NELEX AG – Datenschutzbedingungen / Informationen zum sensitiven Datenschutz von (potenziellen) Kandidaten

General information about the handling of your data
Data protection and discretion is extremely important to NELEX AG! This is not only because of the current regulations under the EU GDPR, but also because we, especially in our industry, are responsible for protecting you and your personal data. For this reason, we forward your data only after consultation and consent on your part to clients or trusted third parties. Our services require trusted handling of client and (potential) candidate information. In this relationship, we will, of course, protect discretion and your sensitive data as much as possible. – NELEX AG.

What data does NELEX AG collect?
In order to assist you and our clients in the selection of jobs and candidates, NELEX GmbH (hereinafter also NELEX, “we”, “us”) collects your name, contact details and other relevant information directly from your CV. In addition, we collect information from telephone and personal conversations with you, which serves to assess your person and professional expertise.

How do we use your personal data?
We use the data we collect to provide you with the best possible service. This includes evaluating your data for the manual and automatic search for potential jobs and informing you about open vacancies. We may also use your data to contact you and notify you of news and promotions.

Whom do we share your personal data with?
We may share your data with all NELEX AG employees and trusted third parties to provide our services to you. Personal data and documents are only forwarded to trusted third parties with your consent. Under certain circumstances, we may be required by a regulatory or law enforcement agency to disclose certain personal data. How long do you store my personal data? We only store your personal data for as long as you wish. In addition, we perform regular data cleanup and updates to ensure that the data we hold is relevant and accurate.

What rights do you have as a (potential) candidate?
You are in control of your data! If you no longer wish to receive e-mails, phone calls or any kind of contact from us, you can unsubscribe from or object to the messages you receive. You can also contact us by e-mail, telephone or post, and we will make that change for you.

How do we use cookies?
We want you to have the best possible user experience when using our services. That is why we use cookies. Cookies are small text files that are stored on your computer and help us to optimise our websites and our online services.

How can you contact us?
Feel free to contact us if you have questions about how we process, store and share personal data. You are welcome to contact your advisor at NELEX AG or contact our data protection officer directly via the e-mail address to do this.


Right to objection:
You have a legal right to objection any time to:
(i) the use of your personal data for direct marketing purposes; and (ii) the processing of your personal data in our legitimate interest, unless there is a compelling legal reason for further processing by us.

NELEX AG (hereinafter also “NELEX”, “we", “us”, “our”, etc.) is committed to protecting the privacy of our candidates, customers and users of our website. It is important to us to provide a safe, secure user experience. That is why we ensure that the data you provide us with, as well as data that we receive through various channels (such as our websites, through written correspondence, including e-mail, in conversation or in meetings with our recruitment consultants or through one of our offices ) is used only for the purposes set out in this privacy policy. We want to use this privacy policy to inform you about the types of personal data that we collect from our candidates, the uses of this data, and how it is processed. In addition, we are required to comply with the transparency requirements of the EU General Data Protection Regulation 2016/679 (“GDPR”) and the national transposition provisions.

The data collected by us
We will collect your personal data such as, but not limited to, your name and contact details (and your e-mail address) as well as other relevant data from your resume and social networks (e.g., and others). If necessary, we may receive your personal details and CV electronically, for example, in the context of a direct application on one of our websites or an application you have sent us via another job exchange. It is likely that in the course of our relationship with you we collect further personal data about you. This data may come from you directly or from third parties, such as organisations to whom we have sent your CV or whom you have contacted as part of a job application.

How we use your personal data
We will use your personal data for our legitimate business purposes, including:

  1. To provide services to you;
  2. To maintain our business relationship, in which you are a user of our website, client or candidate;
  3. To submit your resume for general applications, to apply for specific jobs, or to register for our job postings. In a separate section on your resume below, you can find an explanation of additional uses and disclosures
  4. To match your information with vacancies so that we can find the position that suits you best and to send personal data to clients for application purposes;
  5. To keep your information for future employment beyond the specific role for which you have contacted us;
  6. To answer your questions;
  7. For the direct marketing of services, to inform you about news and industry updates, events, promotions and competitions, reports and more. Before we do this, you will be given the option to decline to receive such communications; each message from us also includes the option to unsubscribe from it.
  8. To fulfil contractual obligations to our clients;
  9. To disclose personal data to regulatory or law enforcement agencies, if we have a duty or authority to do so;
  10. Our website uses a tracking service to record mouse clicks, mouse movements, scrolling and text entered in website forms. The data collected by this service is intended to improve the usability of our website. The data collected will be stored and used for aggregated and statistical reporting purposes and will not be disclosed to third parties.
  11. In order to provide you with personalised content on our website, to make the communication in our e-mails more relevant to you and to tailor the service of our personnel consulting staff to you, we track your use and interaction with our website and our e-mails and record this.

We may process certain sensitive personal data (referred to in GDPR as special categories of personal data) in accordance with local regulations if you include it in information that you send to us, for example, if you include information about your health or religion in the CV you send us. It may also be necessary for us to do a criminal record check against your data in countries where this is required or permitted by law. We have procedures in place to limit the use and disclosure of this sensitive data except as permitted or required by law.

Legal basis for the processing of your personal data
Within the framework of the GDPR, we rely primarily on the following legal bases for the processing of personal data of clients and candidates:

  1. Required for the fulfilment or performance of a contract – To perform duties that we are required to perform as part of the provision of a service to you, or to take steps you requested to conclude a contract with you, we must your process your personal data;
  2. To fulfil a legal obligation – We are subject to certain legal requirements under which we may need to process your personal data. We may also be required by law to share your personal data with a regulatory or law enforcement agency.
  3. To protect legitimate interests – Either we or a third party must process your personal data in order to safeguard legitimate interests, as long as we have determined that these interests are superseded by rights or freedoms, including the right to privacy of your personal data. Our legitimate interests include responding to requests and messages from you and others, optimising our website and customer experience, providing information about our products and services, and ensuring that we conduct our business in an appropriate and efficient manner.
  4. Consent – in some cases, we may seek your consent to the specific processing of your personal data.

How we make your personal data available
In certain circumstances, we may share your personal data with third parties. Information about these third parties and the reasons for such provision can be found below.

We only disclose your personal data to clients who have vacancies that you are interested in and for which we have obtained separate consent from you.

Trusted third parties
We will disclose your personal data and, if necessary, your sensitive personal information to trusted third parties if we have retained the data in order to provide you or our client with the services requested, such as:

  • Examination of work certificates;
  • Examination of qualifications;
  • Examination of the criminal record (where required by law or permitted);
  • Verification of information provided by third parties and/or
  • psychometric evaluations or capability reviews.

We will notify you by telephone or e-mail prior to the disclosure of your data for the purpose of the above-mentioned points. We will also share your personal data with third parties who perform functions on our behalf and provide us with services. These third parties may include:

  • Consultants;
  • Data analytics provider;
  • IT consultants who perform testing and development of our business technology systems;
  • Market Research and Mailing Agencies and/or
  • Function Coordinators.

We require confidentiality and observance of minimum privacy standards from these third parties. In so far as personal data is made available to third parties outside the European Economic Area (hereinafter  “EEA”) or access to this data occurs from outside the EEA, we will ensure that approved safeguards, such as the approved standard clauses or the EU/US Privacy Shield, are in place.

Regulatory and law enforcement agencies
As mentioned above, we may, at the request of a regulatory or law enforcement agency, disclose certain personal data about you, as permitted by the GDPR and other laws.

New company owners
If we merge or become part of another group or company, we will share your personal data with the new owners of the company or group and their career consultants. In such case, you will be notified accordingly.

How long we keep your data
The length of time we retain or store your personal data depends on the services we provide to you and how long you need them. As we in many cases provide candidates with services for many years and potentially throughout their careers, the purpose of keeping applicant data is often an ongoing purpose. We conduct periodic cleanup and updating of the data with our candidates to ensure that

  1. the data we hold is accurate and
  2. we do not store data for too long.

Our general terms and conditions set out that our clients retain candidates’ data, such as resumes, for the purposes of each position your are applying for and that, as the controller responsible for processing your data, they ensure that you are informed that the client retains your resume to inform you of potential future positions, or otherwise keeps your data or uses it for other purposes.

Your rights to the data we store about you You have certain rights in relation to the personal data we hold about you. Details of these rights and their exercise are set out below. Before we can fulfil your request, we need proof of your identity.

Right to access
You have the right to request from us a copy of the personal data we hold at any time. If we have legitimate reasons and the GDPR permits, we may reject your request for your personal data or certain elements of this request. If you reject your request or a part of it, we will inform you of our reasons.

Right to correction or completion
If personal data we hold about you is incorrect, inaccurate or incomplete, you are entitled to correct, update or complete the data. Let us know about this by contacting us using one of the methods listed in the contact section below.

Right to deletion
In certain circumstances, you may request the deletion of personal data we hold about you, e.g. if the data is no longer needed for the purposes for which it was collected or processed, or the processing of the data occurs on the basis of your consent and there are no other legal bases on which we can process the data.

Right to object to or restrict processing
In some circumstances you may object to our processing of your personal data by notifying us using any of the methods described in the contact section below. This may be the case, for example, if we process your data based on our legitimate interests and there are no compelling legal reasons for our processing that take precedence over your rights and interests. You also have the right to object to the use of your personal data for direct marketing purposes. In addition, you may have the right to restrict our use of your personal data, e.g. if you have questioned the correctness of the data and during the period in which we verify the correctness.

Right to data portability
Under certain circumstances, you have a right to receive personal data we hold about you in a structured, frequently used and machine-readable format. You may require us to transfer such data to you or directly to a third-party organisation. The above-mentioned right exists only in relation to personal data which:

  • You have provided us at an earlier time and
  • we process in an automated way.

We are happy to comply with such requests but cannot guarantee technical compatibility with third-party systems. In addition, we cannot comply with any requests that relate to the personal data of third parties, without us obtaining the consent of these third parties.

You may exercise the above rights by contacting us using any of the methods in the contact section below.

Most of the above rights are subject to restrictions and exceptions. We will give reasons if we are unable to observe requests for the exercise of your rights.

Insofar as we process your personal data on the basis of your consent, you have the right to revoke this consent at any time. Let us know by contacting us using the details in the contact section below.

Job Notifications
To sign up for job notifications, you must provide us with your name and e-mail address or telephone number, which we will then use to e-mail you or phone you to keep you up to date with the latest job vacancies in the industry you specify and to provide you with industry news and other information concerning our services. The job notifications are sent by the company or a company within our group of companies. If the consignor is outside the EEA, your data will be communicated to that organisation or will be accessed by that organisation to enable sending of the relevant job notification to you.

We give you the opportunity to submit your resume through our website. Alternatively, you can simply give your resume to one of our recruitment staff. You can either apply for a specific job offer or you can submit the resume for review by our recruitment consultants for future positions. We will keep your resume in our database accessible to our recruitment staff. Your resume can also be forwarded directly to other companies within our business group who review it and enter it into their database to provide you with services. You may withdraw your consent to processing your data outside the EEA after completing your registration form with us. You can update your resume at any time by following the same procedure to submit a new resume. Your old resume will then be automatically archived, provided that the submission details remain the same (e.g. if you submitted both resumes from the same e-mail address or provided your contact person with your new submission).

Use of cookies
Like most websites, we place cookies on your computer or other device when you visit our website. These cookies are used primarily to support the functionality of the website, to improve the user experience or to enable us to optimise our websites, measure visitor traffic or fulfil other internal management purposes. We place targeted, relevant banner ads on a number of well-respected whitelist websites around the world to provide you with job opportunities and content that we believe is of interest to you. Targeted placement is based on your previous interactions with our website, our e-mails and your contact with our recruitment consultants. Your interaction with our advertising may be used to measure the effectiveness of our advertising campaigns and to improve our marketing strategy in accordance with our legitimate interests. There is no collection of your identifiable personal data through advertising campaigns or ad tracking technology.

If you disagree with our use of your personal data, you may contact us using the information in the contact section below. You can also file a complaint with the relevant data protection authority:

Phone: +49 228 997799 0

The Federal Commissioner for Data Protection and Freedom of Information
Husarenstraße 30 53117

If you live or work outside of Germany or have a complaint regarding our activities outside of Germany, you can also address this complaint to another supervisory authority. A list of the relevant authorities in the EEA and in the European Free Trade Association can be found here.

Other websites
Please note that clicking on links and banner ads on our websites may result in your browser accessing a third-party website that has different data practices than our company. We are not responsible for and have no control over any data that you submit to or that is collected from or for any third party; you should therefore read their privacy policy.

Internet-based transmission
Given the fact that the Internet is a global environment, the collection and processing of personal data inevitably involves the international transfer of data. Unfortunately, the transmission of data over the Internet is not 100% secure. While we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site through third-party networks; all transfers are at your own risk. Once we receive the data, we will use strict procedures and security features in an effort to prevent unauthorised access.

Changes to our privacy policy
This privacy policy may be changed by NELEX at any time. If we change our privacy policy in the future, we will notify you of any material changes or updates to our privacy policy by e-mail, provided you have provided us with an e-mail address.

The company attaches great importance to equal opportunity as an employer and is committed to diversity. This means that we treat all job seekers and applicants equally and we do not discriminate on the basis of gender, marital status, race, ethnic origin, skin colour, nationality, national origin, disability, sexual orientation, religion or age. As part of our commitment to equality, we will use the information you provide from time to time for the purpose of diversity monitoring. The use of this data is always anonymous.

If you have any questions or wish to contact us regarding our processing of your personal data, including exercising your rights described above, please contact us by e-mail or write to us at the following address:


Attn. Data Protection Officer
Kranhaus 1 - Im Zollhafen 18
D-50678 Cologne
+49 (0) 221-170 42 140

If you have any complaints, please contact us either by e-mail or by writing to the following address:
Contact person: Karsten Berge (Data Protection Officer)

When you contact us, we will ask you to confirm your identity.

Our business address is:
Kranhaus 1 - Im Zollhafen 18
D-50678 Cologne
+49 (0) 221-170 42 14