Privacy Policy

The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data by which you can be personally identified.

Detailed information on the subject of data protection can be found in our privacy policy set out below this text.

Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. The contact details of the controller can be found in the legal notice (Impressum) and in section 2.2 of this privacy policy.

How do we collect your data? On the one hand, your data is collected when you provide it to us. This may, for example, be data you enter into a contact form.

Other data is collected automatically by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of the page request). This data is collected automatically as soon as you enter our website.

What do we use your data for? Some of the data is collected to ensure that the website is provided without errors.

Other data may be used to analyse your user behaviour. However, such analysis is carried out exclusively on the basis of your prior consent (Art. 6 (1) (a) GDPR).

What rights do you have regarding your data? You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data.

You also have the right to request the rectification, erasure or restriction of processing of this data.

For this purpose and for further questions on the subject of data protection, you can contact us at any time at the address given in the legal notice.

Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

In addition, you have the right, under certain circumstances, to request the restriction of processing of your personal data.

When you visit our website, your surfing behaviour may be statistically evaluated. This is done in particular with cookies and analysis programs.

Important note: Such analysis is carried out exclusively after your express consent pursuant to Art. 6 (1) (a) GDPR in conjunction with § 25 TDDDG.

The analysis of your surfing behaviour is generally based on pseudonymous or anonymised data and cannot readily be directly attributed to you.

You can revoke consent you have already given at any time with effect for the future or adjust it via the cookie settings.

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations (in particular the GDPR and TDDDG) and this privacy policy.

When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains which data we collect, what we use it for, and how and for what purpose this is done.

We point out that data transmission on the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

The controller responsible for data processing on this website is:

Chiway Europe GmbH Prinzenallee 11a 40549 Düsseldorf

Management: Han Li

Phone: +49(0)211-16373530 Email: info@jobmarket-chiway.com

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

If data processing is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, you have the right at any time to object on grounds relating to your particular situation.

If your personal data is processed for the purpose of direct marketing, you likewise have the right to object at any time.

In the event of violations of the GDPR, you have the right to lodge a complaint with a data protection supervisory authority. The authority generally responsible for us is: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestraße 2-4, 40213 Düsseldorf, email: poststelle@ldi.nrw.de, www.ldi.nrw.de. You may also contact another supervisory authority competent under Art. 77 GDPR.

You have the right to receive data which we process automatically on the basis of your consent or in performance of a contract in a common, machine-readable format, or to have it transferred to a third party, insofar as this is technically feasible.

Storage period Unless a more specific storage period is stated in this privacy policy, your personal data remains with us until the purpose of the data processing no longer applies. If you assert a justified request for erasure or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion takes place once these reasons cease to apply.

This site uses SSL or TLS encryption. When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Within the scope of the applicable statutory provisions, you have the right at any time to obtain information free of charge about your stored personal data as well as information about its origin, recipients and the purpose of the data processing.

In addition, you have the right to request the rectification of inaccurate personal data or the completion of your personal data. You may also request the erasure of your data or the restriction of processing, insofar as no statutory retention obligations prevent this.

For this purpose and for further questions on the subject of personal data, you can contact us at any time at the address given in the legal notice.

You have the right to request the restriction of processing of your personal data. To do so, you can contact us at any time at the address given in the legal notice.

The right to restriction of processing exists in the following cases:

• If you contest the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of this verification, you have the right to request the restriction of processing of your personal data.
• If the processing of your personal data is unlawful, you may request the restriction of processing instead of erasure.
• If we no longer need your personal data but you need it for the establishment, exercise or defence of legal claims, you have the right to request the restriction of processing of your personal data instead of erasure.
• If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of processing of your personal data.

If the processing of your personal data has been restricted, this data may – apart from being stored – only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

We hereby object to the use of contact data published in accordance with the legal notice obligation for the purpose of sending unsolicited advertising and information materials.

The operators of this website expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, in particular by means of spam emails.

Our website uses cookies. Cookies are small text files that are stored on your device and saved by your browser. They serve to make our offering more user-friendly, effective and secure.

We use both technically necessary cookies and – if you have consented – cookies for analysis and marketing purposes.

Technically necessary cookies are required for the operation of the website and the provision of basic functions (e.g. page navigation or shopping cart functions). These cookies are stored on the basis of § 25 (2) TDDDG and Art. 6 (1) (f) GDPR.

Non-essential cookies (e.g. for analysis or marketing purposes) are set exclusively on the basis of your express consent pursuant to § 25 (1) TDDDG and Art. 6 (1) (a) GDPR.

You can revoke or adjust your consent at any time with effect for the future. Please use the cookie settings on our website for this purpose. Your consents are managed via a consent management tool through which you can change or revoke your settings at any time.

The specific services used, their purposes and the respective storage periods can be found in the cookie settings.

Most of the cookies we use are so-called "session cookies". They are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them or the respective storage period expires.

You can set your browser so that you are informed about the setting of cookies, allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be restricted.

The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are in particular:

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation, the stability and security of the website, and in the analysis and defence against security risks (e.g. misuse or attacks).

The server log data is stored only for as long as is necessary to achieve the stated purposes and is then deleted, unless statutory retention obligations exist.

Hosting / Vercel This website is provided via Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. In the course of hosting, in particular IP addresses, server log data, meta and communication data, and other data generated when using the website may be processed. Vercel is used for the secure, fast and efficient provision of our online offering on the basis of Art. 6 (1) (f) GDPR. Insofar as Vercel processes personal data on our behalf, the processing is carried out on the basis of a data processing agreement pursuant to Art. 28 GDPR. Data transfers to the USA cannot be ruled out. According to its own information, Vercel is certified under the EU-U.S. Data Privacy Framework and additionally provides suitable transfer mechanisms, in particular standard contractual clauses.

If you send us enquiries via the contact form, we process your details, including the contact data you provide, for the purpose of handling your enquiry and any follow-up questions.

Insofar as your enquiry serves the initiation or performance of a contract, the processing is carried out on the basis of Art. 6 (1) (b) GDPR. In other cases, the processing is carried out on the basis of Art. 6 (1) (f) GDPR due to our legitimate interest in the proper handling of enquiries. Insofar as we obtain consent in individual cases, Art. 6 (1) (a) GDPR is the legal basis.

Enquiries are deleted as soon as their processing is complete and no statutory retention obligations or other permissible reasons for further storage exist.

The data you enter in the contact form remains with us until the purpose for data storage no longer applies (e.g. after your enquiry has been fully processed), you revoke your consent, or you request us to delete it. Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

This data is not passed on to third parties without your express consent.

Legal basis

• Art. 6 (1) (b) GDPR (implementation of pre-contractual measures and provision of the platform functions),
• Art. 6 (1) (a) GDPR (consent, e.g. for inclusion in the talent pool or for headhunting functions),
• Art. 6 (1) (f) GDPR (legitimate interest in the technical provision, quality assurance, IT security and further development of the platform).

Insofar as application data is processed in the employment context in individual cases, § 26 BDSG may additionally apply.

Purpose of processing Applicants can register via our portal and create an applicant profile. The data provided in the course of registration and application is processed in order to:

• enable applications for job advertisements,
• transmit application documents to interested companies,
• provide an applicant profile (talent pool) that companies can use to search for candidates (provided corresponding consent has been given),
• ensure and improve the functionality, security and quality of the platform.

Mandatory / voluntary information Certain information is required for registration, the use of the platform functions and the submission of applications. Further information is provided voluntarily. Voluntary information can in particular help to improve the visibility of the profile, its discoverability in the talent pool and the chances of placement.

Visibility / release The visibility of the profile can be controlled by the user. CVs can be displayed in anonymised form. Data is passed on to companies only within the scope of the platform functions or after release by the user.

Headhunting If you give us corresponding consent, we also process your personal data in order to actively propose you to suitable companies and to draw your attention to suitable job offers.

As a first step, companies are generally shown only anonymised or pseudonymised profile data. In the course of this active placement, selected profile data (e.g. qualifications, professional experience and professional preferences) may be transmitted to potential employers.

Identifying data (e.g. name, contact details) is passed on only if you expressly agree to this in the individual case.

The processing is carried out on the basis of your consent pursuant to Art. 6 (1) (a) GDPR. You can revoke this consent at any time with effect for the future.

Deletion of data Personal data is generally stored for as long as the user account exists.

Users can delete their account at any time or request the deletion of individual data.

After deletion of the account, the data is deleted or anonymised within 30 days, unless statutory retention obligations prevent this.

Categories of data subjects Users (applicants)

Categories of personal data

• Contact data (name, email address)
• Profile data (e.g. qualifications, professional experience, preferences)
• Application data (CV, cover letter, details of applications)
• Connection data (IP address, user agent, metadata, language settings, operating system)

Categories of recipients of the data

• Internal systems of Chiway Europe GmbH
• Employees of Chiway Europe GmbH
• Companies to which the user applies
• Companies that receive access to the talent pool (only with corresponding consent of the user)

Note on special categories of personal data: Please do not submit special categories of personal data within the meaning of Art. 9 GDPR (e.g. health data, information on religion or trade union membership) in profiles, CVs and application documents, insofar as this is not necessary for the respective purpose. If such data is nevertheless submitted voluntarily, it is processed only within the framework of the statutory requirements.

Technical and organisational measures

• Encrypted transmission (HTTPS/TLS)
• Access restrictions (role-based authorisation concepts)
• Logging and control of access
• Regular backups and recovery concepts
• Data protection management and regular review of the measures

Rights of data subjects Data subjects have the right to information (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR) and objection (Art. 21 GDPR).

If the processing is based on consent, this can be revoked at any time with effect for the future.

There is also a right to lodge a complaint with a data protection supervisory authority.

Legal basis The processing is carried out on the basis of Art. 6 (1) (b) GDPR (performance of a contract or pre-contractual measures), insofar as you use or book corresponding offers. Insofar as additional data is collected on a voluntary basis, this is done on the basis of your consent pursuant to Art. 6 (1) (a) GDPR.

Purpose of processing We offer users supplementary services in the area of career development, such as application coaching, training, workshops or consulting offers. In the course of these services, we process personal data in order to:

• provide the booked services,
• enable individual advice and support,
• organise and conduct appointments,
• improve the quality of our offers.

Categories of personal data

• Contact data (e.g. name, email address)
• Profile data (e.g. CV, qualifications, professional experience)
• Communication data (e.g. content from consultations, feedback)

Storage period The data is stored for as long as is necessary to perform the respective service. Beyond that, we store data only insofar as statutory retention obligations exist or legitimate interests (e.g. proof of services rendered) require it.

Disclosure of data Data is generally not passed on to third parties unless:

• this is necessary to perform the service (e.g. external coaches),
• you have expressly consented, or
• a legal obligation exists.

If paid services are booked, payment and billing data may be processed for payment processing and transmitted to the corresponding payment service providers. In this case, the processing is carried out on the basis of Art. 6 (1) (b) GDPR.

If external service providers are used, this is done on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Legal basis The processing is carried out on the basis of Art. 6 (1) (b) GDPR (performance of a contract and pre-contractual measures) and Art. 6 (1) (f) GDPR (legitimate interest in maintaining business relationships and optimising our services).

Purpose of processing We process personal data of contact persons at companies (employers) in order to:

• provide and manage company accounts,
• create, publish and manage job advertisements,
• enable access to applicant profiles and talent pool functions,
• carry out communication processes (e.g. support, consulting, contract handling),
• handle billing and payment processes.

Categories of personal data

• Contact data (e.g. name, business email address, telephone number)
• Company data (e.g. company name, industry, location)
• Contract and billing data (e.g. booked services, invoice information, payment status)
• Usage data (e.g. login data, activities in the system)

Categories of recipients

• Internal systems and employees of Chiway Europe GmbH
• IT and hosting service providers (processors pursuant to Art. 28 GDPR)
• Payment service providers (where required)

Storage period The data is stored for the duration of the contractual relationship.

Beyond that, data is stored only insofar as statutory retention obligations exist, in particular pursuant to § 147 AO and § 257 HGB, or legitimate interests require it.

Disclosure of data Data is passed on to third parties only insofar as this is necessary for the performance of the contract, a legal obligation exists, or you have consented.

If we use external service providers, this is done on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Legal basis Our newsletter is sent on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and Art. 7 GDPR in conjunction with § 7 (2) no. 3 UWG.

Insofar as newsletter usage behaviour is analysed (e.g. open and click rates), this is likewise done only on the basis of your consent.

Purpose of processing Users can subscribe to our newsletter to regularly receive information about new job offers, career content and suitable offers from our portal.

Registration procedure Registration takes place using the so-called double opt-in procedure. After registering, you will receive an email in which you must confirm your registration. The newsletter is only activated after this confirmation.

To document the consent, we store:

• Your email address
• Time of registration
• IP address at the time of registration and confirmation

Categories of personal data

• Email address
• Name (optional)
• Preferences (e.g. location, industry, occupational field)
• Usage data (e.g. open and click rates, insofar as this is done on the basis of your consent and processed in anonymised or pseudonymised form)

Storage period and deletion Your data is stored for as long as you are subscribed to the newsletter. You can unsubscribe from the newsletter at any time. After unsubscribing, your data is deleted or anonymised, unless statutory retention obligations prevent this.

Revocation You can revoke your consent at any time with effect for the future, e.g. via the unsubscribe link in every newsletter email or by notifying us.

Disclosure of data Data is generally not passed on to third parties unless:

• this is necessary for the technical delivery of the newsletter (e.g. mailing service providers),
• or you have expressly consented.

If external service providers are used, this is done on the basis of a data processing agreement pursuant to Art. 28 GDPR.

We use Stripe for paid services. For companies based in Germany, the contractual relationship is generally established via Stripe Payments Europe, Limited (SPEL), Ireland; depending on the Stripe service used, other Stripe entities, in particular Stripe Technology Company, Limited, may be involved. During payment processing, in particular payment data, billing and contact data, transaction data, device and usage data, and information required for fraud prevention are processed.

Insofar as processing is necessary for carrying out the payment and performing the contract, it is based on Art. 6 (1) (b) GDPR. Insofar as statutory retention or documentation obligations exist, Art. 6 (1) (c) GDPR may apply. Depending on the processing operation, Stripe may act as a processor or as an independent controller. Stripe provides a Data Processing Agreement for this purpose.

Further information on data processing by Stripe can be found in Stripe's privacy notices. Data transfers outside the European Economic Area cannot be completely ruled out within the Stripe infrastructure; Stripe uses the respectively required data protection transfer mechanisms for this purpose.

We use Resend for sending technical and transactional emails (e.g. registration confirmations, verification and password reset emails) and – with corresponding consent – for the jobletter/newsletter. The provider is Plus Five Five, Inc. (Resend), 2261 Market Street #5039, San Francisco, CA 94114, USA.

In this process, in particular email address, name, sending and delivery information, technical metadata and – insofar as activated and legally permissible – interaction data may be processed. Transactional emails are sent on the basis of Art. 6 (1) (b) GDPR or Art. 6 (1) (f) GDPR; the jobletter/newsletter on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 7 UWG.

Insofar as Resend processes personal data on our behalf, this is done on the basis of a data processing agreement pursuant to Art. 28 GDPR. According to its own information, Resend is certified under the EU-U.S. Data Privacy Framework; in addition, the Data Processing Addendum provides for standard contractual clauses as a transfer mechanism. Newsletter consent that has been given can be revoked at any time with effect for the future.

Under our current platform concept, no exclusively automated decision-making within the meaning of Art. 22 GDPR takes place that produces legal effects concerning you or similarly significantly affects you. Insofar as matching or recommendation functions are used, they serve to support the search and initiation of contact and do not replace a decision by an employer or by our employees.

There is no statutory or contractual obligation to provide us with personal data. However, for the data that is strictly necessary for the provision of the respective service (see above in each case), provision is necessary if you wish to use these services.

From time to time it may become necessary to update this privacy policy, for example due to new statutory or regulatory requirements or new offerings on our website. We will then inform you at this point. In general, we recommend that you consult this privacy policy regularly to check whether there have been any changes. You can tell whether changes have been made, among other things, by the fact that the version date stated at the very bottom of this document has been updated.

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables us to analyse the behaviour of website visitors. In doing so, we receive various usage data, such as page views, time spent, operating systems used and origin of the user. This data is assigned to your device but not uniquely attributed to any person.

Google Analytics uses cookies and comparable recognition technologies to enable an analysis of the use of the website.

This service is used exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 25 (1) TDDDG. You can revoke or adjust your consent at any time with effect for the future via the cookie settings.

IP anonymisation We have activated the IP anonymisation function on this website. As a result, your IP address is truncated by Google within the European Union or the European Economic Area before being transmitted to third countries. Only in exceptional cases is the full IP address transmitted to a Google server in a third country (e.g. USA) and truncated there.

Data transfer to third countries A transfer of data to the USA cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework. In addition, according to its own information, Google uses standard contractual clauses (SCC) of the European Commission insofar as this is necessary.

Storage period The data stored by Google Analytics is processed by us only for as long as is necessary to achieve the stated purposes. Further information on the storage period can be found in Google's privacy notices.

Data processing We have concluded a data processing agreement (Data Processing Agreement) with Google.

Options to object You can prevent the storage of cookies by setting your browser software accordingly. In addition, you can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de

Alternatively, you can revoke your consent at any time via the cookie settings. Further information on the handling of user data in Google Analytics can be found in Google's privacy policy: https://policies.google.com/privacy

This website uses the functions of Google Analytics Remarketing in conjunction with Google Ads. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

This function enables us to display interest-based advertising to visitors of our website on other websites within the Google advertising network. For this purpose, Google analyses your usage behaviour on our website in order to subsequently assign you to certain advertising target groups.

Cookies or comparable technologies that enable recognition of your browser may be used. In addition, Google may link the collected information with your Google account if you are logged in to it and have given corresponding consent.

This service is used exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 25 (1) TDDDG. No processing takes place without your consent.

You can revoke or adjust your consent at any time with effect for the future via the cookie settings.

In addition, you can deactivate personalised advertising in your Google account: https://adssettings.google.com/

Data transfer to third countries A transfer of data to the USA cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework. In addition, according to its own information, Google uses standard contractual clauses (SCC) of the European Commission insofar as this is necessary.

Further information on the use of your data by Google can be found at: https://policies.google.com/privacy

This website uses Google Ads and the associated conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Within Google Ads we use conversion tracking. If you click on an ad placed by Google, a cookie for conversion tracking is set. These cookies enable us to recognise whether users have reached our website via an ad and have performed certain actions (e.g. submitted an enquiry).

The information collected using the conversion cookie serves exclusively to create statistical evaluations of the success of our advertising measures. We do not receive any information by which individual users can be personally identified.

This service is used exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 25 (1) TDDDG. No processing takes place without your consent.

You can revoke or adjust your consent at any time with effect for the future via the cookie settings.

Data transfer to third countries A transfer of data to the USA cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework. In addition, according to its own information, Google uses standard contractual clauses (SCC) of the European Commission insofar as this is necessary.

You can also deactivate personalised advertising in your Google account: https://adssettings.google.com/

Further information on the handling of user data can be found in Google's privacy policy: https://policies.google.com/privacy

For the uniform display of fonts, this website uses so-called Google Web Fonts, which are stored locally on our server.

No connection to Google servers takes place. As a result, no personal data (in particular no IP address) is transmitted to Google.

The web fonts are used in the interest of a uniform and appealing presentation of our website. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR.

This website uses the map service Google Maps. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to process your IP address. When a page in which Google Maps is embedded is accessed, data may be transmitted to Google servers.

Google Maps is used exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 25 (1) TDDDG.

You can revoke your consent at any time with effect for the future via the cookie settings.

Data transfer to third countries A transfer of data to the USA cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework. In addition, according to its own information, Google uses standard contractual clauses (SCC) of the European Commission insofar as this is necessary.

Further information on the handling of user data can be found in Google's privacy policy: https://policies.google.com/privacy

This website uses the Google reCAPTCHA service. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is intended to verify whether data entry on this website (e.g. in a contact form) is carried out by a human or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics.

In particular, the following data may be processed:

• IP address
• Time spent on the website
• Mouse movements and interactions
• If applicable, further information required for the analysis

The data collected in the course of reCAPTCHA is transmitted to Google. Google reCAPTCHA is used exclusively on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and § 25 (1) TDDDG.

You can revoke your consent at any time with effect for the future via the cookie settings.

Data transfer to third countries A transfer of data to the USA cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework. In addition, according to its own information, Google uses standard contractual clauses (SCC) of the European Commission insofar as this is necessary.

Further information on Google reCAPTCHA can be found at: https://policies.google.com/privacy https://policies.google.com/terms