JobLeads GmbH Privacy Policy

1. Contracting Entity/Data Controller Switch

The data controller is JobLeads GmbH, Brandstwiete 4, 20457 Hamburg, Germany (JobLeads DE). If you purchase a paid subscription and your habitual residence or billing address is in the United States, then your checkout and subscription billing data is processed by JobLeads US, Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA (JobLeads US). JobLeads GmbH always remains your data controller and has concluded the standard contractual clauses with JobLeads US with regards to international data transfers to the USA.

2. Introduction and Our Philosophy

JobLeads GmbH ("we," "us," or "our") operates the www.jobleads.com website (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

At JobLeads, we understand data protection not merely as a regulatory obligation but as an integral part of our business strategy and a central element of a trusting customer relationship. We are convinced that transparent and secure data processing represents a decisive competitive advantage and enables you to have the best possible user experience. Our goal is to present you with the most relevant job offers and to make the application process as efficient as possible through comprehensive data and the use of modern technologies, and guide you throughout your long-term career development as a whole – always in compliance with the highest data protection standards. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

3. Types of Data Collected

3.1. Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Resume/CV information
Phone number
Address, state, province, ZIP/postal code, city

3.2. Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

The collection of this data is carried out to ensure the technical functionality and security of our Service, as well as for statistical analysis to improve our offerings. To the extent that this Usage Data allows conclusions about your person (e.g., your IP address), we process it based on our legitimate interest (Art. 6 (1) lit. f) GDPR). For further analyses that utilize nonessential cookies or similar technologies (e.g., by our analytics partners), we obtain your consent via our Cookie Consent Management System.

Cookies and Usage Data
IP address
User agent information
User ID (when applicable)

4. Use of Data and Legal Basis

JobLeads GmbH uses the collected data for various purposes, based on the following legal grounds according to the General Data Protection Regulation (GDPR):

4.1 To provide and maintain our Service, to provide customer support, and to facilitate the application process with employers

This processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into such a contract (Art. 6 (1) lit. b) GDPR). This includes the use of your email address, name, resume/CV information, phone number, and address data for job matching and recommendations and for long-term career development.

4.2 To notify you about changes to our Service and to allow you to participate in interactive features of our Service when you choose to do so

These processing activities also serve the performance of a contract (Art. 6 (1) lit. b) GDPR) or are based on your consent (Art. 6 (1) lit. a) GDPR), where such consent is legally required for the specific feature.

4.3 To gather analytical or valuable information so that we can improve our Service, to monitor the usage of our Service, and to detect, prevent, and address technical issues

These processing activities are based on our legitimate interests (Art. 6 (1) lit. f) GDPR) to optimize our Service and ensure its security. If nonessential cookies or tracking technologies are used for these purposes (e.g., by our analytics partners), processing will only occur based on your consent (Art. 6 (1) lit. a) GDPR in conjunction with Section 25 (1) Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz [TDDDG]), which you can provide via our Cookie Consent Management System.

4.4 To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or inquired about

This processing is based on our legitimate interest (Art. 6 (1) lit. f) GDPR) in direct marketing to existing customers, in accordance with Section 7 (3) of the German Act Against Unfair Competition (UWG), or based on your explicit consent (Art. 6 (1) lit. a) GDPR) where legally required. You have the right to object to this processing at any time, for example, by using the unsubscribe link in the respective email or by contacting us via the contact details provided in this Privacy Policy.

4.5 To provide and maintain our Service, personalized career development insights, and industry updates relevant to your professional field, and to facilitate the application process with employers

This processing is necessary to deliver comprehensive career services beyond immediate job placement and for the performance of our contract with you or to take steps at your request prior to entering into such a contract (Art. 6 (1) lit. b) GDPR). This includes the use of your data to match you with relevant job opportunities, to facilitate the application process, and to improve our job recommendation algorithms. The processing of your data for these purposes continues as long as you actively use our Service. We consider a user to be active if they, for example, interact with the Service, open our emails, or respond to our notifications, thereby indicating an ongoing interest in our personalized career support.

4.6 To improve our job recommendation algorithms

This occurs based on the performance of a contract (Art. 6 (1) lit. b) GDPR) to provide the core functionality of our Service in suggesting relevant job opportunities to you.

You are not subject to any automated decision-making within the meaning of Art. 22 GDPR.

5. Data Processing Tools, Cookies, and Third-Party Partners

We use various third-party services and tools to process your data. The following partners receive and process your data when you use our services. Those listed under “Marketing and Advertising Partners” and “Analytics and User Experience Partners” require cookie consent and are subject to the preferences set in our Cookie Consent Management System. It may also include “Conversion Tracking,” where we track which interactions on our website have led to specific actions (e.g., registration, application). Your consent via the Cookie Consent Management System is also required for this, as these measurements are carried out via cookies or similar technologies that allow tracking of your behavior.

5.1. Marketing and Advertising Partners

These partners assist us with marketing and advertising activities. The use of their services, which may involve the setting of cookies or similar technologies for tracking and targeting purposes, requires your explicit consent. This consent is managed through our Cookie Consent Management System.

For certain analytical data that serves exclusively for the technical optimization and stability improvement of our Service and does not enable comprehensive profiling, we rely on our legitimate interest according to Art. 6 (1) lit. f) GDPR to continuously ensure the functionality and security of our platform.

Please note that some of these partners, such as “Co-registration services (Lensa),” may also receive your Personal Data for their own marketing purposes, provided you have given us your explicit and specific consent for such data transfer. This separate consent will be obtained prior to any such transfer, clearly indicating to whom your data will be transferred and for what specific marketing purposes. Without this specific consent, no Personal Data will be shared with these partners for their independent marketing activities.

Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Appcast, Inc., 10 Water Street, Suite 150, Lebanon, NH 03766, USA
GoldenBee, 888 7th Avenue, 9th Floor, New York, NY 10106, USA
Co-registration services (Lensa), 2180 Sand Hill Rd, Menlo Park, CA 94025, USA
Cheetah (Marigold), 1295 Bandana Blvd N, St. Paul, MN 55108, USA

5.2. Analytics and User Experience Partners

Mixpanel, Inc., One Front Street, 28th Floor, San Francisco, CA 94111, USA
Typeform, Carrer de Bac de Roda, 163, 08018 Barcelona, Spain
Google Tag Manager, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville, St Julian’s STJ 3141, Malta
Optimizely, Inc., 119 5th Ave, New York, NY 10003, USA

5.3. AI and Machine Learning Partners

We use AI and machine learning partners to continuously improve the quality of our Service, especially our job-matching algorithms, to support the creation of resumes and cover letters, and to optimize communication. The data transmitted is limited to the necessary minimum and is, wherever possible without harming the quality of the Service provided to you, pseudonymized or anonymized. The partners process the data exclusively on our behalf to provide these specific services and are subject to strict confidentiality obligations.

OpenAI, LLC, 3180 18th Street, San Francisco, CA 94110, USA
Anthropic, PBC, 8000 Capwell Drive, Suite 100, Oakland, CA 94621, USA
Cohere Inc., 555 Richmond Street West Suite 900, Toronto, ON M5V 3B1, Canada
Langfuse GmbH, Urbanstraße 71, 10967 Berlin, Germany
Quadrant Information Security, 6817 Southpoint Parkway, Suite 2201, Jacksonville, FL 32216, USA
Google (Gemini), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

6. Data Retention and Transfer

6.1. Retention of Data

JobLeads GmbH will retain your Personal Data only for as long as is necessary to fulfill the purposes for which we collected it. Given that our Service is designed to provide ongoing career support and continuous product improvements, which can be likened to a long-term career coaching relationship, we will retain your Personal Data for the entire duration of our contractual relationship with you unless you request its deletion.

We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, such as tax and commercial law retention periods, to resolve disputes, and to enforce our legal agreements and policies.

We also retain Usage Data for internal analytical purposes to enhance the security and functionality of our Service. This data is generally retained for a shorter period, except when it is used to strengthen our Service or when we are legally obligated to retain it for longer periods.

6.2. Transfer and Storage of Data

Your information, including Personal Data, is stored primarily on servers located within the European Union. We use Amazon Web Services (AWS) with server locations in the EU as our primary infrastructure provider to ensure your data remains within EU borders, in compliance with GDPR requirements.

In some cases, your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside Germany and choose to provide information to us, please note that we transfer the data, including Personal Data, to Germany and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

For partners located outside the EU, data transfers are secured through Standard Contractual Clauses or EU adequacy decisions such as the EU-U.S. Data Privacy Framework. To ensure the security of your data, in addition to contractual guarantees, we regularly conduct thorough Transfer Impact Assessments (TIAs). In doing so, we examine the legal frameworks and technical safeguards in the recipient country to ensure that your data receives an adequate level of protection equivalent to that of the GDPR.

JobLeads will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Where JobLeads US, Inc. acts as the Seller of Record, JobLeads US processes your data as a data processor on behalf of JobLeads DE. Transfers from JobLeads GmbH in Germany to JobLeads US, Inc. in the USA are made under the EU Standard Contractual Clauses.

7. Service Providers and Disclosure of Data

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are not obligated to disclose or use it for any other purpose.

JobLeads may disclose your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of JobLeads
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of users of the Service or the public
Protect against legal liability

8. Your Data Protection Rights under GDPR

As the data subject, you have the following rights with regard to your Personal Data. To exercise these rights, please contact us using the contact details below:

Right of access according to Art. 15 GDPR:

You have a right of access to information about your Personal Data processed by us. This includes the mandatory information set out in Art. 15 GDPR.

Right to rectification according to Art. 16 GDPR:

You have the right to have inaccurate Personal Data corrected or amended without undue delay.

Right to erasure according to Art. 17 GDPR:

You have the right to request the deletion of your Personal Data if one of the reasons mentioned in Art. 17 GDPR takes precedence, in particular if there is no longer a legal basis for the processing.

Right to restriction of processing according to Art. 18 GDPR:

Instead of having your data deleted, you also have the right to demand that the processing of your Personal Data be restricted, if one of the reasons mentioned in Art. 18 GDPR prevails, especially if any restrictive action is triggered by your request.

Right to data portability according to Art. 20 GDPR:

You have the right to receive all personal data you have provided to us in a structured, up-to-date, and machine-readable format, and to transmit this data to another controller without obstruction from us.

Right to withdraw consent:

You have the right to withdraw your consent at any time, should JobLeads GmbH have processed your Personal Data based on your explicit consent. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise your right to withdraw consent, you can:

Adjust your preferences in our Cookie Consent Management System for data processing activities that rely on cookies and similar technologies (e.g., for marketing, advertising, and analytics purposes).
Contact us directly via the contact details provided below (e.g., email to datenschutz@jobleads.com) for other processing activities where you have given consent.
Use any opt-out options provided in specific communications, such as unsubscribe links in marketing emails.

Right to lodge a complaint with a supervisory authority according to Art. 77 GDPR:

According to Art. 77 GDPR, you have the right to file a complaint with the appropriate authority in your jurisdiction.

Please note that we may ask you to verify your identity before responding to such requests.

9. Payment Handling

Adyen N.V, Simon Carmiggeltstraat 6-50, 1011 DJ Amsterdam, Netherlands, processes our payment transactions. We collect your payment data and transmit it to Adyen for further processing. These activities are limited to payment processing and consequently also fall under the legal basis of contract fulfillment.

Adyen’s processing of your data is governed by its privacy policy, which is available at: https://www.adyen.com/policies-and-disclaimer/privacy-policy.

10. Links to Other Websites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Prior to the change taking effect, we will notify via email and/or a prominent notice on our Service, and we will update the “last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Applying for Positions at JobLeads

The website https://www.jobleads.company/ offers you the option to apply directly to positions at JobLeads. In order to manage applicants, we require your contact data (first and last name, telephone number, email address), information on your education, details about your professional career, and skills. In some cases, information on your further education and training (resume and cover letter) is also required.

We process your data within the application process primarily based on Art. 6 (1) lit. b) GDPR for the performance of precontractual measures and the fulfillment of the application contract. Additionally, Section 26 (1) Federal Data Protection Act (Bundesdatenschutzgesetz [BDSG]) applies, which regulates data processing for employment purposes. If necessary, processing may also be based on your consent pursuant to Art. 6 (1) lit. a) GDPR or for compliance with legal obligations pursuant to Art. 6 (1) lit. c) GDPR.

The data of applicants who have not been offered employment shall be deleted after six months.

The data you submit as part of your application will be transmitted using TLS encryption and stored in a database. The database will henceforth be operated by our Service Provider Personio GmbH, Riesstraße 25, 80992 Munich, Germany. We have concluded an agreement for contract data processing with Personio GmbH in accordance with Art. 28 GDPR.

13. Social Media Pages

We operate pages on Facebook, LinkedIn, X (Twitter), and Xing. These networks process your Personal Data to create user profiles and store cookies on your device. For detailed information on their data processing practices, please refer to their privacy policies:

Facebook: https://www.facebook.com/about/privacy/
LinkedIn: https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv
X: https://x.com/en/privacy
Xing: https://privacy.xing.com/en

When you interact with our social media pages, we only have access to public profile information. You can adjust what information is publicly visible in your account settings. We may use data from chat functions to respond to your inquiries. Social networks provide us with anonymous statistics about followers, reach, advertising performance, and demographics. These help us improve our content. We cannot link these statistics to individual users.

13.1. Facebook and LinkedIn Joint Controller Information

For our Facebook page, we are joint controllers with Facebook Ireland Ltd. (4 Grand Canal Square, Dublin 2, Ireland). For our LinkedIn page, we are joint controllers with LinkedIn Ireland Unlimited Company (Wilton Place, Dublin 2, Ireland).

The legal basis for processing your data on these platforms is our legitimate interest (Art. 6 (1) lit. f) GDPR) in providing information and communicating with interested parties. Data may be processed outside Europe by the respective US parent companies under EU-U.S. Data Privacy Framework protections. You can object to data processing at any time by contacting Facebook or LinkedIn directly. You can also adjust your browser settings to manage cookies.

14. Data Protection Officer

You can contact our Data Protection Officer at:

Email: datenschutz@jobleads.com
Address: Lukas Wagner LL.M., HK2 Comtection GmbH, Hausvogteiplatz 11A, 10117 Berlin

15. Contact Us

Primary Controller (all users by default, and for all browsing/platform use):
JobLeads GmbH
Brandstwiete 4, 20457 Hamburg, Germany
Email: membership@jobleads.com

Group company as processor (paid subscriptions where JobLeads US, Inc. is the Seller of Record – see “Contracting Entity/Seller of Record”):
JobLeads US, Inc.
1111B S Governors Ave STE 28351, Dover DE, 19904, USA
Email: imprint-us@jobleads.com

Version: August 2025