Data Protection Statements
English & German
Data Protection Statement
We are very pleased that you are interested in CONGRUENCE.
Discretion is our highest priority as a personnel consultancy. Consequently, data protection is also very important to us. The collection and processing of your personal data is carried out whilst observing the applicable provisions under data protection law, in particular, the General Data Protection Regulation ("GDPR") and the German Federal Data Protection Act (Bundesdaten-schutzgesetz or "BDSG").
The following data protection statement applies to the utilization of our online offer www.congruence.info (hereinafter referred to as the "Website").
1 Controller and Data Protection Officer
The controller responsible for the collection, processing and utilization of your personal data within the meaning of Art. 4 no. 7 GDPR is
Executive Search & Advisory
60322 Frankfurt am Main
Phone: +49 69 – 24 00 72 79
legally represented by its managing director, Anne de Vesian von Bredow.
Our company data protection officer can be reached under the above address and via email at email@example.com.
Users of this Website may contact the data protection officer pursuant to Art. 28 para. 4 GDPR, if they have any questions regarding data protection or on the collection, processing or use of their personal data or want to obtain information on, rectification of, blocking of, revocation or deletion of data or the revocation of issued consents.
In the event of offers by other providers ("Third-Party Offers") being accessible from our internet offer, our data protection policy does not apply to these Third-Party Offers. In this case, neither are we responsible, within the meaning of Art. 4 no. 7 GDPR, for the processing of your personal data in the course of such Third-Party Offers.
2. General Purposes of the Processing Activity
We use personal data for the purposes of operating our Website and in the general framework of the services we provide.
3. The Data we collect and why we do so
The hosting services utilized by us serve to make available the following services: Infrastructure- and platform services, computing capacity, storage space and database services, security services as well as technical maintenance services, all of which we use for the purpose of operating the Website.
In doing so, we and/or our hosting provider process inventory data, contact data, content data, contract data, user data, meta- and communication data of clients, interested parties and visitors of this Website on the basis of our legitimate interests in making our Website available in an efficient and secure manner pursuant to Art. 6 para. 1 sentence 1 f) GDPR in conjunction with Art. 28 GDPR.
3.2 Access Data
When you use our Website, we will collect information concerning you. We automatically collect information on your user behaviour and your interaction with us and register data reaching your computer or mobile device. We collect, save and process data concerning any access to our Website (what are known as server log files). The following information will be collected without any action on your part and will be saved until its automatic deletion:
- Name and URL of the downloaded file;
- Date and time of access;
- Data volume transferred;
- Report on successful access (HTTP answer code);
- Browser type and browser version;
- Operating system;
- Referrer URL (viz. the website you visited prior to our Website);
- Websites being called up by the user’s system via our Website;
- Internet service providers of the user as well as
- IP address and the requesting provider.
The mentioned data will be processed by us for the following purposes:
- Ensuring the establishment of a smooth connection to the Website;
- Ensuring of a smooth use of our Website;
- Evaluation of the system’s security and stability as well as
- For further administrative purposes.
We use this protocol data without any specific assignment to your person or other profiling for statistical evaluations for the purpose of the operation of, the security and the optimization of our Website, but also for the purposes of anonymous record of the number of visitors to our Website (traffic) as well as regarding the scope and type of use of our Website and services, similarly for billing purposes, in order to quantify the number of clicks received by our cooperation partners. On the basis of this information, we can provide personalized and location based contents and analyse the data traffic, search for and eliminate errors and improve our services.
The legal basis of data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest may be derived from the abovementioned purposes of data collection. In no event will we use the collected data for the purpose of drawing conclusions about your person.
3.3 Processing of Candidate Data
If you should submit your application via our Website, via email or by post, we will collect and process the following electronic data in this connection:
- Title, last name and first name;
- Email address as well as
- Additional information and documents, such as cover letter, CV, references, which you supply to us in connection with your application.
Furthermore, we store personal data obtained from sources that are publicly accessible, such as the internet and the press, and which may be processed in a permissible manner.
By submitting your personal data, you declare your consent to CONGRUENCE’s adding this data to its database.
The adding of data to the database enables the establishment of contact with respect to an appropriate vacancy if CONGRUENCE becomes active on behalf and in the interest of an employer who is looking for personnel.
A transfer of this data to third parties will be carried out, in the individual case, only if CONGRUENCE has informed you in advance.
The processing of data for the purpose of making contact with CONGRUENCE is carried out pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of the consent voluntarily declared by you. You may revoke your consent at any time. In this case, the data will be deleted in full and correctly.
Upon completion of the application process, we delete your data after expiry of a retention period of 6 months. Storage for a longer period will be carried out only if we are obliged to do so pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR on the basis of retention and documentation obligations under tax and commercial law or if you have consented to an extended storage pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR.
We use what is known as session cookies, in order to optimize our Website. A session cookie is a concise text file which will be sent by the respective server when you visit an internet site and will be stored temporarily on your hard disk. This file itself contains what is known as session ID which makes it possible to assign different requests of your browser to a joint session. This enables us to recognize your computer if you return to our Website. These cookies will be deleted if you close your browser. They serve, for instance, to enable you to use the shopping basket function between several pages.
To a small extent, we also use persistent cookies (which are similarly small text files saved on the terminal device), which remain on the terminal device and enable us to recognize your browser during your next visit. These cookies will be stored on your hard disk and delete themselves after the predetermined time. Their lifespan is 1 month to 10 years. In doing so, we are able to present our offer in a more user-friendly way, which is likewise more effective and more secure and we can also show you, for instance, information which is specifically matched to your interests.
We have a legitimate interest in using cookies pursuant to Art. 6 para. 1 sentence 1 f) GDPR, because we need to make our Website more user-friendly, more effective and more secure.
These cookies store, inter alia, the following data and information:
- Log-in information;
- Language settings;
- Any search terms entered on your side as well as
- Information about the number of visits to our Website as well as the use of individual functions of our internet presence.
In the event a cookie is being activated, the cookie is assigned an identification number, but your personal data is not assigned to this identification number. Your name, your IP address or similar data, which might permit an assignment of the cookies to you, will not be inserted in the cookie. On the basis of cookie technology, we only receive pseudonymized information, for instance, on the pages of our shop which have been visited or regarding the products that have been looked at, etc.
You may change the settings of your browser so that you will be informed beforehand of the setting of any cookies and may decide, in the individual case, whether you will exclude the acceptance of cookies for certain cases or as a general rule, or whether you will even prevent the setting of cookies in full. However, this may result in the functionality of this Website’s being reduced.
In order to register for the newsletter, we need the data which is being retrieved during the application process. The registration for the newsletter will be recorded.
The legal basis of sending the newsletter is formed by your consent pursuant to Art. 6 para. 1 sentence 1 a) in conjunction with Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb or "UWG"). Our legitimate interest in being able to prove that the sending of the newsletter was carried out with your consent constitutes the legal basis of recording the application.
You may revoke your consent to receive the newsletter at any time and thus unsubscribe the newsletter. Sending a notice in text form to the contact details mentioned under item 1 (for instance by email, fax, letter) will suffice. You will, of course, also find an unsubscribe link in any newsletter.
Your cancelling of the subscription to our newsletter will mean that we will no longer be able to carry out data processing based on the consent in future and will delete the data unless any other legal basis or legal retention obligations exist.
3.6 Email Contact
If you contact us (for instance via contact form or an email), we will process your specifications electronically to process the query as well as should there be any follow-up questions.
If the data processing is carried out for the execution of pre-contractual measures, which will be done upon your request, and/or if you are already recorded in our database, for the execution of the contract, the legal basis of this data processing shall be Art. 6 para. 1 sentence 1 b) GDPR.
Other personal data will be processed only if you declare your consent (Art. 6 para. 1 sentence 1 a) GDPR) or if we possess a legitimate interest in processing your data (Art. 6 para. 1 sentence 1 f) GDPR). Such a legitimate interest lies, for instance, in providing an answer to your email.
3.7 Use of Data which has been provided without having been requested to do so
If you provide us with your personal data in other cases (for instance by handing over a business card, sending a letter or an email), we will include this data in the database we use and store it there. This shall be done on the basis of Art. 6 para. 1 f) GDPR and our legitimate interest in the efficient management of our business contact’s data as well as in ensuring the use of such data in a manner that is data protection conform. This data will be deleted if you request us to do so unless any legal retention requirements exist or we are not entitled to store the data by other means.
3.8 The Intention to transmit Data to a third Country or an international Organisation
Transfer or any other form of transmission of your personal data to a third country or international organization pursuant to Art. 44 ff. GDPR will not be effected, unless this is explicitly necessary for the purpose of processing your application and the abovementioned purposes and services of CONGRUENCE and you have expressly declared your consent to this transfer beforehand.
4. Google Analytics
We use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses what is known as "cookies", text files that will be stored on your Computer and which make it possible to analyse your use of the Website. As a general rule, the information created by the cookie regarding the use of this Website by the visitors to the Website will be transferred to a Google server in the United States, where they are saved.
This is where our legitimate interest within the meaning of Art. 6 para. 1 sentence 1 f) GDPR lies.
Google is subject to the privacy shield agreement entered into between the European Union and the United States and has certified this agreement. In doing so, Google has agreed to comply with the standards and provisions of European data protection law. You will find more detailed information on this point under the following link below: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
We have activated the IP anonymization on this Website (anonymizeIp). In doing so, however, your IP address will be shortened by Google beforehand within the Member States of the European Union or in other Contracting States to the Agreement on the European Economic Area. Only in exceptional cases will your full IP address be transferred to a Google server in the United States and shortened there. On our instruction, Google will use this information in order to evaluate your use of the Website, in order to compile reports on the Website activities and in order to provide further services to us in connection with the Website use and the use of internet.
The IP address which is transferred from your browser by Google Analytics will not be linked to any other Google data. You may prevent cookies being saved by a corresponding setting on your browser software. However, we wish to point out that you may then possibly no longer be in a position to use all functions of this Website in full.
In addition, you may prevent the transfer of data created by the cookie and referring to your usage of the Website (including your IP address) to Google as well as the processing of this data by Google, by downloading and installing the browser plugin which is available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Alternatively to the browser plugin or inside of browsers on mobile devices you may click on the following link, in order to set an opt-out Cookie, which will prevent the registration by Google Analytics within this Website in future (this opt-out cookie will work only within this browser and only for this domain. If you delete the cookies in this browser you will have to click this link once again): [Google Analytics deaktivieren].
5. Storage Period
Unless specifically provided for otherwise, we will store personal data only for so long as this is necessary to fulfil the purposes we are aiming at.
In some cases, the legislator provides for the retention of personal data, for instance, in tax or commercial law. In these cases, we will continue to store data solely for these legal purposes, but the data will not be processed otherwise and will be deleted after the expiry of the legal retention period.
6. Your Rights as Person Concerned by Data Processing
You are entitled to various rights with respect to your personal data pursuant to the applicable laws. If you want to assert these rights, please address your request via email or letter – and whilst uniquely identifying your person – to the address mentioned under item 1.
Hereinafter you will find an overview of your rights:
6.1 Right to request Confirmation and Information
Pursuant to Art. 15 GDPR, you have the right to receive clear information regarding the processing of your personal data.
You have the right, at any time, to receive confirmation by us as to whether personal data concerning yourself has been processed. If so, you have the right to request free information about the personal data we have stored about you together with a copy of this data. Furthermore, there is a right to the following information:
1. The purposes of processing;
2. The categories of personal data which are being processed;
3. The recipients or categories of recipients vis-à-vis the personal data has been or still will be disclosed, in particular, with respect to recipients in third countries or regarding international organizations;
4. If possible, the intended duration during which personal data will be saved or, in the event that this is not possible, the criteria for determination of this duration;
5. The existence of a right to rectification or deletion of personal data concerning yourself or of restricting the processing by the controller or a right of objection against this processing;
6. The existence of a right of appeal to a supervisory authority;
7. If personal data is not collected directly from you, all information available on the origin of the data as well as
8. The existence of an automated decision-making, including profiling pursuant to Art. 22 para. 1 and 4 GDPR and – at least with respect to these cases – significant information on the logic involved as well as the consequences and the intended effects of such processing on yourself.
In the event that personal data is being transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with this transfer.
6.2 Right to Rectification
Pursuant to Art. 16 GDPR, you are entitled to immediately request a rectification of incorrect data or a completion of incomplete data concerning yourself which is being stored by us.
You have the right to request us to immediately correct incorrect personal data concerning yourself. Taking into account the purposes of processing, you have the right to request the completion of incomplete personal data concerning yourself – also by means of a supplementary declaration.
6.3 Right to Deletion ("Right to be Forgotten")
In a number of cases, we are obliged to delete personal data concerning yourself.
Pursuant to Art. 17 para. 1 GDPR, you are entitled to request us to immediately delete personal data concerning yourself and we are obliged to delete personal data immediately, provided that one of the following reasons applies:
1. The personal data is no longer necessary for the purposes for which it has been collected or processed by other means.
3. You file an objection to processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for processing, or you file an objection to processing pursuant to Art. 21 para. 2 GDPR.
4. The personal data were processed unlawfully.
5. The deletion of personal data is necessary to fulfil a legal obligation in accordance with Union Law or with the law of the Member States, to which we are subject.
6. The personal data were collected relating to information society services pursuant to Art. 8 para. 1 GDPR.
In the event that we have made public personal data and that we are obliged to delete this data pursuant to Art. 17 para. 1 GDPR, we will take adequate measures, also of a technical nature, and taking into account the available technology and the implementation costs, in order to inform those responsible for data processing, who process personal data, that you have requested the deletion of all links to this personal data or of copies or replications thereof.
6.4 Right to restrict Processing
In a number of cases you are entitled, pursuant to Art. 18 GDPR, to request from us a restriction of the processing of your personal data.
You have the right to ask for the restriction of processing of your data if one of the following conditions have been met:
1. You deny the correctness of personal data and this is done for so long that we are able to verify the correctness of the personal data;
2. The processing is unlawful and you rejected the deletion of the personal data and, instead, called for the restriction of use of personal data;
3. We no longer need the personal data for the purposes of processing, but you require the data for assertion, exercising or defending of legal claims.
4. You have filed an objection against the processing pursuant to Art. 21 para. 1 GDPR, as long as it is yet uncertain whether our company’s legitimate reasons prevail in comparison to yours.
6.5 Right to Data Portability
Pursuant to Art. 20 GDPR, you have the right to obtain personal data concerning yourself that you have made available to us in a structured, common and machine-readable form and you have the right to transfer this data to another controller without any hindrance, provided that
2. the processing is carried out using automated processes.
When exercising your right to data portability pursuant to para. 1, you have the right to have the personal data transferred directly from us to another controller, provided that this is technically possible.
6.6 Right of Objection
Pursuant to Art. 21 GDPR, you have the right to object to lawful processing of your personal data by us if this is justified by your specific situation and our interests in processing do not prevail.
For reasons following from your specific situation, you have the right, at any time, to file an objection against the processing of personal data that concerns yourself, which has been carried out on the basis of Art. 6 para. 1 sentence 1 e) or f) GDPR; this is also true of any profiling based on these provisions. We will no longer process the personal data, unless we can prove compelling and legitimate reasons for processing, which overrule your interests, rights and liberties, or the processing serves to assert, exercise or defend legal claims.
If we process personal data in order to carry out direct advertising, you have the right, at any time, to file an objection to the processing of personal data concerning yourself for the purposes of such advertising; this shall also apply to profiling, provided that it is connected to direct advertising.
For reasons resulting from your specific situation, you have the right, at any time, to file an objection to the processing of personal data that concerns yourself, which is carried out for the purposes of scientific or historic research or for statistical reasons pursuant to Art. 89 para. 1 GDPR, unless the processing is necessary to fulfil a task which is of public interest.
6.7 Automated Decisions, including Profiling
We refrain from carrying out an automatic decision-making or profiling on the basis of the collected personal data.
6.8 Your Right to Revocation, at any time, of a Declaration of Consent under Data Protection Law
Pursuant to Art. 21 GDPR, you have the right, at any time, to decline to the processing of your personal data or to revoke the consent you declared to us regarding the processing of personal data. Your objection, which may be made informally, should be directed to
Executive Search & Advisory
60322 Frankfurt am Main