Privacy Policy
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Privacy Policy — Websites
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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 (referred to below as “we” or “Bertelsmann”). We process personally identifiable information (“personal data”; also referred to as “personal information”) 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.
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2. What data is collected?
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist 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.
Generally speaking, you can access the content on our website without divulging any information about you, e.g. in order to obtain information about us. However, some features of our website require that you provide personally identifiable 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 data).
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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, your 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”).Our website distinguishes two types of cookies: functional cookies and non-functional (optional) cookies. Functional cookies are essential for the website to work (to provide the website in a technically and functionally flawless manner) (e.g. identifying and authenticating the user, language settings, display of recorded images). Without these functional cookies, the content offered on our website would be limited. Optional cookies, on the other hand, help to optimize what is offered on our website by collecting information on user behavior and subjecting it to statistical analysis.
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may be personally identifiable when the information generated by the cookies is merged with other information, e.g. access data pursuant to section 2 (e.g. when web tracking is used). Any merging is done in a pseudonymized manner.
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. marketing reach measurement, web analysis and market research.
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 an 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. advertising banners clicked, sub-pages visited, search queries conducted).
3.1. Functional Cookies
To obtain and store your consent to the cookies on this website, we use the CookieFirst Consent Management Platform:
CookieFirst by Digital Data Solutions B.V.
Plantage Middenlaan 42a
1018 DH Amsterdam
KvK-number: 75762277
legal@cookiefirst.comThis platform sets a technically required cookie to query the status of your consent and thus to be able to play back corresponding content. A usage analysis in order to measure how the collection of consent works is based on our legitimate interest (Art. 6 par. 1 p. 1 lit. f GDPR).
The cookie is stored until you withdraw your consent and is deleted at lastest after 13 months.
Since a transfer to a third country takes place in this regard, we have concluded EU standard contractual clauses to ensure that the processing of personal data is compatible with the data protection regulation, especially the GDPR.The CookieFirst privacy policy can be found here.
3.2. Consent-based Cookies
For information on cookies that collect and process your data on the basis of your consent, please refer to section 4.5.
Privacy Settings
Within the function “Privacy Settings” on this website you can decide whether you consent to the collection and processing of your data on your device concerning consent-based cookies and other data by the operator of this website and its partners that are used for the personalization, playout and analyzation of content within and outside this website and for the evaluation of the use of this website.
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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 information provided by you 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 with you; and
- To enable you to assert rights as a data subject.
Data processing for taking part in the application procedure, participating in our programs and for taking part in our events including the publication of pictures and video recordings is not done directly via our website. Details on these different processing typescan be found below and under the following link:
Job application platform: https://jobsearch.createyourowncareer.com/content/Privacy-Policy/?locale=de_DE
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 section 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 retention 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 about job applications, Bertelsmann’s programs and talent management 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 number and your request/reason for contacting us are disclosed to us. Depending on the reason you are contacting us (e.g. questions about your application, training opportunities or possible degree courses), 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 apply with us or to take part in a program and/or event, the legal basis for processing your contact details follows from the contract or quasicontractual relationship pursuant to Art. 6 (1) (b) GDPR / section 26 (1) (1) German Federal Data Protection Act (BDSG).
4.2.3 Duration of retention or criteria applied in defining this period
Your details are deleted once your request has been processed and further communication has been discontinued. This does not apply if the purpose of contacting us is your applying with us or taking part in a program and/or event. In this case your details remain on file until all contractual and similar obligations have been fulfilled and statutory retention periods (currently 6 months for applicant data) 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 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.
4.3 Asserting your rights as a data subject
4.3.1 Description and scope of data processing
In this privacy policy we advise you of the option of asserting your rights as a data subject and obtaining information on the information stored on you. In order to assert your rights as a data subject, it may be necessary that you provide information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.
4.3.2 Purpose and legal basis of data processing
Under the GDPR, we are legally obligated to process your data so that you can exercise your rights as a data subject. The legal basis for this follows from Art. 6 (1) (c) GDPR.
4.3.2 Duration of retention or criteria applied in defining this period
We retain the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information obtained to substantiate your identity, e.g. by way of a labeled photocopy of your personal identity card, where we have been provided one. It will be deleted once your identity has been established.
4.3.3 Options for lodging an objection and having your information removed
The processing of your information is required for complying with your rights as a data subject. To that extent you have no right to revoke your consent to its processing.
4.4 Google Tag Manager
This website uses Google Tag Manager, a service is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google Inc.). Google Tag Manager enables 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 only implements these tags. 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 and Google Double Click (web tracking)
4.5.1 Description and scope of data processing of Google Analytics
This website uses Google Analytics. Google Analytics is 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. The information generated by the Google Analytics cookie about your use of this website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Pseudonymity is ensured by the fact that when collecting your access data your IP address is shortened within member states of the EU or in other member states of the EEA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. These usage profiles to which pseudonyms are assigned 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. Description and scope of data processing of Google Double Click
This website uses the service Double Click for the purpose of integrating and displaying YouTube videos and content on the website. The provider of Google Double Click is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). The collection of data by Double Click is not carried out by us and also not for our own purposes, however, Youtube reloads the Double Click service when Youtube videos are integrated on our website, over which we have no influence as such. Double Click then uses advertising cookies to serve ads that are of interest to you, to optimize the content and reach of the ads, and to prevent you from being shown the same ad multiple times. For this purpose, Google uses a cookie ID to record which advertisements are displayed in which browser and also records your access data in accordance with section 2 for the creation of a usage profile. This usage profile is pseudonymous, as personal identification is generally not required for online advertising. The pseudonymity is ensured by the fact that before Google collects your access data, the IP address stored in it is shortened. We have generally prevented the transfer of data to Double Click through data protection-friendly settings, but a transfer of your data when Youtube videos are played on this website cannot be completely ruled out.
For more information on the data processing by Double Click, please see Google's privacy policy: policies.google.com/privacy.
4.5.3 Purpose and legal basis of data processing
The legal basis for recording and evaluating pseudonymous user profiles is founded upon Art. 6 (1) (a) GDPR. By giving your consent to the data processing within our cookie consent tool, we are entitled to process your data in the aforementioned manner and for the aforementioned purposes.
4.5.4 Duration of retention 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 withdraw your consent in this manner. Analytics cookies are stored for a maximum of 24 months. We cannot make any statement about the storage period for Google Analytics and Google Double Click by Google itself.
4.5.5 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: For Google Analytics https://tools.google.com/dlpage/gaoptout. For Google Double Click http://www.google.com/ads/preferences/html/opt-out.html.
Furthermore, it is possible to withdraw your consent at any time for the future via the corresponding data protection setting in our Cookie Consent Tool within the Privacy Settings.
4.6. Facebook Pixel, LinkedIn Pixel, Google Ads (Online Advertising)
4.6.1 Description and scope of data processing of Facebook Pixel
This website uses the Facebook Pixel of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter "Facebook").
Through the use of the pixel on this website, it is possible for Facebook to determine you as a visitor to our online offers for the display of ads so-called Facebook Ads. Accordingly, we use the pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offers or who have certain characteristics in the sense of interests in certain products, which we transmit to Facebook in the context of so-called "Custom Audiences". Furthermore, we can use the pixel to track the effectiveness of Facebook ads for statistical and market research purposes. The information collected via the pixel may also be used by Facebook in general or on the basis of connections of other information for its own advertising purposes as well as for advertising purposes of third parties. We have no influence on the processing of the data collected via the pixel used on this website for the advertising purposes by Facebook. Facebook is solely responsible for processing the data collected via the pixel for its own advertising purposes.
You can find more information on data protection at Facebook at: https://www.facebook.com/policy.php.
4.6.2 Description and scope of data processing of LinkedIn Pixel
This website uses the LinkedIn Pixel of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
Through the use of the pixel on this website, it is possible for LinkedIn to determine you as a visitor to our online offers for the display of ads so-called LinkedIn Ads. Accordingly, we use the pixel to display the LinkedIn ads placed by us only to those LinkedIn users who have also shown an interest in our online offers or who have certain characteristics in the sense of interests in certain products, which we transmit to LinkedIn in the context of so-called "Custom Audiences". Furthermore, we can use the pixel to track the effectiveness of LinkedIn ads for statistical and market research purposes. The information collected via the pixel may also be used by LinkedIn in general or on the basis of connections of other information for its own advertising purposes as well as for advertising purposes of third parties. We have no influence on the processing of the data collected via the pixel used on this website for the advertising purposes by LinkedIn. LinkedIn is solely responsible for processing the data collected via the pixel for its own advertising purposes.
You can find more information on data protection at LinkedIn at: https://www.linkedin.com/legal/privacy-policy?
4.6.3 Description and scope of data processing of Google Ads
Our website uses the functions of Google Ads Remarketing of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Google Ads allows us to display advertisements using a pseudonymous cookie ID based on the pages you visit, in order to show you interest-based advertising both when searching the web via Google and via third-party websites. Pseudonymity is ensured by the fact that the IP address is shortened directly after collection. Further data processing will only take place if you have consented to Google linking your browsing history to your Google account and using information from your Google account to personalize ads. In this case, during your visit to our website, if you have logged into your Google account, the resulting data on usage behavior will be merged with Google Analytics data to create and define target group lists for cross-device remarketing.
With the help of Google conversion tracking, Google and we can recognize whether certain actions were performed by the user on the website. For example, we can evaluate which content on our website was clicked on how often and which products were viewed or purchased particularly frequently. Based on this information and data, Google provides us with statistics, whereby we do not receive any information with which we can personally identify the user due to the pseudonymous cookie ID.
4.6.4 Purposes and legal basis of data processing:
The legal basis for the collection and evaluation of pseudonymous usage profiles for the purpose of analyzing usage behavior and related playout of personalized advertising is Art. 6 para. 1 lit. a GDPR. By granting your consent to data processing within our cookie consent tool, we are entitled to process your data in the aforementioned manner and for the aforementioned purposes.
4.6.5 Duration of retention or criteria applied in defining this period
The data that is collected and analyzed when using the services mentioned in sections 4.6.1. to 4.6.3. is generally stored until you revoke your consent. We cannot make any statements about the storage period the services themselves determine if data processing for own purposes of the services is carried out.
4.6.6 Objection and elimination options:
You can object to the use of the aforementioned services by changing your browser settings and/or using the following link,
https://www.facebook.com/settings?tab=ads
https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences?lang=en
Furthermore, you have the option to object at any time in the future via the corresponding data protection setting in our Cookie Consent Tool under the heading Data Protection Settings or Privacy Center.
4.7 External services and content
We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services and content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.
For further information on the purpose and scope of the collection and processing of your data, please refer to the privacy policy of the responsible provider (under data protection law) of the services or content integrated by us. With regard to the joint processing by us and Facebook when visiting our Facebook fan page, the following data protection information is available to you:
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5. Who comes into possession of my personal information?
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.
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6. Is my personal information processed outside of the EU or EEA (“transfer to a third country”)?
Google uses if possible servers located in the EU for the Analytics and Double Click services. However, it cannot be ruled out that data may also be transferred to the USA. In this case, we ensure that the service providers guarantee an equivalent level of data protection by contract or in some other way. For example, this may secured by the conclusion of a data protection agreement stipulated by the EU Commission (so-called EU standard contractual clauses). You can request a copy of the respective guarantees via the contact data mentioned in section 1 above.
The integration of the pixels from Facebook and LinkedIn can lead to your data also being transferred to third countries, such as the USA, among others, in which no equivalent level of data protection to that of the GDPR can be guaranteed, so that the data is transferred to third countries that may not have an adequate level of data protection and also can’t provide sufficient enforcement of your data subject rights. You agree by consent within the cookie consent manager to the individual pixels to the data transfer to the respective service providers and third parties in the third country.
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7. What data privacy rights do I have?
You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information 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 information provided by you that is held by us 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 with effect for the future. Your notice of revocation is to be addressed to Bertelsmann by writing to the contact address indicated in section 1 or if applicable and possible via the Cookie Consent Manager, to be found under Privacy Settings in the footer of our websites.
Pursuant to Art. 21 GDPR, you also have the right, for reasons relating to your specific situation, to raise an objection at any time to the processing of your information that is done on the basis of Art. 6 (1) (f) GDPR. You also have the right to file an objection 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.
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8. Children
This website is also intended for students. As a rule they are at least sixteen years old, meaning that Bertelsmann need not take into account any other requirements with regard to processing the data of children under the GDPR.
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Privacy Policy — Career Programs at Bertelsmann
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General Information
The following information is designed to provide an overview of our use of personally identifiable information (referred to below as “personal data” or “personal information”) relating to applying for job opportunities and taking part in career programs at Bertelsmann. These are: Bertelsmann Future Leaders and Talent Meets Bertelsmann, as well as the former programs Creative Management Program, Bertelsmann Entrepreneurs Program, Bertelsmann Data Science Program MEDIAN, and Bertelsmann Management Associate Program PERSPECTIVES (“career programs”).
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1. Who is accountable for processing my personal data?
Bertelsmann SE & Co. KGaA
Corporate Management Development Dept.
Carl-Bertelsmann-Strasse 270
33311 Gütersloh, Germany
Phone: +49(0)5241-80-0
Fax: +49(0)5241-80-9662/63/64
Email: createyourowncareer@bertelsmann.de
is responsible for processing your information as described below. “We” or “us” as used below is in reference to Bertelsmann SE & Co. KGaA. We process personal information in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
You can contact our data protection officer by post at the address indicated above by using the reference “Attn: Data Protection Officer”, or by writing to: datenschutz@bertelsmann.de.
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2. Why is my personal data being processed (designated processing purpose) and what is the legal basis for this?
To take part in our career programs you have to apply by sending us your application materials in electronic form (consisting of a cover letter (motivational letter), general information about you including your contact details, details on your formal education & training and professional background, and other information like your hobbies and language skills).
Applying predefined criteria, we decide on your suitability for participating in the career programs. To do this, we review your application materials and conduct interviews with you. These interviews can take place by telephone, virtually (via Microsoft Teams, Skype or Zoom) and / or in person - and possibly also as part of a virtual or personal assessment center. To organize interviews, we process your contact details and communicate with you via email and/or the phone. For further information on data processing via our job application platform, please follow this link: https://jobsearch.createyourowncareer.com/content/Privacy-Policy/?locale=de_DE.
In the graduate program Bertelsmann Future Leaders a position-related online intelligence test called "KF Select", of Korn Ferry International GmbH, is also part of the application procedure. The online test takes about 30 minutes and consists of three sections: verbal, numerical and logical reasoning skills. The test examines your ability to interpret written information (verbal reasoning skills), to analyze and draw inferences from numerical information and data (numerical reasoning skills), and your ability to analyze abstract information and apply this to determine outcomes and patterns (analytical or logical reasoning skills). You can prepare for this test by doing practice exercises. The data collected during the online intelligence test is used exclusively for making hiring decisions. Contractual agreements with Korn Ferry International GmbH ensure that personally identifiable information relating to you is not used for other purposes. For more information about how we process your information, please follow this link: https://www.kornferry.com/privacy.
To take part in our CHROME>> development program you have to apply by sending us your application materials in electronic form (consisting of a cover letter and a motivational letter), general information about you including your contact details, details on your formal education & training and professional background and language skills). Applying predefined criteria, we decide on your suitability for participating in CHROME>>. To do this, we have developed a holistic selection process containing an online assessment hosted by our partner Korn Ferry and an interview session with colleagues from Corporate Talent Management. The Online assessment will take place virtually, the interviews can take place by telephone, virtually (via Microsoft Teams, Skype or Zoom) and / or in person. To organize interviews, we process your contact details and communicate with you via email and/or the phone. In CHROME>> an Online Assessment test called “Leadership Solution”, of Korn Ferry International GmbH, is also part of the application procedure. The online test takes about 60 minutes. The Online Assessments primarily aims to gain insights on personal fit with specific leadership roles, development gaps, and how to close these. The assessment allows driving targeted and individualized leadership development focused on assessment insights. The data collected during the online test is used exclusively for making development decisions. Contractual agreements with Korn Ferry International GmbH ensure that personally identifiable information relating to you is not used for other purposes. For more information about how we process your information, please follow this link: https://www.kornferry.com/privacy.
In Talent Meets Bertelsmann, an asynchronous video interview is conducted with viasto GmbH in lieu of a personal interview, owing to the international orientation of this career program. The video interview also facilitates the application process for applicants outside of Germany, by saving them time and money. The video interview takes approximately 20 to 30 minutes, during which you respond to previously arranged questions on your motivation for taking part in Talent Meets Bertelsmann. Between the responses to the individual questions you have time to prepare for the next question. Contractual agreements with viasto GmbH ensure that personally identifiable information relating to you is not used for other purposes. For more information about how your information is processed, please follow this link: https://www.viasto.com/en/imprint/.
Additionally, as part of the realization of a (virtual) assessment center for the graduate program Bertelsmann Future Leaders or for your participation in our diverse Talent Meets Bertelsmann events, we might send a Bertelsmann- and program-related goodie box to the selected, participating applicants in advance or afterwards. For this purpose, we will collect and process postal address data. For assessment events taking place in presence, it is also possible that we obtain information on hotel requirements and dietary habits / allergies in advance in order to provide you with the best possible care on site. These queries are usually implemented via a short survey per "Smartsheet".
The legal basis for processing your information in the application procedure is founded upon the requirement to create a contractual or participation agreement as provided for by Art. 6 (1) (b) GDPR. Participating in an asynchronous video interview is part of the application procedure for this career program, however, you can discontinue the interview and/or repeat it at any time. If you do discontinue it, we offer an alternative (e.g. phone interview, MS Teams, Zoom or Skype call). As a general principle, you are not penalized in the application procedure if you discontinue the interview.
By participating in the career program, a contract is created between you and Bertelsmann. The subject of this contract is essentially your participation in the career program. Depending on the type and scope of the program, we process your data for participating in, organizing and conducting meetings and/or events, and for human resources management, payroll and/or time tracking. If you receive an employee profile on our HR platform peoplenet when participating, we also process your information for communication and exchanges with the JAM communities, for registering for and conducting training and CPD programs and/or assessing your performance and/or development potential.
The legal basis for processing your information when taking part in the career programs is founded upon the requirement to perform a contractual or participation agreement as provided for by Art. 6 (1) (b) GDPR.
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3. Am I under an obligation to provide personal information?
In applying for and taking part in the career programs you must provide the personal information that is necessary for conducting and completing the application process. Without this information we cannot select you as a program participant or enable you to take part.
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4. Who comes into possession of my personal information?
The career program generally addresses and is conducted throughout the Bertelsmann group, and thus is not exclusively limited to a single company, Bertelsmann SE & Co. KGaA. Depending on the type and scope of the program, in order to apply and/or participate it may be necessary for other persons in our subsidiaries, apart from selected staff of the Corporate Management Development Dept., to process your information (e.g. executive management, talent managers, event managers) by being given access to your information. By taking appropriate technical and organizational measures we ensure that only a limited number of persons gain access to your information, and that access is limited in time and restricted exclusively to the information that is necessary for the designated processing purpose, including but not limited to, the application procedure.
In individual cases people are hired by subsidiaries that are headquartered outside of the European Union / European Economic Area (“third countries”) (e.g. Penguin Random House New York City). A level of data privacy and protection that satisfies GDPR can be ensured in third countries by way of the presence of an adequacy decision issued by the EU Commission (cf. Art. 45 (1) GDPR) or by way of appropriate guaranties, including, but not limited to, the agreement of EU standard contractual clauses (cf. Art. 46 (2) (c) GDPR. Guarantees can be waived in exceptional cases, i.e. if you have given your consent or where data processing has to be performed via a contractor located in a third country for creating and/or performing the contract with you (cf. Art. 49 (1) (a), (b) GDPR).
Finally, we contract service providers (contract data processors, e.g. data centers and delivery services) who are bound by our directives to store your details, the online tests, video interviews, send out emails, etc.). Contract data processors are provided access to your information only to the extent and for the period necessary to provide the services contracted by us. Where these service providers process your personal information outside of the European Union or the European Economic Area, this may result in it being transmitted to a country which does not provide for the same standard of data privacy and protection as the European GDPR. In this case, we ensure that the service providers guarantee an equivalent level of data privacy and protection by way of Commission adequacy decisions and model contract clauses that are provided by the EU Commission. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
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5. How long is my personal information stored?
When the application procedure is concluded, your application materials are retained on file for six months for the purpose of defending against any legal claims founded on labor law and social security law or social protection law. Your application materials are then deleted upon the lapse of this six-month period.
When the career program is completed, your data will be deleted unless you consent to taking part in our Alumni programs, are hired in, and/or we are compelled to retain your information on file due to statutory retention periods.
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6. What rights do I have with regard to my personal information?
You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information deleted and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. Where our processing of information provided by you by automated means is based on your consent or is the subject of a contract with you, you have the right to request a copy of this data in a structured, commonly-used, machine-readable format (right to data portability).
Where the legal basis for processing your information is founded upon Art. 6 (1) (f) GDPR (“legitimate interest”), you have the right to lodge an objection to the processing of your information as provided for by Art. 21 GDPR.
If you want to exercise any of your rights, or if you have questions of a general nature about data privacy as it relates to career programs, you can address these issues to the contact indicated in section 1 above at any time.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is LDI NRW (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Postfach 200444, 40102 Düsseldorf). However, you also have the right to contact the competent data protection authority at your place of residence, who will refer your matter to the competent authority.
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7. To what extent is my information processed by means of automated decision-making, including profiling?
No automated decision-making or profiling takes place. This applies in particular to online tests and video interviews conducted in the application process.
Last updated: 10/2019
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Privacy Policy — Career Events at Bertelsmann
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General Information
The following information is designed to provide an overview of our use of personally identifiable information (referred to below as “personal data” or “personal information”) relating to you when participating in Talent Meets Bertelsmann and/or associated Alumni events. The following events are specifically affected: the main event Talent Meets Bertelsmann (TMB), TMB Alumni Meetings, and TMB Alumni Hubs (“TMB Events”). In the original sense, these events are usually held in presence, in various international cities, but in particular in Berlin. In the course of the increasing digitization of events, virtual events have also been implemented, which are generally held via the platforms "Zoom" or "Microsoft Teams". Participation in all Talent Meets Bertelsmann events is voluntary.
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1. Who is accountable for processing my personal data?
Bertelsmann SE & Co. KGaA
Corporate Management Development Dept.
Carl-Bertelsmann-Strasse 270
33311 Gütersloh, Germany
Phone: +49(0)5241-80-0
Fax: +49(0)5241-80-9662/63/64
Email: createyourowncareer@bertelsmann.de
is responsible for processing your information as described below. “We” or “us” as used below is in reference to Bertelsmann SE & Co. KGaA. We process personal information in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
You can contact our data protection officer by post at the address indicated above by using the reference “Attn: Data Protection Officer”, or by writing to: datenschutz(at)bertelsmann.de.
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2. What information on me is stored?
As a general rule, you are or have been a participant at Bertelsmann’s TMB and are invited to TMB Alumni Events. This means that we have access to some information on your that is already available, including your contact details (consisting of your name, postal address, email address, phone number, birthday, year of participation and the like). However, we also collect new data on you, i.e. travel data and personal preferences / dislikes / food intolerances / allergies when making restaurant and/or hotel reservations or updated contact information. The TMB Events are covered by one or more photographers in order to document the event and publish its highlights via our communication channels. This means that pictures and videos showing you may be made.
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3. Why is my personal data being processed (designated processing purpose) and what is the legal basis for this?
We use your contact details to send you invitations to our TMB Events, and to send you relevant information (e.g. event program, restaurant and/or hotel bookings) by postal mail or email in advance of an event. The legal basis for processing this information is Art. 6 (1) (f) GDPR, based on our legitimate interest in maintaining relations with TMB participants and Alumni and integrating them in our networks.
If you should no longer wish to receive any invitations to our events, you have the option of lodging an objection to the use of your details for this purpose by writing to: datenschutz@bertelmann.de. In this case, we would immediately discontinue sending you invitations to our events.
When you take part in a TMB Event we process your personal data in order to conduct the event and to enable you to take part in it. This also extends to including your details in a participant list that is provided to the others attending the event (including in electronic form), or providing your information (name, details on your company/institution) to the moderators/hosts of the event for the purpose of conducting the event. We also use this information to send you relevant material after the event. We also share your information with cooperating organizations to the extent that this is required for conducting the event and enabling you to take part in it, e.g. external guest management. For some of our TMB events a quick survey via “Smartsheet” or Email will be a touchpoint, where you will be asked for the above mentioned personal information, which we need to prepare the events. The legal basis for this processing of information follows from Art. 6 (1) (1) (b) GDPR.
In addition, pictures and videos are routinely made at our TMB Events. Some of them are published on our website, on our social media channels, in the course of external and internal reporting or in Bertelsmann newsletters, together with your name, as applicable. In addition to the pictures and videos, metadata such as the time and location is automatically stored in digital cameras. The legal basis for making and storing photographs and video recordings follows from Art. 6 (1) (1) (f) GDPR, based on our legitimate interest in reporting on the TMB Events. The legal basis for publishing photographs and video recordings is founded upon section 22, 23 German Art Copyright Act (KUG).
Pursuant to Art. 21 (1) GDPR, you have the right, for reasons relating to your particular situation, to lodge an objection at any time to the making and storage of photographs and video recordings in which you appear with effect for the future by writing to datenschutz@bertelmann.de and setting out your objection.
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4. Am I under an obligation to provide personal information?
You are not legally or contractually obligated to provide personal information. However, if you take part in our TMB Events or would like to receive an invitation to them, you must provide your personal details. Without your details we are generally not able to send you invitations to our TMB Events or enable you to take part in them.
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5. Who comes into possession of my personal information?
We share your personal information with the departments and positions indicated in section 3 for the purposes set out in section 3. We also contract service providers (contract data processors, e.g. data centers and delivery services) who are bound by our directives to store your details, the online test, video interviews, send out emails, etc.).Contract data processors are provided access to your information only to the extent and for the period necessary to provide the services contracted by us. Where these service providers process your personal information outside of the European Union or the European Economic Area, this may result in it being transmitted to a country which does not provide for the same standard of data privacy and protection as the European GDPR. In this case, we ensure that the service providers guarantee an equivalent level of data privacy and protection by way of Commission adequacy decisions and model contract clauses that are provided by the EU Commission. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
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6. How long is my personal information stored?
We store your contact details for the purpose of sending out invitations – unless you should lodge an objection – for the purpose of catering to our legitimate mutual interest in communication and the provision of information. We will store any objection lodged by you for a period of three years for evidentiary purposes.
The pictures and videos of you which are stored along with their metadata are retained on file until you legitimately lodge an objection against their retention, unless there are overriding legitimate reasons for processing them.
In the event that contract data processors, who are bound by our directives, are given access to your information this is done only to the extent and for the period necessary to provide the services contracted by us. Bertelsmann ensures that relevant agreements on deleting data are complied with.
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7. What rights do I have with regard to my personal information?
You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information deleted and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. Where our processing of information provided by you by automated means is based on your consent or is the subject of a contract with you, you have the right to request a copy of this data in a structured, commonly-used, machine-readable format (right to data portability).
Where the legal basis for processing your information is founded upon Art. 6 (1) (f) GDPR (“legitimate interest”), you have the right to lodge an objection to the processing of your information as provided for by Art. 21 GDPR.
If you want to exercise any of your rights, or if you have questions of a general nature about data privacy as it relates to TMB Events, you can address these issues to the contact indicated in section 1 above at any time.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is LDI NRW (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Postfach 200444, 40102 Düsseldorf). However, you also have the right to contact the competent data protection authority at your place of residence, who will refer your matter to the competent authority.
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8. To what extent is my information processed by means of automated decision-making, including profiling?
No automated decision-making or profiling takes place.
Last updated: 10/2019
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9. Privacy Policy – Talent Meets Bertelsmann 2021
If you have applied for or also participated in Talent Meets Bertelsmann 2021, you can find associated privacy policy information here.
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10. Privacy Policy – Talent Meets Bertelsmann 2022
If you have applied for or also participated in Talent Meets Bertelsmann 2022, you can find associated privacy policy information here.
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11. Privacy Policy — Talent Meets Bertelsmann 2023
If you have applied for or also participated in Talent Meets Bertelsmann 2023, you can find associated privacy policy information here.
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Privacy Policy — Talent Meets Bertelsmann 2024
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General Information
In accordance with the legal requirements (Art. 12 et seq. of the EU General Data Protection Regulation (GDPR)), the following information provide you with an overview of how your personal data is processed during registration for and participation in our Talent Meets Bertelsmann 2024 event and what rights you have as a data subject.
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1. Who is accountable for processing my personal data?
Bertelsmann SE & Co. KGaA
Corporate Management Development Dept.
Carl-Bertelsmann-Strasse 270
33311 Gütersloh, Germany
Phone: +49(0)5241-80-0
Fax: +49(0)5241-80-9662/63/64
Email: createyourowncareer(at)bertelsmann.de
is accountable for processing your information as described below. “We” or “us” as used below is in reference to Bertelsmann SE & Co. KGaA. Your information are processed compliantly with the provisions of the GDPR and the German Federal Data Protection Act (BDSG).
You can contact our data protection officer by mail at the address indicated above by using the reference “Attn: Data Protection Officer”, or by writing to: datenschutz(at)bertelsmann.de We appreciate a reference that your inquiry concerns Talent Meets Bertelsmann.
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2. For what purpose do we process your data?
Your data will be processed for the organization and hosting of the 2024 main event of Talent Meets Bertelsmann. You are not legally or contractually obligated to provide personal information. However, if you wish to participate in our TMB Events or would like to receive an invitation to them, we need at least some personal details. Without your details we are generally not able to send you invitations to our TMB Events or enable you to take part in them.
After being nominated as a participant or guest for this year’s event, you will be invited via email and receive first information about the upcoming event. After you have confirmed your participation via email, your next touchpoint will be a quick survey (via “Smartsheet”) that will require you to complete some personal information (see section 3 below) in order to prepare the event. This refers to different event-related aspects such as guest lists, name tags, hotel bookings and such in order to conduct the event and to enable you to take part in it. Relevant information regarding your professional background you provide in that survey will be presented to the other active participants by means of name tags as well as a profile booklet for the purpose of enabling networking among the event’s participants and other Bertelsmann employees.
In 2024, we will let as many Bertelsmann employees join in the final presentations as possible. This enlarges the participants’ radius in which they may arouse the interest of further relevant Bertelsmann departments/representatives. Therefore we will be recording the final case study presentations, taking place on Tuesday afternoon, June 25, 2024, and share it via the Bertelsmann internal tech platform called “Bertelsmann Collaboration Platform” (BCP). This platform is only accessible for Bertelsmann employees. Although, as an event participant in Berlin, you will not be using this platform yourself, your personal data will be shared here in the form of images and sounds. In addition, we will provide the Bertelsmann colleagues with the digital version of our above-mentioned profile booklet via this platform. Find out more about the BCP and its privacy policy here.
Additionally we will start a LinkedIn-Community, where you can join voluntarily. Participation in the event does not require a profile. We cannot influence the data processing by LinkedIn, please confer their respective websites and Privacy Policies. Beside that LinkedIn group, Talent Meets Bertelsmann is about community and we will therefore gladly keep you in the loop whenever there is something new. This community is based on processing your contact data.
During the event, we will be conducting polls via Mentimeter, and participants and guests can join voluntarily. Participation in the event does not require the use of Mentimeter, so that it remains in your discretion whether you which to join the polls and which data you want to share in this context. We cannot influence the data processing by Mentimeter, please refer to their respective websites and privacy policies.
As part of TMB 2024, a virtual kick-off event will take place via Zoom for Business or Microsoft Teams two weeks prior to the main event. The overall purpose is to support you and your group by introducing the Bertelsmann-related topics you are going to work on in your respective workshops and to meet and connect with your team members beforehand. Additionally we will inform you about the most relevant eventinformation, interesting and helpful for you to know about prior to your participation in Berlin.
Within Zoom for Business or Microsoft Teams, we will be recording the main virtual meeting room for the whole time as well as the smaller break-out rooms after specific announcements. If you don’t want to be recorded in these situations, you can decide to switch off your camera and mic and participate via chat. Video snippets, pictures and audio tracks may be used afterwards in internal and external presentations, including promotional measures. During the virtual kick-off event you might additionally be using other tools , such as Miro, an online whiteboard for visual collaboration.
After the event, active participants will have the opportunity to hold virtual, half-hour career talks with the organizing Bertelsmann department to discuss their own professional future. Participation is voluntary and can take place via Microsoft Teams or Zoom for Business as well as by phone.
Most of the overall event communication will be taking place via e-mails and we will be using the e-mail address you will be handing to us in your application.
With regard to safety measures concerning COVID-19 and in order to make TMB24 as safe as possible , we reserve the right to require an official negative test for each day you participate in the event. In any case, we will observe the German Ordinance on the German Ordinance on Coronavirus Entry Regulations at the time of and during the event.
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3. Which of your personal data will be processed?
Which of your personal data will be processed and for which purpose depends on your position and your participation during the event. In general, there are two types of users: active participants and more or less passive guests.
Next to a handful of actively participating Bertelsmann employees who act, for example, as workshop hosts or coaches, active participants are first-time participants of the main event. For you, there will be exciting case studies, collaborative working sessions and networking options, for instance in Berlin or via our LinkedIn community. For the services described above, we will process the data you share in your application, on the “Smartsheet” board, within MS Teams and Zoom and during the whole live event in Berlin as well as within the recordings via BCP. These are, in particular, your name, picture, email address, a brief overview of your personal and professional background (education, professional experience, company, title), video footage, audio files and your LinkedIn profile link. As an active participant, you may receive a goodie bag prior to or after your participation. For that purpose, we process your postal address.
Passive guests are alumni from previous years, some employees of Bertelsmann and affiliates and other guests. We process passive users’ data you share in the manner described above during the event, which comprise your name, picture, company you are working at, country you are working in, your video and audio tracks (in case you will be seen in the auditorium during the livestream) and your LinkedIn profile. For the purpose of the TMB community, we process your contact details consisting of name, email address and sometimes information on your first participation in TMB.
In addition, referring to all active and passive participants, PICTURES AND VIDEOS ARE ROUTINELY MADE AT OUR TMB EVENTS as mentioned above. Some of them are published on our website, on our social media channels, in the course of external and internal reporting or in newsletters, together with your name, as applicable. In addition to the pictures and videos, metadata such as the time and location are automatically stored in digital cameras.
Pursuant to Art. 21 (1) GDPR, you have the right, for reasons relating to your particular situation, to lodge an objection at any time to the making and storage of photographs and video recordings in which you appear with effect for the future by writing to datenschutz@bertelmann.de and setting out your objection.
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4. What cookies are being used?
Our event is free of tracking technologies. However, we need to use cookies for some of the purposes mentioned above.
Peoplenet uses session cookies in order to provide you a consistent session and therefore an undisrupted option to apply. These cookies are therefore technically necessary; they will be deleted from your device once you end the session by closing your browser or similar. Session cookies are also required during the kick-off event – the technical delivery of video and audio requires certain data stored in cookies on your device.
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5. Legal basis
The legal basis for processing your personal data varies, depending on the specific purpose set out above.
For the purpose of collecting and evaluating your application and, after successful application, shipping material our legal basis is your consent pursuant to Art. 6 (1) (a) GDPR, which you grant upon completion of the application and the “Smartsheet” form. This consent applies as well to the transfer of data by means of the participant booklet, nametags, recordings and event app. Providing your data for the above mentioned purposes is voluntary.
Should you no longer wish to receive any invitations to our events, you can withdraw your consent to these purposes at any time by writing to: datenschutz(at)bertelmann.de with a reference that your withdrawal concerns TMB. In this case, your data will no longer be processed for these purposes.
For the purpose of organizing and hosting the event in the manner described above, our legal basis is the legitimate interest pursuant to Art. 6 (1) f GDPR of the participants, guests and Bertelsmann in general. Leitmotif for the legitimate interest of these parties is their reasonable expectation regarding their data. What can be expected in the course of the event is set out above. In addition, pictures and videos are routinely made at our TMB events and possibly published afterwards as pointed out above. The legal basis for making and storing photographs and video recordings follows from Art. 6 (1) (1) (f) GDPR, based on our legitimate interest in reporting on the TMB events. The legal basis for publishing photographs and video recordings is founded upon section 22, 23 German Art Copyright Act (KUG).
Pursuant to Art. 21 (1) GDPR, you have the right, for reasons relating to your particular situation, to lodge an objection at any time to the making and storage of photographs and video recordings in which you appear with effect for the future by writing to datenschutz@bertelmann.de and setting out your objection.
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6. Who gets my data?
We share your personal information with the parties indicated in section 3 for the purposes set out there. Those parties are involved as so-called data processors, which means that we have a strict contract with them (pursuant to Art. 28 GDPR) that binds them to process your data only in the way and for those purposes we instructed them. Data processors are provided access to your information only to the extent and for the period necessary to provide the services contracted by us. Where these service providers process your personal information outside of the European Union (EU) or the European Economic Area (EEA), this may result in it being transferred to a country where a level of data protection similar to the one within EU/EEA is not warranted. In this case, we ensure that the concerned processors guarantee an equivalent level of data protection by use of standard contractual clauses (SCCs) issued by the EU Commission and, where necessary, supported by additional measures. You can request a copy of these safeguards by contacting the addresses indicated in section 1 above.
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7. Duration of storage or criteria
In general, data processed in the course of our event is not subject to any retention periods. Therefore your data will be processed as long as is necessary in order to fulfil the purposes mentioned above and then be deleted, unless there has been a change (e.g. retention period due to litigation or similar) or you have consented to a continued storage.
Data collected during the event will also be used, as set out above, for purposes of internal and external presentation. Data such as pictures, video and audio footage (see section 3 data categories) will therefore be subject to continued usage until you inform us that you no longer wish us to do so. In this case we have different options on how to proceed with pictures and video recordings that have already been used – this could be for example to cut out, to pixelate or to delete them partly or entirely. This will happen without undue delay. Additionally, we will prompt others who received the data to do the same, provided it is technically possible for us to identify such recipients.
Data collected for the purpose of application and selection will be deleted six months after successful completion of the event.
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8. What data subject rights do I have?
You have the right at any time to request access to your personal information that is currently on file with us. If this information is incorrect or not up to date, you have the right to request that it be corrected. You also have the right to have your personal information 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 information provided by you that is held by us 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 with effect 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 situation, to raise an objection at any time to the processing of your information that is done on the basis of Art. 6 (1) (f) GDPR. You also have the right to file an objection 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: +49 211 38424-0
Fax: +49 211 38424-10
Email: poststelle(at)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.
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