Data Protection

Data Protection Privacy Policy

The protection of your personal information, e.g. when you visit our website, when you contact us and when you enter into a contractual relationship with us regarding our services is of the utmost importance to us.

Below you will find information on what data we collect when you visit our homepage, when you fill out our web forms or use other functions on our website, and how and for what purpose we process this data. We collect, process and use personal information only in accordance with the following principles and in compliance with the applicable legal provisions, in particular the GDPR (General Data Protection Regulation).

Questions about privacy in connection with our website and the services offered through our website can be directed to us using the contact information in section 1, directly below.

1. Responsible party and data protection officer

This privacy information applies to the data being processed by:

Pinguin AG

Address:                        Hauptstraße 8, D-10827 Berlin


Phone:                            +49 (0)30 30 36 63 366

(hereinafter also referred as “Pinguin” or “we”).

You can contact data protection officer here:


2. Collection and storage of personal data and the nature and intended use

  • 2.1 While visiting our website

    When you visit our website, the browser used on your end device automatically transmits information to the server of our platform. This information is temporarily stored in a so-called log file. The following information is recorded without requir-ing any action on your part:

    The above-listed data will be processed by us for the following purposes:

    The data is stored in server log files in a format that allows the identification of the persons concerned, for a maximum period of 14 days, unless a security-relevant event occurs (e.g., a DDoS attack). When a security-relevant event occurs, server log files are stored until the security-relevant event has been eliminated and fully re-solved.

    The legal basis for data processing is our legitimate interest, which results from the above listed purposes for data collection. Under no circumstances will we use the data collected for the purpose of drawing conclusions about your person. The provision of this data is not required by law or contract or necessary for the conclu-sion of a contract. You are not obligated to provide us with any personal infor-mation. If you choose to not provide such information, it will not be possible to ac-cess our website.

    Furthermore, we use cookies and analytical services when you visit our website. You can find further information on this below.

    • the IP address of the requesting end device,
    • the date and time of access,
    • the name and URL of the retrieved file,
    • the website from which access is made (so-called referrer URL),
    • the browser used and, if necessary, the operating system of your computer and the name of your Internet access provider.
    • to ensure a smooth connection of the website,
    • to guarantee a user-friendly experience of our website,
    • to evaluate system safety and stability,
    • for other administrative purposes.
  • 2.2 When contacting us

    We offer you the option of contacting us via a contact form which you can find by clicking on "We are Hiring/Apply now" at the top of our website. You will need to provide us with your name, e-mail address, telephone number and information about your education, language-level and work-experience. Your birthday and fur-ther application documents may be provided/uploaded voluntarily.

    You also can send us an Email to using your preferred Email server. When doing so, it is necessary to provide your name, a valid Email address and a description of your problem so that we know who the request comes from and can appropriately address it. Additional information e.g. as in the application form may be provided voluntarily.

    In the event that your enquiry concerns a contract to which you are a contractual party, or concerns the implementation of pre-contractual actions, the data processing will be carried out in accordance with Article 6 (1)(b) GDPR. For all other inquiries, data processing for the purpose of establishing contact is based on a balance of interests (Article 6 (1)(f) GDPR). In this case our legitimate interest is the processing of your request.  

    If you are interested in our job-offers we store your information in order to find a suitable offer for you or to be able to send you such offers in the future based on the interests you have expressed.

           You can find more information about applicant data protection at Pinguin here.

    The personal information collected by us in the course of contacting you will be deleted in accordance with the legal requirements after the inquiry you have made has been completed.

3. Information Disclosure

  • 3.1 In General

    We have entered into data processing agreements with technical service providers which we use for the operation and maintenance of our website, as well as with the providers of tracking and web analysis tools listed in sections 2, 5 and 6 of this privacy policy, who process the data on our behalf for the purposes of user analysis and statistical evaluation. Service providers who process personal information on our behalf outside of the European Union (so-called third countries) will only be used if an adequacy decision by the European Commission or suitable or adequate safeguards are in place for this third country with respect to the recipient. Beyond that, we do not transfer or share your personal information with third parties, ex-cept for the purposes listed below. We will only disclose your personal information to third parties if the following is applicable:

    • you have provided your explicit consent,
    • the disclosure of information is necessary to protect our legitimate interests or the legitimate interests of a third party and there is no reason to assume that you have an interest worthy of protection in not disclosing your data,
    • in the event that there is a legal obligation for disclosure, and
    • a disclosure is legally permissible and required for the processing of contractual relationships.
  • 3.2 Data transfer to third countries

    Service providers who process personal data on our behalf outside the Euro-pean Union (so-called third countries) will only be used without your consent in accordance with Article 49 (1)(a) GDPR if an adequacy decision by the Eu-ropean Commission or suitable guarantees have been obtained from the re-cipient for this third country. If you consent to the transfer of your personal data to third countries, we will transfer your data to the USA in connection with the following services without suitable data protection guarantees:

          Google Analytics, Google Tag Manager, Google Dynamic Remarketing, Google Marketing Platform (Google Ireland Limited / Google LLC)

    The transfer of personal data to third countries that do not offer an adequate level of data protection (in particular to the USA) carries the risk that the data may be processed for the purposes of third parties without your knowledge and that the data may not be protected against access by third parties. In par-ticular, there may be governmental access in the USA, for example, within the scope of intelligence investigation powers according to Section 702 FISA and Executive Order 12 333.

4. Cookies

Please be advised that when you visit our website, we store information on your end device using cookies (please see our Cookie-Policy. Cookies are small files that are transferred to your browser from an Internet server and stored on your hard drive. Information is stored in the cookie, which occurs in connection with the respective end device. This does not mean, that we obtain direct knowledge of your identity. We use the term "cookies" in these guidelines for all files that collect data in this way.

The use of cookies enables us to make the use of our services more enjoyable for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted when you leave our website. In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our website the next time, we will automatically recognize that you have already visited our website, and which entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to record the use of our website statistically and to evaluate this for the purpose of optimizing our offer for you (see section 5 "Analysis Tools"). These cookies enable us to automatically recognize that you have already visited us when you return to our website. We also use cookies for retargeting purposes (see section 6 "Marketing"). These cookies are automatically deleted after a specific time period.

When you visit our website, we ask for your consent to the use of all cookies that are not absolutely necessary for the provision of our website (Article 6 (1)(a) GDPR). You can also visit our website without accepting cookies. Our Cookie-Policy provides detailed information about the cookies we use and you will be able to manage your cookie settings and choose for which cookies you give us your consent.

If you do not want your end device to be recognized during your next website visit, you can refuse the use of cookies by changing the settings in your browser to "reject cookies". You will find the respective procedure in the operating instructions of your browser. If you refuse the use of cookies, you may experience limitations in the use of some areas of our website.

5. Analytical Tools

The tracking procedures listed below and used by us are carried out on the basis of the consent you have provided voluntarily. With the tracking procedures we use, we want to ensure that our platform is designed to meet your needs and is continuously optimized. Furthermore, we want to ensure that we can provide you with personalized recommendations based on your user behavior. We also use the tracking procedures to record the use of our website statistically and to optimize our offers for you. The provision of this information is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obligated to provide this personal information.

The respective data processing purposes and categories of data can be found in the information on the corresponding tracking tools.

Use of Google Analytics in combination with anonymization function

For the purpose of designing our platform to meet the needs of our customers and continuously optimizing it, we use Google Analytics, a web analytics service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) ("Google"). In this context, pseudonymized user profiles are created and cookies are used.

The information generated by the cookie about your use of this platform, such as

  • browser type/version,
  • the operating system used,
  • referrer URL (the previously visited page),
  • host name of the accessing computer (IP address),
  • time of the server request,

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the platform, compile reports on the platform activities and provide additional services connected with the use of the platform and the internet for the purposes of market research and the design of this platform in line with the requirements. This information may also be transferred to third parties if this is required by law or if third parties process this information on our behalf. Under no circumstances will your IP address be merged with other Google data. IP addresses are made anonymous so that an assignment is not possible (IP masking). This means that your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before.

You can prevent the installation of cookies by means of a corresponding setting in the browser software; however, we would like to point out that not all functions of this platform can be used to their full extent in this case. You can also prevent the collection of data generated by the cookie and related to your use of the platform (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on.

Further information on data protection in connection with Google Analytics can be found on Google Analytics Help.

We also use Google Analytics to evaluate data from AdWords and the double-click cookie for statistical purposes. You can deactivate this in the Ads Preferences Manager if you prefer.

  • 5.1 Google Tag Manager

    We use Google Tag Manager, an application that allows us to manage website tags from a single interface. Tags are small pieces of code on our website that are used, to measure visitor traffic and behavior, measure the impact of online adver-tising and social channels, use remarketing and targeting, and test and optimize our website among other things. The Tag Manager tool itself (which implements the tags) is a cookie-free domain. The tool triggers other tags that can collect data on their own. Google Tag Manager does not access this data.

  • 5.2 Google Dynamic Remarketing

    We use the Google Dynamic Remarketing tag (embedded in all pages of our website) as part of Google Ads. Google Dynamic Remarketing allows us to not only display interest-based ads on other websites and apps for past visitors to our website, but also to display ads that include specific products and services that users have viewed on our website. For this purpose, we have created a feed with details of the services we wish to display as ads (Remarketing List). The Google Ads Product Referral Tool extracts individual services from this feed and determines the best variety of services for each ad based on the popularity and what visitors have viewed on our site.

    The information collected and used for remarketing includes details such as the URL and referral URL for the website that triggers a tag hit and any resulting remarketing list memberships. Remarketing data is used to match users with Google accounts, add users to remarketing lists, generate similar audiences, serve dynamic ads, and ensure that Google Ads remarketing campaigns comply with Google's policies. In addition, reports including user information are available in our Google Ads account. Google may also use remarketing data to optimize the performance of our campaign, identify other audiences relevant to us, and gain specific insight into the composition of our remarketing lists. Google also uses aggregated and anonymous remarketing data for the benefit of all advertisers, including, for example, to improve similar audiences.

    Google will not share this information with third parties or other advertisers, and Google will not use our remarketing lists to promote its own products.

    You can opt-out of Google's use of device identifiers by visiting Google's ad settings (click here). Alternatively, you can disable cookies in your browser or device settings.

    Additional information on data protection in connection with Google Dynamic Remarketing can be found here and here.

  • 5.3 Google Marketing Platform

    We also use the Google Marketing Platform (formerly "Google DoubleClick" and "Google Analytics 360 Suite"), a unified advertising and analysis platform. For advertising and analysis purposes, cookies are used to display ads that are relevant to you, to improve reports on campaign performance or to prevent a user from being shown ads more than once.  

    Google uses a cookie ID to record which ads are played in which browser and can prevent them from being shown more than once. In addition, Google can use cookie IDs to record so-called conversions, i.e. whether a user has seen an advertisement and later visits the advertiser's website to make a purchase. If you are registered with one of Google's services, Google can assign the website visit to your user account.

    In addition, the Google Marketing Platform enables us to understand whether you perform certain actions on our website after you have viewed or clicked on one of our ads on Google (conversion tracking) or another platform ("floodlight"). In this way, we are able to display personalized advertising to you in the future.

    If you do not want your end device to be recognized on your next visit, you can refuse the use of cookies by not giving us your consent or by changing the settings in your browser to "block cookies". You will find the respective procedure in the operating instructions of your browser. 

    Information on how to deactivate personalized advertising by Google can be found here or when you visit the deactivation page of the Network Advertising Initiative. However, if you choose to decline the use of cookies, you may be limited in your use of some areas of our website.

    More information about the Google Marketing Platform, can be found here and information about the use of cookies within the Google Marketing Platform, can be found here. For more information please visit the Network Advertising Initiative (NAI).

  • 5.4 Indeed Conversion Tracker Snippet

    Our website uses the Indeed Conversion Tracker Snippet by Indeed Ireland Operations Limited 124 St. Stephen's Green, Dublin 2, Ireland ("Indeed"). In order to analyze how applicants use this site, certain usage data provided by your browser is collected and analyzed by Indeed. Indeed uses cookies to collect this usage data. In addition, the IP address assigned to your device at that time and a browser-specific identifier are transmitted. The IP address is used solely for session identification and geolocation (as far as city level).

    The Conversion Tracker Snippet counts how many visitors actually applied for a job via an Indeed website. We have no knowledge of whether a specific application was submitted to Indeed as a result of a job advertisement.

    Please visit Indeed Privacy Policy for additional information.

6. Security

On our website we use the common TLS (Transport Layer Security) procedure in connection with an encryption level that corresponds to the respective state-of-the-art technology. The actual level of encryption also depends on the browser you use. You can determine whether an individual page of our website is being transmitted in encrypted form by the key or lock symbol in the lower status bar of your browser.

We have also taken technical and administrative security precautions to protect your personal information against loss, destruction, manipulation and unauthorized access. All our employees as well as service providers working for us are subject to the valid data protection laws. Our security precautions are subject to a continuous improvement process and our data protection declarations are constantly revised. Please make sure that you have the latest version.

7. Rights of the individuals affected

You have the following rights:

  • to request information about your personal information processed by us;
  • to immediately demand the correction of incorrect or incomplete personal information stored by us;
  • to request the deletion of your personal information stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims (if we have published your personal information, we are obligated, taking into account the available technology and implementation costs, to take reasonable measures, including technical measures, to inform the data controllers who process the personal data that you have requested the deletion of all links or of copies or replications of such personal information)
  • to demand the restriction of the processing of your personal information if the accuracy of such information is disputed by you, if the processing is unlawful but you refuse to have it deleted and we no longer need the information, but in the case when you need the data for the assertion, exercise or defense of legal claims or have filed an objection to the processing
  • to receive the personal information that you have provided to us in a structured, common and machine-readable format or to request its transfer to another responsible party;
  • to revoke your consent towards us at any time. As a result, we are no longer allowed to continue the data processing that was based on this consent in the future and
  • to complain to a regulatory agency. As a rule, you can contact the supervisory authority at your usual place of residence or work or at our registered office.

8. Right to Appeal

If your personal information is processed on the basis of legitimate interests, you have the right to object to the processing of your personal data for reasons relating to your particular situation or direct marketing. In the latter case, you have a general right to appeal, which will be implemented by us without indicating any specific circumstances.

If you wish to make use of your right to cancel or to appeal you can simply send an eMail to

9. Applicant Data Protection

If you want to become a member of the Pinguin team, your personal data transmitted in the context of this will of course be subject to special data protection regulations. You can find out how we handle these data here.

10. Privacy Policy Updates

This privacy policy represents the current status.

Due to the further development of our website and offers above or due to changed legal or official requirements, it may become necessary to amend this privacy statement. The current privacy statement can be accessed and printed out at any time by clicking here.

Updated: 25.02.2021