WELCOME
Transparency and trust are core values at Westhouse. It goes without saying that we therefore treat all data, especially personal data, that you entrust to us only for the intended purpose and strictly confidentially, in compliance with the statutory provisions.
We process your personal data solely in accordance with the requirements of the DS-GVO and the German Federal Data Protection Act (BDSG) as well as other relevant laws.
To help you quickly access the relevant sections of the privacy statement, we provide the following summary. The summary does not replace the comprehensive explanations in the privacy statement. Therefore, if in doubt, please always refer to the relevant section in the full statement below.
SUMMARY
The Privacy Policy describes what personal data is processed by Westhouse, who uses your personal data, for what purpose and for how long, and what rights you have in this context.
Who collects and processes your personal data?
Your personal data is collected and processed by the relevant legal entity of Westhouse. The legal entity is either Westhouse Holding GmbH or another legal entity of the global Westhouse group.
What personal data is collected?
Westhouse processes various types of personal data about you in the course of its business, including:
- personal contact information,
- personal data that relates to your or your employer’s business relationship with Westhouse,
- personal data that Westhouse is required to collect for legal and regulatory compliance purposes,
- personal usage, registration and participation data that Westhouse may generate in the course of your use of web or online services,
- special categories of personal data,
- personal data that Westhouse may receive from third parties,
- personal data that Westhouse needs to ensure your satisfaction with our products, services and offerings.
For what purposes is your personal data processed?
Westhouse processes your personal data in order to:
- To comply with the business relationship with you, your employer or customer, including ensuring your satisfaction with and providing you with updated information about our products and services,
- provide you with Total Workforce Management services,
- ensuring the protection of its legal rights and, where appropriate, defending against unlawful attacks, asserting its legal claims or defending against legal claims,
- to comply with the legal regulations and obligations applicable to Westhouse,
- Operate web offerings or online events, including analyzing user behavior,
- identify you as a potential candidate for Westhouse,
- share it with recipients such as other Westhouse affiliates, third party vendors, partners and others.
What data protection rights do you have?
You have the right to request Westhouse to access your personal data and to correct and/or return or delete it. You may request Westhouse to restrict access to your personal data or to exclude it from further processing. You may withdraw your opt-in consent to processing activities by Westhouse in the given case or object to the processing. If you believe that Westhouse is not processing your personal data in accordance with the requirements described in this Privacy Policy or with applicable data protection laws, you may lodge a complaint with the relevant data protection authority. The Privacy Policy describes each of these rights in detail, including information on how to contact us to exercise these rights against Westhouse.
WESTHOUSE PRIVACY POLICY
C) WHAT TYPES OF PERSONAL DATA DOES WESTHOUSE PROCESS?
D) HOW IS YOUR PERSONAL DATA COLLECTED?
E) HOW IS YOUR PERSONAL DATA USED?
F) TO WHOM IS YOUR PERSONAL DATA DISCLOSED?
G) HOW IS YOUR PERSONAL DATA PROTECTED?
H) HOW LONG WILL YOUR PERSONAL DATA BE STORED?
I) HOW CAN YOU ACCESS, CHANGE OR WITHDRAW PERSONAL DATA THAT YOU HAVE PROVIDED TO US?
I.3) RIGHT TO RESTRICT PROCESSING
I.4.B) Information to third parties
I.6) RIGHT TO DATA PORTABILITY
I.8) RIGHT TO REVOKE DATA PROTECTION CONSENT
I.9) AUTOMATED DECISION-MAKING IN INDIVIDUAL CASES, INCLUDING PROFILING
I.10) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
J) HOW IS YOUR DATA STORED AND TRANSFERRED INTERNATIONALLY?
K) OUR LEGAL BASIS FOR PROCESSING YOUR DATA
L) NOTICE ON THE USE OF THIRD PARTY SERVICES
M) DATA TRANSFER TO COUNTRIES OUTSIDE THE EEA
O) ID CHECK FOR CANDIDATES AND SUPPLIERS
P) Country-specific variations of our privacy policy
A) CONTACT PERSON
The company responsible for processing personal data is:
Westhouse Holding GmbH, (hereinafter “Westhouse”).
Parkring 6
85748 Garching
E-mail: dsb@westhouse-group.com
To exercise your rights or if you have any questions, you can contact:
- Your contact person at your local Westhouse company.
- Westhouse Data Protection Officer, by e-mail to: dsb@westhouse-group.com or by mail to: Data Protection Officer, Westhouse Holding GmbH, Parkring 6, 85758 Garching near Munich.
- If you have any questions about data protection in connection with our services or the use of our website, you can also contact our data protection officer at any time. She can be reached at the following postal address (Attn: Data Protection Officer) and at the e-mail address given below.
External data protection officer, Ms. Lea Imschweiler, Am Hamburger Bahnhof 4, 10557 Berlin, imschweiler@isico-datenschutz.de
B) WHO ARE WE?
Westhouse is a group of recruitment companies focused on the technology and engineering industries.
Westhouse Group, its subsidiaries and affiliates provide products and services in the following countries:
In Germany:
- Westhouse Holding GmbH
- Westhouse Consulting GmbH
- WExpert GmbH
- Westhouse Services GmbH
- Westhouse Professionals GmbH
- Westhouse Engineering GmbH
In Austria:
- Westhouse Austria GmbH
In Switzerland:
- Westhouse Schweiz AG
In Romania:
- Westhouse International SRL
In Italy:
- Westhouse Italia SRL
- Westhouse Managed Services SRL
C) WHAT TYPES OF PERSONAL DATA DOES WESTHOUSE PROCESS?
IF YOU ARE A WESTHOUSE CANDIDATE:
In order to provide you with optimal, customized employment opportunities, we need to process certain information about you. We only ask for such information that we believe will actually help us serve you better.
Depending on the governing conditions and applicable local laws, we may collect some or all of the information listed below in order to provide you with employment opportunities that are best tailored to your situation and interests:
• Name
• Age/Date of Birth
• Birth Number
• Sex/Gender
• Photograph
• Marital status
• Contact details
• Education details
• Employment history
• Emergency contacts and details of dependants
• Contact details for a reference
• Immigration status (whether you need a work permit)
• Nationality/citizenship/place of birth
• Start date or availability date
• A copy of your driver’s license or passport/ID card
• Bank account information
• Financial information (if we need to check your financial background)
• Social security number (or equivalent in your country) and other tax information
• Diversity information (any race or ethnic origin, religious affiliation or similar beliefs, and physical and mental health, including any disability-related information)
• Details of any criminal record, if relevant to a position you are applying for
• Details of your previous and current remuneration, pension and benefit arrangements
• Information about your interests and entitlements in relation to future employment; this will be both directly collected and inferred, for example, from job listings you read on our website or links you have clicked on in emails we send to you
• Additional information that you provide to us on your own initiative
• Additional information that your contacts for a reference provide to us about you on their own initiative
• Additional information that our customers tell us about you or that we receive from third parties, e.g. job portals
• IP address
• Date, time and frequency of your access to our services
• Video recordings when you enter our premises.
Please note that this is not a complete list of the personal data we collect:
IF YOU ARE A WESTHOUS APPLICANT:
We collect limited information about you and only to evaluate how we can help you if we believe our services may interest or benefit you. In order to contact you, this information typically includes your name and contact information. If we found you while searching for jobs on LinkedIn or other sites, we may also obtain additional information about you. In this case, we collect information such as your professional history, education, qualifications, skills, and interests, as well as additional information you have provided in a publicly available profile or resume that you have uploaded to one of these websites that we can access.
IF YOU ARE A WESTHOUSE TEMPORARY EMPLOYEE:
To ensure a smooth business relationship, we will need to process additional information in conjunction with the information collected from candidates if we hire you directly as a temporary employee. Only significant data such as personnel numbers or other identities, start dates, bank details and details of previous remuneration, pension and benefit arrangements will be held. Consequently, in accordance with local laws and regulations, we may also collect information about trade union membership, sexual orientation, childcare or carer arrangements where appropriate, if you provide us with information about payroll deductions for union memberships or childcare coupons or details of your emergency contact. Information we may process may include:
• Personnel number/other identifier
• Location of your employment or place of employment with the client
• Membership of a trade union
• Details of leave you take or request during our temporary employment relationship or sick leave, including health information
• Information about your performance in your position during our temporary employment relationship, including details of bonuses or promotions you may have received, performance evaluations, and other information related to your employment, interactions with colleagues, and work-related issues
• Details of any travel undertaken
Please note that the above list of categories of personal data we collect is not exhaustive.
IF YOU ARE A WESTHOUSE CUSTOMER:
If you are a client of Westhouse, we may need to collect and use information about you or individuals within your organization to provide or offer services to you, such as:
(i) searching for suitable candidates who are a good fit for you or your organization
(ii) providing a managed service provider (“MSP”) model to you (or assisting another organization to do so)
(iii) notifying you of content published by Westhouse that is likely to be important and useful to you.
Generally, we only need your contact information or the contact information of individual contacts within your organization (such as names, phone numbers, and email addresses) to contact you regarding our services and to ensure a smooth business relationship. In addition, we may store information provided to us by individuals within your organization on their own initiative.
IF YOU ARE A WESTHOUSE SUPPLIER:
Our goal is to collect information from our contacts within your company, such as names, phone numbers, and email addresses. We also collect banking information in order to make payments to you. In addition, we may store information provided to us by individuals within your organization on their own initiative.
WHEN WE RECEIVE YOUR INFORMATION FROM CANDIDATES AND/OR EMPLOYEES, E.G., REFERENCE CONTACTS, EMERGENCY CONTACTS
We require some basic background information in order to provide suitable employment opportunities to our candidates and applicants. We ask for very basic contact information so that we can contact you for a reference or to get in touch with you. We may also receive your information because you were provided as an emergency contact or relative of one of our candidates or employees.
IF YOU ARE A VISITOR TO OUR WEBSITE:
We collect only a limited amount of data from visitors to our website and use that data to help you better manage our website or apps and to better manage the services we provide. This includes, but is not limited to, information about how you use our website, how often you access it, and when it is most in demand.
D) HOW IS YOUR PERSONAL DATA COLLECTED?
IF YOU ARE A WESTHOUSE CANDIDATE:
We collect your personal information either from you or from third parties. In addition, we will automatically collect or provide certain information when you access our website or read or click on an email from us.
IF YOU ARE A WESTHOUSE APPLICANT:
We collect your personal information or information about you from external sources such as social media, professional networks, job search engines, online job posting providers and MSP vendors, suppliers, or MSP clients when they contact us.
We use your information to determine if you are interested in or could benefit from our services and to determine if and how we can help you. We will use your contact information to contact you to determine if you are interested in our services if we believe we can help you. In Germany, we do not contact you by email, but by phone or message through the job network/portal (unless you have agreed to be contacted by email).
IF YOU ARE A TEMPORARY EMPLOYEE OF WESTHOUSE:
We collect your personal information either: from you or from third parties.
IF YOU ARE A CUSTOMER OF WESTHOUSE:
We collect your personal information either from you or from third parties (e.g., our candidates or temporary employees) and other limited sources (e.g., online and offline media).
IF YOU ARE A SUPPLIER OF WESTHOUSE:
We collect your personal data in the course of working with you.
WHEN WE RECEIVE YOUR INFORMATION FROM CANDIDATES AND EMPLOYEES, E.G., REFERENCE CONTACTS, EMERGENCY CONTACTS.
We collect your contact information only when a candidate or one of our employees designates you as an emergency contact or relative, or when a candidate names you as a reference contact.
IF YOU ARE A VISITOR TO OUR WEBSITE AND A RECIPIENT OF E-MAILS:
FOR THE PROVISION OF THE WEBSITE AND CREATION OF LOG FILES
Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is collected in this process:
a) information about the browser type and version used,
b) the operating system of the user
c) the user’s Internet service provider,
d) the IP address of the user,
e) date and time of access,
f) websites from which the user’s system accesses our website,
g) websites that are accessed by the user’s system via our website.
The log files contain IP addresses or other data that allow an assignment to a user. This could be the case, for example, if the link to the website from which the user accesses the Internet site or the link to the website to which the user goes contains personal data. The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
WHEN USING TOOLS ON OUR WEBSITE
This website uses various services and applications (collectively, “tools”) that are offered either by ourselves or by third parties. These include, in particular, Tools that use technologies to store or access information in the terminal device:
• Cookies: information stored on the end device, consisting in particular of a name, a value, the storing domain and an expiration date. So-called session cookies (e.g. PHPSESSID) are deleted after the session, while so-called persistent cookies are deleted after the specified expiration date. Cookies can also be removed manually.
• Web Storage (Local Storage / Session Storage): information stored on the end device, consisting of a name and a value. Information in Session Storage is deleted after the session, while information in Local Storage has no expiration date and basically remains stored unless a mechanism for deletion has been set up (e.g. storage of a Local Storage with time entry). Information in Local and Session Storage can also be removed manually.
• JavaScript: programming codes (scripts) embedded in or called up from the website that, for example, set cookies and web storage or actively collect information from the end device or about the usage behavior of visitors. JavaScript can be used for “active fingerprinting” and the creation of usage profiles. JavaScript can be blocked by a setting in the browser, although most services will then no longer function.
• Pixel: Tiny graphic automatically loaded by a service, which can make it possible to recognize visitors by automatically transmitting the usual connection data (in particular IP address, information about browser, operating system, language, address called up and time of call-up) and to determine, for example, whether an e-mail has been opened or a website visited. With the help of pixels, “passive fingerprinting” and the creation of usage profiles can be carried out. The use of pixels can be prevented, for example, by blocking images, for example in e-mails, although the display is then severely restricted.
With regard to the use of non-technical cookies for analysis purposes, we refer to Section IX (Web analysis by Google Analytics).
FOR OUR NEWSLETTER (WELERT)
On our website there is the possibility to subscribe to a free newsletter. When registering for the newsletter, the data from the input mask (e-mail address of the user) is transmitted to us. In addition, the following data is collected during registration:
a) IP address of the calling computer.
b) Date and time of registration
For the processing of the data, your consent is obtained during the registration process and reference is made to this privacy policy. No data will be passed on to third parties in connection with the processing of data for the dispatch of newsletters. The data is used exclusively for sending the newsletter.
FOR OUR REGISTRATION (WELOUNGE)
On our website, we offer users the opportunity to register by providing personal data. The data is entered in an input mask and transmitted to us and stored. The data is not passed on to third parties. The following data is collected during the registration process:
a) first and last name of the user
b) e-mail address of the user
c) Address of the user (optional)
d) The following data is also stored at the time of registration:
e) The IP address of the user,
f) Date and time of registration.
During the registration process, the user’s consent to the processing of this data is obtained.
FOR OUR CONTACT FORM AND E-MAIL CONTACT
A contact form is available on our website, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask is transmitted to us and stored. These data are:
a) e-mail address of the user
b) any additional personal data voluntarily provided in the message.
c) At the time the message is sent, the following data is also stored:
d) The IP address of the user
e) Date and time of sending
For the processing of the data, your consent is obtained during the sending process and reference is made to this privacy policy. Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored. In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.
FOR WEB ANALYSIS BY GOOGLE ANALYTICS
To improve our website, we use optional tools to recognize visitors and to statistically collect and analyze general usage behavior based on access data (“analytics tools”). We also use analytics services to evaluate the use of our various marketing channels. The usage information collected is processed in aggregated form and enables us to track usage habits of our visitors. This is used to adapt and optimize the design of our website and to make the user experience more pleasant.
Our website uses the Google Universal Analytics (“Google Analytics”) service, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for persons from Europe, the Middle East and Africa (EMEA) and by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA for all other persons.
Google Analytics uses JavaScipt and pixels to read information on your terminal device and cookies to store information on your terminal device. This is used to analyze your usage behavior and improve our website. We will process the information obtained to evaluate your use of the website and to compile reports on website activity for the website operators. If details of our website are called up, the following data will be stored:
a) IP address of the user’s calling system,
b) the website called up,
c) the website from which the user accessed the accessed website (referrer),
d) the sub-pages called up from the website called up,
e) the length of time spent on the website,
f) the frequency with which the website is accessed.
The information generated by the cookie about your use of this website is usually transmitted to and stored by Google Inc (“Google”) on servers in the United States. In the case of activation of IP anonymization on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of 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.
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.
The personal data transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
E) HOW IS YOUR PERSONAL DATA USED?
IF YOU ARE A WESTHOUSE CANDIDATE:
We use your information primarily to help you find suitable employment. The more information we have about you, your skills and your goals, the better we can provide that service. Where appropriate and permitted by local laws and regulations, we will also use your personal information to advertise our services to you, profile you, etc. Where appropriate, we will ask for your consent for some of these actions.
If YOU ARE WESTHOUSE APPLICANTS:
We are always looking for exceptional candidates to advance your career. If we find your profile on an online platform and we believe it may be relevant to our clients, we will – with your prior express consent – enter your information into our database and send you relevant job offers by message, where this is lawful under local direct marketing legislation (relating to emails, SMS, social media messages, telephone or post).
IF YOU ARE A TEMPORARY EMPLOYEE OF WESTHOUSE:
We use your personal information to ensure a smooth business relationship and to fulfill our contractual and other obligations to you and to our customers in our temporary employment relationship, as well as our obligations to third parties such as tax authorities and government agencies.
IF YOU ARE A WESTHOUSE CUSTOMER:
We use your data primarily to ensure that the contractual agreements between us can be properly implemented and to ensure a smooth business relationship. This will include:
(i) Identifying candidates who we believe are a good fit for you or your organization,
(ii) Providing an MSP program to you (or supporting another organization in doing so,
(iii) providing a marketplace for the direct sourcing and engagement of candidates by the client.
IF YOU ARE A WESTHOUSE SUPPLIER:
We use your personal data to ensure that the contractual agreements between us can be properly implemented to enable a smooth business relationship. On the other hand, to ensure compliance with legal requirements, e.g. in the context of commissioning by one of our client companies.
WHEN WE RECEIVE YOUR CANDIDATE AND EMPLOYEE INFORMATION, E.G., REFERENCE CONTACTS, EMERGENCY CONTACTS:
We use the personal information of reference contacts to help our candidates find suitable employment. If we can verify their information and qualifications, we can ensure that they are a good fit for potential clients. If a reference is requested from a reference contact based on a candidate’s professional experience and we believe they may be interested in becoming our client, we may also use their information to contact them about this alternative opportunity, as appropriate and permitted in accordance with local laws and requirements.
IF YOU ARE A VISITOR TO OUR WEBSITE:
We use your information to help you use our website or apps, for example, by analyzing your recent job search criteria so that we can better show you jobs that we think may be of interest to you. In addition, we use your information to provide you with the service you signed up for or the services you participated in, such as to send you a newsletter or allow you to participate in an online survey If you are also a candidate or client of Westhouse, we will use information about your use of the Site to improve other aspects of our communications with you or the service we provide to you.
Temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. an evaluation of the data for marketing purposes does not take place in this context.
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change. We require cookies for the following applications:
a) Adoption of language settings
b) Remembering search terms
c) The user data collected through technically necessary cookies are not used to create user profiles.
The processing of personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
F) TO WHOM IS YOUR PERSONAL DATA DISCLOSED?
IF YOU ARE A WESTHOUSE CANDIDATE:
We will share your information primarily with potential clients to increase your chances of landing the job or project you want. Unless you have indicated otherwise, we will also share your information with any of our group companies as well as affiliated third parties, such as service providers we use and selected job search engines, marketplaces and other third party vendors, if we believe doing so will help us provide the best service to you and maximize your chances of obtaining the job or project you desire.
We will share your personal information, as appropriate and in accordance with local laws and regulations, in numerous ways and for numerous purposes with the following categories of people:
• All group companies
• Appropriate colleagues at Westhouse (this may include colleagues in offices in other EU countries).
• In the case of temporary employees, and in limited circumstances where applicable, medical professionals such as your family doctor or an occupational health expert
• In the case of temporary employees, the client where you (will) work as a temporary employee
• In the case of temporary workers, potential employers (for example, if a reference is provided, to the extent consistent with local laws and regulations)
• Individuals and organizations who, in order to work with us, have information related to the reference or application, such as current, previous or prospective employees, trainers and review boards, and employment and recruitment agencies
• Tax, audit or other government agencies if we believe in good faith that we are required by law or other regulation to disclose such information (for example, because of a request from a tax authority or in connection with anticipated litigation)
• Service providers (whether third parties or our group companies) who provide services on our behalf (including external consultants, business partners and professional advisors such as lawyers, accountants and auditors, administrative functions, technical support functions and IT consultants who carry out development and testing work on our company’s technology systems)
• Providers of outsourced IT services and storage providers, if an appropriate contract processing agreement (or comparable protection) is in place
• Marketing technology platforms and suppliers
• In the case of candidates: potential employers and other recruitment service agencies/organizations to improve your chances of finding employment
• In the case of candidates: external partners, job portals, job platforms, job search engines, software developers and external (cloud-based) databases, where we believe this will increase the chance of finding the right job for you or improve the recruitment process generally
• In the case of candidates: MSP providers as part of our clients’ MSP programs
• In the case of candidates and our candidates’ and prospective employees’ reference contacts: third parties we have engaged to provide services such as reference checks, qualifications checks and criminal history checks, where such checks are appropriate and permitted under local laws
• In the case of candidates and candidate reference contacts: internal and external auditors of our clients when we need to share this data with them upon request to comply with our contractual or regulatory obligations
• In the case of candidates: Third parties who help us by developing services and procedures to streamline the candidate selection process to improve the quality and efficiency of our recruiting services
• In the event that Westhouse merges with or is acquired by another company or corporation in the future, then we may share your personal information with the (future) new owners of the company or corporation.
IF YOU ARE A WESTHOUSE APPLICANT:
If you have been identified as an applicant or potential candidate, we may share your information with all Group companies and related third parties, such as service providers we use, in order to contact you regarding our services. In all other respects, please refer to the comments under Candidate Data.
IF YOU ARE A TEMPORARY EMPLOYEE OF WESTHOUSE:
We refer to the explanations on the disclosure of candidate data.
IF YOU ARE A CUSTOMER OF WESTHOUSE:
We share your information for the following purposes:
(i) To ensure that contractual agreements between us can be properly implemented and to ensure a smooth business relationship.
(ii) To provide (or assist another organization in providing) an MSP program to you.
Unless you have indicated otherwise, we will share your information with any of our group companies as well as related third parties, such as service providers engaged by us, in order to better achieve these objectives.
In all other respects, please refer to the comments on the disclosure of candidate data.
IF YOU ARE A SUPPLIER TO WESTHOUSE:
Unless you have indicated otherwise, we will share your information with any of our group companies as well as affiliated third parties, such as service providers we use and organizations for which we provide services.
For a detailed list of potential recipient groups, please see the discussion of sharing candidate data under IV.
IF WE RECEIVE YOUR DATA FROM CANDIDATES AND EMPLOYEES, E.G. CONTACT PERSONS FOR REFERENCES, EMERGENCY CONTACTS:
Unless you have indicated otherwise, we will share your information with any of our group companies as well as affiliated third parties, such as service providers we use and organizations for which we provide services.
For a more detailed list of potential recipient groups, please see the discussion of Candidate Data Sharing under IV.
IF YOU ARE A VISITOR TO OUR WEBSITE:
Unless you indicate otherwise, we will share your information with providers of web analytics services, marketing automation platforms, and social media services to ensure that you receive only targeted advertising from us. For a detailed list of the possible recipient groups, please see the explanations on the sharing of candidate data under IV.
G) HOW IS YOUR PERSONAL DATA PROTECTED?
The protection of your information is our top priority. Therefore, we take appropriate measures to prevent unauthorized access to and misuse of your personal information. We have taken a number of technical and organizational measures We will take all reasonable and appropriate measures to protect the personal information we hold from misuse, loss or unauthorized access.
If you suspect that your personal information has been misused, lost or accessed without authorization, please notify us as soon as possible using our contact form.
H) HOW LONG WILL YOUR PERSONAL DATA BE STORED?
We store your personal data in order to provide services to you or receive services from you, or to provide you with information about our services that we think may be of interest to you. We will delete your personal data from our systems unless we have a good faith belief that we are required by law or other regulation to retain it (e.g., because of a tax authority request or a connection to a prospective lawsuit) or because of other legal exceptions.
The exact retention period will depend on the nature of the data, our legitimate business needs, and other legal or regulatory rules that impose certain minimum retention periods on us. For example, we may be required to retain certain data for purposes of filing tax returns or responding to tax questions. We may also retain the data if it is relevant to potential litigation. In jurisdictions where it is permitted, we will generally retain personal information about you if it is necessary for us to provide you or a prospective employee with a reference.
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
I) HOW CAN YOU ACCESS, CHANGE OR WITHDRAW PERSONAL DATA THAT YOU HAVE PROVIDED TO US?
Even if we are already in possession of your personal data, you have various rights with regard to this data. If you wish to contact us in this regard, please contact us. We will endeavor to process your request as quickly as possible and in any case in accordance with the applicable legal provisions. Please note that we may keep records of our communications in order to better resolve issues you raise.
I.1) RIGHT TO INFORMATION
You may request confirmation from Westhouse as to whether personal data concerning you is being processed by us.
If such processing is taking place, you may request information from Westhouse about the following (right of access under Article 15 of the GDPR):
(a) The purposes for which the personal data are processed,
(b) the categories of personal data which are processed,
(c) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed,
(d) the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, the criteria for determining the storage period,
(e) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing,
(f) the existence of a right of appeal to a supervisory authority,
(g) any available information on the origin of the data, if the personal data are not collected from the data subject,
(h) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer. Where this is the case and the European Commission has not issued an adequacy decision (Art. 45 DSGVO) for the third countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses of the European Union or binding internal data protection regulations.
Where this is not possible, we base the data transfer on exceptions of Art. 49 DSGVO, in particular your explicit consent or the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.
If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. When obtaining your consent via the consent banner, you will also be informed of this.
I.2) RIGHT TO RECTIFICATION
You have a right to rectification, pursuant to Art. 16 DSGVO and/or completion vis-Ã -vis. Westhouse, insofar as the processed personal data concerning you are inaccurate or incomplete. Westhouse shall carry out the rectification without undue delay.
I.3) RIGHT TO RESTRICT PROCESSING
Under the following conditions, you may request the restriction of processing pursuant to Art 18 DSGVO of the personal data concerning you:
(a) If you contest the accuracy of the personal data concerning you for a period enabling Westhouse to verify the accuracy of the personal data,
(b) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data,
(c) Westhouse no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defense of legal claims; or
(d) if you have objected to the processing pursuant to Article 21 (1) DSGVO and it is not yet clear whether the legitimate grounds of Westhouse override your grounds.
If the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by Westhouse before the restriction is lifted.
I.4) RIGHT TO ERASURE
I.4.A) obligation to erase
You may request Westhouse to erase the personal data concerning you without undue delay in accordance with Art. 17 DSGVO, and Westhouse is obliged to erase such data without undue delay if one of the following reasons applies:
• Personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
• You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a DSGVO and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing,
• or you object to the processing pursuant to Art. 21 (2) DSGVO.
• The personal data concerning you have been processed unlawfully.
• The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which Westhouse is subject.
• The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
I.4.B) Information to third parties
If Westhouse has made public the personal data concerning you and is obliged to erase it pursuant to Article 17(1) of the Data Protection Regulation, it shall implement reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data.
I.4.C) Exceptions
The right to erasure does not exist insofar as the processing is necessary:
• for the exercise of the right to freedom of expression and information
• for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller,
• for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO,
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) DSGVO, insofar as the right referred to in the first paragraph is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
• for the assertion, exercise or defense of legal claims.
I.5) RIGHT TO INFORMATION
If you have asserted the right to rectification, erasure or restriction of processing against Westhouse, Westhouse is obliged to notify all recipients to whom the personal data concerning you has been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right against Westhouse to be informed about these recipients.
I.6) RIGHT TO DATA PORTABILITY
You have the right to receive the personal data concerning you that you have provided to Westhouse in a structured, commonly used and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance by the controller to whom the personal data was provided, provided that
a) the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and
b) the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Westhouse.
I.7) 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 carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
Westhouse shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
Regarding the use of cookies, Google Tag Manager & Google Analytics, the following applies: Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
We offer our users the option of opting out of the analysis process on our website. Google Tag Manager & Google Analytics. In this way, another cookie is set on your system, which signals to our system not to store the user’s data. If the user deletes the corresponding cookie from their own system in the meantime, the must set the opt-out cookie again.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link (http://tools.google.com/dlpage/gaoptout?hl=de).
For more information on terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/. We would like to point out that on this website Google Analytics has been extended by the code “anonymizelp” to ensure anonymized collection of IP addresses (so-called IP masking).
I.8) RIGHT TO REVOKE DATA PROTECTION CONSENT
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
To assert your rights described here, you can contact us at any time using the contact details above. This also applies if you would like to receive copies of guarantees to prove an adequate level of data protection. Provided that the respective legal requirements are met, we will comply with your data protection request.
Your requests for the assertion of data protection rights and our responses to them will be stored for documentation purposes for a period of up to 3 years and, in individual cases, for a longer period if there are grounds for asserting, exercising or defending legal claims. The legal basis is §§ 195, 199 of the German Civil Code (BGB) as well as Art. 6 (1) lit. f DSGVO, based on our interest in defending against any civil claims under Art. 82 DSGVO, avoiding fines under Art. 83 DSGVO and fulfilling our accountability obligations under Art. 5 (2) DSGVO.
You have the right to revoke your consent at any time. This has the consequence that we no longer continue the data processing based on this consent for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Insofar as we process your data on the basis of legitimate interests, you have the right to object to the processing of your data at any time on grounds relating to your particular situation. If it is a matter of objecting to data processing for direct marketing purposes, you have a general right to object, which will also be implemented by us without giving reasons.
If you are a user of our homepage: Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
You can revoke your consent for certain cookies, i.e. for the storage and access to information in the terminal device, the processing of your personal data and the transfer of your data to third countries, at any time with effect for the future.
To do so, click on the blue “Open cookie settings” button on the homepage. There you can also change the selection of cookies to whose use you wish to consent, as well as obtain supplementary information on the cookies used. Alternatively, you can assert your revocation for certain cookies directly with the provider.
If you wish to exercise your right of revocation or objection, it is sufficient to send an informal message to the above contact details.
I.9) AUTOMATED DECISION-MAKING IN INDIVIDUAL CASES, INCLUDING PROFILING
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
a) is necessary for the conclusion or performance of a contract between you and the controller,
b) is permitted by legal provisions of the Union or the Member States to which Westhouse is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests, or
c) is made with your express consent.
However, these decisions must not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect your rights and freedoms as well as your legitimate interests.
With regard to the cases mentioned in a) and c), Westhouse shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a data subject on the part of the controller, to express his or her point of view and to contest the decision.
I.10) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. In Bavaria, our headquarters, the competent supervisory authority is: Bavarian State Office for Data Protection Supervision (BayLDA), Promenade18, 91522 Ansbach.
Contact details of other competent local supervisory authorities:
For our companies located in Baden-Württemberg/Stuttgart, the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg.
1) Mail: P.O. Box 10 29 32, 70025 Stuttgart, Germany
2) Email: poststelle@lfdi.bwl.de
For our companies located in North Rhine-Westphalia/Düsseldorf, the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia:
1) Mail: P.O. Box 20 04 44, 40102 Düsseldorf, Germany
2) Email: poststelle@ldi.nrw.de
The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.
J) HOW IS YOUR DATA STORED AND TRANSFERRED INTERNATIONALLY?
Westhouse is an international company and offers you international services. In order for us to maintain our high level of service, we may need to transfer or store your information internationally in certain circumstances:
• Between Westhouse’s individual companies and within those companies,
• to third parties (such as consultants or other suppliers to Westhouse),
• to customers in other countries, if applicable
• to customers in their country, if applicable, who may in turn transfer your data internationally,
• to a cloud-based storage provider; and
• to other third parties see Section IV.
We want to ensure that your data is stored and transferred in a secure manner. Therefore, we only transfer data outside the European Economic Area or EEA (i.e., the member states of the European Union plus Norway, Iceland and Liechtenstein) if this complies with data protection law and the method of transfer provides adequate protection for your data, for example:
• by means of a data transfer agreement that incorporates the current standard contractual clauses provided by the European Commission for transfers of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection law; or
• the transfer of your data to a country with a legally required level of data protection that has been assessed as adequate by the European Commission, or
• if it is necessary for the formation or performance of a contract between us and a third party and the transfer is in your interest for the purposes of that contract (for example, if we need to transfer data outside the EEA to perform our obligations under that contract if you are a customer of ours), or
• Where you have given your consent for the transfer of data.
To ensure that your personal data receives an appropriate level of protection, we have implemented appropriate measures with third parties with whom we share your personal data to ensure that your personal data is handled by those third parties in a manner consistent with data protection laws.
K) OUR LEGAL BASIS FOR PROCESSING YOUR DATA LEGITIMATE INTEREST
Article 6 (1) (f) of the GDPR states that we may process your data if it is “necessary for the purposes of the legitimate interests [of us] or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms [of you] which require the protection of personal data.”
We do not believe that the following activities have a negative impact on individuals. Instead, they help us provide more tailored and effective services to you, which is beneficial to all parties. However, you have the right to object to our processing of your personal data on this basis. Information on how you can do this can be found here.
IF YOU ARE A WESTHOUSE CANDIDATE OR APPLICANT:
As a candidate or applicant, we believe that you consent to our collection or use of your personal information to provide recruitment services to you or on your behalf, to our sharing of that information with prospective employers or clients, and to our matching your skills with available job postings. Therefore, we believe it is appropriate to process your information to ensure that we send you relevant content and provide you with the best job opportunities.
We also believe that if you have posted your professional resume to a job portal or professional networking website, you are looking for job opportunities and therefore consent to us collecting or using your personal data to evaluate whether we can offer or provide you with recruitment services and to contact you regarding those services.
In addition, we need to ensure that our operations run smoothly so that we can continue to serve candidates like you. Therefore, we are also required to use your information for internal administrative purposes such as payment and possibly invoicing.
IF YOU ARE A TEMPORARY EMPLOYEE OF WESTHOUSE:
If we employ you as a temporary employee, we believe that the following non-exhaustive examples of processing activities are in our legitimate interest to establish a successful temporary employment relationship:
• For our internal administrative purposes, such as facilitating payroll and invoicing procedures, if applicable to your jurisdiction
• Determining the terms and conditions under which you will work during your temporary employment relationship
• Recording the start and duration of the assignment, hours worked during the assignment, and (in certain jurisdictions) promotions, salary increases or bonuses awarded to you
• Giving or receiving feedback in connection with your assignment; and
• Where applicable, to help us assert, exercise or defend legal claims.
IF YOU ARE A WESTHOUSE CUSTOMER:
To ensure that we are providing optimal services to you, we will retain your personal information and/or the personal information of individual contacts within your organization and maintain records of interviews, meetings, reported jobs and job placement. Occasionally, we may also ask you to participate in a customer satisfaction survey. We believe this is appropriate and that this use of your information is necessary for our legitimate interests as a company providing various recruitment services to you.
IF YOU ARE A SUPPLIER TO WESTHOUSE:
We use and store the personal data of individuals within your organization to obtain services from you as one of our suppliers. We also store your financial information so that we can pay for your services. We consider all of these activities to be within the scope of our legitimate interests as a recipient of your services.
INDIVIDUALS WHOSE INFORMATION WE RECEIVE FROM CANDIDATES AND EMPLOYEES, E.G., REFERENCE CONTACTS, EMERGENCY CONTACTS, AND DEPENDENTS:
If you have been provided by a candidate or employee for a reference, we will use your personal information to contact you about that reference. This is part of our quality assurance process, which is why we consider the processing of data necessary for our legitimate interests as a company providing recruitment services.
If you are asked to provide a reference based on a candidate’s professional experience and we believe you may be interested in becoming our client, we may also use your information to contact you about this alternative opportunity (subject to applicable local laws and requirements).
If a candidate or employee has designated you as an emergency contact, we will use this information to contact you in the event of an accident or emergency. I’m sure you will agree that this is an important element for our organization, which is primarily about people, and therefore necessary for our legitimate interests.
IF YOU ARE A VISITOR TO OUR WEBSITE:
The legal basis for this processing is Art. 6 (1) lit. b DSGVO, provided that the page view occurs in the course of the initiation or performance of a contract. Otherwise, the legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO due to our legitimate interest in enabling website access and permanent functionality and security of our systems. However, the automatic transmission of the connection data and the log files developed from it do not constitute access to the information in the end device in the sense of the implementation laws of the ePrivacy Directive of the EU member states, in Germany § 25 TTDSG. For the rest, however, it would be absolutely necessary anyway.
IF YOU HAVE CONSENTED TO DATA PROCESSING.
In certain circumstances, we may need to obtain your consent to process your personal data in connection with certain activities. Depending on exactly what your data is needed for, we will obtain this consent explicitly by “opt-in” or implicitly by “soft opt-in”. We keep records of the consents you have given in this way.
As mentioned above, you have the right to withdraw your consent for these activities. You may do so at any time. Details on how to do so can be found here.
WHEN WE NEED YOUR DATA TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS
Sometimes it is necessary for us to process personal data and, where applicable and in accordance with local laws and regulations, sensitive personal data in connection with the exercise or defense of legal claims. Article 9(2)(f) of the GDPR allows us to do this.
For example, this will occur when we need legal advice in relation to a legal proceeding or are legally required to preserve or disclose certain information as part of the legal proceeding.
WHEN WE NEED YOUR INFORMATION TO EXERCISE OUR RIGHTS OR FULFILL OUR OBLIGATIONS UNDER EMPLOYMENT AND SOCIAL SECURITY LAW
For some candidates, temporary employees, and individuals whose personal data is provided by candidates and employees, it may be necessary for us to process your sensitive/special category personal data. Article 9(2)(b) of the GDPR authorizes us to do so.
WHERE THE PROCESSING OF YOUR PERSONAL DATA IS NECESSARY FOR US TO PERFORM OUR OBLIGATIONS UNDER OUR CONTRACT WITH YOU
The relevant basis for this is Article 6(1)(b) of the GDPR.
WHERE THE PROCESSING OF YOUR PERSONAL DATA IS NECESSARY FOR US TO COMPLY WITH OUR LEGAL OBLIGATIONS
When we employ temporary workers, as well as in relation to our obligations to our project partners and suppliers under our contract, we are also subject to other legal obligations with which we must comply. Article 6 (1) c) of the GDPR allows us to do so.
An example of a legal obligation we must comply with is our obligation to cooperate with tax authorities, including providing details of your remuneration and taxes paid.
L) NOTICE ON THE USE OF THIRD PARTY SERVICES
In the course of using our Services, Candidates, Suppliers, and Temporary Employees may wish to access independent third-party websites and services (e.g., job platforms) that are not operated by us. Such independent websites and third parties are not under our control, and we are not responsible for, and have not reviewed or approved, their content or privacy policies (if any). You must use your own independent judgment as to whether you use such independent websites, including your use of the services they offer.
M) DATA TRANSFER TO COUNTRIES OUTSIDE THE EEA
If we have asked you for your marketing consent in relation to our advertising partners or if your data needs to be processed by our customers or suppliers as part of one of our MSP programs and these parties are located outside the European Economic Area, you consent (Art. 49 I a DSGVO) to a transfer to countries outside the European Economic Area and you are aware that a lower level of data protection may exist with these providers/countries than in the European Economic Area.
In particular, there is a risk that your data may be accessed by public authorities for monitoring purposes, even without legal recourse. Exercising data protection rights that you know and are familiar with under the GDPR may be more difficult or even impossible.
N) MARKET RESEARCH PURPOSES
If you have consented to the use of your personal data for market research purposes, this means that we will conduct surveys on satisfaction, NetPromoterScore, people topics, preferences, offers, socio-demographic characteristics, testing of new platforms, test groups, UX testing and brand panels.
O) ID CHECK FOR CANDIDATES AND SUPPLIERS
1) Purpose of data collection / type of data we collect:
Unfortunately, in today’s digital world, we no longer meet many of our candidates, temporary employees and suppliers in person. However, we still want to verify the identity of our individuals (or, when working with companies, those individuals acting on behalf of the company) for the purposes of conducting proper business. Our goal is to follow certain internal compliance standards and to ensure legal requirements (such as the obligation not to provide services to “sanctioned persons” or to provide them only in a limited manner).
To make identification as easy as possible for you, we use a web-based video identification process. A Westhouse employee or an employee of our service provider, acting on our behalf and following our instructions, will ask you to identify yourself with a camera during this process. Various images (screenshots) will be taken of the identification document you are using (the front and back with their respective security features) and of yourself while the conversation is being recorded. We will ask for your consent during the conversation, but before the recording process begins.
(“In the course of establishing your identity, we have the option of taking photographs of you and the entire front and back of your ID card (including its security features). It is also possible for a video call to be recorded both visually and audibly to establish identity. Subsequently, the information is stored in accordance with the law.”).
In addition, the information contained in your identification document, such as first name, last name and citizenship, is processed and documented in this process. Then, after we verify this data and determine that the verification was successful, we delete it. If there are any discrepancies, we will resolve them with you and the data will be stored for that period of time.
This information is necessary to ensure identification and to properly document the process.
2) Legal basis
Art. 6 I f DSGVO (legitimate interest).
3) Retention period
We keep the data collected during the call for the period of the identity check and delete it afterwards. This period is usually a few days. After identity verification, we only store the information that your identity has been verified for the duration of our business relationship and for a period of 3 years beyond that.
4) Alternatives
Video identification is the fastest and most uncomplicated method for you to legitimize yourself to us. We can and will also offer you alternative solutions for identification if you ask us about this and explicitly request this.
P) Country-specific variations of our privacy policy
P.1) Jurisdiction: Switzerland
Our contact details
Country in which you receive services from Westhouse or provide services to Westhouse: Switzerland
Westhouse company responsible for processing personal data: Westhouse Schweiz AG, Dreikönigstrasse 8 · 8002 Zurich
How to contact us:
To access, modify or withdraw personal data that you have provided to us,
if you suspect that your personal information has been misused, lost or accessed without authorization,
to withdraw your consent for the processing of your personal information (if consent is the legal basis for the processing of your personal information), for comments or suggestions about this Privacy Policy.
Postal address
Westhouse Schweiz AG, Dreikönigstrasse 8, 8002 Zurich
Alternatively, you can reach our privacy team and the data protection team by email at: dsb@westhouse-group.com
Contact information for the relevant local regulatory authority
Federal Data Protection and Information Commissioner (FDPIC).
Feldeggweg 1, CH – 3003 Bern
Phone: (+41) (0)58 462 43 95
Fax: (+41) (0)58 465 99 96
Country specific Legal Requirements
Soft opt-in
As described in the body of our Privacy Policy, we are entitled to rely on “soft opt-in” consent with respect to certain marketing messages that we would like to send to you. The following conditions apply to our use of soft opt-in consent: (i) we obtained your email address in connection with the sale of goods or services; (ii) we are using that address solely for direct marketing of our (or substantially similar) services; (iii) you have not objected to such use; and (iv) we clearly indicate your right to object in each such communication.
Opt-In
In all other e-marketing cases, we must obtain your specific “opt-in” consent and document that we have obtained such consent. To comply with our obligations, we follow the consent process commonly known as “double opt-in,” in which we first ask you to consent to e-marketing and then send you an email asking you to confirm that you have given your consent. We will not add you to our marketing list until we receive this second email confirmation.
Transfer outside of Switzerland and the EEA.
If we have asked for your marketing consent in relation to our advertising partners and if these parties are located outside Switzerland and the European Economic Area, you consent (Art. 6 II b Federal Data Protection Act) to a transfer outside Switzerland and the European Economic Area and you are aware that there may be a lower level of data protection with these providers/countries than in Switzerland.
In particular, there may be a risk that authorities may access your data for monitoring purposes even without legal recourse. It may be more difficult or even impossible to assert data protection rights that you are aware of under the Federal Data Protection Act.
Market Research Purposes
If you have consented to the use of your personal information for market research purposes, this means that we may conduct surveys related to satisfaction, NetPromoterScore, people topics, preferences, offers, socio-demographic characteristics, testing of new platforms, test groups, UX testing, and brand panels.
P.2) Jurisdiction: Romania
Our contact details
Country in which you receive services from Westhouse or provide services to Westhouse: Romania
Westhouse company responsible for processing personal data: Westhouse International SRL, Strada Stirbei Voda 69, 010105 Bukarest
How to contact us:
To access, modify or withdraw personal data that you have provided to us, if you suspect that your personal information has been misused, lost or accessed without authorization, to withdraw your consent for the processing of your personal information (if consent is the legal basis for the processing of your personal information),
Postal address
Strada Stirbei Voda 69
010105 Bucharest
Alternatively, you can reach our privacy team and the data protection team by email at: dsb@westhouse-group.com
Contact details of the relevant local supervisory authority
The National Supervisory Authority For Personal Data Processing
28-30 G-ral Gheorghe Magheru Bld.,
District 1, postal code 010336
Bucharest, Romania
Phone: +40 318 059 211
E-mail: anspdcp@dataprotection.ro
Homepage: https://www.dataprotection.ro/