Controller
Alma operates from two locations:
CÔNG TY TNHH ALMA RECRUITING
Mã số thuế: 0319259039
Phòng R5-16, Tầng 5, Số 343, Đường Hoàng Sa,
Phường Tân Định, Ho Chi Minh City, Vietnam
Điện thoại: +84 96 989 8472
The controller responsible for data processing on this website is:
Alma Recruiting GmbH
Christinenstraße 6
10119 Berlin
Germany
Email: contact@almarecruiting.com
Phone: +49 30 220118550
Managing directors: Tien Nguyen, Maddin Truong, Anh Nguyen, Son Le Duc
Amtsgericht Berlin-Charlottenburg
Commercial register no.: HRB 279487 B
The selection, preparation and support of applicants in Vietnam is carried out at the Ho Chi Minh City location. The two companies work together throughout the application and placement process. Responsibility for data processing on this website lies solely with Alma Recruiting GmbH. For questions about your data you may contact either company; a message to contact@almarecruiting.com is enough.
Introduction
At Alma we value your privacy and are committed to protecting your personal data. This Privacy Policy explains, in accordance with Art. 13 and 14 GDPR, what data we collect when you visit our website or use our services, what we use it for, and what rights you have.
In short
We do not use analytics or marketing cookies on this website, which is why you will not see a cookie banner. Our audience measurement runs on Matomo, without cookies and with a shortened IP address. We do not sell data, do not build advertising profiles and do not follow you across other websites. The full detail is set out under Cookies and Tracking.
Data you actively provide, for instance as part of an application or an employer enquiry, is handled separately and used only for that purpose.
What data we collect
When you simply visit the website
Server log data and data from cookieless audience measurement: shortened IP address, pages opened, referring website, campaign parameters from links we place ourselves, browser type, operating system, and the time and duration of your visit. We cannot connect this to you personally.
When you contact us or apply
Personal data: name, email address, telephone number, date of birth, nationality and other details you provide when contacting us or applying.
Employment data: CVs, educational background, professional experience, language certificates (e.g. Goethe-Zertifikat B1/B2) and qualifications submitted as part of an application.
Application photos and videos: where you provide us with application photos or video interviews.
Company data: for employer enquiries, the name and contact details of the contact person, company name, location and details of staffing requirements.
Legal bases for processing
Art. 6 (1)(a) GDPR (consent): where you have expressly agreed to the processing, for example when your application documents are shared with a specific employer.
Art. 6 (1)(b) GDPR (performance of a contract): to carry out the application and placement process and to take steps prior to entering into a contract.
Art. 6 (1)(c) GDPR (legal obligation): where we are legally required to process data, in particular under residence and employment law and under commercial and tax retention obligations.
Art. 6 (1)(f) GDPR (legitimate interests): for the secure operation of the website, cookieless audience measurement and responding to business enquiries.
For applicant data, Art. 88 GDPR in conjunction with § 26 Abs. 1 BDSG applies in addition.
Where we process special categories of personal data within the meaning of Art. 9 GDPR, such as health information required for occupational health purposes, we do so solely on the basis of your explicit consent under Art. 9 (2)(a) GDPR, or where this is necessary for exercising rights under employment law.
How we use your data
Handling applications and recruitment processes
Matching applicants with employers in Germany
Preparing and supporting the visa and qualification recognition process
Communicating important updates, responding to enquiries and sending service notifications
Improving our website, services and user experience
Meeting legal obligations and protecting our rights
Hosting and server log files
Our website is hosted by Framer B.V., Rokin 75, 1012 KL Amsterdam, Netherlands, on servers within the European Union. Framer acts as a processor for us under Art. 28 GDPR.
When our pages are accessed, information transmitted by your browser is automatically recorded in server log files. This includes IP address, date and time of the request, the file requested, transfer status and the browser used. This is technically necessary in order to deliver the website and ensure its stability and security.
The legal basis is Art. 6 (1)(f) GDPR. This data is not combined with other data sources. Log files are deleted after 30 days at the latest, unless they are needed to investigate a specific security incident.
Audience measurement with Matomo
We use Matomo to understand which content is being read and how visitors find us. Matomo runs in a cookieless configuration and stores no information on your device.
The following is processed: IP address shortened by two bytes, pages opened, referring website, campaign parameters from links we place ourselves, browser type, operating system, approximate region at country level, and the time and duration of your visit. We also record whether a contact form was submitted or a call-to-action button was clicked.
Because the IP address is shortened, we cannot connect this data to you personally. No recognition across separate visits takes place.
The legal basis is Art. 6 (1)(f) GDPR. Our legitimate interest lies in designing our offering around actual demand and improving it. We delete raw data after twelve months; beyond that we keep only anonymous, aggregated reports.
Matomo is operated on our behalf by InnoCraft Ltd., 150 Willis Street, Te Aro, Wellington 6011, New Zealand, as a processor under Art. 28 GDPR. Data is stored on servers within the European Union. New Zealand is covered by an adequacy decision of the European Commission under Art. 45 GDPR.
You can object to audience measurement at any time. The opt-out and further detail are available under Cookies and Tracking.
Search visibility
We use Google Search Console to see which search queries lead people to our pages. This analysis happens entirely on the search engine’s side. Nothing is stored on or read from your device. We receive only aggregated statistics with no personal reference.
Contact forms and enquiries
When you contact us via a form, by email or by telephone, we process your details in order to handle your enquiry. Mandatory fields are marked as such; all other information is optional.
The legal basis is Art. 6 (1)(b) GDPR where your enquiry is directed at entering into a contract, and otherwise Art. 6 (1)(f) GDPR based on our legitimate interest in responding to business enquiries.
Booking an appointment
Our contact page embeds an appointment calendar provided by HubSpot Ireland Limited, 1 Sir John Rogerson’s Quay, Dublin 2, Ireland. It loads only after you have explicitly activated it with a click. Before activation, no connection to HubSpot is made and no information is stored on your device.
By activating it you consent to the transmission of your IP address to HubSpot and to the setting of the cookies required by the booking tool. The legal basis is § 25 Abs. 1 TDDDG in conjunction with Art. 6 (1)(a) GDPR. You may withdraw your consent at any time with effect for the future by deleting the cookies set by HubSpot in your browser.
HubSpot acts as a processor for us under Art. 28 GDPR. Details of the cookies set are available under Cookies and Tracking, and HubSpot’s privacy notice at https://legal.hubspot.com/privacy-policy
Communication via messenger services
For communication with applicants in Vietnam we use email and also the messenger service Zalo (VNG Corporation, Ho Chi Minh City, Vietnam). Our website only links to this service. Data is transmitted only once you actively click the link and contact us through the service.
Please note that the provider’s own privacy terms apply to the use of Zalo, and that Vietnam is a third country without an adequacy decision from the European Commission. If you would prefer to avoid this route, you can reach us by email at contact@almarecruiting.com at any time.
Links to social networks
In the footer of our website we link to our profiles on LinkedIn, Facebook and Zalo. These are plain links, not embedded plug-ins. A connection to the providers’ servers is established only when you click one of these links.
Application and placement process
We process application documents solely for the purpose of assessing suitability and matching candidates with suitable employers. Within our company, access is limited to those responsible for the relevant step.
Your documents are shared with a specific employer only after you have been informed in advance and have given your explicit consent. You will be told which company is involved beforehand and may decline, without any disadvantage to you in the remainder of the process.
Sharing your data
We do not sell or rent your personal data. It is shared only with:
Employers and partner businesses for placement purposes, and only with your explicit consent
Language schools and educational partners in Vietnam, where necessary for training preparation
Service providers acting as processors under Art. 28 GDPR who support the operation of our website and services, in particular hosting, email, analytics and IT support
Public authorities where legally required, in particular immigration authorities, embassies and the Bundesagentur für Arbeit in visa and approval procedures
We have concluded corresponding agreements under Art. 28 GDPR with all processors.
International data transfers
Because we place applicants from Vietnam with German employers, personal data is transferred to Vietnam. The principal recipient is CÔNG TY TNHH ALMA RECRUITING in Ho Chi Minh City, alongside language schools and educational partners on the ground. There is no adequacy decision from the European Commission for Vietnam.
These transfers take place on the basis of necessity for the performance of a contract under Art. 49 (1)(b) GDPR, your explicit consent under Art. 49 (1)(a) GDPR, or European Commission standard contractual clauses under Art. 46 (2)(c) GDPR, where applicable.
We apply additional technical and organisational measures to ensure an appropriate level of protection for international transfers. Since the changes to our website, no transfers to the USA for analytics or advertising purposes take place.
Retention periods
Application documents: up to 6 months after the process concludes, where no placement results. At your request we will additionally add you to our talent pool, for which we obtain your separate consent
Where a placement is successful: in line with contractual and statutory retention periods, in particular § 257 HGB (6 years) and § 147 AO (10 years)
Contact enquiries: 2 years after final handling
Server log files: 30 days
Audience measurement data: 12 months, thereafter anonymous reports only
Your rights
Right of access (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR)
Right to erasure (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to object (Art. 21 GDPR)
Right to withdraw consent (Art. 7 (3) GDPR)
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
A message to contact@almarecruiting.com is enough to exercise your rights. Doing so is free of charge and carries no disadvantage in any ongoing application or placement process.
Right to object under Art. 21 GDPR
Where we process data on the basis of legitimate interests under Art. 6 (1)(f) GDPR, you have the right to object at any time on grounds relating to your particular situation. We will then stop processing the data concerned, unless we can demonstrate compelling legitimate grounds that override your interests, or the processing serves to establish, exercise or defend legal claims.
You may object to cookieless audience measurement without giving reasons. The opt-out is available under Cookies and Tracking.
Supervisory authority
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59-61, 10555 Berlin
Phone: +49 30 13889-0
Email: mailbox@datenschutz-berlin.de
Website: www.datenschutz-berlin.de
Data security
We apply technical and organisational measures to protect your data against unauthorised access, disclosure, alteration or loss. These include end-to-end TLS encryption of the website, role-based access controls and regular reviews of our systems.
No method of transmitting data over the internet is completely secure. We therefore cannot guarantee absolute security.
Automated decision-making
We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR. All decisions about suitability and placement are made by people.
Changes to this Privacy Policy
We update this Privacy Policy when our processing activities or the legal requirements change. The current version is always available on this page, with the effective date shown above.
This is a translation provided for convenience. In case of any discrepancy, the German version applies.
