I. General information about data protection at Etengo
- Trust and transparency have been Etengo’s central values for many years now. These are values we advocate and are committed to. Therefore, it is a matter of course that we handle all data, in particular personal data that you entrust to us, in a strictly confidential manner and only for the specified purpose in accordance with legal provisions. The new EU General Data Protection Regulation (GDPR) entered into force on 25 May 2018. This harmonises data protection within the EU while strengthening data subjects’ rights. We have always attached particular importance to the protection and security of all data. Our Fort Knox Guarantee ensures that your data (such as that required for the candidate presentation, business initiation or business relationship) will never be transferred to third parties without your knowledge or consent. This always has and will guarantee the responsible use of your data.
- The Employee Data Protection Guideline, which is available on the Etengo intranet, shall apply to internal employees of the Etengo Group. The Etengo Group (hereinafter ‘Etengo’) comprises Etengo AG and its fully owned subsidiary Etengo Academic Experts GmbH.
- The responsible body for the processing of personal:
Telephone: +49 621 15 021 0
Fax: +49 621 15 021 399
Etengo AG, the provider of this online presence, shall be the controller in accordance with Section 3 (7) of the German Federal Data Protection Act (BDSG) and Art. 4 (7) of the GDPR, and service provider in accordance with Section 12 ff. in conjunction with Section 2 (1) of the German Telemedia Act (TMG).
- The responsible body for the processing of personal data at our wholly owned subsidiary is:
Etengo Academic Experts GmbH
Telephone: +49 621 15 021 0
Fax: +49 621 15 021 399
Etengo AG shall provide shared services (such as IT and accounting) on behalf of and on the instruction of Etengo Academic Experts GmbH within the scope of a commissioned data processing agreement with Etengo Academic Experts GmbH. In this respect, your personal data shall be processed by both Etengo AG and Etengo Academic Experts GmbH.
III. Data protections for candidates
1. Data collection through registration on our website
You can register as a candidate with Etengo and include your profile in our pool of specialists (database) on our website. As a registered user, you may log in repeatedly and continuously update your profile. Once you are logged in, you can bookmark or apply for specific projects without obligation.
If you are already engaged in a specific project through Etengo AG, you may additionally use the online billing portal (ORP) and online time sheet (OLN) to bill your hours on a monthly basis free of charge.
You can also submit a ‘short-form application’ for specific projects without registering beforehand. In this case, you must provide your name and surname, a valid email address and your telephone or mobile phone number. You can include a message and attach relevant documents such as your profile or CV.
2. Data collection through or from generally accessible data sources and recommendations
Etengo is a specialist staffing service provider for the placement of highly skilled DIG.IT specialists in fixed-term.
Therefore, we also actively search for and obtain, even from generally accessible sources, personal data about candidates. Thus, when we search for potential candidates in external sources such as LinkedIn, XING and other career networks, we may learn about you. The same applies in the case of recommendations. In many cases, colleagues and also customers of skilled DIG.IT specialists provide us with their contact information.
In these cases, we shall initially only store the minimum of your personal data, comprising:
- name and surname;
- email address;
- place of residence and postcode;
- qualification (for example, project manager); and
- skills (for example, SAP HCM)
We shall then contact you ‘without culpable delay’ pursuant to Section 121 (1) of the German Civil Code (BGB) with regard to the storage of this minimum data and simultaneously ask you to consent to the processing of your personal data for the aforementioned purposes. Should you not consent or reply, we shall delete the minimum data within the legally permissible period.
3. Employees of system vendors or consultancies
Should you be an employee of a system vendor or consultancy that works with Etengo for the purpose of allocating projects, we shall process your personal data in the same manner as we do for candidates.
Partner companies can provide Etengo with confirmation that employees whose personal data is transferred to Etengo have been informed about this procedure (for example, as part of the employment contract or some other agreement with the employer). Etengo then processes the personal data of permanently employed external consultants for the purposes of its legitimate interests in accordance with Art. 6 (1) lit. f of the GDPR.
In the case of partner companies that do not or cannot provide the above confirmation, we will contact the employees to obtain their consent. For this purpose, we grant a contact person administrator access to register company employees and organise the consent process. We require the actual consent directly from the respective employee.
4. Data processing
We shall process the data you transfer to us and take appropriate technical and organisational precautions to protect it against unauthorised access by third parties.
Generally, we shall use your information to create a qualification profile without your postal address, email address and other contact details (hereinafter ‘Personal Contact Data’), but with your name, qualification, gender, age, place of residence, nationality, information from your profile, your photo if applicable and information from other data and files provided to us for presentation purposes.
In the case of specific customer enquiries, we shall conduct a ‘matching’ process to assess your suitability for a specific project of one of our customers. This means that we shall filter out or derive your skills (abilities) and experience from the data you transfer to us (in particular, from your CV, project history, etc.) to then match you to the customer enquiry in a semi-automated, automated or manual process.
6. Transfer of data to third parties
Your qualification profile, which is stored in Etengo’s database or candidate pool, is made available to customers, potential customers and service providers that they engage (such as managed services providers and neutral or master vendors) as a file or through a secure link. This gives such recipients the opportunity to read your qualification profile and assess or select it according to specific criteria, and forward it to the relevant office or department. Thus, the qualification profile serves to present you as a candidate for the project in question, with the aim of achieving a placement in the project at the customer or end customer. Etengo shall transfer your qualification profile, including commercial terms, to the respective recipient exclusively with your prior consent, usually in the course of a telephone briefing but in no case automatically. Customers, potential customers and service providers that they engage shall not be able to search through our database directly and will therefore have no access to your Personal Contact Data. In each individual case, you shall always decide what Personal Contact Data you would like to transfer, if applicable before or only after you have been selected for placement in a project. Naturally, we shall not accept responsibility for whether customers, potential customers and service providers that they engage handle your transferred data, in particular your Personal Contact Data, confidentially, for the specified purpose and in accordance with data protection requirements. Please take note of this in particular when specifying data in your qualification profile, transferring other data and files for presentation purposes and releasing Personal Contact Data through a social network, for instance. In principle, you are under no legal or contractual obligation to transmit your personal data to Etengo. However, in order to make use of the services offered by Etengo, which involve offering and staffing interesting and innovative IT projects, it is necessary to process personal data. Therefore, when registering or submitting a short-form application among other things, you shall be required to consent to the processing of data:
7. Declaration of consent for inclusion in the Etengo
Consent to data processing
I consent to the processing of my personal data that I have provided to Etengo AG (hereinafter ‘Etengo’), in particular, my surname, name, address, date of birth, marital status, curriculum vitae, photograph, professional skills and knowledge, certificates and documentation, conditions and billing information, nationality, work and residence permit, and contact information (particularly my email address, telephone number and links to my social networks), by Etengo, even beyond the scope of any specific placement in a project and also subsequent to successful collaboration for the duration of my consent, for the purpose of notifying me of freelance projects that match my professional profile and my wishes.
Etengo may contact me for these purposes and/or providing current or project-related news using the contact details I have provided (in particular, by email, telephone, post or SMS), as well as using digital channels such as messenger services and notification services on professional social media platforms such as Xing, LinkedIn and freelance.de, and sending me information about Etengo services.
Retention of my personal data
Etengo may retain my aforementioned data in an electronic database for the aforementioned purposes. My consent shall also apply to data about my qualifications and professional activities from generally accessible data sources (in particular, from professional and social networks), which Etengo is permitted to collect.
Better prospects of collaboration within the Etengo Group
Furthermore, I consent to the transmission of my aforementioned personal data to Etengo Academic Experts GmbH and, if applicable, to other companies subsequently affiliated with Etengo pursuant to company law. I may refer to a list of such companies on https://www.etengo.de/en/legal... at any time. This shall occur only to the extent necessary for the purpose of offering me any existing opportunities for collaboration with these affiliated companies. The provisions of this consent shall in turn apply to the affiliated companies.
Profile presentation and transfer of personal data
I consent to the transmission of my personal data to potential principals and/or a service provider engaged by a potential principal (such as a managed services provider and a neutral or master vendor) by Etengo, to the extent necessary for the purpose of initiating a project staffing procedure (in particular, my name, qualifications, project history or curriculum vitae and certificates, nationality, place of residence and postcode, photograph and year or date of birth).
Optional, and may be withdrawn at any time
My consent to the above data processing is optional. Failure to grant such consent, in whole or in part, shall not affect my chances of being considered for any current application or staffing procedure.
Should I not grant my consent in whole or in part, or should I withdraw such consent, Etengo may be unable to proactively offer me its services in future, or do so only to a limited extent.
I may withdraw this consent with future effect, in whole or in part, by written notice to Etengo (for example, by sending an email to firstname.lastname@example.org) at any time.
Additional declaration for special categories of data in accordance with Art. 9 of the GDPR
If I myself have provided documents containing ‘special categories of personal data’ in accordance with Art. 9 of the General Data Protection Regulation (GDPR; such as a photo revealing ethnic origin, information about a severe disability, etc.) in the course of the application or staffing procedure, my consent shall also apply to this data. However, Etengo shall assess all candidates solely according to suitability and qualification, and therefore requests that such information or ‘special categories of personal data’ be dispensed with as far as possible.
IV. Data protection for projects providers or customers
- Data collection
If you are a customer looking for highly skilled DIG.IT specialists, you may submit a non-binding enquiry (by email, telephone, fax or through the needs enquiry contact form on our website) with information about your project or needs to Etengo. We shall process the search requests you submit to us and, subject to availability, present a suitable DIG.IT specialist by transferring a qualification profile to you. This anonymous qualification profile shall not contain any Personal Contact Data. However, it shall contain the qualification, gender, age, place of residence, nationality and, if applicable, a photograph and information from other data and files provided to us by the candidate for presentation purposes. As a customer, you may not search for DIG.IT specialists in our database yourself. This research and (pre)selection is a fee-based service provided exclusively by Etengo.
You shall not have to consent separately to the processing of the data (provided that it is function-related data), since the processing of your data (provided that it is personal data) shall be conducted on the grounds of the legal permission ensuing from Art. 6 (1) lit. f of the GDPR.
- Data collection through or from generally accessible data sources and recommendations
Etengo is a specialist staffing service provider for the placement of highly skilled DIG.IT specialists in fixed-term projects.
Therefore, we also actively search for and obtain, even from generally accessible sources, personal data from (potential) customers or their contact persons/employees. Thus, when we search for potential customers in external sources (usually through an Internet search but also through business portals such as LinkedIn, XING and other job networks), we may learn about you.
In addition to the independent search in generally accessible sources, we also use the option of obtaining this information via the service of Echobot Media Technologies GmbH, Südstr. 52.76135 Karlsruhe.
This service offers the possibility of obtaining generally accessible data on companies and the contact persons / employees via automated search queries. The sources used for this are online news, blogs, company websites, register databases and business-related social media networks.
In these cases, we shall initially only store the minimum of your personal data, comprising:
- name and surname;
- email address;
- technical area/department;
- company’s registered office and postcode; and - IT interests/needs.
processing of your data (provided that it is personal data) shall be conducted on the grounds of the legal permission ensuing from Art. 6 (1) lit. f of the GDPR. Should no collaboration ensue or should we not reach you, we shall erase this minimum data within the period specified by the legislator.
- Data storage and processing
The data and files you transfer to us in connection with your needs or desired service shall be stored by us and protected against unauthorised access by third parties with appropriate technical and organisational measures.
From your data, we shall create anonymised, web-based projects (hereinafter ‘Company Data’), however, with a precise description of your project needs or the requirements for the candidate, including the required soft and hard skills as well as other relevant information. These projects may be viewed by potential candidates through the search facility accessible on the Etengo website.A history of any communication between you and Etengo—be it by email, post, face-to-face meeting or telephone—shall be documented in a customer relationship management (CRM) system. In addition to such direct contact, internal notes or notifications relevant to current or future staffing processes shall also be recorded in the CRM system. Such documentation helps us conduct our processes quickly, correctly and without loss of information, and eventually achieve an optimised service in accordance with your wishes and expectations.
V. Data storage period
Your personal data shall be erased as soon as its processing is no longer necessary, the purpose of its processing no longer applies or if you no longer give or you withdraw your consent. However, please note that personal data must still be retained for the duration of the period in which claims against our company can be asserted (such as contractual and legal limitation periods of between three and 30 years). In addition, we shall store personal data if we are legally required to do so (in particular, in accordance with the German Commercial Code, Fiscal Code, Social Security Code, Money Laundering Act and Principles for Properly Maintaining and Storing Books, Records and Documents in Electronic Form and for Data Access [GoBD]); the storage period shall be 10 years.
VI. Commissioned data processing
Within the scope of the regulation on commissioned data processing (Art. 28 of the GDPR), we shall have the right to commission third parties to process personal data. In this case, the processing shall be conducted exclusively on our instruction and only for the purposes specified in the relevant commissioned data processing agreement.
Data processing at Etengo
Etengo comprises Etengo AG and its fully owned subsidiary Etengo Academic Experts GmbH.
External service providersWe shall occasionally make use of external service providers to fulfil individual contractual and legal obligations. The following table lists the contractors and service providers with whom we have a long-term business relationship.
Etengo makes use of the following service providers:
Object and purpose of use
Commissioned data processing for Etengo Academic Experts GmbH
Lettershops, printers and postal and parcel services
Printing and dispatching post and parcels
Credit reference agencies
Obtaining account information
Market and opinion researchers, rating agencies
Conducting market and opinion research, and customer surveys
Designing and implementing communication and marketing services
Documents and data shredders
Legally compliant disposal of documents and data storage media
VII. Cookies and technologies
In the event that you use our website merely for informational purposes, that is, you do not register, log in or otherwise provide us with any information, we shall only collect the personal data that your browser transfers to our server in accordance with your browser settings. If you would like to use our website, we shall collect the following data that is technically required to display our website correctly and to ensure its stability and security (the legal grounds for this shall be Art. 6 (1) lit. f of the GDPR):
- IP address;
- date and time of the request;
- difference in time zone from Greenwich Mean Time (GMT);
- content of the request (specific page); - request status/HTTP status code;
- respective volume of data transferred;
- website sending the request;
- operating system and interface; and
- language and version of the browser software.
This is a cookie that is used to store cookie settings for a period of one year.
This cookie guarantees security for site visitors by preventing cross-site request forgery, increasing the overall security of the website. It is stored for the duration of a session.
Google Tag Manager
Google Tag Manager is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager itself does not collect any personal data; it makes it easier for us to integrate and manage our tags. Tags are small pieces of code that are used to measure traffic and visitor behaviour, track the effects of online advertising and social channels, set up remarketing and targeting, and test and optimise websites, among other things. We use the Google Tag Manager for all the services listed here within the scope of operating and optimising our online services. If you have disabled the service, Google Tag Manager will take this into account. Further information about the Google Tag Manager is available here.
Other cookies and technologies
In addition to processing the technically necessary information mentioned, we use statistical and analysis technologies to improve our offer and integrate external media via YouTube and Google Maps.
When using these technologies, your data will also be passed on to third parties, which is why we ask for your permission when you first visit our website. You can call up and change your selection at any time via cookie settings.
You may configure your browser settings as you wish and refuse to accept third-party or all cookies, for instance. Please note that, in this case, you may be unable to use all the features of this website.
If you give us your consent, cookies will be stored on your device when you use our website. Cookies are small text files that are assigned and stored on your hard drive to the browser you are using and through which certain information flows to the location that sets the cookie (here by us). Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall.
This website uses the following types of cookies, the scope and functionality of which are briefly described below:
Transient cookies are deleted automatically when you close the browser. In particular, these include session cookies, which store a session ID that assigns the various browser requests to a single session, allowing your computer to be recognised when you return to our website and significantly increasing your and our security. Session cookies are automatically deleted when you log out or close your browser.
Persistent cookies are automatically deleted after a specific period, which may vary depending on the cookie. You may manually delete cookies through your browser’s security settings at any time.
The following cookies we only use with your consent:
Use of local storage
This website uses the local storage function to store data locally, in your browser’s cache. This data will persist, even after you close your browser window or quit your browser—provided you do not delete the cache—enabling specific website features, such as applying your preferred settings, when you visit our website again.
Notice regarding data processing in the USA by Google LLC and/ or LinkedIn Corporation:
By clicking ‘Accept all cookies’ or selecting the cookies issued by Google LLC (Google Analytics, YouTube, Google Maps) or LinkedIn Corporation, your data will be processed in the USA. According to the Court of Justice of the European Union (CJEU), the USA does not provide an adequate level of data protection. There is currently no adequacy decision. Furthermore, there is a risk that your data may be processed by US authorities for control and monitoring purposes, possibly also without access to legal remedy. If you disable or reject cookies issued by Google LLC or LinkedIn Corporation, your data will not be transferred. Any consent you have given can be revoked through the cookie settings.
Cookie name: _ga,_gat,_gid,
Period of validity: 2 years, 1 minute, 24 hours
Cookie Name und Laufzeit:
GPS, Expiry: 1 day; IDE, Expiry: 1 year; PREF, Expiry: 8 months; Test_cookie, Expiry 1 day; VISITOR_INFO1_LIVE, Expiry: 179 days; YSC, Expiry: Session; Yt-remote-cast-installed, Expiry: Session; Yt-remote-connected-devices, Expiry: Persistent; Yt-remote-device-id, Expiry: Presistent; Yt-remote-fast-check-period, Expiry: Session; Yt-remote-session-app, Expiry: Session; Yt-remote-session-name, Expiry: Session; Session till 1 year
This website may use Google Maps to display maps. Google Maps is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
By activating Google Maps, a connection to Google Maps is established and data is transferred directly from the user to Google. The processed data may include IP addresses and users’ location data. The provider may also install cookies on devices.
Cookie name: NID
Period of validity: 6 months
LinkedIn Insight Tag
Our website uses the "LinkedIn Insight Tag" tool from LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland for so-called conversion tracking. The use of the tool enables Etengo to display targeted advertising outside of its website and to call up statistics on the website target groups and the display performance from the provider. In addition, LinkedIn offers the option of retargeting via the Insight Tag. The "LinkedIn Insight Tag" creates a cookie in your web browser, which enables the collection of the following data, among others: IP address, device and browser properties and page events (e.g., page views). LinkedIn shortens the IP addresses or hashes them when tracking the target across devices. After seven days, direct identifiers are removed and pseudonymized. The remaining data will be deleted within 180 days. Logged-in LinkedIn members can also control settings for the use of their personal data for advertising purposes in their account settings.
Further information on the technologies and activities of LinkedIn can be found at: https://de.linkedin.com/legal/cookie-policy
Further information on the handling of your user data can be found in the data protection declaration of provenexpert.com: www.provenexpert.com/de-de/datenschutzbestimmungen/
Cookie name: PE_SESSION, _pelocale
Period of validity: Session, 29 days
VII. Your rights
You shall have the following rights with regard to personal data concerning you:
- Right of access (Art. 15 of the GDPR)
- Right to rectification and completion (Art. 16 of the GDPR)
- Right to erasure (‘right to be forgotten’) (Art. of the GDPR)
- Right to restriction of processing (Art. 18 of the GDPR)
- Right to data portability (Art. 20 of the GDPR)
- Right to object (Art. 21 of the GDPR)
- Right to withdraw your consent (Art. 7  of the GDPR)
- Right to lodge complaints with the supervisory authority (Art. 57  lit. f of the GDPR)
1. Right of access (Art. 15 of the GDPR)
You shall have the right to request confirmation as to whether we process personal data concerning you. Should this be the case, you shall have the right to access to this personal data as well as additional information, including the purposes of the processing, the recipients and the envisaged period for which it will be stored, or the criteria used to determine that period.
2. Right to rectification and completion (Art. 16 of the GDPR)
You shall have the right to request rectification of incorrect data without delay. Taking into account the purposes of the processing, you shall have the right to request completion of incomplete data.
3. Right to erasure (‘right to be forgotten’) (Art. 17 of the GDPR)
You shall have a right to erasure insofar as the processing is not required. This shall be the case if your data is no longer necessary for the original purposes for which it was collected, you have withdrawn your consent in accordance with data protection law or the data has been unlawfully processed.
4. Right to restriction of processing (Art. 18 of the GDPR)
SYou shall have the right to request restriction of the processing of your personal data. This means that you may request that we restrict processing if one of the conditions specified in Art. 18 (1) of the GDPR applies. This may be the case if you contest the accuracy of the personal data. In this case, the restriction shall be for a period that would enable us to verify the accuracy of personal data. Restriction means that we shall flag the stored personal data with the aim of restricting processing in future.
5. Right to data portability (Art. 20 of the GDPR)
You shall have the right to receive the personal data concerning you in a structured, conventional and machine-readable format.
6. Right to object (Art. 21 of the GDPR)
You shall have the right to object to the processing of personal data concerning you if the conditions of Art. 21 of the GDPR are fulfilled. More detailed information about this matter is available below:
Right to object to the collection of data in specific cases and to direct marketing (Art. 21 of the GDPR)
Should your personal data be processed for direct marketing purposes, you shall have the right to at object to the processing of personal data concerning you for the purpose of such marketing any time. This shall also apply to profiling insofar as it is related to such direct marketing. If you object, your personal data shall no longer be processed for the purpose of direct marketing (objection in accordance with Art. 21  of the GDPR).
7. Right to withdraw your consent (Art. 7  of the GDPR)
You shall the right to withdraw your consent with future effect, in full or in part, at any time. The lawfulness of the processing of your data prior to the withdrawal of consent shall remain unaffected by the withdrawal of consent. We shall record any withdrawal of consent.
8. Right to lodge complaints (Art. 57  lit. f of the GDPR)
Exercising your rights
XI. Data protection officer
The contact details of the Etengo data protection officer are as follows:
Etengo Group Data Protection Officer
C/O intersoft consulting services AG
Beim Strohhause 17
Fax: +49 621 15 021 399
X. Competent supervisory authority
Our competent supervisory authority is:
Landesbeauftragter für Datenschutz und Informationsfreiheit Baden-Württemberg
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Version: 4.1 as of 23. March 2021