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Privacy Policy

This English translation is provided for convenience only; the German version is the legally binding one.

Thank you for visiting our website and for your interest in our services.

We, Emerge Tech GmbH, Scharnhorststraße 24, 10115 Berlin (hereinafter “Emerge Tech” or “we” / “us”), offer a powerful AI solution for skilled-trades businesses (Handwerksbetriebe) to recruit and retain employees and to optimise their employer positioning (“Service”).

When you visit our website and use our Service, your personal data may be processed by us.

The protection of your data is important to us, and with this privacy policy we would like to inform you, in accordance with Art. 13 of the General Data Protection Regulation (“GDPR”, Datenschutzgrundverordnung, DSGVO), how we handle your personal data (hereinafter also “data”).

Last updated: 5 April 2026

A. Definitions

Our privacy policy is intended to be easy to read and understand for visitors and users of our website as well as for our customers and prospective customers. To ensure this, we would like to explain the most important terms. In this privacy policy we use, among others, the following terms:

  • “personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject” or “affected person”), e.g. name, address, email addresses, user behaviour;

  • “processing” means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

  • “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

  • “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

  • “profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

B. Controller

Unless otherwise specified in this privacy policy, the controller for the data processing is:

Emerge Tech GmbH

Scharnhorststraße 24

10115 Berlin

info@emerge-tech.io

Any data subject may contact the controller directly at any time with any questions and suggestions regarding data protection.

C. Processing activities

I. Provision of our Service

1. Data you provide to us

In the context of our contractual, quasi-contractual or pre-contractual business relationship, i.e. if you are already our customer or are interested in such a business relationship (“contractual partner”), we process the following data, insofar as necessary:

  • General personal data (e.g. surname, first name) and (business) contact data (e.g. address, email address, telephone number) of the contact persons

  • Payment data and billing information (e.g. bank details, payment history)

  • Contract data (e.g. services used, contract contents, contract term, contractual communication, names of contact persons).

As part of our Service, we offer you the possibility to optimise advertising and job advertisements via third-party providers such as Facebook, LinkedIn, Google Ads and similar platforms. To provide these services, it may be necessary for us to pass on customer data, including personal data, to these third-party providers.

The data is processed for the following purposes:

  • To communicate with you,

  • To answer your enquiries,

  • To establish and fulfil our contractual obligations,

  • To comply with our legal obligations,

  • To protect our rights,

  • To perform administrative tasks,

  • To support our business organisation.

The legal bases for processing your data are therefore Art. 6 para. 1 sentence 1 lit. b GDPR for the performance of the contract and pre-contractual enquiries, Art. 6 para. 1 sentence 1 lit. c GDPR with regard to compliance with legal obligations, and Art. 6 para. 1 sentence 1 lit. f GDPR to protect our legitimate interests.

2. Processing of data in the context of the use of our Service

When using our Service, in particular in the context of applicant management, customers have the possibility to record and process a wide range of personal data of applicants (e.g. CV, name, telephone number, contact information, professional qualifications, work preferences, application status).

As a rule, we store and process personal data on behalf of our customers as a processor pursuant to Art. 28 GDPR. Our customers are responsible for compliance with all applicable data protection laws and regulations, in particular for the lawful collection and processing of the personal data. This also includes the information obligations towards data subjects, in particular applicants, and obtaining any necessary consents, insofar as required by law.

If you have questions about the personal data we process on behalf of a customer, please contact the customer directly and read their privacy notice.

II. Visiting our website and using our online offering

1. Website visit

When you use the website for information purposes only, i.e. merely view it without otherwise providing us with information, we process the following personal data that your browser transmits to our server:

  • IP address

  • Date and time of the request

  • Time zone difference to Greenwich Mean Time (GMT)

  • Content of the request (page visited)

  • Access status/HTTP status code

  • Amount of data transferred in each case

  • Previously visited page

  • Browser type

  • Operating system used

  • Language and version of the browser software

  • Host name of the accessing computer.

This data is technically necessary for us to display our website to you and to ensure its stability and security, and must therefore be processed by us. The legal basis for this is Art. 6 para. 1 sentence 1 lit. f GDPR.

2. Registration and login

To use our Service, customers must register or log in on our website. This requires the entry of data (e.g. email address, name, password). You will be informed of the mandatory information required during the registration process.

When you use our registration and login functions and when you use the Service, we store the IP address and the time of the respective user action. The storage is based on our legitimate interest and the interest of our users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless this is necessary to pursue our claims or there is a legal obligation to do so.

The processing in the context of registration is carried out to perform or initiate a contract, to provide the Service, to manage or answer enquiries and as a security measure (legal bases: Art. 6 para. 1 sentence 1 lit. b GDPR: performance of the contract and pre-contractual enquiries; Art. 6 para. 1 sentence 1 lit. f GDPR: legitimate interests).

3. Cookies

We use cookies in some areas of our website. Cookies are small text files that are stored by the browser on your device (e.g. computer, tablet or mobile phone) when you visit a website and that can be read by us or a third-party provider. They serve to identify your device for a certain period of time.

Some of the cookies we use are so-called “session cookies”, which are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognise your browser on your next visit.

Some cookies are necessary for the use of our website. These cookies are not used for analysis, tracking or advertising purposes. These cookies are essential for user guidance, security and the operation of the website. We use these cookies on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR and § 25 para. 2 of the Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, TDDDG) to ensure basic functions of the website.

You can set your browser so that you are informed about the placement of cookies, which makes the use of cookies transparent for you. You can also delete cookies at any time via the corresponding browser setting and prevent new cookies from being set. Please note, however, that this may mean that our website can no longer be displayed and some functions are technically no longer available.

In addition, on the basis of your consent, we also use cookies that are not strictly technically necessary. This processing takes place only after your express consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR and § 25 para. 1 TDDDG. If you would like to manage your consent or obtain further information about the cookies used on our website, click on our cookie banner.

4. Contacting us

When you contact us (e.g. online contact form, email, telephone or via social media) and in the context of an existing customer relationship with us, your data is processed insofar as this is necessary to answer your contact request and any measures requested.

Regardless of the chosen means of communication, we collect the content of your enquiry (e.g. first name and surname, email address, telephone number, availability, reason for your enquiry). We process your data for the following purposes: individual communication with you, management and answering of enquiries, provision of our online offering and user-friendliness.

We process your data to protect our legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR in appropriately answering contact requests. If you are seeking information about our Service or have questions about an existing contractual relationship with us, the processing is carried out to take pre-contractual measures or to perform a contract pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR. If you have consented to the storage of your data, Art. 6 para. 1 sentence 1 lit. a GDPR is the legal basis. In this case, you can withdraw your consent at any time with effect for the future.

III. Disclosure of data to third parties

As a matter of principle, we do not pass on your personal data to third parties unless this is necessary for the performance of the contract, due to a legal obligation or to protect our legitimate interests, or you have expressly consented to the disclosure. Your data is passed on to third parties in the following cases:

  • For the performance of the contract: We pass on your data to third parties insofar as this is necessary to provide the services you have requested, e.g. to third-party providers such as Facebook, LinkedIn, Google Ads and similar platforms (see above), hosting providers, payment service providers or IT support.

  • To protect legitimate interests: If this is necessary to protect our legitimate interests, we may pass on your data to third parties, e.g. to enforce our claims, to prevent fraud or to carry out security measures.

  • Legal obligation: We may pass on your personal data to third parties if we are legally obliged to do so, e.g. supervisory authorities in the context of fulfilling legal obligations.

  • External service providers and subcontractors: We use external service providers (see the list below) to support us in providing our services. These service providers are contractually obliged to process your data only within the scope of the instructions we have given and to take appropriate security measures to protect your data.

Your personal data is passed on only to the extent necessary to achieve the stated purposes. Where your data is passed on to third parties, we ensure that this is done in accordance with the applicable data protection provisions and on the basis of a corresponding contract, such as a data processing agreement.

IV. Use of external service providers and tools

In connection with our website, our business activities and the provision of our Service, we use service providers as processors. This includes, among other things, areas such as hosting, operation of the website, marketing, CRM, document management, finance and accounting services, email providers, scheduling and conferencing tools.

We have concluded data processing agreements (Auftragsverarbeitungsverträge, AVVs) with the respective service providers. When your data is transferred to countries outside the EU/EEA (hereinafter “third countries”), we ensure that an adequate level of protection is guaranteed. This is done either through the recognition of the countries concerned as safe by the EU Commission (adequacy decision), specific approved contracts (standard contractual clauses, SCCs) or, if necessary, by obtaining your express consent.

Applicant tracking and Conversions APIs. For the applicant funnels operated on behalf of our customers and for our own marketing, we use server-side Conversions APIs (Meta Conversions API, LinkedIn Conversions API, TikTok Events API, Google Ads / Google Tag Manager). In this process, conversion events (e.g. the submission of an application form) are transmitted together with hashed contact data to the respective advertising platform so that campaigns can be evaluated and optimised. This transmission takes place exclusively on the basis of the active consent of the data subject via the cookie/consent banner pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR in conjunction with § 25 para. 1 TDDDG; without consent, no events are transmitted. Details on the individual providers can be found in the list below.

Anthropic - Anthropic Ireland, Limited

Address: 6th Floor, South Bank House, Barrow Street, Dublin 4, Ireland (contractual partner for EEA/UK/Swiss customers under the Commercial Terms of Service; technical data processing is carried out via the parent company Anthropic, PBC, USA)

Description of the service: Large language model API (Claude models) for text and language processing, multimodal image analysis and agent-based workflows as part of our Service

Categories of data processed: Image material (photos) of the client’s (Auftraggeber) employees or other third parties, insofar as provided by the client for style analysis or campaign creation. Processing in multimodal AI models for style analysis; no use of the models for the biometric identification of the persons depicted (no matching against databases of persons, no face matching). In addition, model responses and technical metadata of the API calls.

Purpose of processing: Generation of texts, style and image analyses, code and analysis tasks as well as agent-supported workflows within our Service

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and a Data Processing Addendum (DPA); no training on API inputs (default setting)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the use of powerful AI models)

Provider’s privacy policy: https://www.anthropic.com/legal/privacy

Attio - Attio Limited

Address: 42 St John’s Square, 2nd Floor, London EC1M 4EA, United Kingdom (Companies House no. 10719702)

Description of the service: Cloud-based, collaborative CRM and data management system for managing customer and contact relationships; offers flexible data models, automations and integrations.

Categories of data processed: Customer contact data, communication history, activity and interaction data, organisational data, technical metadata

Purpose of processing: Management and analysis of customer relationships; support of sales processes; automation of workflows; collaborative use of CRM data in the team

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing predominantly within the EU; for transfers to the United Kingdom on the basis of the EU Commission’s adequacy decision, for other third countries safeguarded by standard contractual clauses (SCCs)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in customer and sales management)

Provider’s privacy policy: https://attio.com/legal/privacy

Amazon Web Services - Amazon Web Services EMEA SARL

Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg (contractual partner for EEA customers under the AWS Customer Agreement)

Description of the service: Cloud computing platform with services such as hosting, data processing, storage and databases

Categories of data processed:

  • Customers (employees of the clients): first name and surname, email address, login and session data, documents and images uploaded by the customer (e.g. campaign assets), including photos of the client’s employees or other third parties, insofar as provided for campaign creation
  • Applicants (end users of the funnels): IP address, contact data provided in the funnel (e.g. name, email, telephone number), answers and any uploaded application documents; for voice/text chat configurations additionally audio recordings and transcripts

Purpose of processing: Provision of cloud infrastructure for hosting, storage, processing and management of data as well as operation of applications; storage of media files and management of user accounts

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing exclusively in the EU (AWS region Frankfurt, eu-central-1); any intra-group access by Amazon Web Services, Inc. (USA) is safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the stable operation of our infrastructure)

Provider’s privacy policy: https://aws.amazon.com/privacy/

Calendly - Calendly, LLC

Address: 3423 Piedmont Road NE, Atlanta, GA 30305-1754, USA

Description of the service: Online scheduling tool for arranging consultation meetings

Categories of data processed: Name, email address, meta/communication data (e.g. IP address)

Purpose of processing: Provision of an integrated online calendar for straightforward scheduling of appointments

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the most straightforward possible scheduling of appointments); where consent has been requested, Art. 6 para. 1 sentence 1 lit. a GDPR

Provider’s privacy policy: https://calendly.com/legal/privacy-notice

Cloudflare - Cloudflare, Inc.

Address: 101 Townsend St., San Francisco, CA 94107, USA

Description of the service: Content delivery network (CDN), DDoS protection, web application firewall (WAF), DNS services

Categories of data processed: IP addresses, HTTP headers, user agent data, TLS certificates, where applicable further technical metadata

Purpose of processing: Improvement of the performance, security and availability of web applications

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the security and performance of the website)

Provider’s privacy policy: https://www.cloudflare.com/privacypolicy/

DocuSign - DocuSign Inc.

Address: 221 Main Street, Suite 1000, San Francisco, CA 94105, USA

Description of the service: Digital signature and management of documents

Categories of data processed:

  • Customers (employees of the clients who sign contracts with the contractor (Auftragnehmer)): first name and surname, email address, signature and the contract documents to be signed

Purpose of processing: Handling of contract conclusions between client and contractor; evidence and documentation purposes

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract or pre-contractual measures) and Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in evidence and documentation purposes)

Provider’s privacy policy: https://www.docusign.com/privacy

Dripify - Dripify

Address: see the provider’s website

Description of the service: Tool for sales automation and lead nurturing

Categories of data processed: Name, contact data, professional context

Purpose of processing: Support of sales processes and lead nurturing

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing possibly outside the EU; safeguarded by standard contractual clauses (SCCs)

Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in sales optimisation)

Provider’s privacy policy: https://dripify.io/privacy-policy/

ElevenLabs - Eleven Labs Inc.

Address: 169 Madison Ave #2484, New York, NY 10016, USA

Description of the service: Speech synthesis (text-to-speech) and conversational voice AI agents (ElevenLabs Agents). The agents form the basis of the AI-supported voice chat through which prospective applicants conduct a voice interview with the AI agent.

Categories of data processed: Input texts for speech synthesis; in the AI-supported voice chat additionally voice recordings and transcripts of the applicant chats (e.g. name, chat content, telephone number / email insofar as mentioned in the conversation) as well as technical metadata (session IDs, timestamps)

Purpose of processing: Generation of synthetic speech output (text-to-speech) and operation of the conversational voice agents for conducting applicant chats and providing voice-controlled funnels of our Service

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and a Data Processing Addendum (DPA)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the use of powerful voice AI)

Provider’s privacy policy: https://elevenlabs.io/privacy-policy

fal.ai - fal – Features & Labels, Inc.

Address: 2261 Market Street, Suite 10467, San Francisco, CA 94114, USA

Description of the service: Hosted inference platform for image, video and multimodal AI models (e.g. for asset generation in campaigns). fal.ai acts as a model gateway to curated end models from various providers.

Categories of data processed: Input prompts and reference assets, including where applicable photos of the client’s employees or other third parties, insofar as provided by the client for campaign creation; processing in generative AI models to create derived image/video outputs; no use of the models for the biometric identification of the persons depicted (no matching against databases of persons, no face matching); generated image/video outputs; technical metadata.

Purpose of processing: Generation of visual assets (images, videos) for our customers’ campaigns by means of hosted AI models

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the USA; safeguarded by standard contractual clauses (SCCs) and a Data Processing Addendum (DPA); zero retention of inputs via API header is being sought

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in the use of powerful generative AI models)

Provider’s privacy policy: https://fal.ai/legal/privacy-policy

Fivetran - Fivetran, Inc.

Address: 1900 Owens St, Suite 700, Oakland, CA 94612, USA

Description of the service: Fully automated ELT data integration platform for synchronising and replicating data from various sources into data warehouses.

Categories of data processed:

  • Customers (employees of the clients): contact data, login and account metadata from connected source systems (e.g. CRM)
  • Applicants (end users of the funnels): contact data collected in the funnels (name, email), IP addresses, funnel interactions and conversion events

Purpose of processing: Automated data replication, data aggregation and transfer for analysis; monitoring and maintenance of the data pipelines

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing in the EU (Frankfurt region); group access from the USA safeguarded by standard contractual clauses (SCCs) and the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in automated data integration and analysis)

Provider’s privacy policy: https://www.fivetran.com/legal/privacy

Address: Gordon House, Barrow Street, Dublin 4, Ireland

Description of the service: Advertising platform (Google Ads) and tag management system (Google Tag Manager) for serving advertisements, conversion tracking and managing measurement tags on our web funnels

Categories of data processed: Hashed contact data (Enhanced Conversions), IP address, user agent, click IDs (GCLID), conversion events, cookie IDs

Purpose of processing: Serving and measuring online advertising campaigns, managing conversion and analytics tags, optimising our customers’ campaigns

Processing in a third country / safeguards under Art. 44 et seq. GDPR: The contractual partner is Google Ireland Limited (EU); intra-group transfer to the USA on the basis of standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR (consent) in conjunction with § 25 para. 1 TDDDG

Provider’s privacy policy: https://policies.google.com/privacy

Google Cloud (including BigQuery, Workspace) - Google Ireland Limited

Address: Gordon House, Barrow Street, Dublin 4, Ireland

Description of the service:

  • Cloud hosting, cloud-based data warehouse platform for storing and analysing large volumes of data,
  • Email communication and cloud-based file storage

Categories of data processed:

  • Google Workspace (email, Drive, Calendar):
    • Customers (employees of the clients): contact data, communication history from business email exchange, documents and images provided by the customer by email or Drive (including photos of the client’s employees or other third parties, insofar as sent for campaign creation)
  • Google Cloud / BigQuery (analytics warehouse):
    • Customers: aggregated account and usage data
    • Applicants: contact data collected in the funnels (name, email), IP addresses, campaign and interaction data for reporting and evaluation

Purpose of processing:

  • Data analysis, reporting and evaluation of usage patterns for customer reporting
  • Exchange and management of business communication as well as storage of files and media

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing within the EU; for transfers to third countries, application of standard contractual clauses in accordance with the GDPR

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in an efficient communication and collaboration platform)

Provider’s privacy policy: https://policies.google.com/privacy

LinkedIn Conversions API - LinkedIn Ireland Unlimited Company

Address: Wilton Place, Dublin 2, Ireland

Description of the service: LinkedIn’s server-side conversion API for transmitting campaign events (e.g. lead submission) for campaign optimisation and advertising measurement

Categories of data processed: IP address, user agent, event metadata (time, conversion type)

Purpose of processing: Optimisation and measurement of advertising campaigns on LinkedIn, conversion tracking for our customers’ applicant funnels

Processing in a third country / safeguards under Art. 44 et seq. GDPR: The contractual partner is LinkedIn Ireland Unlimited Company (EU); intra-group transfer to the USA on the basis of standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR (consent) in conjunction with § 25 para. 1 TDDDG

Provider’s privacy policy: https://www.linkedin.com/legal/privacy-policy

LinkedIn Sales Navigator - LinkedIn Ireland Unlimited Company

Address: Wilton Place, Dublin 2, Ireland

Description of the service: Tool for contact management, network management and lead generation

Categories of data processed: Name, contact data, occupation, company information

Purpose of processing: Lead generation and network management as part of our sales activities

Processing in a third country / safeguards under Art. 44 et seq. GDPR: Data processing possibly outside the EU; safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in lead generation and network management)

Provider’s privacy policy: https://www.linkedin.com/legal/privacy-policy

Meta Conversions API - Meta Platforms Ireland Limited

Address: Merrion Road, Dublin 4, D04 X2K5, Ireland

Description of the service: Meta’s (Facebook/Instagram) server-side conversion API for transmitting campaign events (e.g. lead submission) for campaign optimisation and advertising measurement

Categories of data processed: IP address, user agent, event metadata (time, conversion type)

Purpose of processing: Optimisation and measurement of advertising campaigns on Meta platforms, conversion tracking for our customers’ applicant funnels

Processing in a third country / safeguards under Art. 44 et seq. GDPR: The contractual partner is Meta Platforms Ireland Limited (EU); intra-group transfer to the USA to Meta Platforms, Inc. on the basis of standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF)

Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR (consent) in conjunction with § 25 para. 1 TDDDG

Provider’s privacy policy: https://www.facebook.com/privacy/policy/

TikTok Events API - TikTok Technology Limited

Address: 10 Earlsfort Terrace, Dublin, D02 T380, Ireland

Description of the service: TikTok’s server-side Events API for transmitting campaign events (e.g. lead submission) for campaign optimisation and advertising measurement

Categories of data processed: IP address, user agent, event metadata (time, conversion type)

Purpose of processing: Optimisation and measurement of advertising campaigns on TikTok, conversion tracking for our customers’ applicant funnels

Processing in a third country / safeguards under Art. 44 et seq. GDPR: The contractual partner is TikTok Technology Limited (EU); transfer to affiliated companies outside the EU (in particular the USA and in individual cases China) on the basis of standard contractual clauses (SCCs) and additional technical/organisational measures (“Project Clover”)

Legal basis: Art. 6 para. 1 sentence 1 lit. a GDPR (consent) in conjunction with § 25 para. 1 TDDDG

Provider’s privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE

Vercel - Vercel Inc.

Address: 440 N Barranca Ave #4133, Covina, CA 91723, USA

Description of the service: Cloud platform for frontend development and hosting of web applications, including serverless functions and a global CDN

Categories of data processed:

  • Customers (employees of the clients): login and session data of the employees when using app.emerge-tech.io; documents and images provided by the customer (e.g. campaign assets), including photos of the client’s employees or other third parties, insofar as provided for campaign creation
  • Applicants (funnel visitors): IP addresses, user agent, page view and click events; for funnel configurations with a contact form additionally form entries (name, email address, telephone number, any uploaded application documents)
  • Website visitors (emerge-tech.io): connection data that technically arises when the website is requested (IP address, user agent, requested URL, time of the request)

Purpose of processing: Hosting of our application app.emerge-tech.io (login and management area for the client’s employees) and of the applicant funnels and landing pages operated on behalf of the client; in addition, hosting of our website emerge-tech.io

Processing in a third country / safeguards under Art. 44 et seq. GDPR: The funnels and landing pages deployed by us are served in the Vercel region Frankfurt (EU); group/support access from the USA safeguarded by standard contractual clauses (SCCs) and participation in the EU-U.S. Data Privacy Framework (DPF). Our website emerge-tech.io is delivered via Vercel’s global CDN, usually from the nearest location; connection data may therefore also be processed at locations outside the EU, likewise safeguarded by SCCs and the DPF

Legal basis: Art. 6 para. 1 sentence 1 lit. b GDPR (performance of the contract) or Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest in operating high-performance and secure web applications and websites)

Provider’s privacy policy: https://vercel.com/legal/privacy-policy

V. Data processing of applicants

If you apply to us for a position, we process the information and personal data you submit for the purpose of handling the application procedure. This data includes in particular your name, your email address, your address and telephone number, your CV data and qualifications. We may also ask you for further information that helps us in our recruitment process and in making a job offer, such as your date of birth and your employment records. The processing may also be carried out electronically. This is the case in particular if an applicant submits the relevant application documents to us electronically, for example by email. We process your personal data to fulfil our contractual or pre-contractual obligations on the legal basis of Art. 6 para. 1 sentence 1 lit. b GDPR or, where applicable, to carry out the employment relationship with you (§ 26 of the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG)). If you have consented to the processing for the purpose of handling your application, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.

If we do not conclude an employment contract with the applicant, the application documents are automatically deleted six months after notification of the rejection decision, provided that no other legitimate interests preclude deletion. Another legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz, AGG).

VI. Online presences on social media

We have presences on so-called social media platforms. We operate these presences with the following providers:

For these information services we use the technical platform and the services of the respective providers. Please note that you use our presences on social media platforms and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting, rating, sharing).

When you visit our social media presences, the platform providers collect, among other things, your IP address and further information that is stored on your device in the form of cookies. This information is used to provide us, as the operator of the accounts, with statistical information about your interactions with our posts. The data collected about you in this process is processed by the platforms and, where applicable, transferred to third countries, in particular to the USA.

The above-mentioned providers are certified under the EU-US Data Privacy Framework (DPF) and have committed themselves to complying with European data protection principles.

We do not know in what way the social media platforms use the data from your visit to our account and your interactions with our posts for their own purposes, how long this data is stored and whether it is passed on to third parties. The data processing may differ depending on whether you are registered and logged in to the social network or visit the page as a non-registered and/or non-logged-in user. When you access a post or our account, the IP address assigned to your device is transmitted to the provider of the social media platform. If you are currently logged in, a cookie on your device can be used to track how you have moved around the web. Via buttons embedded in websites, the platforms can record your visits to these websites and assign them to your profile in order to offer you targeted content or advertising. To avoid this, you should log out, deactivate the “stay logged in” function, delete the cookies present on your device and restart your browser.

As the provider of the information service, we otherwise process only the data that you provide to us in the context of using our service and that requires an interaction. If, for example, you ask us a question that we can only answer by email, we store your details in accordance with the general principles of our data processing described in this privacy policy. The legal basis for the processing of your data on the social media platform is Art. 6 para. 1 sentence 1 lit. f GDPR.

With regard to requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you nevertheless need help, you can contact us.

The providers of the social media platforms explain in their privacy policies which information they receive and how it is used. These policies (see the links above) also contain information on contact options and the settings options for advertisements.

D. Storage and deletion of data

The data processed by us is deleted in accordance with the statutory provisions as soon as the consents given for its processing are withdrawn or when the purpose of processing this data ceases to apply or the data is no longer required for the purpose. This means that we store your personal data only for as long as is necessary for the respective processing purpose and limit the storage period to the necessary minimum. Beyond this, we store your data only if we are entitled or obliged to do so under statutory retention periods (e.g. under the German Commercial Code (Handelsgesetzbuch, HGB) or the German Fiscal Code (Abgabenordnung, AO)). Our privacy policy may also contain further information on the retention and deletion of data that takes precedence for the respective processing.

E. Rights of data subjects

You have the right to

  • access pursuant to Art. 15 GDPR,

  • rectification pursuant to Art. 16 GDPR,

  • erasure pursuant to Art. 17 GDPR,

  • restriction of processing pursuant to Art. 18 GDPR,

  • object under Art. 21 GDPR (on the right to object, see below) and

  • data portability under Art. 20 GDPR.

As already mentioned in the corresponding sections of this privacy policy, you can also withdraw any consent you have given to us to the processing of personal data at any time. The withdrawal can be made via the contact options described in this privacy policy. Please note that the withdrawal only takes effect for the future. Processing that took place before the withdrawal is not affected.

In addition, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR.

F. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 para. 1 sentence 1 lit. e or f GDPR; this also applies to profiling based on this provision within the meaning of Art. 4 no. 4 GDPR.

G. Data processing when accessing linked content

This website may contain external links or hyperlinks to websites of other providers. These are to be distinguished from our own content. This external content does not originate from us, and we have no influence on the content of third-party pages. If you are redirected to other pages via links on the website, please inform yourself there about the respective handling of your data.

H. Automated decision-making / profiling

No automated decision-making or profiling takes place.

I. Changes to this privacy policy

As a result of the further development of our website, our online offering or our Service, or due to changes in legal and regulatory requirements, it may become necessary to amend this privacy policy from time to time.

If you have any questions regarding the processing of your data, you can contact us at any time.