WANTEDLY PRIVACY POLICY

Germany

1. Our principles for the handling of your data:

We process your data to provide you with the Wantedly services.

We will not pass your data on to third parties without legal basis or your previous agreement, in particular we will not sell it for advertising purposes.

We work hard every day to protect your data against misuse and access from outside.

When handling personal data that we collect or otherwise process in Germany, the other member states of the European Union and the states of the European Economic Area, we strictly adhere to the strict legal standards resulting from the Basic Data Protection Ordinance (DSGVO) and the Federal Data Protection Act (Germany).

Even if we have received personal information about you but not from you, the information and rights stated in this Privacy Policy apply to you.

2. Who is responsible for the processing of my data?

WANTEDLY, Inc, MG Shirokanedai Building 4F, 5-12-7, Shirokanedai, Minato-ku, Tokyo, 108-0071, registered in the Japanese Commercial Register of the Japanese Ministry of Economy, Trade and Industry under registration number 0110-01-066673 (hereinafter "Wantedly", "we" or "us") is responsible for the processing of your data.

 Contact person of Wantedly in Germany is Christian Walter, ℅ WeWork, Stressemannstraße 123, 10963 Berlin as domestic representative.

3. What is personal data?

Personal data is all information relating to an identified or at least identifiable natural person. This could be your name, date of birth, contact details, gender, level of education, profession, completed training but also the way in which you use our services. You are identifiable as a person if your identity can be identified directly or indirectly, e.g. by being assigned certain data such as name, contact data, location data, profile data, usage data, etc.

4 What personal data do we process and for what purposes?

Wantedly processes (1) user-generated data that you enter directly as a user (e.g. login data and data that you enter into your profile, data that you enter into the contact form on the Wantedly website, e.g. support requests, or contributions or comments that you publish, e.g. in the blog or news feed on the Wantedly website), (2) general data that we collect about Wantedly users via the backend (e.g. IP address, access point, Internet service provider, device used, browser type and version, the sub-pages from which a person accesses the Wantedly website, i.e. the so-called "referrer" and similar data required or helpful for the traceability of access for statistical purposes or for security reasons) and (3) behavioural data about user behaviour on the Wantedly platform (e.g. Time and duration of access, viewed profiles, interaction with other Wantedly users; opening of newsletters and articles in the journal), which we use for content suggestions, for statistical purposes as well as the placement and insertion of Wantedly advertisements tailored to the Wantedly user and our advertising customers.

You only have to enter some data. Most of your details are voluntary:

5. Who can see my personal data?

By default, mandatory and voluntary information can be viewed as follows (public, all Wantedly users, only for contacts, transfer to potential employer with whom you are applying):

Type of data

Visibility

Possible Visibility Restrictions

Visibility for employers whom you send an application

Profile data (profile picture, first name, last name, tag line, about me, contacts, recommendations, Wanted Score, similar profiles,)

Open to the public

Only Wantedly users or only users you are directly connected to. You can also restrict visibility for individual information.

Yes

Current position, location, date of joining, social media links, goals, resume, training, languages spoken, links, interests, general information, contact details, posts

Wantedly users only

Users you are directly connected to. You can also restrict visibility for individual information.

Yes

6. Can I limit the visibility and use of my personal data?

Yes, Wantedly allows you to set and limit the use and visibility of your personal information in the settings of the website. The setting options are continuously expanded in accordance with feedback from Wantedly users so that you can configure Wantedly the way you want to use it.

In the privacy settings you can specify whether all other Wantedly users can view your complete profile or only your contacts ("connections"). You can also choose to have your contacts automatically notified of changes to your profile. By default, a profile is set up so that Wantedly users can view your entire profile and your contacts are automatically informed about changes.

In the scout settings you can specify whether you want to be scouted by companies and create a black list of companies from which you do not want to receive requests and which are not to actively follow your profile. By default, your profile is set up in such a way that you can be scouted by companies.

For company profiles, you can also specify whether your employer can post job postings on your Facebook timeline if your employer has a company account on Wantedly and you are registered as an employee of the company on Wantedly.

7. On what legal basis do we process your personal data?

We process your personal data (i) in order to fulfil our contract with you and us with respect to pre-contractual obligations (Art. 6 para. 1 lit. b DSGVO), to fulfil legal obligations to which we are subject, e.g. commercial and tax recording obligations (Art. 6 para. 1 lit. c DSGVO) and (iii) in the exercise of the legitimate interests of Wantedly or a third party in processing, unless your interests or fundamental freedoms granted to you by law or constitution pursuant to Art. 6 para. 1 lit. f DSGVO prevail.

Justified interests can be the interest in a functional and efficient design of the use of our website, for example through the use of cookies, but also marketing purposes (e.g. when sending newsletters or using analysis services that enable us to better understand the use of and interaction with our services, or the use of counting pixels that help us to understand the interaction with our website, the effectiveness of referrers or even the perception of our messages), the use of contact forms for the processing of user and support requests, the verification of compliance with the rules for the use of Wantedly services, as well as the assertion or defence of claims.


We will inform you if the use of your personal data requires your consent. If the processing of your data is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO), you have the right to revoke this consent at any time. In this case, however, the processing of your personal data up to your revocation remains legal. The revocation of your consent does not prevent us from processing your personal data on another legal basis.

8. Do we obtain and process personal data from third parties?

We collect data on principle directly from Wantedly users.

In addition, we may not collect your information directly from you, especially if Wantedly users submit your personal information to us. This is the case, for example, with the Wantedly People feature, where Wantedly users scan business cards using our system and we help Wantedly users link to the Wantedly profiles of the person named on the business card. We use this data exclusively for the provision of the relevant Wantedly services and do not pass it on to third parties.

As far as we obtain personal data from other services, in particular from social media profiles that you have at other companies, this is at your instigation and therefore only with your consent. This data is used to create and supplement your Wantedly profile and is thus processed by us like user-generated data.

If in individual cases we should also obtain personal data from third parties (e.g. statistical data), these are usually large data sets in pseudonymised form or data sets which would theoretically permit an individualisation of the persons concerned, but which do not allow us to inform the persons concerned about the processing or disclosure of such data with reasonable effort.

9. Can data of mine be processed if I do not use Wantedly services myself?

Generally, we collect information directly from you, for example by you logging in to Wantedly, entering profile information and using Wantedly services. However, we may process your personal information even if you have never used Wantedly services before. This is the case with our Wantedly People feature, for instance, when a Wantedly user scans your business cards and Wantedly crosschecks the data on the business card with already registered users to link different Wantedly users.

Apart from this, Wantedly does not process any data from third parties that we do not collect directly from you, unless there is a legal basis for this.

10. Tracking our newsletters and emails

The Wantedly newsletters and status emails contain tracking pixels. These are miniature graphics that allow us to determine if and when emails sent by Wantedly have been opened and enable us to determine the actual reach of mailings. The associated personal data will only be used for the optimisation of our newsletter or email dispatch. We do not pass this information on in a form that would enable third parties to identify you.

You are entitled to revoke your consent to receive newsletters at any time. After your revocation we will delete the data concerning the newsletter dispatch.

11. Contact form

If you send requests to us using the contact form included on the website, your details from the request form, including the contact data you provided there, will be stored for processing your request and for further correspondence on your request. We will not pass on this data without your consent.

If the processing does not take place for the other purposes mentioned in clause 4, i.e. in particular on the basis of a justified interest existing for us after weighing up the interests (Art. 6 para. 1 lit. f DSGVO), we process the data entered via the contact form on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time. All you need to do is, for example, send us an informal e-mail.
The legality of the data processing processes carried out up to the revocation remains unaffected by the revocation.

The data entered by you in the contact form will remain stored by us until you request deletion, revoke your consent to storage or the purpose ceases to apply (e.g. after your request has been processed or after our general deletion periods have expired). Mandatory statutory provisions, in particular those concerning retention periods, remain unaffected.

12. Does Wantedly share personal information with third parties?

Wantedly may disclose personal information about Wantedly users to third parties in accordance with the following rules for the purposes of statistical analysis, improvement of Wantedly products and services, marketing of Wantedly and the collection of Wantedly advertisements tailored to the interests of Wantedly users and advertisers.


Third parties are usually providers of analysis and big data applications. The passing on of data takes place as a rule and as far as possible in pseudonymized or anonymous form to prevent a traceability to the respective Wantedly user.

Personal data is also disclosed to companies affiliated with Wantedly, currently Wantedly Singapore Pte.


Personal data will only be disclosed within the framework of statutory obligations or on the basis of statutory authorisations, insofar as such Wantedly authorise such disclosure, in particular if this is necessary within the framework of contract processing, for example to the companies commissioned to process payments (Art. 6 para. 1 lit. b DSGVO), this is necessary for the protection of life, health or physical integrity of persons (Art. 6 para. 1 lit. d DSGVO) or the passing on for the fulfilment of legal or enforceable official duties or orders (Art. 6 para. 1 lit. c DSGVO).


Certain data is also collected by third parties via cookies, pixels or similar on our site (see below).

Furthermore, the data may be passed on to third parties within the framework of the sale of Wantedly's company as a whole or parts of the company, insofar as there is a legal basis or authorisation for this.
For the rest, personal data will only be passed on with your consent.

13. Will your personal data be processed in or transferred to third countries?

Personal information is currently shared with and processed by Wantedly and its affiliates outside the EU, in Japan and Singapore. For Japan and Singapore, the European Commission has not established that these countries have an adequate level of protection for personal data (the so-called adequacy decision). It must therefore be assumed that there is no level of protection comparable to that provided by the DSGVO. Processing is therefore carried out on the basis of and subject to an appropriate guarantee within the meaning of Art. 46 para. 1 DSGVO in accordance with the standard data protection clauses published by the European Commission referred to in Art. 46 para. 2 lit. c) DSGVO. As a data subject, you are hereby granted directly enforceable rights to the processing of personal data and effective remedies to the extent provided for by the DSGVO, which you can assert directly against Wantedly. If you are in the European Union (Art. 3 para. 2 DSGVO), the processing of your personal data by Wantedly (i.e. usually by registration with the Wantedly services, but possibly also by the entry of your data by third parties or mere use of the Wantedly website) results in a guarantee contract between Wantedly and you, which entitles you without any acceptance or other action on your part. The warranty and standard contract clause can be viewed here.

14. How long do we store your personal data?

We store your personal data as long as you maintain a Wantedly profile or use Wantedly services. If you delete your profile, we will delete your personal data as soon as this is no longer necessary to enable us to fulfil legal obligations or enforceable official orders, in particular obligations to tax authorities and supervisory authorities, such as the retention periods for business letters and invoices of 6 and more. 10 years, or - in particular with regard to any or alleged infringement of third party rights - to assert, enforce or defend legal claims in connection with your use of Wantedly within the applicable limitation periods of up to 10 years from the damaging event in individual cases.

We reserve the right to delete your personal data completely only after expiry of the relevant limitation periods.Prior to this, and in the cases mentioned in Section 19 below, in which you may request a restriction on the processing instead of deletion of data, we will restrict the processing of such data so that they cannot be viewed by us in ongoing operations or by third parties or processed for operational purposes.


However, we do not assume any obligation to store your personal data for a certain period of time.

15. Our data protection officer

If you have any questions about the personal data we process, please contact our data protection officer: Data Protection Officer, dpo.mcATwantedly.com, MG Shirokanedai Building 4F, 5-12-7, Shirokanedai, Minato-ku, Tokyo, 108-0071, Japan

16. Your right to information about your personal data stored by us

You have the right to receive free information about your personal data stored by Wantedly and a copy of this information at any time. You may also request information about which categories of personal data are processed and for what purposes, to which recipients your personal data have been or will be disclosed, especially in third countries, for how long your personal data is expected to be stored, whether there is a right of appeal to a supervisory authority, for personal data that is not collected from yourself, about where we obtained this data from. If we transfer personal data to a country outside the EU or the EEA, you also have a right to information about the appropriate guarantees for the protection of your data during transmission. If you would like to receive any of the above information, please contact us, preferably at the following email address: dpo.mcATwantedly.com

17. Your right to confirmation

You have the right to ask us to confirm whether personal data concerning you is being processed. If you wish to exercise this right, please contact our data protection officer, preferably at the following email address: dpo.mcATwantedly.com

18. Your right to have your personal data corrected

To err is human and erroneous data may occur. You may request us to correct any inaccurate personal data concerning you without delay. Furthermore, taking into account the purposes of the processing, you may request the completion of incomplete personal data - also by means of a supplementary declaration.

If you wish to exercise this right, please contact our data protection officer, preferably at the following email address: dpo.mcATwantedly.com.

19. When will Wantedly delete or restrict the processing of your personal data?

You have the right to demand the immediate deletion of the personal data concerning you, insofar as its processing is not necessary and your personal data was processed for purposes for which it is no longer necessary; you have revoked your consent to the data processing and we are also not entitled to process on any other legal basis; you object to the processing and there are no compelling and therefore predominant reasons for the processing; or you have objected to the processing for the purpose of direct marketing; or we process your personal data unlawfully; or we are otherwise legally obliged to delete or delete at the request of the respective affected party, i.e. the person whose data is processed.

You also have the right to ask us to limit the processing of your personal data for a period that allows us to verify the accuracy of the personal data, if you dispute the accuracy of the personal data collected about you; the processing is unlawful; you refuse to delete the personal data and instead request that the use of the personal data be restricted; or we no longer need the personal data, but you do need it to assert, exercise or defend legal claims; you have filed an objection to the processing and it is not yet clear whether we are entitled to process the personal data for overriding compelling reasons.

If you wish to request the deletion or restriction of personal data stored by us, please contact our data protection officer, who will arrange for the deletion or restriction of processing.

20. Your right to have your personal data transferred

You have the right to receive the personal data concerning you that you have provided in a structured, common and machine-readable format. You also have the right to transfer this data to another data processor, provided that the processing is based on your consent pursuant to Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of public authority which was transferred to us.
Furthermore, you may require us to transfer the personal data directly from us to another person responsible, insofar as this is technically feasible and provided that the rights and freedoms of other persons are not affected by this.
If you wish to exercise this right, please contact us, preferably at the following email address: dpo.mcATwantedly.com.

21. Your right to revoke your consent under data protection law

You may revoke your consent to the processing of your personal data at any time. If you wish to exercise this right, please contact our data protection officer or use the function provided on our website.

22. Your right to object to the use of your personal data for certain purposes, direct advertisement

You have the right to object at any time, for reasons arising from your particular situation to the processing of personal data concerning you, which we carry out on the basis of Art. 6 para. 1 lit. e or f DSGVO (performance of a task in the public interest or processing on the basis of a legitimate interest).

We will then no longer process your personal data unless we can prove that we can rely on compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If we use personal data for direct marketing, you may at any time object to the processing of your personal data for these purposes. Upon receipt of your objection, we will no longer process your personal data for these purposes.

You may also object to the processing of your personal data, which we process for statistical or scientific purposes, for reasons arising from your particular situation, unless the processing would be necessary to fulfil a task in the public interest.

If you wish to exercise the above rights, please contact our data protection officer, whereby the objection is also permissible in the case of automated procedures.

23. Right of appeal to the competent supervisory authority

In the event of breaches of data protection law, the data subject is entitled to lodge a complaint with the competent supervisory authority. The responsible supervisory authority for data protection issues is the State Data Protection Commissioner in Berlin.

24. Use of Facebook and Twitter plugins on our website

Our website includes social plugins ("plugins") from Facebook and Twitter. The underlying services are provided by Facebook Inc. and Twitter Inc. ("Providers").

Facebook is operated by Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is responsible for the processing of personal data if you live outside the USA or Canada. You can find an overview of the plugins used by Facebook here: https://developers.facebook.com/docs/plugins/?locale=en_EN

Twitter is operated by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA ("Twitter"). An overview of the Twitter buttons and their appearance can be found here:

When you visit a page on our website that contains such plugins, your browser establishes a direct connection to the Facebook and Twitter servers. The content of the plugin is transmitted directly from Facebook and Twitter to your browser and integrated into our site. In this way the providers receive information including your IP address that your Internet browser has accessed the relevant page of our website, even if you do not have a Facebook or Twitter profile ("Social Media Profile") or are not logged in to your Facebook or Twitter profile at this time.

Twitter stores this personal data in the United States of America. Twitter may disclose personal data collected in this way to third parties.

If you are logged in to a social media profile, the provider concerned can also assign your visit to our website to your profile directly. If you interact with the plugins, e.g. by clicking the "Like" button or the "Tweet" button, this information will also be transmitted to the respective provider and processed and saved there. This information will also be published on your Facebook or Twitter profile.

The purpose and scope of the data collected and its further processing by the respective provider and your rights and configuration options for the protection of your privacy are explained in the data protection information of the respective provider:

Facebook: https://de-de.facebook.com/about/privacy

Twitter: https://twitter.com/privacy?lang=en

If you do not want Facebook or Twitter to associate the data collected through the plugins with your social media profile, you should log out of that social media profile before visiting our website. You can also use different third-party apps or browser extensions that allow you to opt out of submitting data to Facebook.


Twitter and Facebook are based in the USA, and are certified for the "Privacy Shield" data protection agreement between the USA and the EU, which guarantees compliance with the data protection level applicable in the EU.

25. Cookies

Cookies are small information files that we use to store information about you on the device you use to access the Wantedly website.

We use session cookies, which are deleted after the web browser window is closed, but no later than 48 hours after visiting our website. Your login data will be stored for up to 14 days, unless you have logged out before closing the browser window.

In addition, we use permanent cookies. These help us understand, for example, how our website and our services are used, how often you access our website, the respective sub-pages and services and are necessary to enable certain technical functionalities such as a permanent login.

The information stored in the cookies does not contain any personal data and does not enable us to identify you. They are also not used together with other data to record your use in a form that can be assigned to you. If personal data are also processed by individual cookies set by us, the processing pursuant to Art. 6 para. 1 letter b DSGVO either for the execution of the contract or pursuant to Art. 6 para. 1 letter f DSGVO, in keeping with our legitimate interest in the best possible functioning of our website and a customer-friendly and effective design of the use of our website.

Accepting cookies is not a prerequisite for visiting our website. However, if you do not accept the storage of cookies, the functionality of the website may be restricted.

You can prevent the acceptance of cookie files at any time by adjusting the settings of your Internet browser so that cookies are blocked, i.e. not accepted and saved. Detailed information about the possibilities and ways of handling cookies is available in the software settings (web browser). You can also delete cookies at any time in the settings of your browser program.
This also applies to cookies from third parties that are set when you visit our website, such as Google's services.

26. Third party services on our website

Google Analytics (with anonymisation function) 

Our websites use Google Analytics, a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. "("Google"). Google Analytics uses cookies that are stored on your computer and other end devices and enable an analysis of how you use our website and services.


The information obtained by the cookie about the use of our website and services is generally transmitted to and stored by Google on servers in the United States. However, we use the suffix "_gat._anonymizeIp" for the analysis using Google Analytics. This addition shortens and anonymizes the IP address of the Internet connection through which you access our website and services if the access takes place from a member state of the European Union or from another state party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. In these exceptional cases, this processing is carried out in accordance with Art. 6 Para. 1 letter f DSGVO on the basis of our legitimate interest in the statistical analysis of user behaviour for optimisation and marketing purposes.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, it is then possible that certain functions of our website are not available or do not function smoothly. You can also prevent the transmission of information collected by the Google cookie and data relating to the use of our website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout.

For more information about Google's Terms of Use and Privacy Policy, please visit https://www.google.com/intl/de/policies/privacy.
Google Analytics will be explained in more detail under this link
https://www.google.com/intl/de_en/analytics.

Google AdWords

We have integrated Google AdWords, a Google service, into our website. Google AdWords allows us to serve targeted and relevant ads in Google's search engine results and the Google advertising network by defining certain search terms (AdWords).


If you access our site through such an ad, Google places a 30-day conversion cookie on the device you use. The conversion cookie shows whether you came to our website via a Google AdWords ad and which subpages of our website you have visited.


Google uses the data collected in this way to compile visit statistics for our website. We use these visit statistics to determine the number of users who have reached our website via AdWords ads. We do not receive any information from Google with which we could identify you.


With the help of the conversion cookie, personal information is collected, for example the websites you have visited. Personal data, including the IP address of the Internet connection used by the person concerned, is therefore transferred to Google each time he or she visits our Internet pages. Personal data is processed by Google in the United States of America. Google may share this personal information with third parties.


You may refuse the use of cookies at any time by selecting the appropriate settings on your browser. In addition, a cookie can be deleted at any time via your Internet browser software. You can also object to Google's interest-based advertising by making the desired settings at
www.google.de/settings/ads
For more information and Google's privacy policy, visit
https://www.google.de/intl/de/policies/privacy.
Google, based in the USA, is certified for the "Privacy Shield" data protection agreement between the USA and the EU, which guarantees compliance with the data protection level applicable in the EU.

Facebook Pixel

On the Wantedly website, we use visitor activity pixels from Facebook, a service of Facebook Inc, 1601 S. California Avenue, Palo Alto, CA 94304, USA ("Facebook"). The Facebook pixel allows your user behavior to be tracked after you have been redirected to the Wantedly website by clicking on a Facebook ad. This process is designed to evaluate the effectiveness of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts.

The data collected is anonymous for us, and therefore does not provide us with any information about the identity of the users. However, Facebook will store and process the information so that it can connect it to your Facebook user profile and Facebook can process the information for its own promotional purposes. You can find the applicable policy for the processing of your personal data at https://www.facebook.com/about/privacy.

You can revoke your consent to use the visitor action pixel of Facebook at any time by clicking on the link below: https://www.wantedly.com/user/preference/edit


Facebook, based in the United States, is certified under the Privacy Shield Agreement between the United States and the European Union, which ensures compliance with the level of data protection applicable in the European Union.

27. Status of the data protection declaration

This Privacy Policy is current as of May 2018 and may need to be amended as a result of further development of the Wantedly Services or changes in legal or regulatory requirements. You can find the current data protection declaration on our website.