Privacy Policy for Applicants

Privacy policy for applicants


Thank you for your interest.


The protection of your personal data is of the utmost importance to us. Our data protection policy complies with the provisions of the EU General Data Protection Regulation (EU GDPR) and the UK General Data Protection Regulation (UK GDPR). If you are a resident of the European Economic Area, we will generally transfer your personal data to third countries (e.g. USA) in accordance with the standard contractual clauses for the transfer of personal data. This privacy policy explains what data is stored by us and how it is used.


In addition to the EU GDPR and the UK GDPR, we comply with all data protection laws that apply to us.


We reserve the right to update and/or modify this Privacy Policy from time to time in the future.


Please read the following information and regulations carefully.




Part I – Information about the responsible person and his representative


Name and contact details of the person responsible:


adviqo GmbH

Max-Dohrn-Str. 8 – 10, D10590 Berlin

Phone +49 (0)30 22445 0

Fax +49 (0)30 224455-9100

E-mail: [email protected]



Contact details of the data protection officer of the data controller:


Data Protection

c/o adviqo GmbH

Max-Dohrn-Straße 8 – 10, 10589 Berlin

[email protected]


Contact details of the representative in the United Kingdom:


For the application of the UK General Data Protection Regulation (UK GDPR), adviqo GmbH is the data controller. Our representative in the United Kingdom is


adviqo UK Limited

Anglia House, 6 Central Avenue, St Andrews Business Park,

Thorpe St. Andrew, Norwich, Norfolk, NR7 0HR, United Kingdom




Part II – Information on the processing of personal data


If you would like to apply for a job with us, we will need some information about you. The following application data is therefore collected and processed as part of the application:


  • Name, address, contact details such as email address and telephone number
  • Information about your qualifications, knowledge, experience and professional background
  • Your fortunica User-ID
  • Other information you provide to us in connection with your application


We process work-related information that you have made publicly available, such as a profile on professional social media networks.


  1. Obligation to provide the data:


The provision of the data is not required by law or contract. The data subject is not obliged to provide the data. However, if the data is not provided, an application procedure or subsequent employment is not possible.


  1. Purposes and legal basis:


Data processing is permitted for the application process, among other things. We use your data to decide whether to consider you in the short-listing process or to make a personal impression in an interview to decide whether to offer you the job for which you have applied. The processing also serves the purpose of corporate communication.


The data may also be used to assert, exercise or defend legal claims.


Furthermore, we would like to point out that the data you provide may be used to compile statistics on the application process. These statistics are compiled exclusively for our own purposes and are never personalised, but anonymised.


  1. Recipient:


Due to our global business activities, your personal data will also be transferred to affiliated companies, among others. “Affiliated companies” are legally independent companies that are affiliated with us under company law (cf. §§ 15 ff AktG) and/or are part of the same group of companies. For the purposes of data transfer, this refers to Ingenio Europe GmbH (Germany), Barges Technologies, Inc (USA), Inc. (USA) and Ingenio LLC (USA).


We use service providers in the provision of our services. Data is therefore transferred to shipping service providers, IT service providers and possibly external lawyers. These service providers are contractually or legally obliged by us to exercise the same care in processing personal data as we do ourselves.


In certain circumstances, we may be required to disclose information to courts, authorities, the government or the police.


  1. Data transfer to third countries:


Due to our global business operations, your personal data may also be transferred to affiliated companies outside the EEA. Similarly, the employees of certain service providers may be located outside the EEA.


We have concluded a data transfer agreement with our affiliated companies, which regulates the cross-border transfer of your personal data within the group. This agreement is based on the EU Commission’s standard contractual clauses, which you can view and, if necessary, download here: If third parties transfer your personal data outside the EEA, we will take steps to ensure that your personal data receives an adequate level of protection, for example by entering into data transfer agreements or by ensuring that third parties are certified under appropriate data protection regimes.


  1. Storage period:


We do not keep your personal data longer than is necessary for the purpose for which this personal data is processed. However, please note that we must retain personal data if there is a legal obligation to retain it, e.g. in accordance with Section 257 of the German Commercial Code (HGB) and Section 147 of the German Tax Code (AO).


We store your data,


-if you have consented to the processing, at most until you withdraw your consent,

-If we require the data for the performance of a contract, at most for as long as the contractual relationship with you exists or for as long as statutory retention periods apply,

-if we use the data on the basis of a legitimate interest at most for as long as your interest in deletion or pseudonymisation does not prevail.


The deletion of the transmitted data takes place automatically in case of rejection of your application 6 (six) months after completion of the application procedure.


If we are not able to offer you a current vacancy, but believe on the basis of your profile that your application may be of interest for future vacancies, we will store your personal application data for twelve months, provided you expressly consent to such storage and use.


If your application is followed by the conclusion of a contract, your data may be stored and used for the purposes of the usual organisational and administrative process, in compliance with the relevant legal provisions.




Part III – Commissioned processing and data security


We attach great importance to the protection of your personal data. In order to protect the data collected in the course of your application from manipulation and unauthorised access, we have taken various technical and organisational precautions.


Our online application portal is technically operated by our service provider softgarden e-recruiting GmbH, Tauentzienstraße 14, D-10789 Berlin, (hereinafter: Softgarden). Softgarden only provides software and computing capacity and otherwise has no influence on the application process. This is commissioned processing in accordance with Art. 28 GDPR.


The operation of our career pages is realised through so-called widgets provided by Softgarden. These processing windows on the application pages establish a direct technical connection to Softgarden as soon as you call up these pages. This means that data is automatically transmitted to Softgarden via your internet browser for technical operating and maintenance purposes. The following data is stored by Softgarden:


  • Date and time of access
  • Browser type and version
  • Operating system used
  • URL of the previously visited website
  • Amount of data sent
  • IP address of the access


This data is stored by Softgarden exclusively for technical reasons and is not assigned to a specific person at any time. The legal basis is Art. 6 para. 1 p. 1 lit. f DS-GVO.


Softgarden is contractually obliged to take technical and organisational measures to ensure the protection of your personal data. Your data is stored in a secure operating environment that is not accessible to the public. Your data is encrypted during transmission using Transport Layer Security (TLS). This means that communication between your computer and the data servers used takes place using a recognised encryption method.




Part IV – Information on data subjects’ rights


Rights of the data subject to information as well as to rectification or erasure or to restriction of processing or a right to object to processing as well as the right to data portability:


If your personal data is processed, you are a data subject within the meaning of the GDPR. As a data subject, you have the right – partly under certain conditions,


a)request    information about the processing of your data,

  1. b) have your data corrected and/or completed,
  2. c) have your data deleted or blocked,

d)restrict the            processing of your data,

  1. e) object to the processing of your data,
  2. f) to receive your data in a transferable format and to transmit it to a third party,
  3. g) withdraw your consent to the processing of your data for the future; and
  4. h) complain to the competent supervisory authority about unlawful data processing. The competent supervisory authority is the Berlin Commissioner for Data Protection and Freedom of Information.
  5. i) Right of objection: You have the right to object at any time to the processing of personal data relating to you on the basis of Article 6 (1) (e) or (f) GDPR for reasons arising from your particular situation; this also applies to profiling based on these provisions.
  6. j) Right to withdraw consent: You have the right to revoke your consent at any time.


If you have any questions about the collection, processing or use of your personal data, or in cases of information, correction or deletion of data, as well as revocation of consent given, please contact our data protection officer: [email protected] or our human resources department: [email protected].




Part V – California, USA (CCPA)


This section applies only to you if you are a resident of the State of California in the U.S. and applies only to personal information for which we have a “business” (as defined in the CCPA) and not to personal information we collect from you in the course of providing our services to you if you are an employee, owner, director, officer or contractor of a business, partnership, sole proprietorship, non-profit organisation or government agency. It applies to personal information we collect from California residents on or through our Services and in other ways (e.g., offline or in-person data collection).


  1. Overview of the personal data we collect about you


For individuals residing in California, the California Consumer Privacy Act (CCPA) requires disclosure of the categories of personal information we collect and how we use it, the categories of sources from which we obtain personal information, and the third parties to whom we disclose that information. We are keen to keep the information simple for our users. The categories, as required by the CCPA, are set out below. See our Privacy Policy for examples and more information about how we collect and use information.


Depending on how you interact with us, we may collect the following categories of data as set out in the table below.


Any personal data we collect about you (as set out below) comes from the following categories of sources:


  • From you
  • Automatically captured by you
  • Third parties (for example, if you have made this data publicly available online)


Categories of personal data we collect Categories of third parties with whom we share this data
Identifiers (such as name, address or email address) – Third parties (such as our service providers)

– Aggregators (such as analytics services)

Activities on the internet or other networks or devices (such as browsing history) – Third parties (such as our service providers)

– Aggregators (such as analytics services)


Location data (for example, obtained by inferring your IP address) – Third parties (such as our service providers)

– Aggregators (such as analytics services)


Classifications protected by law (such as gender and marital status) Third parties (such as our service providers)


Other data that identifies you or can be linked to you in a meaningful way – Third parties (such as our service providers)

– Aggregators (such as analytics services)




  1. Categories of business purposes for our use of your data


All categories of personal data we collect about you (as detailed in the above) will be used for the following purposes:


  • Application procedure
  • where appropriate, for the assertion, exercise or defence of legal claims


  1. Rights and choices in California


Subject to certain limitations, if you are a California resident, you have the right to request the following from us:


Disclosure of the personal data we have collected about you, deletion of all our data collected about you or stored by you. You also have the right to object to the sale of your personal information. As a California resident, you also have the right to designate an agent to exercise these rights on your behalf.


This section describes how you can exercise these rights and how we deal with requests made to us, in particular to verify your identity. If you would like more information about your rights under applicable law, or if you would like to exercise any of these rights, please contact us at [email protected].


  1. Access to and deletion of your personal data


  1. Right to request access to your personal data

As a California resident, you have the right to request that we disclose the categories of your personal information that we collect, use or sell. You also have the right to request certain portions of the personal information we collect about you. However, we may withhold information that poses too great a risk to you or your personal information to disclose (for example, in the case of financial information or passwords).


  1. Right to request the deletion of your personal data

You have the right to request that we delete all personal data that we have collected about you / from you.




However, we may withhold certain personal data under applicable law, including personal data necessary to fulfil the following purposes: Providing our services; Protecting our business and system from fraudulent activity; Identifying and correcting errors that affect existing functionality; Exercising freedom of expression or other rights as necessary for us or others; Complying with law enforcement requests under a lawful process; For scientific or historical research; For our own internal purposes that are reasonably related to your relationship with us; or To comply with legal requirements.


Users residing in California may exercise their privacy rights granted by the State of California by sending their request by email to [email protected].


  1. Identification


Also, for security reasons, we may request supplemental information from you that is necessary to verify your identity when you apply to exercise your privacy rights in California.


  1. Sale of personal data


The CCPA requires companies that “sell” personal information (as that term is defined in the CCPA) to give California residents the right to opt-out of such sales. adviqo does not “sell” your personal information as we understand and interpret the term.


  1. Non-discrimination rights


Users residing in California have the right not to be discriminated against for exercising their rights as described in this section. We do not discriminate against users for exercising their rights under the CCPA.




Part VI – Brazil (LGPD)


For users who are residents of Brazil, the following additional provisions apply:


Legal provisions regarding data processing equivalent to those already mentioned can be found in Art. 7 LGPD.


  1. Additional rights


In addition to the aforementioned rights (according to the GDPR), you have the right to request confirmation of the existence of the processing. Access to your data will be given to you, according to your choice, either in a simplified and printed form or in an electronic form, or by a clear and complete statement indicating the origin of the data, the non-existence of the data set, the criteria used and the purpose of the processing, subject to commercial and industrial confidentiality and within fifteen days from the date of your request. To request confirmation or access to your data, please submit a request to the following email address: [email protected], or use the contact details provided above and indicate the form in which you wish to receive the information requested.


You also have the right to request the anonymisation of unnecessary or excessive data or data processed in breach of the provisions of the LGPD, unless we are required by law to retain your personal data (see Art. 16 LGPD). Please submit a request to the following email address: [email protected].


In the case of fully automated processing of personal data, you have the right to request a review by a natural person if the automated decision negatively affects your interests. We will therefore provide clear and sufficient criteria and procedures used for the automated decision, subject to commercial and industrial confidentiality.


  1. Data security


We use technical and administrative measures to protect your personal data from unauthorised access and accidental or unlawful destruction, loss, alteration, communication or disclosure, and to prevent the occurrence of damage resulting from the processing of personal data. Please be aware that despite our efforts, no security measure is perfect or impenetrable. However, if a security incident occurs, we will notify you in accordance with applicable law.


Status: 02.05.2022