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Privacy Policy of InterNations GmbH (InterNations)

Version 12 October 2018

For the use of the services under the sub-domain business.internations.org and the corresponding mobile applications

Part A: Privacy Principles

Welcome to InterNations Business Solutions. The protection of your privacy and your personal data is taken very seriously and of utmost concern for InterNations.

InterNations is a community of trust which helps its members at the Internet portal www.internations.org to exchange and share information as well as to connect with other members. InterNations Business Solutions is a trusted partner for global mobility and international talent acquisition professionals. We provide expert insights and tailored solutions for smooth and successful foreign assignments and improved retention of international hires. InterNations ensures the highest standards for the protection of your personal data and your privacy.

This Privacy Policy supplements the General Terms and Conditions for using business.internations.org and any aliases of this sub-domain (InterNations Business Solutions Website(s) or Website(s)), and are applicable to all services provided to the User or offered on the InterNations Business Solutions Websites.

This Privacy Policy is designed to help you better understand how InterNations collects and deals with your personal data and information.

If you have any questions or comments regarding this Privacy Policy, please contact InterNations by using the contact form, or by sending a fax or letter to InterNations GmbH, Schwanthalerstraße 39, 80336 München, Germany.

By using the InterNations Business Solutions Websites, you consent to the practices described in the following Privacy Policy.

1. InterNations Principles

InterNations works hard to earn and keep its User’s trust. Therefore, InterNations strictly adheres to the following principles to protect the User’s privacy:

InterNations collects, processes, and uses all data and/or information about and related to the User’s person and the User’s account with InterNations (Personal Data) in accordance with the laws and statutes on data protection of the Federal Republic of Germany and those of the European Union.

InterNations uses Personal Data solely to provide the User with InterNationsServices. InterNations will never rent, sell, or otherwise provide Personal Data to any third party for advertising or for marketing purposes without the User’s consent. The User is aware of the fact and agrees that in case of online debiting procedures (i.e. payment via credit card) any data (e.g. name, credit card number, expiry date, bank details etc.) which is necessary for the due processing of such payment will be transferred to third parties involved in the execution of the debiting procedure (e.g. operator of the payment module, credit card acquirer and the bank issuing the credit/debit card).

2.  Information Collection by InterNations

2. 1 User Data Processing

In order to become a business contact of InterNations Business Solutions through business.internations.org it is necessary to submit a form providing full name, email, telephone and company name and/or subscribe with an email to our marketing communications and opt-in to further communication as business contact.

All information that the User enters or uploads about his/her contacts will be covered by the same terms of this Privacy Policy as those covering his/her own personally identifiable information.

2.2 Cookies and Log Files

Like most websites, InterNations uses cookies to identify the User during the course of his/her session and to recognize him/her as a User when he/she returns to the InterNationsWebsites using the same computer and web browser. A cookie is a piece of data stored on the User’s computer tied to information about the User.

Each time the User accesses the InterNationsWebsites, InterNations automatically receives the URL of the site from which the User came and of the site to which the User is going when leaving the InterNationsWebsites. InterNations also receives the Internet Protocol (IP) address of the User’s computer (or the proxy server the User uses to access the World Wide Web), the computer operating system and type of web browser he/she is using, as well as the name of the User’s ISP. This data is saved in a log file and will be stored by InterNations in the standardized combined log file format unless the User objects to the processing of such data and notifies InterNations accordingly by sending a fax or letter to InterNations. The information is used in anonymous form to analyze overall trends to help InterNations improve its service, e.g., InterNations may analyze on which days and at which time the InterNationsWebsites are particularly frequented. The linkage between the User’s IP address and his/her personally identifiable information is never shared with any third party without the User’s permission except when required by law. InterNations reserves the right to review the log files from the last known IP address of the User where InterNations has reasonable cause to believe that the User is using InterNationsServices in breach of contractual agreements or the applicable legislation. In doing this, InterNations protects other users, the safety of its user’s data, as well as InterNationsWebsites and the InterNationsServices.

Cookie and log file data is used to customize the User’s experience on the InterNationsWebsites.

2.3  Information Collection from other Sources

InterNations reserves the right to use information about the User that is collected from other sources, including but not limited to newspapers and Internet sources such as blogs, instant messaging services, and other Users at InterNations, to supplement the User’s profile in order to provide the User with more useful information and a more personalized experience. Where such information is used, InterNations generally allows the User to specify the use in the privacy settings.

3. Sharing Information with Third Parties

3. 1 Sharing Personal Data with third parties

Posting User Content on or through the InterNationsService or the InterNationsWebsites, or transmitting to or sharing with other Users on the InterNationsWebsites is at the User’s own risk. Although InterNations allows the User to set privacy options that limit access to his/her personal information, the User should be aware that no security measures are perfect or impenetrable and the User’s Personal Data, his/her User Content and other information may become publicly available. InterNations cannot control the actions of other Users with whom the User may choose to share data and information. Therefore, InterNations cannot and does not guarantee that Personal Data, User Content, and other information the User posts on InterNationsWebsites will not be viewed by unauthorized persons. InterNations is not responsible for circumvention of any privacy settings or security measures contained on the InterNationsWebsites. The User understands and acknowledges that, even after removal, copies of Personal Data, User Content, and other information may remain viewable in cached and archived pages or if other Users have copied or stored this data and information.

3.2 Newsletters, Emails, and Notifications to Contacts

InterNations regularly sends out newsletters, service-related announcements, or other notification messages and emails (Marketing Communication) to all Contacts of InterNations Business Solutions. Through this direct contact, InterNations Business Solutions informs the Contact, among other things, about new content and information relating to services. InterNations Business Solutions may also offer consulting services..

Generally, the User may opt out of Marketing Communications through personal settings or actively request to opt out.

3.3 Information Sharing with Third Parties

InterNations does not forward the User’s Personal Data, his/her User Content, or other information to third-party marketers without the User’s permission. InterNations shares Personal Data, his/her User Content, and other information with third parties only in limited circumstances where InterNations believes such sharing is legally permitted and either 1) reasonably necessary to offer the InterNationsService or, 2) legally required or, 3) permitted by the User. For example:

InterNations may forward Personal Data, User Content and other information to service providers (including service providers located outside the European Union) to help InterNations offer the InterNationsServices. Specifically, InterNations may use third parties to facilitate InterNations’ business, such as to host the service at a co-location facility for servers, to send out email updates about InterNations, to remove repetitive information from User lists, to process payments for products or services, or to provide search results or links. In connection with these offerings and business operations, the InterNations’ service providers may have access to the User’s Personal Data, his/her User Content and other information for use for a limited time in connection with these business activities. Where InterNations utilizes third parties for the processing of any personal information, InterNations will implement reasonable contractual and technical protections limiting the use of that information to the InterNations-specified purposes.

InterNations may be required to disclose Personal Data, User Content or other information in compliance with applicable laws or pursuant to lawful requests, such as subpoenas or court orders. InterNations does not reveal information unless InterNations has the bonafide belief that an information request by law enforcement or private litigants meets applicable legal standards. Additionally, InterNations may share account or other information when InterNations believes it is necessary to comply with the law, to protect the interests or property of InterNations, to prevent fraud or other illegal activity perpetrated through the InterNationsService or using the InterNations name, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents, or government agencies.

If the complete or partial ownership of the InterNations business, or individual business units owned by InterNations GmbH, were to change, the User’s personal information may be transferred to the new owner or shareholder. In any such transfer, the User’s Personal Data, his/her User Content, and other information would remain subject to the promises made in any pre-existing Privacy Policy.

InterNations may use the User’s Personal Data, his/her User Content, or any other information in an anonymous way without identifying the User as an individual to third parties. This includes for instance providing aggregated data about the usage of the InterNationsService to third parties for such purposes as InterNations deems to be appropriate. InterNations may segment its Users by e.g., gender, age, geographic location, nationality, or employer.

4. Use of Third Party Tools

4.1 Google Analytics

InterNations uses the web analysis tool Google Analytics, developed by Google Inc. ("Google"). Google Analytics uses so-called "cookies": text files that are saved on your computer and enable the analysis of your usage of a website. The information generated by the cookie about your use of this website (including your IP address) is transferred to a server of Google in the USA and saved there. We use the so-called "_anonymizeIp()" script here, which ensures that your IP address (after identifying the geolocation) is immediately anonymized by Google. InterNations has also closed a data processing agreement with Google. Google will use this information to evaluate your use of the website, to compile reports about website activity for website operators, and to provide other services relating to website and online usage. Google may also pass this information on to third parties if this is required by law or if these third parties process the data on behalf of Google. Google will not link your IP address to any other data about you it has stored.

You can prevent the installation of cookies by adjusting the settings in your browser software accordingly; please note though that you may not be able to use all the features of the InterNationsWebsite in full as a result. Google also offers so-called deactivation tools for some web browsers, where you can opt out of your user behavior being recorded and analyzed. You will find more information and download options for these tools here: http://tools.google.com/dlpage/gaoptout?hl=en-GB

4.2 Hotjar

InterNations uses Hotjar, developed by Hotjar Limited, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps InterNations to better understand users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables InterNations to build and maintain the InterNations service with user feedback. Hotjar uses cookies and other technologies to collect data on the InterNations users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor InterNations will ever use this information to identify individual users or to match it with further data on an individual user. For more information please review the Hotjar privacy policy available under https://www.hotjar.com/legal/policies/privacy.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link: https://www.hotjar.com/legal/compliance/opt-out.

4.3 NewRelic

InterNations uses NewRelic, developed by New Relic, 101 Second Street, 15th Floor, San Francisco, CA 94105, USA, to monitor the performance of the InterNations servers as well as the client side performance of the InterNations website. The tool collects potentially personally-identifying information such as internet protocol addresses and database queries. Neither NewRelic nor we will use this information to identify individual users. NewRelic is fully compliant with European data protection laws and certified under the EU-U.S. Privacy Shield. For more information please review the New Relic privacy policy available under https://newrelic.com/privacy.

4.4 Salesforce

For customer care, InterNations uses the Customer Relationship Management module "Salesforce Marketing Cloud" and "Salesforce Sales Cloud" from Salesforce.com Inc., The Landmark @ One Market Street, Suite 300, San Francisco, California, CA 94105, USA. Salesforce Marketing Cloud is a database management service for user data. The data is processed in the USA. Salesforce.com has certified this service under the EU-US Privacy Shield Scheme. For more information about the Salesforce Marketing Cloud and Sales and the processed data, please visit www.salesforce.com/euen/company/privacy/.

4.5 Hubspot

For online marketing activities, InterNations uses HubSpot, an integrated software solution that allows us to cover a wide range of aspects, including:

  • e-mail marketing (newsletter and automated e-mails, e.g., to provide downloads)
  • social media publishing and reporting
  • reporting (e.g., sources of traffic, access, etc.)
  • contact management (e.g., user segmentation and customer relationship management)
  • landing pages, blogs, and contact forms

The InterNations contact forms allow you as a visitor to the InterNations website, to find out more about InterNations, download content and share your contact and demographic information with InterNations. This information and the content of the InterNations Business Solutions website are stored on servers belonging to the InterNations software partner HubSpot. InterNations will use this information to contact you. Cookies also allows InterNations to find out which of the InterNations services might interest you. To do so, InterNations stores information about your interaction with the InterNations website, such as the documents you download, the pages you visit, and the date and time of your visit (“usage data”), as well as whether and when you have opened marketing e-mails from InterNations.

HubSpot is a US software company with offices in Berlin.

HubSpot Germany GmbH
Unter den Linden 26
10117 Berlin
Germany

4.6 Surveymonkey

InterNations uses Surveymonkey, developed by SurveyMonkey, One Curiosity Way, San Mateo, CA 94403, to conduct online surveys. Usage data as well as the information that you enter in our surveys will be stored and processed on servers in the US. Surveymonkey is fully compliant with European data protection laws and certified under the EU-U.S. Privacy Shield. For more information please review the Surveymonkey privacy policy. 

4.7 Social Media Plugins

On certain webpages of the InterNations website, InterNations may implement so-called social media plugins, in particular Facebook, Inc.’s “like” button and other services such as Linkedin, Xing and Twitter. When you visit a page that displays one or more of such buttons your browser will establish a direct connection to the respective service. At the same time these services will know that the respective page on our website has been visited. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents InterNations’ legitimate interest to improve your website experience and to optimize our services.

5. Miscellaneous

5.1 Under Age

Children and minors (under the age of 18) are not eligible to use any InterNationsService and are therefore not allowed to submit any personal information to InterNations. Parents and legal guardians are responsible for the protection of their children’s privacy.

5.2 Links

InterNations may contain links to other websites. InterNations is not responsible for the privacy practices of other websites. InterNations encourages the User to be aware when he/she leaves the InterNationsWebsites to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by InterNations.

5.3 Terms of Use

The use of InterNations Business Solutions Services, and any disputes arising from it, are subject to this Privacy Policy as well as InterNations’ Business Solutions General Terms and Conditions for the use of the services under the sub-domain business.internations.org, the InterNations Business Solutions mobile applications and all of its provisions including limitation on damages and choice of law.


Part B: User’s Consent

The User acknowledges the principles set forth in this privacy policy (Part A) and also consents to the processing of his/her personal data as described below. The User shall be entitled to revoke his/her consent at any time and with effect for the future. For such revocation please contact InterNations by using the , or by sending a fax or letter to InterNations GmbH, Schwanthalerstraße 39, 80336 München, Germany. The User declares the following:

1. Single-Sign-On-Process

I agree that InterNations shall be entitled to pass on personal data (first name, last name and email-address) to third party providers for the purpose described hereinafter:

Third parties may offer certain services on or via the InterNationsWebsites. If the User decides to order such services he/she will access the third parties’ websites through a link or frame embedded in the InterNationsWebsites and will then have the opportunity to use the third party services. In order to facilitate the ordering process InterNations and such third parties may have agreed on a single-sign-on-process. This means that the User does not have to enter his personal data on the third party website again, but InterNations rather passes on to the third party the personal data which is necessary for the third party service.

2. Usage of personal data for marketing purposes of partners of InterNations

I agree that InterNations shall be entitled to process and use my personal data for advertising or marketing purposes of partners of InterNations via the InterNationsWebsites. Particularly, my personal data may be used in order to tailor the advertisement presented to me to my specific interests.

3. Cookies and Log Files

I agree that InterNations shall be entitled to use Cookies and Log Files as described in section 2.2 of Part A of this Privacy Policy.

4. Breach of obligations

I agree that InterNations shall be entitled to review my personal data, communication and networking, in the event InterNations has good reason to believe that I have breached my obligations under Section 5 of the GTC, however, only to the extent as required to verify such breach.

5. Changes to this Privacy Policy

InterNations reserves the right to update or change this Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If InterNations makes any material changes to this Privacy Policy, you will be notified either through the email address you have provided, or by placing a prominent notice on the InterNations website.