1. General Definitions
Service provider who has to process the customer’s personal data for the provision of services:
MINTtalents OÜ (Registry number: 14899369; Address: Lõõtsa St. 5-11, Tallinn, Estonia), offers the services and operates the website of EINWANDERUNGSBERATER / https://www.einwanderungsberater.com.
A natural person who uses the website www.einwanderungsberater.com or MINT Talents services.
Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
All information relating to an identified or identifiable natural person; An identifiable natural person is a person who can be identified directly or indirectly, in particular with reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more physical-physiological factors, genetic, psychological, economic, cultural or social identity of this natural person.
Section 3 describes how MINT Talents processes personal data.
Any operation or series of operations that are applied to personal data or groups of personal data, individually or automatically. This includes collecting, recording, organizing, structuring, storing, adapting or changing, retrieving, consulting, using, disclosing by transmission, distribution or other provision, alignment or combination, restriction, deletion, or destruction.
A person who, alone or jointly with others, determines the purposes and means of processing personal data. MINTtalents OÜ is responsible for the personal data of MINT Talents customers.
A person who processes personal data on behalf of the controller.
Any service made available by MINT Talents via the einwanderungsberater.com website.
This Policy applies to the processing of personal data for which MINTtalents OÜ acts as the controller. Any processing of personal data carried out on behalf of the customer or his legal person is subject to an additional data processing agreement signed between MINTtalents OÜ and the legal person controlled by the customer.
3. Collection of personal data
MINT Talents processes the following personal data about the customer:
3.1 Personal data – full name (surname and first name), contact mail address, email address, mobile phone number, the bank where the personal bank account is available;
3.2 CV-related data – data that is required for job searches, the recognition and visa procedures, or for creating applications for customers, e.g. B. CV, photo, diploma, URL of a portfolio or LinkedIn profile;
3.3 Job Posting Data – data required to create a job posting for clients, such as company information, photos, URLs.
3.4 Profile data – Google profile data of the customer such as name, email address, language setting, and profile picture;
3.5 Payment data – data necessary for payments for services, such as account number (IBAN), name of the account holder, bank name, transaction details. If the customer pays for the service with a credit card or PayPal, his payment details are not stored by MINT Talents and can therefore not be accessed by MINT Talents.
3.6 Device Information – Information about the device on which the customer is using the website, including the model, name, or other identifier of the device and the IP address of the device;
3.7 Preference data – customer preferences on the website;
3.8 Customer support data – communication between MINT Talents and the customer (inquiries via the website, email, social media, phone, Skype or chat);
3.9 Usage data – data on customer interaction on the website.
4. Sources of collection of personal data
Most of the customer’s personal data processed by MINT Talents is recorded directly from the customer. MINT Talents can, however, also collect the customer’s personal data from publicly accessible third-party sources such as social profiles or websites.
5. Purposes for the collection and processing of personal data of the customer
Personal data collected by MINT Talents will be processed for the purposes set out by law or described herein, including but limited to the following purposes:
5.1 Contractual purpose – MINT Talents must process the customer’s personal data in order to conclude a service contract with the customer and to offer the customer service.
5.2 Analytical Purpose – MINT Talents needs to process the client’s personal data in order to manage, analyze and improve the service and the website.
5.3 Marketing purpose – MINT Talents must process the customer’s personal data in order to send the customer-relevant advertising information about services and related offers from third parties with whom we work if the customer has given express consent to the use of his personal data for this purpose has granted;
5.4 Purpose of personalization – MINT Talents must process the customer’s personal data in order to personalize the service and the content provided to the customer.
5.5 Purpose of communication – Contacting the customer for administrative purposes such as customer service, resolving technical or legal problems in connection with the service provided, or forwarding updates and notifications about the service;
MINT Talents may not use the customer’s personal data for other purposes that are incompatible with the purposes mentioned above or that are required, permitted, or approved by law.
6. Legal grounds for processing
MINT Talents relies on the following legal reasons when processing the customer’s personal data:
6.1 The processing is necessary for the performance or the conclusion of a contract between the customer and MINT Talents (Article 6 Paragraph 1 Letter b of the GDPR). MINT Talents process personal data for contractual purposes within the framework of a contract between MINT Talents and the customer.
6.2 The processing is necessary in order to comply with a legal obligation to which it is subject (GDPR Article 6 Paragraph 1 Letter c). MINT Talents processes personal data for compliance purposes within the framework of legal obligations to which MINT Talents are subject;
6.3 The processing is necessary for the purposes of the legitimate interests of MINT Talents (Article 6 Paragraph 1 Letter f of the GDPR). MINT Talents processes personal data for analysis or personalization purposes with a legitimate interest.
6.4 The customer has consented to the processing of his personal data (GDPR Article 6 Paragraph 1 Letter a). MINT Talents processes personal data for marketing purposes with the customer’s consent.
7. Transmission of personal data
MINT Talents can pass on personal data of the customer to third parties, such as:
7.1 server hosts hosting MINT Talents servers;
7.2 Communication service providers who enable emails, calls, SMS messages, and other communication between MINT Talents and the customer;
7.3 customer service and customer administration service providers;
7.4 Marketing service provider;
7.5 MINT Talents partner bank that provides banking services for the customer or the legal entity controlled by the customer or another financial service provider;
7.6 other parties involved in the provision of MINT Talents services (translators, accountants, auditors, lawyers, suppliers, and IT systems support or other outsourcing providers).
7.7 Authorities, institutions, and organizations in the context of recognition and visa procedures.
7.8 other personnel consultancies and recruitment agencies.
MINT Talents has taken steps to ensure that these data recipients protect the confidentiality and security of personal data and that personal data is only processed for the provision of services and in accordance with the applicable laws.
Such third parties may be located in countries outside the European Economic Area (“EEA”), whose data protection regulations may differ and which are not subject to the adequacy decisions of the European Commission. In these countries, the security of personal data (including protection against misuse, unauthorized access, disclosure, modification, or destruction) may not be guaranteed, as it is secured in the European Union due to the lack of an adequate level of data protection.
When transferring collected personal data outside the EEA, MINT Talents must ensure that the appropriate protective measures are in place. If the customer would like a copy, please contact us as indicated below.
MINT Talents will take appropriate legal, organizational, and technical measures to protect personal data in accordance with the applicable laws for the protection of privacy and data security. Security measures must be applied to protect personal data from involuntary or unauthorized processing, disclosure, or destruction.
When passing on personal data to third parties, the following security precautions apply to MINT Talents:
8.1 MINT Talents concludes a data processing agreement with the third party concerned;
8.2 MINT Talents ensures that this third party undertakes to take suitable technical and organizational measures to ensure the processing of the customer’s personal data in accordance with this policy and the applicable laws.
8.3 MINT Talents ensures that (a) the third party is located in a jurisdiction that the European Commission has recognized as ensuring an adequate level of protection of personal data, or (b) the processing of the customer’s personal data takes other appropriate protective measures subject to the EU GDPR.
9. Integrity and storage of personal data
MINT Talents store personal data for the period required or permitted under applicable law, but no longer than is reasonable to achieve the purposes for which the personal data was collected.
MINT Talents takes reasonable steps to ensure that the personal data we process is reliable, accurate, and complete for the intended use in order to fulfill the purposes described here.
10. Customer's rights in relation to the collection of personal data
The customer has the following rights with regard to the processing of his personal data:
10.1 Request information – MINT Talents has provided all information to which the customer is entitled in this data protection declaration. The current version of the declaration is always available on the MINT Talents website.
10.2 Right of Access – The customer has the right to ask MINT Talents to provide a copy of the customer’s personal data, which is processed by MINT Talents.
10.3 Right to correction – The customer has the right to request MINT Talents to correct personal data if the data is incorrect or incomplete.
10.4 Right to deletion – The customer has the right to request MINT Talents to delete personal data, unless MINT Talents is obliged to continue processing the customer’s personal data under the law or a contract between the customer and MINT Talents, or if MINT Talents has other legitimate reasons for further processing personal data.
10.5 Right to restriction – The customer has the right to ask MINT Talents to restrict the processing of his personal data if the data is incorrect or incomplete or if his personal data is processed unlawfully.
10.6 Right to data portability – The customer has the right to request MINT Talents to provide his personal data, which the customer has provided for MINT Talents and which is processed in accordance with the customer’s consent or a contract between the customer and MINT Talents. If this is technically feasible, the data can also be made available to third parties.
10.7 Right to object – The customer has the right to object to the processing of his personal data if there is reason to believe that MINT Talents has no legitimate reasons for processing the personal data.
10.8. Right of revocation for the processing of personal data – The customer is entitled to revoke the consent given for the processing of personal data at any time. The revocation does not affect the legality of the processing carried out before the revocation.
10.9 Right to lodge complaints – The customer has the right to lodge complaints regarding the processing of his personal data.
In order to exercise the rights mentioned herein, the customer must submit a written application to MINT Talents (the contact details of MINT Talents can be found under Section 15). MINT Talents has the right to reject this application by giving reasons.
According to Article 12 (3) of the GDPR, MINT Talents is obliged to respond to the request within one month. However, MINT Talents does its best to respond to the customer’s request within 1 week.
11. Cookies and Tracking Technologies
MINT Talents uses automatically collected information and other information that is collected on its website through cookies and similar technologies.
Cookies are small text files that a website or its service provider transfers to the customer’s computer hard drive via their website browser (if the customer allows this). This enables the systems of the website or the service provider to recognize the customer’s browser and to collect and store certain information. Cookies can, for example, help a website to remember certain settings that the customer has selected on the website, e.g. B. Language settings.
11.1 MINT Talents uses the following types of cookies on the website:
First party cookies that MINT Talents stores on the customer’s device. These cookies allow website owners to collect analytics data, save language settings and perform other useful functions that provide a good user experience.
Third-party cookies that are stored on the customer’s device by other service providers on the website. MINT Talents may use third party analytics tools (e.g. Google Analytics) that allow us to measure traffic and usage trends for the MINT Talents service. Web analysis service providers analyze the use of the website and our services so that we can improve and change our website and its functionality.
11.2 Cookies are used for the following purposes:
Store authentication information and protect personal data from third parties;
to personalize our service, remember the customer’s choices on the website, understand and remember the customer’s preferences for future visits;
provide tailored advertising, content and information;
Track customer entries, submissions, and the status of any promotional or other activity on the Service;
Monitoring and analyzing the effectiveness of the service;
Compiling aggregated data about site traffic and site interactions to provide better site experiences and tools in the future.
The customer can delete or block cookies at any time via his browser settings. However, some cookies may be necessary for the functionality of the MINT Talents services and the use of the website. The customer is therefore aware that if the cookies are blocked or deleted, some functions of the website may not function properly. You can find more general information about cookies at http://www.allaboutcookies.org
11.3 MINT Talents uses the following third-party services:
- Google (Analytics, Ads, Tag Manager): https://support.google.com/analytics/answer/6004245?hl=en
- Google Workspace (Business tools, data storage & email services): https://policies.google.com/privacy?hl=de
- Siteground (Hosting & Email Services): https://www.siteground.com/privacy.htm
- NetHunt (CRM system): https://nethunt.com/privacy
- MailChimp (Newsletter): https://mailchimp.com/legal/privacy/
- PayPal (Online payment processing): https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
- Stripe (Online payment processing): https://stripe.com/gb/checkout/legal
- Calendly (Appointment system): https://calendly.com/de/pages/privacy
- Recruitee (Candidate management yystem): https://recruitee.com/de/privacy
- Borlabs Cookie (Data protection): https://de.borlabs.io/datenschutz/
11.4 To change the cookie selection later, please click here:
12. Google Analytics, Ads, Tag Manager
MINT Talents has implemented the following Google functions:
12.2 Impression Reporting for the Google Display Network;
12.3 Campaign Manager Integration;
12.3 Reporting on Demographics and Interests.
MINT Talents, together with third-party providers such as Google, use first-party cookies (such as Google Analytics cookies) and third-party cookies or other third-party IDs to compile data on customer interactions with ad impressions and other service functions relating to our website.
Customers can configure preferences for how Google advertises them on the Google Ad Settings page. Alternatively, the customer can unsubscribe by visiting the unsubscribe page of the Network Advertising Initiative or by permanently using the Google Analytics unsubscribe browser add-on.
MINT Talents uses Google Analytics to measure and evaluate access to and traffic in the public area of our website and to generate user navigation reports for our website administrators.
MINT Talents takes measures to protect the technical information collected using Google Analytics. The data collected is only used on the basis of knowledge to solve technical problems, administer the website and identify visitor preferences.
13. Commercial communication
If a customer receives commercial emails or the newsletter from us, they can unsubscribe at any time by following the instructions in the email or by sending an email to [email protected].
The customer must be aware that it may take up to five (5) business days for us to process the request if they do not receive commercial emails from us. Even after they unsubscribe from receiving commercial communications from us, they will continue to receive administrative communications from us regarding the service.
MINT Talents is entitled to unilaterally change this data protection declaration from time to time. After the policy has been changed, MINT Talents will inform the customer of the conditions by email. If the new terms relate to the processing of the customer’s personal data for a new purpose for which the customer’s consent is required, MINT Talents will not process personal data for that new purpose until they have received the appropriate consent.