INTRODUCTION

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Latzer Associates Group Deutschland GmbH specializes in executive search, executive coaching, and talent management,with a strong commitment to safeguarding the privacy of our clients,candidates, and other service users.

We adhere rigorously to all relevant legalstandards to ensure the protection of your personal data and information. In this document, we clarify the terms "client", "candidate","employee", and "potential employee", which refer to different people within our business activities:

·       Client: Individuals or organizations utilizing our services for executive search, talentmanagement, or related purposes. This encompasses hiring managers, human resourcedepartments, executives, or other relevant parties involved in recruitment and talent management.

·       Candidate: Individuals either employed by our clients or under consideration for employment opportunities.

·       Employees: Individuals employed by Latzer Associates Group Deutschland GmbH.

·       Potential Employee: Individuals who apply for positions or express interest in job opportunities through our portal, LinkedIn, or directly via email.

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The definition of these terms ensures transparency and clarity in our communication regarding the handling of personal data. This Privacy Policy applies to all individuals mentioned and governs our dataprocessing practices.

Our GDPR Privacy Policy outlines the scope, methods, and purposes of our collection and processing of personal information. We are dedicated to transparency, integrity, and compliance with data protection lawsand regulations. Our aim is to provide clear and comprehensive information tofacilitate informed decision-making about your privacy.

Responsible Body Within the Meaning of Data Protection Law:

Latzer Associates Group Deutschland GmbH

Otl-Aicher-Straße 68, 80807 Munich

Germany in adherence to GDPR regulations, Latzer Associates Group Deutschland GmbH has appointed Parisa Peikareh as our internal Data Protection Officer (DPO). While Parisa Peikareh provides advice and support on data protection matters, Latzer Associates Group Deutschland GmbH retains full legal responsibility for compliance with data protection regulations. For any inquiries or clarifications regarding our privacy practices, please do not hesitate to contact Parisa Peikareh at the following email address: dpo@latzerassociatesgroup.com.
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1. PURPOSES AND LEGAL BASES OF PROCESSING

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We process your personal data in accordance with theprovisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

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1.1 Collection of applicant data for the provision of services (BDSG §26, GDPR Art.6 para. 1 lit. b)

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We collect personal data from candidates to facilitate our services to clients. This includes information such as resumes, workexperience, educational background, and contact details, among others. The legal basis for the processing of this data is §26 of the Federal DataProtection Act (BDSG) and Art. 6 (1) (b) GDPR, which allow the processing of personal data if this is necessary for the performance of a contract or for theimplementation of pre-contractual measures at the request of the data subject.

The legal basis for this is Art. 88 GDPR inconjunction with § 26 BDSG for the purposes of the employment relationship, insofar as this is necessary for the decision on the establishment of anemployment relationship.

In addition, we may process your personal data if this is necessary to comply with legal obligations (Art. 6 para. 1 lit. c GDPR) or to defend against or assert legal claims. The legal basis for this is Art. 6(1) (f) GDPR. The legitimate interest is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

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1.2. Collection of customer data for the purpose of addressing candidates (BDSG §26, GDPR Art. 6para. 1 lit. f)

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We also collect data from our clients to informcandidates about potential employment opportunities. This can include information such as job descriptions, company profiles, and specific requirements for open positions. We only share the information necessary for the recruitment process and ensure that it aligns with the legitimate interestsof both our clients and candidates. Disclosure of further information is only upon client's consent in case of confidential recruitment. This ensures that sensitive information is handled with due care and in accordance with thecustomer's preferences and requirements.

The legal basis for the processing of customer data is § 26 BDSG and Art. 6 (1) (f) GDPR, which permit the processing of personal data if this is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject prevail.

1.3. Collection of potential employee data for internal recruitment (BDSG §26, GDPR Art. 6 para. 1 lit. b)

In the case of potential employees who apply for jobs through third-party platforms or contact us directly via email to express interest in job opportunities, we collect personal data for internal recruitment purposes. This includes information suchas resumes, cover letters and contact details. The legal basis for the processing of this data is § 26 BDSG and Art. 6 (1) (b) GDPR, which allow the processing of personal data if necessary for the performance of a contract or for the implementation of pre-contractual measures at the request of the data subject.

2. CATEGORIES OF PERSONAL DATA

We process personal data relevant to various aspectsof our business, including job applications and ongoing services to ourclients. This may include a range of information that is relevant to your cooperation with us, such as:

·       General personal data (name, address, contact details,etc.).

·       Details of your professional qualifications andeducational background.

·       Information about your professional career.

·       Any additional data you voluntarily provide inconnection with your engagement.

We collect personal information with your consent, as it is voluntarily shared with us as part of your use of our services. By engaging with us, you acknowledge and consent to the sharing of your data for the described purposes.

It is essential to note that sensitive data is handled with the utmostcare and will never be sold or used for discriminatory practices. All personal data is collected only if voluntarily provided by the candidate and is usedsolely to provide our services to clients and enhance our offerings.

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3. DATA SOURCES

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We receive personal data from various sources tofacilitate our operations and effectively provide our services. These sourcesmay include, but are not limited to:

·       Candidates and potential employees: Personal information is collected directly from candidates who submit resumes via email, make phone calls or         interviews, or interact with us through other communication channels.

·       Clients: Data may be provided by our clients when they useour services for recruitment, talent management or other recruitment consultingpurposes.

·       Third-Party Platforms: We may receive personal information fromthird-party platforms such as social media, job boards, professional networkingsites such as         LinkedIn, or publicly available sources where individuals haveprovided their information for professional purposes.

·       Referrals: Personal data may be obtained through referrals fromexisting clients, candidates, or other professional contacts.

·       Internal databases: We maintain internal databases of personaldata of candidates, clients and other relevant persons collected in the course of our business         activities.

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4. RECIPIENTS OF THE DATA

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Your personal data will be processed on our behalfbased on data processing agreements in accordance with Art. 28 of the GDPR. In these cases, we ensure that personal data processing complies with GDPR provisions.

Recipients of the data include internal employees of Latzer Associates Group Deutschland GmbH. Employees are strictly prohibited from disclosing information to third parties and are obliged to maintain strict confidentiality of all data in the exclusive interest of the company.

Additionally, data may be shared with various customergroups involved in the recruitment process, such as hiring managers, Human Resources staff, and other relevant decision-makers.

Furthermore, external service providers working for Latzer Associates Group Deutschland GmbH, such as IT and database providers,website hosts, and other service providers, may have access to the data solelyfor providing their respective services to our company. However, access isstrictly limited to what is necessary to fulfill their contractual obligations.

While Latzer Associates Group Deutschland GmbH assumes responsibility for lawful data processing within our organization, we cannot beheld liable for unauthorized disclosure of information by individuals beyondour control.

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5. TRANSFER TO A THIRD COUNTRY

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A transfer to a third country only takes placeif necessary and is processed in accordance with GDPR Art. 45 and BDSG § 78.

6. DURATION OF DATA STORAGE

Latzer Associates Group Deutschland GmbH retains personal data collected from candidates and potential employees for a period of 5 years, in accordance with Article 5 of the General Data Protection Regulation(GDPR) and Section 1 of this document. This retention period ensures thecontinuity of our services and facilitates future mandates. Regarding employeesand clients, we retain their data for a period of 10 years to maintain accuraterecords in compliance with German laws.

The decision to establish these retention periods isbased on legal requirements, operational needs, and the necessity to balancethe interests of the company with the privacy rights of individuals. By adhering to these retention periods, we aim to uphold our commitment to dataprotection and privacy while ensuring the effective delivery of our services.

Individuals have the right to request the deletion, modification, or a report of their data before the expiration of the specifiedretention periods, as outlined in Section 7 of this document.

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7. YOUR RIGHTS

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Latzer Associates Group Deutschland GmbH is committedto protecting your rights as a data subject in accordance with the General DataProtection Regulation (GDPR).

Here is a summary of your rights:

·       Right of access (Art. 15 GDPR): You have the right to receiveinformation about the processing of your personal data.

·       Right to rectification (Art. 16 GDPR): You have the right to requestthe rectification of inaccurate or incomplete personal data.

·       Right to erasure (Art. 17 GDPR): You have the right to requestthe deletion of your personal data under certain circumstances.

·       Right to restriction of processing (Art. 18 GDPR): You have the right to requestthe restriction of the processing of your personal data under         certaincircumstances.

·       Right to data portability (Art. 20 GDPR): You have the right to receiveyour personal data in a structured, commonly used, and machine-readable format.

·       Right of revocation (Art. 21 GDPR): If the processing of yourpersonal data is based on legitimate interests (Art. 6 para. 1 lit. f GDPR),you have the right to object         to the processing at any time on grounds arisingfrom your particular situation. We will then no longer process your personaldata unless we can demonstrate         compelling legitimate grounds for theprocessing.

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You also have the right to lodge a complaint with adata protection supervisory authority if you believe that the processing ofyour personal data is not lawful (Art. 77 GDPR).

If the processing of the data is based on yourconsent, you have the right to withdraw your consent at any time (Art. 7 GDPR). Please note that the revocation is only effective for future processing and hasno effect on the processing that took place before the revocation.

To exercise your rights or withdraw your consent, please contact our Data Protection Officer (DPO), Ilenia Pontoriero, at dpo@latzerassociatesgroup.com.

8. NECESSITY OF PROVIDING PERSONAL DATA

The provision of your personal data, whether as a candidate, potential employee, or client, is voluntary. However, LATZERASSOCIATES GROUP Deutschland GmbH relies on the information provided to makeinformed decisions and effectively provide tailored services.

For candidates and potential employees, providing thenecessary personal data is critical for assessing qualifications, skills, andsuitability for roles or career opportunities. Your data allows us tocomprehensively evaluate your candidacy and facilitate possible placements orengagements.

Similarly, providing relevant information to customersensures the effective delivery of our services, allowing us to understand yourrequirements and preferences to better meet your needs.

8.1. Legal Responsibility for Accuracy of Information

By providing data to LATZER ASSOCIATES GROUPDeutschland GmbH (whether as a client, candidate, employee, or potentialemployee), the individual confirms that all information submitted is accurate,complete, and truthful. The individual assumes full legal responsibility forthe accuracy of the data they provide and acknowledges that LATZER ASSOCIATESGROUP Deutschland GmbH is not liable for any inaccuracies or misleadinginformation submitted.

Knowingly providing false, misleading, or incompleteinformation may result in legal consequences, including, but not limited to, rejection of applications, termination of employment, or other contractualpenalties. The individual is also responsible for any consequences arising from the provision of incorrect or dishonest information, including impacts onemployment status, application outcomes, or other related matters.

Individuals are encouraged to regularly review and update their personal information to ensure it remains accurate and up-to-date.

9. AUTOMATED DECISION-MAKING

At Latzer Associates Group Deutschland GmbH, transparency, and fairness are prioritized in decision-making processes. Advanced technologies are utilized to enhance operations; however, it iscrucial to note that decisions concerning applications, engagements, or servicedelivery are not solely automated. Consequently, individual cases are notsubjected to automated decision-making as defined by Article 22 of the General Data Protection Regulation (GDPR).

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10. SEVERABILITY

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If any provision of this Agreement is or becomes invalid, unenforceable, or void in whole or in part, the validity of the remaining provisions shall not be affected.

In place of the invalid, unenforceable or void provision, the valid, enforceable, and valid provision shall be deemed to have been agreed which comes closest to the economic purpose of the invalid, unenforceable or voidprovision. The same applies in the event of a gap in this contract.

The purpose of this clause is to ensure that in the event of the invalidityor unenforceability of any provision in a contract, the remaining provisions will continue to apply, and the parties will be able to pursue their intentions as far as possible.

11. UPDATES TO THIS POLICY

Latzer Associates Group Deutschland GmbH regularly reviews its privacy practices, which may be modified as necessary to ensure compliance with applicable data protection laws and regulations and to adapt to evolving industry standards and best practices.

You can determine when this policy was last revised by reviewing the Last Update legend at the end of the policy.

Any changes to the Policy will be effective upon posting of the revised Policy on our website.

Last Update: 23.10.2024

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