Legal: Privacy Policy and Cookies Policy

This Privacy Policy satisfies the disclosure requirements according to Art. 12 ff. of the EU General Data Protection Regulation (“GDPR”) and provides a summary of the processing of your personally identifiable information (“personal data”, “personal information”) on the following websites: www.createyourowncareer.de/com, www.creativemanagementprgram.de, www.talentmeetsbertelsmann.com und www.data-science-bertelsmann.com (collectively referred to below as “website”).

Contents
    1. Who is accountable for processing my personal data?
    2. What data is collected?
    3. What cookies are used?
    4. What data is collected and for what purpose?
      4.1 Provision of the website
      4.2. Establishing contact with us
      4.3 Application procedure
      4.4 Google Tag Manager
      4.5 Google Analytics (web tracking)
    5. Who comes into possession of my personal data?
    6. Is my personal data processed outside of the EU or EEA (‘transfer to a third country’)?
    7. What data privacy rights do I have?
    8. To what extent does automated decision-making take place?
    9. Is profiling done?
   10. Children

1. Who is accountable for processing my personal data?

Bertelsmann SE & Co. KGaA
Carl-Bertelsmann-Straße 270
33311 Gütersloh, Germany
Phone: +49 (0) 5241-80-0
Fax: +49 (0) 5241-80-62321
Email: createyourowncareer@bertelsmann.de

is responsible for processing your personal data on this website (hereinafter referred to as “we” or “Bertelsmann”). We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).

You can contact Bertelsmann’s designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: datenschutz@bertelsmann.de

The subsidiaries of Bertelsmann are responsible for the data processing associated with the application process. No processing of applicant data for the purpose of creating an employment relationship takes place on this website. For further information, see section 4.3.

2. What data is collected?

When you visit our website, the data of the computer you use to access our website is auto-matically logged (“access data”). This access data includes server log files that generally con-sist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information con-tained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.

Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or to process a matter submitted by you (e.g. search queries, entries made in forms or contracts, click da-ta).

3. What cookies are used?

Cookies are used on our website. Cookies are small text files that are saved to your computer when visiting a website. The cookies that are saved can be attributed to the web browser used by you. When the website is visited again, the web browser returns the content of the cookies, thus enabling you, the user, to be recognized. Certain cookies are deleted when you log out or end the browser session (“transient cookies” or “session cookies”). Other cookies are saved for a specific period of time (“temporary cookies”) or indefinitely (“persistent cookies”). These cookies are automatically deleted when the defined period lapses. The privacy and security settings of your browser enable cookies to be deleted at any time and also enable you to con-figure the use of cookies in accordance with your preferences. However, you may not be able to use all the features of our website if you delete the cookies used by our website.

As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies them-selves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. analysis of user be-haviour or displaying advertising-related content.

The cookies that are required for the provision of website features include the following in particular:
• Cookies that are used to identify or authenticate the user;
• Cookies used to temporarily store user input (e.g. the content of a shopping cart or online form);
• Cookies used to store user preferences (e.g. search or language settings);
• Cookies that store data to enable the trouble-free rendering of video or audio content.

Cookies that are needed for other purposes of the website include analytics cookies to record the usage behaviour of our users and evaluate it in the form of statistics (e.g. sub-pages visited, search queries conducted).

4. What data is collected and for what purpose?

The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.

We use the data described in section 2 for the following purposes:

• To provide website features and content and for technical security in troubleshooting technical issues, and also to ensure that unauthorized persons do not gain access to our website systems;
• To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
• To establish contact and engage in communication; and
• To create an employer-employee relationship and/or for participation in programs by students and young professionals (application process).

For information on other data processing purposes, please refer to the sections below of this Privacy Policy.

4.1 Provision of the website

4.1.1 Description and scope of data processing

In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see sec-tion 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.

4.1.2 Purpose and legal basis of data processing

The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.

4.1.3 Duration of storage or criteria applied in defining this period

When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless a denial of service or other attack occurs.

4.1.4 Options for lodging an objection and having your data removed

You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.

4.2. Establishing contact with us

4.2.1 Description and scope of data processing

On our website you have the option of contacting various people at Bertelsmann by email or by telephone using the designated email address and phone number. If you take advantage of this option, the information you provide such as your email address and/or your phone num-ber and your request/reason for contacting us are disclosed to us. Depending on the reason you are contacting us (questions about your application, training opportunities or possible de-gree courses, or pursuing your rights as a data subject, e.g. submitting a request for infor-mation) your contact details are subjected to further processing. If necessary for processing your request, this information may be shared with third parties (e.g. subsidiaries).

4.2.2 Purpose and legal basis of data processing

The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to create an employment contract, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR / section 26(1)(1) German Federal Data Protection Act (BDSG).

4.2.3 Duration of storage or criteria applied in defining this period

Your contact details are deleted once your request has been processed and further commu-nication has been discontinued. This does not apply if the purpose of your establishing contact with us is to create an employment contract or you wish to exercise your right as a data sub-ject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 6 months for applicant data and 3 to 4 years for data securing the rights of data subjects) do not prevent this information from being deleted.

4.2.4 Options for lodging an objection and having your information removed

You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for setting up a contract or exercising your rights as a data subject.

4.3 Application procedure

4.3.1 Description and scope of data processing

Job listings are published on this website enabling you to apply for a job with us. The job listing leads you to the job application platform. This means that the actual data processing for the application procedure does not take place on this website. With the exception of your IP ad-dress, no data is transmitted to our job application platforms. The individual subsidiaries of Bertelsmann are responsible for the job listings. For details on the person/unit responsible, the purpose of data processing and the legal basis, in additional to potential recipients, please refer to the respective job listing. For further details on data processing for the application pro-cedure, please refer to the privacy policies of the job application platforms BeCruiter and Peoplenet:

BeCruiter: https://myjobs-en.becruiter.net/jobagent/pcp/help_frameset.aspx?page=privacy

Peoplenet: https://performancemanager5.successfactors.eu/doc/Bertelsmann/External_Privacy_Statement.pdf

For details on the programs, please refer to the FAQs:

Talent Meets Bertelsmann: https://www.talentmeetsbertelsmann.com/#section-faq

Creative Management Program: https://creativemanagementprogram.de/

Data Science Program: https://data-science-bertelsmann.com/

4.3.2 Purpose of data processing and legal basis

The processing of applicant data is permissible when this is necessary for making a hiring decision. This necessity is determined by the job listing. Consequently, the purpose is to create an employment contract and the legal basis for this follows from section 26(1)(1) German Federal Data Protection Act (BDSG-neu) (Art. 6(1)(b) GDPR generally applies outside of Germany). Where other legal provisions apply, you will be informed of this in the privacy policy of the job application platforms.

4.3.3 Duration of storage or criteria applied in defining this period

As a general rule, applicant information is retained on file until the respective application process has been concluded and a hiring decision has been made. Applicant details are retained for six months upon the conclusion of the application process for the purpose of providing a documentary account and for defending against any claims pursued under the German Gen-eral Equal Treatment Act (AGG). This does not apply when the hiring decision is in your fa-vour and your details are processed further to enable the employment relationship to come about and be maintained. Where other criteria apply to determining the period during which information is retained, you will be inform of this in the privacy policy of the respective job application platform.

BeCruiter: https://myjobs-en.becruiter.net/jobagent/pcp/help_frameset.aspx?page=privacy

Peoplenet: https://performancemanager5.successfactors.eu/doc/Bertelsmann/External_Privacy_Statement.pdf

4.3.4 Right to lodge an objection and have your information removed

The processing of your information is required for the application procedure and consequently for creating an employment contract. This means you have no option to lodge an objection. Where this does not apply, you will be informed of this at the time information is collected by way of the privacy policy of the job application platform where you are registered.

BeCruiter: https://myjobs-en.becruiter.net/jobagent/pcp/help_frameset.aspx?page=privacy

Peoplenet: https://performancemanager5.successfactors.eu/doc/Bertelsmann/External_Privacy_Statement.pdf

4.4 Google Tag Manager

This website uses Google Tag Manager, a service is provided by Google Inc., 1600 Amphi-theatre Parkway, Mountain View, CA 94043, USA (Google Inc.). Google Tag Manager ena-bles the web tracking services integrated in this website (see section 4.4) and other services to be administered by tags (tags are placeholders for website code). Google Tag Manager implements these tags only. No cookies are used nor is any personally identifiable information collected by Google Tag Manager in a targeted manner. Google Tag Manager only triggers other tags that in turn gather other data as applicable. However, Google Tag Manager never accesses this data.

4.5 Google Analytics (web tracking)

4.5.1 Description and scope of data processing

This website uses Google Analytics, a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as de-scribed in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are as-signed are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing agreement we have concluded with Google Inc.

For more information on data processing related to Google Analytics, refer to the Google’s privacy policy: https://policies.google.com/privacy?hl=en.

4.5.2 Purpose and legal basis of data processing

The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6(1)(f) GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in opti-mizing the user-friendliness of our website and performing marketing reach measurements.

4.5.3 Duration of storage or criteria applied in defining this period

As a general rule, the data that is collected and analyzed in association with Google Analytics is retained until you raise an objection to it being used in this manner. Analytics cookies are stored for a maximum of 24 months.

4.5.4 Options for lodging an objection and having your data removed

You can raise an objection to the use of Google Analytics by changing your browser settings and/or clicking on the following link to download and install the browser plug-in: https://tools.google.com/dlpage/gaoptout

4.5 Links to other websites

This website contains links to the websites of other website operators. Clicking on the links takes you to the respective websites (e.g. Facebook, YouTube). With the exception of your access data to make the other website available, no data of yours is transmitted to these website operators.

Our Privacy Policy only covers our website; we are not responsible for the privacy policies of other websites. Nevertheless we recommend that you read the privacy policies of the websites you access by clicking on the links leading to them.

5. Who comes into possession of my personal data?

Within Bertelsmann those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

No data is shared with other recipients such as our subsidiaries (“third parties”) unless this is permitted by law or you have consented to this.

6. Is my personal data processed outside of the EU or EEA (‘transfer to a third country’)?

The use of Google Analytics as described in section 4.4 above causes personal data to be transferred to a third country since the data centers of Google Inc. are located outside of the European Union and the European Economic Area (“EU or EEA”). Such transfers of personal data to third countries may result in your personal information being transmitted to a country which does not provide for the same standard of data protection as the EU or EEA. However, by being certified under the EU-US Privacy Shield, Google Inc. ensures that a level of data protection comparable to that in the EU/EEA is ensured. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.

7. What data privacy rights do I have?

You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data pro-vided by you in a structured, commonly-used, machine-readable format (right to data portability).

If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to Bertelsmann by writing to the contact address indicated in section 1.

Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situa-tion to raise an objection to the processing of your data that is done on the basis of Art. 6(1)(f) GDPR. You also have the right to lodge an objection to the processing of your personal in-formation for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.

You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for Bertelsmann is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Phone: 0211/38424-0
Fax: 0211/38424-10
Email: poststelle@ldi.nrw.de

You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.

8. To what extent does automated decision-making take place?

We do not use any fully automated decision-making processes for any of the purposes set out in section 4.

9. Is profiling done?

No profiling takes place for any of the purposes set out in section 4.

10. Children

This website is also intended for students. As a rule they are at least sixteen years old, mean-ing that Bertelsmann need not take into account any other requirements with regard to processing the data of children under the GDPR.

Date of this Privacy Policy: May 2018

What is CYOC?

CYOC is the abbreviation for "Create Your Own Career"

The slogan emphasizes individual career opportunities and entrepreneurial freedom, which employees of Bertelsmann get. The following video shows what Create Your Own Career means for our employees.

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