1. General Information and Data Controller

This Privacy Policy informs you about the collection, processing, and use of personal data by Arrowgate Talent in accordance with the General Data Protection Regulation (GDPR).

We operate a recruitment platform connecting qualified professionals from Tunisia with employers in Germany.

Data Controller:

Arrowgate Talent

Owner: Montasser Fouzai

Germany

Email: contact@arrowgate.de

2. Categories of Data Processed

A. Candidates

We process personal data necessary for recruitment and placement services, including:

• Identity and Contact Data: Name, date of birth, address, email address, telephone number
• Professional Information: CV, diplomas, certificates, work history, references
• Language qualifications
• Administrative Documents: Passport copies, visa-related documentation
• Communication records

Processing occurs for recruitment matching, employer presentation, and visa coordination.

B. Partner Agencies (Tunisia)

We process business contact data of agency staff, including: Name, Position, Business email address, Business phone number. Processing serves the management of cooperation agreements and recruitment coordination.

C. Employers (Germany)

We process business contact data of employer representatives, including: Name, Job title, Company, Email address, Phone number. Processing is required for recruitment services and contractual communication.

3. Legal Basis for Processing

Processing of personal data is based on:

• Art. 6 (1) (b) GDPR – Performance of a contract or pre-contractual measures
• Art. 6 (1) (a) GDPR – Consent (e.g., Talent Pool enrollment)
• Art. 6 (1) (f) GDPR – Legitimate interest (fraud prevention, verification of qualifications, business communication)
• Art. 6 (1) (c) GDPR – Compliance with legal obligations

Where special categories of data are processed (if applicable), processing is based on Art. 9 (2) GDPR where required.

4. International Data Transfers (Tunisia)

For candidate sourcing and screening, Arrowgate Talent cooperates with authorized partner agencies in Tunisia. Tunisia is considered a third country under GDPR.

To ensure an adequate level of data protection:

• EU Standard Contractual Clauses (SCCs) have been implemented
• Technical and organizational safeguards are applied
• Access is limited to authorized personnel
• Data transfers occur solely for recruitment-related purposes.

5. Data Sharing with Employers

Candidate profiles may be shared with potential employers in Germany for recruitment purposes.

Upon receipt of a candidate profile, the employer acts as an independent Data Controller under GDPR.

Employers are contractually required to process candidate data lawfully and delete it when no longer necessary for recruitment purposes.

6. Storage and Deletion

We store personal data only as long as necessary for the purposes stated.

• Active Recruitment: Duration of the recruitment process plus 6 months (legal defense period)
• Talent Pool: 24 months based on consent
• Business Records (contracts, invoices): 10 years in accordance with German tax and commercial law

Data is deleted or anonymized after expiration of retention periods.

7. Hosting and Server Log Files

When visiting our website, our hosting provider automatically collects technical data: IP address, Date and time of access, Browser type, Operating system, Referrer URL.

Processing is based on Art. 6 (1) (f) GDPR to ensure system security and stability. Server log data is stored for a limited period and then automatically deleted.

8. Cookies

Our website uses cookies necessary for technical operation.

Non-essential cookies (e.g., analytics) are only activated after explicit user consent via our cookie consent banner. You may withdraw your consent at any time.

9. Google Analytics (GA4)

If you consent, we use Google Analytics (GA4), a web analytics service provided by Google Ireland Limited.

Purpose: Analyze website usage and improve functionality and performance.

Legal Basis: Art. 6 (1) (a) GDPR (Consent)

Features: IP anonymization enabled, Data processing agreement concluded with Google, Data may be transferred to the United States under EU Standard Contractual Clauses, Data retention settings configured to minimum necessary duration. You may withdraw consent at any time via the cookie settings.

10. Contact and Application Forms

When contacting us or submitting application data: Data is processed exclusively for handling the request or recruitment process. Legal basis: Art. 6 (1) (b) GDPR.

11. Data Security

We implement appropriate technical and organizational measures, including: SSL/TLS encryption, Encrypted data storage, Restricted access rights, Secure authentication systems.

12. Data Protection Officer

Arrowgate Talent is currently not legally required to appoint a Data Protection Officer. For privacy inquiries, please contact: contact@arrowgate.de

13. Your Rights

Under the GDPR, you have the following rights:

• Access (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Objection (Art. 21)
• Withdraw consent at any time (Art. 7 (3))

You also have the right to lodge a complaint with a supervisory authority.

14. Supervisory Authority

You have the right to lodge a complaint with the competent data protection authority in Germany.

15. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on individuals within the meaning of Art. 22 GDPR.