Data Protection Declaration
Name/Company: Needle & Haystack GmbH by headhunting for fashion (hhff) international GmbH
Street No.: Königsallee 82-84
ZIP, City, Country: 40212 Düsseldorf, Germany
Managing Directors: Frank Czernio
Phone: +49 211 13866314
Data Protection Officer: Melanie Hahne
1. Basic information on data processing and legal bases
1.2. The terms used, such as „personal data“ or their „processing“, we refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (DSGVO).
1.3. The personal data of users processed within the scope of this online offer include inventory data (e.g., names), usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form).
1.4. The term „user“ covers all categories of data subjects. These include our business partners, customers, interested parties and other visitors to our online offering. The terms used, such as „user“, are to be understood as gender-neutral.
1.5. We process personal user data only in compliance with the relevant data protection regulations. This means that user data will only be processed if a legal permission has been obtained. This means, in particular if data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, if the user has given his or her consent, as well as on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation and security of our online services within the meaning of Art. 6 Para. 1 letter f. DSGVO, in particular for range measurement, creation of profiles for advertising and marketing purposes, collection of access data and use of third-party services.
1.6. We would like to point out that the legal basis for all data collected is the legal basis for consents Art. 6 para. 1 lit. a. and Art. 7 DSGVO, the legal basis for processing for the fulfilment of our services and implementation of contractual measures Art. 6 para. 1 lit. b. DSGVO, the legal basis for processing to fulfil our legal obligations Art. 6 para. 1 lit. c. DSGVO, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. DSGVO.
2. Security measures
2.1. We take organizational, contractual and technical security measures in accordance with the state of the art in order to ensure that the provisions of data protection laws are observed and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.
2.2. The security measures include in particular the encrypted transmission of data between your browser and our server.
2.3. This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from „http://“ to „https://“ and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
2.4. If after conclusion of a chargeable contract there is an obligation to provide us with your payment data (e.g. account number for direct debit authorization), this data is required for payment processing.
2.5. Payment transactions via the common means of payment (Visa/MasterCard, direct debit) are made exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address line of the browser changes from „http://“ to „https://“ and by the lock symbol in your browser line.
2.6. In the case of encrypted communication, your payment data that you transmit to us cannot be read by third parties.
3. Passing on of data to third parties and third providers
3.1. In principle, we do not pass on any data to third party providers when you apply for jobs, on your own initiative or upon our request via our website or other channels. You transmit your data exclusively to us and are proactively informed and asked for consent before we forward your data to a company for a specific position.
3.2. If data is passed on to third parties, this shall only take place within the framework of legal requirements. We only pass on user data to third parties if, for example, this is necessary for contractual purposes on the basis of Art. 6 para. 1 lit. b) DSGVO or on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO on the economic and effective operation of our business operations.
3.3. If we use subcontractors to provide our services, we will take appropriate legal precautions as well as appropriate technical and organisational measures to ensure the protection of personal data in accordance with the relevant statutory provisions.
3.4. If content, tools or other means from other providers (hereinafter jointly referred to as „third party providers“) are used in the context of this data protection declaration and their named registered office is in a third country, it is to be assumed that data is transferred to the countries in which the third party providers have their registered office. Third countries are countries in which the DSGVO is not directly applicable law, i.e. in principle countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if an appropriate level of data protection, user consent or other legal permission is available.
4. Performance of contractual services
4.1. We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. DSGVO.
4.2. Furthermore, we process the application documents provided by the users within the scope of an application for the advertised positions on our websites as well as unsolicited applications.
4.3. The data described under 4.2. are usually CVs, certificates and personal contact data. Depending on the position, further job-specific documents can be requested.
4.4. All personal data collected within the scope of points 4.2. and 4.3. will be processed exclusively for processing the specific requests of the users concerned and stored for the duration of the request (e.g. the successful or unsuccessful completion of the specific application procedure to which the user applied).
4.5. In particular, we point out that the legal basis for the data described under 4.2. and 4.3 is the legal basis for processing to fulfil our legal obligations Art. 6 para. 1 lit. c. DSGVO and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. DSGVO are.
4.6. After completion of the request mentioned under 4.4. the user’s data will be completely deleted, except for the note of deletion. However, we reserve the right, within the framework of our legitimate interest (Art. 6 para. 1 lit. f. DSGVO), to obtain consent to the storage of the data mentioned under 4.2. and 4.3. for future appointments that match the profile of the user.
4.7. When registering, re-registering and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary to pursue our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c DSGVO.
4.8. We process usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes and job offers in a user profile in order to show the users e.g. job references based on their previously used services.
5. Comments and contributions
5.1. When contacting us (via contact form or e-mail), the user’s details will be processed for processing the contact request and its handling in accordance with Art. 6 Para. 1 lit. b) DSGVO.
5.2. User information may be stored in our Customer Relationship Management System („CRM System“) or comparable request organization.
5.3. We use the database system of our affiliatet company headhunting for fashion (hhff) international Königsallee 82-84, 40212 Düsseldorf respectively the crm system „Otris“ of the provider otris software AG, Königswall 21, 44136 Dortmund, Germany) on the basis of our legitimate interests (efficient and fast processing of user inquiries). Otris and headhunting for fashion also operates under the legal requirements of the DSGVO. otris software AG and Needle & Haystack GmbH / headhunting for fashion (hhff) international GmbH and Needle & Haystack GmbH have concluded an order processing agreement to secure your data.
6. Comments and contributions
6.1. If users leave comments or other contributions, their IP addresses will be used on the basis of our legitimate interests within the meaning of Art. 6 para. 1 letter f. DSGVO for 7 days.
6.2. This takes place for our safety, in case someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
7. Collection of access data and log files
7.1. On the basis of our legitimate interests within the meaning of Art. 6 para. 1 letter f. DSGVO data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
7.2. Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
8. Cookies & Range Measurement
8.1. Cookies are information that is transferred from our web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
8.2. We use „session cookies“ that are only stored on our website for the duration of your current visit (e.g. to enable the storage of your login status or the shopping basket function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close your browser, for example.
8.4. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
9. Google Analytics
9.2. Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
9.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services connected with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
9.4. We use Google Analytics to display advertisements placed by Google and its partners within advertising services only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that we transmit to Google (so-called „remarketing“ or „Google Analytics Audiences“). With the help of remarketing audiences we would also like to ensure that our ads correspond to the potential interest of the users and are not annoying.
9.5. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under this link. As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking this link: Click here to opt-out of Google Analytics. An opt-out cookie is set to prevent future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
9.6.We continue to use Google Analytics to evaluate data from double-click cookies and AdWords for statistical purposes. If you do not want this to happen, you can disable it using the Ads Preferences Manager at http://www.google.com/settings/ads/onweb/?hl=en.
9.7. We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
9.8. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
9.9. Further information on data use by Google, possible settings and objections can be found on the Google websites: https://www.google.com/intl/de/policies/privacy/partners („Data use by Google when using our partners‘ websites or apps“), http://www.google.com/policies/technologies/ads („Data use for advertising purposes“), http://www.google.de/settings/ads („Manage information that Google uses to show you advertising“).
10.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services („Google Marketing Services“ for short) of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“).
10.2. Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
10.3. The Google marketing services allow us to target ads for and on our site in order to present users only with ads that potentially match their interests. For example, if a user sees ads for products he has been interested in on other websites, this is referred to as „remarketing“. For these purposes, when our and other websites on which Google marketing services are active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as „web beacons“) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked on, furthermore technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of the online offer. The IP address of the users is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states of the European Economic Area Agreement and only in exceptional cases completely transmitted to a Google server in the USA and shortened there. The IP address is not combined with the user’s data within other Google offers. The above information may also be linked by Google to such information from other sources. If the user then visits other websites, the ads tailored to his interests can be displayed.
10.4. The data of the users are processed pseudonymously within the framework of the Google marketing services. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
10.5. One of the Google marketing services we use is the online advertising program „Google AdWords“. In the case of Google AdWords, each AdWords customer receives a different „conversion cookie“. Cookies cannot therefore be traced through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that personally identifies users.
10.7. We can also use the „Google Optimizer“ service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called „A/B testing“. Cookies are stored on the user’s devices for these test purposes. Only pseudonymous user data is processed.
10.8. We may also use Google Tag Manager to integrate and manage Google analytics and marketing services on our website.
10.9. Further information on Google’s use of data for marketing purposes can be found on the overview page: https://www.google.com/policies/technologies/ads, Google’s data protection declaration can be accessed at https://www.google.com/policies/privacy
10.10. If you wish to object to interest-based advertising by Google marketing services, you can use the setting and opt-out options provided by Google: http://www.google.com/ads/preferences
11. Integration of third-party services and content
11.1. Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as „content“). This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. Pixel tags“ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.
11.2. The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):
Our website uses social plugins („plugins“) of the social network facebook.com, which is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA („Facebook“). The plugins are marked with a Facebook logo or the addition „Facebook Social Plugin“. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights and setting options for the protection of your privacy can be found in the Facebook data protection information. If you do not want Facebook to collect data about you via our website, you must log out of Facebook before visiting our website.
12. Rights of Users
12.1. Users have the right, upon request and free of charge, to receive information about the personal data that we have stored about them.
12.2. In addition, users have the right to correct inaccurate data, to limit the processing and deletion of their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to file a complaint with the competent supervisory authority.
12.3. Users may also revoke their consent, in principle with effect for the future.
13. Deletion of Data
13.1. The data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal storage obligations to prevent deletion. If the user’s data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax reasons.
13.2. In accordance with statutory requirements, the records shall be kept for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).
14. Right of Objection
Users can object to the future processing of their personal data in accordance with legal requirements at any time. The objection may be lodged in particular against processing for direct marketing purposes.
15. Changes to the data protection declaration
15.1. We reserve the right to change the data protection declaration to adapt it to changed legal situations or to changes in the service and data processing. However, this only applies with regard to declarations on data processing. If user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the users‘ consent.
15.2. Users are asked to inform themselves regularly about the contents of the data protection declaration.