Privacy Policy:
We take the protection of your personal data very seriously and want you to feel comfortable on our website. This is why we treat your personal data confidentially and in accordance with the statutory data protection regulations and this Privacy Policy. We would like to inform you below about the processing of personal data in the context of using our website.
Preamble:
Look & Graffelder GmbH (hereinafter referred to as “Look & Graffelder” or “we”), Hafenstrasse 4a, 51063 Cologne, represented by its managing directors Oliver Look and Robin Kellmann, supports companies (hereinafter referred to as “Employers”) as a service provider in their search for highly qualified personnel (hereinafter referred to as “Candidates”) and provides them with top-level executives, managers, high potentials and experts who cannot be found through the traditional recruitment channels. For this purpose, Look & Graffelder GmbH collects, stores and processes personal data of the Candidates and, if the respective Candidate fulfils the requirement profile of the respective employer, transmits this data to the Employers in accordance with this Privacy Policy.
1. Data controller
The controller for the processing of personal data on this website within the meaning of the GDPR is:
Look & Graffelder GmbH
Hafenstraße 4a
51063 Köln
Telefon: 0221 / 98592 – 0
Telefax: 0221/98592-229
E-Mail: tiger@l-g.de
Represented by the Managing Directors: Oliver Look and Robin Kellmann
2. General
2.1 Terminology
With regard to the terms used in this data protection declaration, we refer to the definitions in Art. 4 GDPR.
When visiting our website, personal data such as inventory data, contact data, content data, contract data, usage data and meta and communication data of customers, interested parties and visitors to this online offer are processed.
2.2 Legal basis
The legal basis for processing the data is found in Art. 6(1) GDPR. Insofar as the processing of the data is based on our legitimate interest, the legal basis is Art. 6(1)(f) GDPR, whereby our legitimate interest is usually the secure and efficient operation of this online offer or our economic interest. If we process your data on the basis of your consent, the legal basis is Art. 6(1)(a) and Art. 7 GDPR. If we process your data in order to fulfil our own obligations, the legal basis for this is Art. 6(1)(c) GDPR. If vital interests of the data subject or another natural person make the processing of personal data necessary, the legal basis for the processing is Art. 6(1)(d) GDPR.
2.3 External service providers
We use external service providers to operate this website. In doing so, they may obtain knowledge of your personal data.
Cooperation within the scope of a contract processing relationship with external service providers takes place exclusively on the basis of a contract processing agreement (Art. 28 GDPR), as well as on the basis of our legitimate interests in providing this online offer efficiently and securely, on the basis of consent granted by you or on the basis of legal permission (for example, if the transfer is necessary for the performance of a contract).
Every service provider is checked before we start working with them. In particular, we take a critical look at the technical and organisational measures taken by the service provider for data protection and data security. Only if it is ensured that the legally stipulated contractual regulations for the protection of your personal data are adhered to, will a cooperation take place.
3. Collection of access data and logs files
Already when visiting our website, certain data is processed by us or our hosting service provider on the basis of our legitimate interest within the meaning of Art. 6(1)(f) GDPR. This includes IP address, date, time, accessed file/page/resource, as well as browser information.
After 7 days, the IP address is deleted from all systems related to the use of this website, until then the storage is required for security reasons. The remaining data is stored for a longer period, but a personal reference can no longer be established after the IP address has been deleted.
In exceptional cases, the data will be stored for a longer period, i.e. if the storage is necessary for evidentiary purposes. The data will then be deleted after the incident has been clarified.
4. Contact
Personal data is collected when you contact us, for example by e-mail. Which data is collected depends on the respective method of contact (e.g. e-mail address when contacting us by e-mail) and the data transmitted by the person concerned (name, availability data, etc.). The collected data is stored exclusively for the purpose of answering your request or to be able to contact you to answer your request.
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent. The processing of this data is based on Art. 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary for implementing pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), provided you have given such consent.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (for example, after we have completed processing your enquiry). Mandatory legal provisions – in particular retention periods – remain unaffected.
5. Cookies
We use cookies to make your visit to our website as enjoyable as possible and to allow you to use certain functions. Cookies are small text files that are stored on your end device via your browser. A distinction is made between session cookies, which are automatically deleted by your browser when you end your visit to our website, and cookies that allow your browser to be recognised the next time you visit our website (persistent cookies). A session ID is stored in a session cookie. This is a randomly generated unique identification number.
Insofar as the cookies we use process personal data, the processing is carried out either in accordance with Art. 6(1)(b) GDPR for the performance of a contract, in accordance with Art. 6(1)(a) GDPR if you have given your consent for non-essential cookies, or in accordance with Art. 6(1)(f) GDPR for the protection of our legitimate interests, whereby our legitimate interest is to provide you with an especially customer-friendly visit to our website, as well as to ensure the seamless use of our website. In addition, the storage takes place with your consent if you have given such consent when you first visited our website or if you make a corresponding declaration later. You can change or revoke your consent at any time in connection with the cookie declaration on our website.
We also work with advertising partners to tailor our website to your interests. In this case, cookies from third-party providers may also be stored on your hard drive when you visit our website. In this case, we will inform you separately and in detail about the use of cookies from third-party providers and the scope of the information collected.
If you wish to restrict the use of cookies, you can configure the appropriate settings in your browser. You can be informed about the setting of cookies, individually decide whether to accept them or exclude the acceptance of cookies for certain cases or in general. You can find out how to set or change the settings at the following links:
Internet Explorer: https://windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: https://support.google.com/chrome/bin/answer.py?hl=de&hlrm=en&answer=95647
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
und https://support.apple.com/de-de/HT201265
Opera: https://help.opera.com/Windows/10.20/de/cookies.html
On our website, we distinguish between necessary and non-necessary (e.g. statistics, marketing, external media) cookies. Necessary cookies help to make a website usable by enabling basic functions such as page navigation and access to secure areas of the website. The website cannot function properly without these cookies. They are necessary.
Cookies from statistical services help us track the behaviour of users on our website in order to improve our service and our website for you. We only use these cookies with your prior consent.
Marketing cookies store information about websites you have used. This data is used to display advertisements tailored to your interests. Marketing cookies may only be used with your prior consent.
Cookies for external media are those for social media or video platforms (e.g. Facebook, Instagram, Twitter, YouTube). Your prior consent is also required for this.
Under no circumstances will the data we collect be passed on to third parties without your prior consent or linked to personal data without your consent.
Storage period and cookies used
We use the following technically necessary cookies:
Borlabs Cookie
If you have given us your prior consent to the use of one or more cookies, the following cookies may be used on our websites:
Facebook (external media)
Google Maps (external media)
Instagram (external media)
Twitter (external media)
Insofar as these cookies may (also) affect personal data, we inform you about this in the following sections.
Consent with Borlabs Cookie
Our website uses Borlabs Cookie Consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection law. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).
When you enter our website, a Borlabs cookie, which stores the consents you have given or the revocation of these consents, is stored in your browser. This data is not shared with the Borlabs cookie provider.
The collected data will be stored until you request us to delete it or until you delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
Borlabs cookie consent technology is used in order to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.”
6. Third-party services
Within our website, we use content and service offers from third-party providers. We use these on the basis of your prior consent (Art. 6(1)(a) GDPR), which you have declared when entering our website and the data protection settings there. If you have not declared your consent here and also in direct connection with the respective offers, these services remain unused. If you have given your consent, we will, for example, enable you to see exactly where our locations are using street maps in order to make it easier for you to find us.
6.1 Google Maps
We use Google Maps (API) from Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on our website. Google Maps is a service that allows maps to be displayed on the website.
When you open a sub-page that contains such a map, it is first necessary for you to confirm the retrieval of the maps by pressing a corresponding button. After you have confirmed the retrieval of a map, information such as your IP address is transmitted to Google’s server in the USA and stored there.
In principle, the USA has a level of data protection that – as the ECJ has ruled – does not fully match the level of data protection in the EU. There is no adequacy decision or corresponding appropriate guarantees. It is possible that government authorities may also have access to your data within the framework of the laws applicable in the USA. Therefore, there is a data protection agreement with Google that includes EU standard contractual clauses. You can find more information at: https://business.safety.google/compliance/#!#gdpr
If you have a Google account and are logged in, the data will also be associated directly with your account.
If you are a Google member and do not want Google to link the data it collects about you to your Google account, you can prevent this by logging out and deleting your cookies before visiting our website.
Even if you are not a member or not logged in, Google stores the data as user profiles and evaluates them on the basis of its legitimate interests in displaying personalised advertising, market research and the needs-based design of its website (Art. 6(1)(f) GDPR).
You have the right to object to this creation of user profiles. To exercise your right to object, you must contact Google.
If you would like to prevent the transmission of your data to Google through the use of Google Maps in the future, you have the option of deactivating the Google Maps service by switching off the JavaScript application in your browser.
You can find Google’s terms of use at
https://www.google.de/intl/de/policies/terms/regional.html.
The additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html.
Detailed information on data protection regarding the use of Google Maps can be found on the Google website (“Google Privacy Policy”): ): https://www.google.de/intl/de/policies/privacy/
You can make additional settings regarding the use of your data for personalised advertising at https://adssettings.google.com/authenticated
6.2 Google Fonts
In addition to the maps from Google Maps, we also integrate fonts (Google Fonts) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The use of Google Web Fonts allows us to ensure a uniform presentation of our online offer and thus represents a legitimate interest within the meaning of Art. 6(1)(f) GDPR.
If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
You can find more information about Google Web Fonts at unter https://developers.google.com/fonts/faq and in Google’s privacy policy:
Google: https://www.google.com/policies/privacy/.
We have entered into a data protection agreement with Google taking into account EU standard contractual clauses. You can find more information at: https://business.safety.google/compliance/#!#gdpr
6.3 Facebook and Instagram
Components of the social networks Facebook and Instagram are integrated into our website.
A social network is an online service through which users can communicate and interact with each other in a virtual space. This social meeting place (online community) operated on the internet can be used to exchange opinions and experiences and to make personal or company-related information available to other users within the internet community. Facebook allows users to create personal profiles, upload photos and network with other users via friend requests, among other things.
The operator of Facebook and Instagram is Meta Platforms, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. If you live outside the USA or Canada, Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, is responsible for processing personal data.
We are jointly responsible with Meta Platforms Ireland Ltd. for collecting data that Facebook receives through the components embedded on our websites. The same applies to the possible transmission of data to Facebook in connection with content and advertising information adapted to the presumed interests of users. Likewise, it is possible that Facebook uses information to address users via Facebook Messenger and improve the recognition of which content or advertising information presumably corresponds to the interests of the users.
If you open a page on our website on which a Facebook component (Facebook plug-in) has been integrated, your IT system will automatically be prompted by the respective component to download a representation of the corresponding Facebook component from Facebook. All Facebook plug-ins can be found in the complete overview at developers.facebook.com/docs/plugins/.
This technical procedure enables Facebook to determine which specific sub-page you are visiting.
If you are also logged in to Facebook, Facebook can recognise which specific sub-page has been visited each time you visit our website and for the entire duration of your visit. The installed Facebook component collects this information and Facebook assigns it to the respective Facebook account of the user. If you click on one of the Facebook buttons integrated on our website or make a comment, this information is assigned to your personal user account by Facebook and this personal data is stored.
Each time you visit our website and are logged in to Facebook at the same time, Facebook receives information about this via the respective component. This is independent of whether you click on the Facebook component or not. If you do not wish your data to be transmitted to Facebook in this way, you can prevent this by not giving your consent and ensuring that you are logged out of your Facebook account before accessing our website.
Facebook’s data policy, which can be found at https://de-de.facebook.com/about/privacy/,
explains which personal data is collected, processed and used by Facebook. It also explains the settings Facebook offers to protect your privacy. We have entered into a special agreement with Facebook (“Controller’s Addendum”). This agreement, which can be found at https://www.facebook.com/legal/controller_addendum, regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms ) and that it complies with the rights arising from the GDPR.
6.4 Twitter
We have integrated elements of the short message service Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA on our website, which you can use if you have declared your consent to their use.
The data collected about you when using the service is processed by Twitter and may also be transmitted to countries outside the European Union. This concerns your IP address, the application used, details of your terminal device (including device ID and application ID), information on websites accessed, your location and your mobile phone provider.
Twitter assigns this data to the data of your Twitter account or your profile. The data may be passed on to third parties by Twitter, which we have no control over. Details on the use of data by Twitter can be found here: hier: https://twitter.com/de/privacy as well as on the possibility of viewing your own data on Twitter. (https://help.twitter.com/de/managing-your-account/accessing-your-twitter-data) We do not collect or process any further data from your use of Twitter.
You can restrict the processing of your data by choosing the appropriate settings in your Twitter account. You can find information on this on the following Twitter super pages: https://support.twitter.com/articles/105576#, https://help.twitter.com/de/using-twitter/tailored-suggestions, https://help.twitter.com/de/rules-and-policies/twitter-cookies.
Twitter assures (https://twitter.com/de/privacy) that even when transmitting data to the USA, it will comply with legal framework conditions that guarantee a level of protection equivalent to EU law and also bases itself on the standard contractual clauses of the EU Commission.
7. Additional data processing in the context of the candidate search
7.1 Purposes of processing in the context of the candidate search
The data processing by Look & Graffelder is carried out with the aim of obtaining information about candidates using the data collected, evaluating this information according to the employers’ requirements for the suitability of potential employees and placing the candidates who meet these requirements with the employers for filling the jobs that the employers commission Look & Graffelder to find candidates to fill.
7.2 Legal basis for data processing in the context of the candidate search process
The processing is lawful under Article 6(1)(a) of the GDPR (the candidate’s consent) and Article 6(1)(f) of the GDPR (legitimate interest in the processing) because the candidates’ personal data is processed on the basis of the declared consent of the respective candidate or a legitimate interest of Look & Graffelder in the processing, which is the commercial placement of highly qualified personnel with different employers.
7.3 Data collection in the context of the candidate search
Among other things, Look & Graffelder collects the following personal data of the candidates for the purpose of placing the candidates with the employers, insofar as the data are provided by the candidate or are publicly available:
Name, place of residence, date of birth, educational qualifications, foreign languages, employer, profession, salary, period of notice, references, telephone no., e-mail address, etc.
7.3.1 Active sourcing in the context of the candidate search
Look & Graffelder also searches for candidates using what is known as active sourcing. In active sourcing, suitable candidates are identified on the basis of freely accessible information. For this purpose, Look & Graffelder collects freely accessible personal data about the potential candidates via various media, in particular via internet search engines and social networks.
7.3.2 Notification of persons subject to active sourcing
The persons subject to active sourcing are not notified of the collection of their personal data, which is freely accessible to everyone. This is because, based on the weighing of the effort that such notification would require and the interests of the data subject that are worthy of protection, such notification represents a disproportionate effort.
Transmission by the candidates
Personal data is also collected from candidates on their own initiative or when approached by Look & Graffelder. As part of this, the candidate agrees to the processing of their personal data by Look & Graffelder and its transfer to employers for the purpose of filling vacancies.
7.4 Data storage and storage period in the context of the candidate search
Look & Graffelder stores the collected personal data of the candidates on servers rented by it from Insigma IT Engineering GmbH, Europaallee 31, 50226 Frechen on the territory of the Federal Republic of Germany in Frechen. Insigma IT Engineering GmbH has given a contractual undertaking to Look & Graffelder to comply with data protection regulations and to guarantee the security of the data stored on its servers. The personal data collected will be stored until the respective candidate revokes their consent to data processing or ceases to be a candidate for placement with employers due to age (usually by reaching the statutory retirement age).
7.5 Data evaluation in the context of the candidate search
The data is evaluated by the Look & Graffelder consultant responsible for the respective commissioned placement on the basis of the data provided or confirmed by the candidate during a telephone interview or a personal meeting with the candidate.
In the process, the Look & Graffelder consultant checks the professional suitability of the candidate against the requirements of the respective client of Look & Graffelder.
7.6 Disclosure of data in the context of the candidate search
As part of the assignment by employers, Look & Graffelder will provide the employer with the personal data of candidates who, following an evaluation by Look & Graffelder, meet the requirements of the employer seeking employees for the job to be filled and insofar as this is necessary for the intended placement.
8. Data subjects’ rights
The applicable data protection law grants you comprehensive data subject rights. You have legal rights to information, correction, deletion, restriction of processing and objection to the processing as well as a right to data portability. In addition, you can revoke any consent you may have given to processing at any time and complain to a supervisory authority.
8.1 Right to information
Upon request, Look & Graffelder will provide information in accordance with Art. 15(1) GDPR about the data processed by them and a copy of the personal data free of charge immediately after receipt of the request for information, but within one month at the latest.
In complex cases, the information may, if necessary, only be provided within two further months, i.e. within three months after receipt of the request for information. If such a complex case exists, the person requesting the information shall be informed within one month of receipt of their request, stating the reasons leading to the delay.
The right to information also includes information on whether personal data of the person requesting information is being processed at all.
If personal data of a person and thus of a candidate has been collected by Look & Graffelder, the right of access extends to information about the candidate’s personal data processed by Look & Graffelder, including information about where and how the personal data was collected as well as any further information about the processing of the personal data.
If personal data is transmitted to third countries, the candidates concerned can also request information about the appropriate safeguards taken in connection with the data transfer in accordance with Art. 46 GDPR (e.g. agreed standard data protection clauses or binding internal data protection regulations). However, personal data will not be transmitted by Look & Graffelder.
The information shall be provided in writing, by electronic means or verbally upon express request. However, if verbal provision of information is requested, the identity of the person requesting information must be proven in another form. If the request for information is made electronically, the information to be provided shall be made available in a common electronic format (e.g. a PDF).
In any case of a request for information, Look und Graffenfelder will ensure that appropriate security requirements are met when providing the information.
8.2 Right of objection or revocation of consent
Insofar as we process your data on the basis of our overriding legitimate interest, you have the right to object to this processing for the future at any time on grounds arising from your particular situation.
We will then no longer process this data unless there are compelling legitimate grounds for the processing which override your interests or the processing is necessary for the assertion, exercise or defence of legal claims. However, we will then restrict the processing as much as possible.
If we process your data on the basis of consent, you have the right to object to this processing at any time. If you exercise this right, we will stop processing your data.
8.3 Complaint to the supervisory authority
Wenn Sie der Meinung sind, dass die Verarbeitung Ihrer personenbezogenen Daten nicht den gesetzlichen Vorgaben entspricht, haben Sie die Möglichkeit, sich bei einer Aufsichtsbehörde zu beschweren. Dies können Sie zum Beispiel bei der für uns zuständigen Aufsichtsbehörde tun.
The supervisory authority responsible for us is:
State Commissioner for Data Protection and Freedom of Information Nordrhein-Westfalen
PO BOX 20 04 44
40102 Düsseldorf
Tel.: 0211/38424-0
Fax: 0211/38424-10
E-Mail:poststelle@ldi.nrw.de
8.4 Right to rectification of personal data
If a candidate’s request for information pursuant to section 3 of this privacy policy has revealed that the personal data stored about them is inaccurate or if the personal data has changed for other reasons (e.g. marriage, acquisition of further qualifications, etc.), the candidate may request that their personal data be corrected at any time.
8.5 Right to deletion of personal data
Candidates may request the full or partial deletion of their personal data at any time. The candidate’s personal data which the candidate requests to be deleted will be deleted completely and definitively.
8.6 Restriction of proces
Candidates can restrict the scope of their personal data being processed and the scope of the processing of that data at any time by making a declaration to Look & Graffelder or its data protection officer.
8.7 Assertion of the rights of the data subjects
If you wish to request information about the data stored about you or assert other data subject rights, please contact us via the following contact option:
Look & Graffelder GmbH
Hafenstraße 4a
51063 Köln
Tel.: 0221/98592-100
Fax: 0221/98592-229
E-Mail: tiger@l-g.de
9. Duration of the storage of personal data
We generally only store your data for as long as processing is necessary for the purpose for which the data was originally collected. We store your personal data for no longer than the respective statutory retention periods provide for. This means that we store your data for 6 years in accordance with Section 257(1) of the German Commercial Code (HGB) and for 10 years in accordance with Section 147(1) of the German Tax Code (AO).
After this period has expired, your data will be routinely deleted unless it is required for the fulfilment or initiation of a contract and we have no legitimate interest in further processing.
10. Documentation obligations
Look & Graffelder fulfils the documentation obligations regarding the handling of personal data. For this purpose, Look & Graffelder records, among other things, which personal data is collected in which manner, where it is stored, where and for what purpose the data is processed and to whom it is passed on.
11. Changes to the data protection regulations
Look & Graffelder reserves the right to change security and data protection measures if this becomes necessary due to technical developments. In these cases, the Privacy Policy will also be amended accordingly. For this reason, please note the current version of the Privacy Policy.
12. Scope
This Privacy Policy applies to the Look & Graffelder websites and the data we collect and store and process within our area of responsibility. It does not apply to data outside the area of responsibility of Look & Graffelder.