christopher Schewior
Email: dsb-sport-thieme@intersoft-consulting.de
intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg
Germany

Right to lodge a complaint

You have the right to lodge a complaint with a supervisory data protection authority regarding our processing of your personal data.