1. Basic Principles of ZUGVOGL for handling your Personal Data
ZUGVOGL strictly adheres to the following basic principles in the protection of your
- ZUGVOGL shall collect and process your Personal Data in accordance
with the provisions of the EU General Data Protection Regulation (GDPR) and the
German Federal Data Protection Act (BDSG).
- ZUGVOGL shall use your Personal Data solely to provide you the
ZUGVOGL Ser-vices on the Internet for which you have registered.
- ZUGVOGL will not pass your Personal Data on to any third party,
neither for advertising, nor for marketing or for any other purposes as for the
ZUGVOGL service provision without your consent or legal permission.
- With the exception of some general information about your
profession you alone decide which of the Personal Data you have made available to
ZUGVOGL in your profile may be displayed by ZUGVOGL to other users of ZUGVOGL
(cf. Section 3 of these Terms and Conditions on Data Protection).
- Persons not registered with ZUGVOGL cannot not view any of
your Personal Data.
The following terms used in these Terms and Conditions on Data Protection
shall have the following meanings:
- "Account" shall mean the (primary) means through which a User
has access to the Platform through his/her Login credentials.
- “Ambassador” shall mean a natural person who uses the
ZUGVOGL Platform on behalf of an Employer.
- "Employer" shall mean an organisation using the Platform for
recruitment and/or employer branding purposes.
- "Information" shall mean Data.
- "Personal Information" shall mean any information relating to
an identified or identifiable natural person (also “personal data”).
- "Profile Information" shall mean the definition as given in
section 3.1 of this Policy.
- "ZUGVOGL Websites" shall mean all websites on which ZUGVOGL
provides the ZUGVOGL Services.
- "Opportunity" shall mean a job, internship, placement or career
event that is advertised by an Employer on the ZUGVOGL Platform.
- "Recruiter" shall mean the natural person who uses the
ZUGVOGL Platform on behalf of an Employer.
- "User" shall mean a Job Seeker, a Recruiter and Ambassador.
- "Visitor" shall mean an individual other than a User, who uses
the public area of the Website, but has not access to the restricted are of the
ZUGVOGL Platform for which a login is required.
- “ZUGVOGL account team” means employees of ZUGVOGL GmbH that
operates and checks the accounts of User and registrations of Job Seekers.
3. Personal Information we collect
We collect three types of Personal Information from or through the Service. The legal bases
for ZUGVOGL’s processing of Personal Information are primarily that the processing is
necessary to fulfil the contractual obligations towards the Users and Ambassadors.
The processing of personal data is necessary for providing the Service in accordance with
ZUGVOGL’s Terms of Service. Furthermore, the processing is carried out in ZUGVOGL’s legitimate
interests, which are further explained in the section “How We Use the Information We Collect”
of this Policy. We may also process data upon your consent, asking for it as appropriate.
Further information may be provided voluntarily.
3.1 User-provided Personal Information
When you use the Service and/or Platform, as a User or as a Visitor, you may provide,
and we may collect Personal Information. There are both mandatory entry fields
(which as marked as such) and optional information you can provide.
For Ambassadors this may be:
- Account Information/ Login details. When you sign up to
our Service, we require certain information like your first name, last
name, email address and city of residence. For the login, the username
and password is required.
- Profile Information. Information about your education,
work experience, skills, travels, sports, interests, language proficiencies
and other information, like your profile picture, birthday (year),
survey answers and information from the uploaded CV.
- Career Preferences. Information about what kind of
internships, jobs and/or employers you prefer.
- Address Book Contact Information. With your consent,
your address book contacts and manually entered contacts’ information
to invite them to use ZUGVOGL.
- We delete this data when you delete your user account.
For Recruiters this may be:
- Account Information/Login details and company information.
When you start using our Service, we require certain information like
your first name, last name, email address and job title and company
information. For the login, username and password is required. On top of
this, you may otherwise choose to provide us information when you fill in
a form, conduct a search, update or add information to your
ZUGVOGL Account, respond to surveys or use other features of the
- Personal Information. As Ambassador you may provide your
name, e-mail address, phone number, work experience, skills, job title,
birthday (year), photo, video, testimonials and survey answers.
3.2 Automatically collected Information
When you use the Service and/or Platform, as a User or as a Visitor, we automatically
collect information, including Personal Information, like:
- Account Information/Login details and company information.
When you start using our Service, we require certain information like your
first name, last name, email address and job title and company information.
For the login, username and password is required. On top of this,
you may otherwise choose to provide us information when you fill in a form,
conduct a search, update or add information to your ZUGVOGL Account,
respond to surveys or use other features of the ZUGVOGL Platform.
- Usage Information. Information about your interactions with the
ZUGVOGL Platform such as the pages or content you view, your searches for
events, internships, placement or jobs and other actions on the
- Data about you is automatically collected by means of tracking
whenever you visit or make use of the ZUGVOGL service. We collect data about
users and third parties on our server. In addition to this, we collect
this information via cookies, pixels and similar tracking technologies
on end devices.
- This takes place with the help of various tracking technologies.
In the socalled "back end", at our web server level, we collect the data
of users and third parties, which we use first and foremost for the
provision and preservation of the security of the ZUGVOGL service.
similar tracking technologies to collect data about users and third parties
to enable the provision of our service and the analysis of user behaviour,
and for statistical purposes. In addition, we record e.g. whether and when
you have opened an e-mail (if your e-mail program permits HTML). Tracking
involves the processing of login data (e.g. date and time of the visit,
referrer, IP address, cookie ID, location data, product and version
information about the browser or app used, device ID or data) and interaction
data (e.g. pages viewed or searches carried out). When we measure user
behaviour for the provision and improvement of our product experience the
data is linked during the analysis with your user ID. In all other cases
tracking is carried out without any linking to the user ID – for example,
for statistical purposes. In order to be able to identify you as a user
during your visit to ZUGVOGL, we use socalled session cookies. These session
cookies are automatically deleted at the end of a session. These cookies are
required to be able to use ZUGVOGL. When you register you can choose to
remain logged in. If you do, a cookie is then saved in the browser
of your end device that means that you don’t need to log in again for as
long as the cookie remains saved. We also conduct a very approximate
geo-localisation that informs us of the towns/cities you have been to.
In order to do this we use your shorted and anonymised IP address, and your
geo-coordinates if you have agreed to this on your mobile end device. We do
not save your precise location. We only store information about which cities
you are in on a regular basis. Specific addresses or geo-coordinates
are not saved.
- Ensuring security
One reason for tracking is to ensure and preserve the legitimate interest of
the protection of users, the security of user data, ZUGVOGL Website, and the
ZUGVOGL service. To this end, we save the data we record for up to
90 days in its full form. Only a limited number of our employees with the
respective authorisation rights have access to this data. The legal basis
for this processing of personal data is Article 6 (1) f) of the
EU General Data Protection Regulation (GDPR).
- Provision of our service
The main purpose of tracking and the analysis of user behaviour that this
entails is to fulfil our contractual obligations. The legal basis for this
processing of personal data is Article 6 (1) b) of the EU General Data
Protection Regulation (GDPR). You can opt out of tracking by
third-party providers if you wish.
- Determination of statistics
We also use tracking technologies to determine statistics about the use of
our services. The legal basis for this processing of personal data is
Article 6 (1) f) of the EU General Data Protection Regulation (GDPR).
You can opt out of tracking by third-party providers if you wish.
- If you’d like to prevent tracking by external providers within
the ZUGVOGL environment, you can deactivate the integration. Please visit
your settings to adjust your tracking settings for all devices.
4. How we use the Information we Collect
We process the information for the provision of ZUGVOGL Service.
4.1 Provide and improve the ZUGVOGL Platform
Enable you to access and use all features of the ZUGVOGL Platform, like, but not limited
to receiving matching Opportunity suggestions.
4.2 If you provide us with your contacts’ information, we may process this
information to facilitate your referral invitations. The legal basis for the
processing of personal data is the consent of the user or ambassador.
- Enable you to communicate with other Users (i.e. if you are a
Job Seeker, to communicate with a Recruiter and if you are a Recruiter to
communicate with Job Seekers and communication between the Job Seeker and the
Ambassador). The legal basis for the processing of personal data is to fulfil the
contractual obligation of ZUGVOGL towards the user and/or Ambassador.
- The Recruiter may view the information of the Job Seeker who
applied for the company of the Recruiter. The Ambassador receives name, e-mail
address and CV in the event that the Job Seeker wishes to get to know the
company of the Ambassador.
- ZUGVOGL account team operates and checks the accounts of User
and the registrations of Job Seekers for the provision of the Service of ZUGVOGL.
- To operate, protect, improve and optimise the ZUGVOGL Platform
and experience, and personalise and customise your experience (such as making
job suggestions and ranking search results), we conduct this analysis and
evaluation based on your interactions with the ZUGVOGL Platform, your search
history and your profile information and preferences. The legal basis for the
processing of personal data is the legitimate interest of ZUGVOGL.
4.3 Provide Customer Service
- ZUGVOGL uses anonymized or aggregated data to research social,
economic and/or labour market trends, like what type of study background are
most in demand or what the preferences of job seekers are when it comes to
finding a job.
- ZUGVOGL uses anonymized or aggregated data to produce
aggregated insights for specific Employers, such as which universities they are
most popular at, how their jobs have been performing on the ZUGVOGL Platform
and share these in a dashboard or a report. These aggregated insights do not
Provide customer service and support, like resolving issues (i.e. bugs).
Send you service or support messages, updates, reminders, security alerts,
account notifications and/or other communications. You may change your
communication preferences at any time, but please be aware that you cannot
opt-out of receiving service messages, including security and legal notices.
The legal basis for the processing of personal data is to fulfil the
contractual obligations of ZUGVOGL towards users and/or ambassadors.
5. For how long will my data be stored
We process and store your personal data as long as this is required to meet our contractual
and statutory obligations. If the data are no longer required for the performance of
contractual or statutory obligations, these will be deleted or anonymized on a regular basis
unless we have your consent for a longer storage or – temporary – further processing is
necessary for the fol-lowing purposes: (i) Compliance with obligations of retention under
commercial or tax law which, for example, may result from the German Commercial Code (HGB),
the German Fiscal Code (AO). As a rule, the time limit specified there for retention or
documentation is two to ten years. (ii) Preservation of evidence under the statutory
regulations regarding the statute of limitations. According to Section 195 et seqq. of
German Civil Code (BGB), theses statutes of limitations may be up to thirty years, the regular
statute of limitation being three years.
We generally retain your Personal Information for as long as is necessary for the
performance of the contract between you and us (see Terms of Service if you are a Job
Seeker and the con-tract between Employer and ZUGVOGL if you are a Recruiter) and to comply
with our legal obligations. If you no longer want us to use your information to provide the
ZUGVOGL Service to you, you can request that we erase and close your ZUGVOGL Account. Please
note that if you request the erasure of your Personal Information, information that you have
shared with others (like applications and messages) may continue to be visible to other Users.
We will, however, disassociate this information from personal identifiers as much as possible.
Because we maintain the ZUGVOGL Platform to protect from accidental and malicious loss and
destruction, residual copies of your Personal Information may not be removed from backup
systems for a limited period of time.
6. To whom we disclose Information
6.1 Sharing of Job Seeker Information with Employers
In order to provide the ZUGVOGL Service and fulfil the proposition that we offer to
you as a Job Seeker (as set out in our Terms of Service) we may share information
(i.e. Profile Information) of the Job Seeker, including Personal Information with Recruiters.
6.2 Sharing of Recruiter Information with Job Seekers
In order to provide the ZUGVOGL Service and fulfil the proposition that we offer to you
as an Ambassador (as set out in the offer between the Employer and ZUGVOGL) we may share
certain information, including Personal Information, with Job Seekers. Subject to your
visibility set-tings which you can adjust in the personal settings section of the ZUGVOGL
Platform, Personal Information like your first name, the first letter of your last name and
job title may be visible to Users or Visitors on your employer page.
6.3 Compliance with law
ZUGVOGL may disclose your information, including Personal Information if required to do so
by law or in the good-faith belief that such action is necessary to comply with applicable
laws, in response to a facially valid court order, judicial or other government subpoena or
warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
ZUGVOGL also re-serves the right to disclose information, including Personal Information
that we believe, in good faith, is appropriate or necessary to (i) take precautions against
liability, (ii) protect ourselves or other from fraudulent, abusive, or unlawful uses or
activity, (iii) investigate and defend our-selves against any third-party claims or
allegations, (iv) protect the security or integrity of the Service and any facilities or
equipment used to make the Service available, or (v) protect our property or other legal
rights, enforce our contracts, or protect the rights, property, or safety of others.
6.4 Aggregated Information
We may also share aggregated information (i.e. information about our users that we combine
together so that it no longer identifies or references an individual user) and other
anonymized information for regulatory compliance, industry and market analysis, demographic
profiling, marketing and advertising, and other business purposes, like creating reports
with aggregated insights for Employers. This aggregated information does not identify you.
6.5 Transfer to third parties
We only pass your personal data on to third parties when this is required to fulfil our
business purposes (i.e. if you are a Job Seeker, to communicate with Ambassadors and if
you are an Ambassador to communicate with Job Seekers), when you have given your consent to
this, or when we are obliged to on legal grounds, by court order, or at the request of
another official authority.
- When you connect with the selected Employer on ZUGVOGL by
clicking “Get In-troduced” or a similar button.
- Subject to your visibility settings which you can adjust in the
“Personal settings” section of the ZUGVOGL Platform, certain information such as
your first name, last name and Profile Information, will be visible to the
Recruiter(s) of the Employer that has posted the concerning Opportunity for as
long that Opportunity is live on the ZUGVOGL Platform, when you meet the
requirements of an Opportunity.
- When you apply to an Opportunity, certain information such as
your first name, last name and Profile Information will be visible to the
Recruiter(s) of the Employer that has posted the concerning Opportunity.
In cases where we work together with external service providers for our data processing
(e.g. in software developers, hosting, e-mail sending providers, technical service
providers, postal providers (letter shops), marketing automation software providers,
market research and survey tool providers and remarketing/retargeting providers), this is
usually - where necessary - carried out on an order processing basis, whereby we remain
responsible for data processing. We review each of these service providers beforehand with
regard to the measures they have undertaken to ensure data protection and data security,
thereby safeguarding the contractual provisions as stipulated by law for the protection of
the personal data.
6.6 Business transfers
If ZUGVOGL undertakes or is involved in any merger, acquisition, reorganisation, sale of
assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all
of our assets for the purpose to continue the Service in a substantial same kind, including
your information in connection with such transaction or in contemplation of such transaction
(e.g. due diligence). In this event, we will notify you before your Personal Information is
processing of personal data is the legitimate interest of ZUGVOGL in the continuation of
7. Your rights and choices
You may exercise any of the rights described in this section by sending an email to
7.1 Managing your Information
You may access and update your information through in your “My Profile” section and/or
“Personal settings” section on the ZUGVOGL Platform. You are responsible for keeping your
Personal Information up-to-date.
7.2 Rights with regard to data protection
You have the right of access pursuant to Article 15 GDPR, the right to rectification
pursuant to Article 16 GDPR, the right to erasure pursuant to Article 17 GDPR, the right
to restriction of processing pursuant to Article 18 GDPR, the right to object pursuant to
Article 21 GDPR and the right to data portability pursuant to Article 20 GDPR. As far as
the right to obtain information and the right to erasure are concerned the restrictions
pursuant to Secs. 34 and 35 German Federal Data Protection Act (BDSG) are applicable.
Moreover, there is a right to appeal to a competent data protection supervisory authority
(Article 77 GDPR in conjunction with Sec. 19 BDSG).
Your consent to the processing of personal data granted to us may be revoked at any time
by informing us accordingly. This also applies for the revocation of declarations of
consent given to us before the effective date of the GDPR (before 25 May 2018). Such
revocations will be effective only for the future with no impact on processing carried out
before the date of revocation. In the event of revocation the processing of personal data
may continue based on a contractual obligation of ZUGVOGL towards you, if applicable.
7.3 Right to object pursuant to Article 21 GDPR
Right to object on individual cases: You have the right to object, on grounds relating to
your particular situation, at any time to the processing of personal data concerning you
which is based on Article 6 para. 1 lit. f GDPR (data processing on the basis of the
balance of interests); this also applies for profiling as defined in Article 4 (4) GDPR.
If you object, we will no longer process your personal data unless we have compelling
justified reasons for such processing which take precedence over your interests, rights and
freedom or, alternatively, such processing serves to assert, exercise or defend legal
Right to object to processing data for the purpose of direct marketing: In individual
cases, we will process for the purpose of direct marketing, we will refrain from using
your personal data for such purposes henceforth.
Such objection may be submitted to [email protected]
8. Minor’s and children’s privacy
Protecting the privacy of young children is especially important. The ZUGVOGL Service is
directed to (university) students and not to children under the age of 16, and we do not
knowingly collect Personal Information from children under the age of 16 without obtaining
parental consent. If you are under 16 years of age, then please do not use or access the
Service at any time or in any manner. If we learn that Personal Information has been collected
on the Service from persons under 16 years of age and without verifiable parental consent,
then we will take the appropriate steps to delete this information. If you are a parent or
guardian and discover that your child under 16 years of age has obtained an Account on the
Service, then you may alert us at [email protected]
and request that we delete that child’s
Personal Information from our systems.
9. Data security
We follow security related laws, regulations, industry standards and best practices
relevant to its line of business in order to protect your business data and personal
information while in transit and at rest in storage facilities. These security measures
and controls, both technical and physical, ensure protection of data against accidental
and unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure
or access, misuse, and any other unlawful form of access. Security Monitoring and Analysis
tools are deployed to provide system health and abnormal behavior indications. Zugvogl
will report the authorities and inform its users of data and information breaches in
accordance with applicable law and will update its solution with the necessary mitigation
to fix the breach. If you believe your Personal Information has been compromised,
please contact us at
10. Google Analytics
We use on your Websites Google Analytics from Google Inc., 1600 Amphitheatre Pkwy,
Mountain View, CA 94043-1351, United States. Google Analytics analyses the traffic on our
website. Google uses the collected data and information, inter alia, to evaluate the use of our
website and to provide online reports, which show the activities on our websites, and to provide
other ser-vices concerning the use of our Websites.
We use the anonymization function "anonymizeIp". By means of this function the IP
address of the Internet connection of the data subject is abridged by Google and anonymised
when accessing our websites from a Member State of the European Union or another Contracting
State to the Agreement on the European Economic Area.
Google Analytics places a cookie. With the setting of the cookie, Google is enabled to analyze
the use of our website. With each call-up to one of the individual pages of this Internet site,
which is operated by the controller and into which a Google Analytics component was integrated,
the Internet browser of the data subject will automatically submit data through the Google
Analytics for the purpose of online advertising and the settlement of commissions to Google.
During the course of this technical procedure, Google gains knowledge of personal information,
such as the IP address of the data subject. The cookie is used to store personal information,
such as the access time, the location from which the access was made, and the frequency of
visits of our website by the data subject. With each visit to our Websites, such personal data,
including the IP address of the Website access used by the data subject, will be transmitted to
Google in the United States of America. These personal data are stored by Google in the United
States of America. Google may pass these personal data collected through the technical procedure
to third parties.
The data subject may prevent the setting of cookies by adjustment of the web browser used. Such
an adjustment to the browser used would also prevent Google Analytics from setting a cookie on
the system of the data subject. In addition, cookies already in use by Google Analytics may be
deleted at any time via a web browser or other software programs.
The data subject may object to the collecting of data:
The installation of the browser add-ons is considered an objection by Google.
Legal basis for the processing of the personal data is Article 6 para. 1 lit. f GDPR.
11. Google reCAPTCHA
We use Google reCAPTCHA from Google Inc. (1600 Amphitheatre Parkway, Mountain View,
CA 94043, USA) to protect the transfer of electronic forms (i.e. registration, contact form).
This service uses your IP-address and further from Google necessary data to Google. The
Article 6 para. 1 lit. f GDPR.
We use SparkPost in 9160 Guilford Road, Columbia, MD 21046, USA for the sending of our
newsletter. SparkPost participates in and has certified its compliance with the EU-U.S.
Privacy Shield Framework. SparkPost primarily stores personal information (i.e. name, e-mail
address, subject line and e-mail content) sent or collected via or by SparkPost in the European
Legal basis for the processing of the personal
data is Article 6 para. 1 lit. f GDPR.
We use MailChimp to send out newsletters via email. MailChimp is a Georgia limited liability
company whose legal name is The Rocket Science Group LLC d/b/a MailChimp, based in Atlanta, USA.
MailChimp may collect personal information, such as distribution lists which contain name,
email address, subject line and e-mail content and other information relating to those email
addresses. For further information about the type of personal information MailChimp collects,
used to create, send and manage emails, measure email campaign performance, improve the used
features for our users, evaluate your use of our website, compile reports on website activity
for website operators, and provide other services relating to website activity and internet
usage. MailChimp may transfer this information to third parties where required to do so by law,
or where such third parties process the information on MailChimps’s behalf. MailChimp collects
information about when you visit the website, when you use the services, your browser type and
version, your operating system, and other similar information.
MailChimp is based in the United States of America (USA) and the information collected about
your use of the website (including your IP address) will be transmitted to and stored by
MailChimp on servers located outside of Europe. By subscribing to our newsletter:
You consent to your personal information being collected, used, disclosed and stored as set out
You understand and acknowledge that this service
utilises a MailChimp platform, which is located in the United States of America (USA) and
relevant legislation of the USA will apply. MailChimp participates in and has certified its
compliance with the EU-U.S. Privacy Shield Framework.
You can opt out of our mailing list if you choose the ‘unsubscribe’ service provided by
however, you may not be able to use the services provided by MailChimp if cookies are disabled.
Legal basis for the processing of the personal data is Article 6 para. 1 lit. f GDPR.
We offer the opportunity to give feedback with the help of software from the company
UserVoice Inc., 121 2nd St, Floor 4, San Francisco, CA 94105, USA. User Voice has
self-certified to the EU-U.S. Privacy Shield. Your data (name, e-mail address, subject line
options. When a user presses the UserVoice button, the browser establishes a direct connection
to the UserVoice servers and the data you have entered is stored there. We receive a
notification by UserVoice that a contact request has been received and answer this request
via the UserVoice IT infra-structure. Details on how to deal with your personal data are found
Legal basis for the processing of the personal data is Article 6 para. 1 lit. f GDPR.
15. Changes and updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may
update from time to time. If we modify this Policy, we will make it available through the
Service, and indicate the date of the latest revision, and will comply with applicable law.
Your continued use of the ZUGVOGL Service after the revised Policy has become effective
indicates that you have read, understood and agreed to the current version of the Policy.
16. How to contact us
Please contact us with any questions or comments about this Policy, your Personal Information,
our use and disclosure practices, or your consent choices by email at
If you have any concerns or complaints about this Policy or your Personal Information, you
may contact ZUGVOGL’s Data Protection Officer by email at