Data Privacy Policy pursuant to Art. 13, 14 GDPR  

In the following we would like to inform you about the types of data processed by SIXT and about the purposes of such data processing. We would also like to inform you about important legal aspects of data protection, such as your rights. 

 

Controller

The party responsible for processing your data (controller) is Sixt GmbH & Co. Autovermietung KG, Zugspitzstraße 1, 82049, DE 82049 Pullach (hereinafter also referred to as SIXT).

 

Contact information for data protection officer

If you have any questions regarding data protection, please address your query to the following email address: dataprotection@sixt.com. You can also contact our data protection officer by writ-ing to the following address: Sixt GmbH & Co. Autovermietung KG, Zugspitzstraße 1, 82049 Pullach, Germany 

 

Categories of personal data

The following categories of personal data can be processed by us in connection with our ser-vices: 

• Master data: These include, for example, a person’s first name, surname, address (pri-vate and/or business), date of birth.

• Communication data: These include, for example, a person’s telephone number, email address (private and/or business) fax number if applicable, as well as the content of communications (e.g., emails, letters, faxes).

• Educational and career data: These include, for example, information on a person’s schooling, further vocational training, including training in companies and at university, professional career.

• Voluntary data: These include data that you provide to us voluntarily without us explicitly having asked for such data.

• Special data categories: Nationality 

 

The purposes of data processing at SIXT

 

I. Application process

We process your master data, communication data and career data as well as the data you pro-vide to us voluntarily during the entire application process. We receive applications either on the basis of a job advertisement directly/via one of our partner portals or as an unsolicited applica-tion. We process the aforementioned data to manage, select and interview job applicants. We further process data for documentation purposes, to communicate with applicants, to bill or settle costs and to send out hiring letters, including, if applicable, terms of employment and to send refusal letters and, in connection with a refusal, to return or destroy application documents. 

 

 

II. Job portal

 

We also process the aforementioned data concerning you through our job portal at www.sixt.jobs. Whenever you use our job portal, you will transmit your application together with your master, communication and career data, which we will then process for the purposes stated in section I. 

In order to improve website performance and user experience, our web servers also store by default the IP address allocated to you by your internet service provider, the referral website that has led you to our site, the pages that you visit on our website, the date and duration of the visit and information about the device you use to access the platform (such as operating system and web browser). 

 

1. Use of cookies

SIXT uses cookies in order to analyse web traffic, optimise platform services and contents, measure the effectiveness of advertising campaigns and to promote the trust in the platform and its security features. Cookies are small text files that your internet browser stores on your com-puter. Most cookies are deleted from your hard disk after the end of the browser session (so-called session cookies). Other cookies remain on your computer and ensure that SIXT can rec-ognise your computer the next time you visit and can analyse the way you use the websites (so-called persistent cookies). You can prevent your computer from storing cookies by adjusting the settings of your web browser accordingly; you can instruct your browser to refuse new cookies, to warn you when new cookies are placed or to delete all the cookies previously received. More information on how to change your settings is available in the help function of your web browser or at www.allaboutcookies.org. Please note that some of the website features can only be used in connection with cookies. We therefore recommend that you allow cookies.

 

2. Use of Google Analytics

Our platform uses Google Analytics, a web analysis service offered by Google Inc., 1600 Amphi-theatre Parkway Mountain View, CA 94043, USA (“Google”). Here, we use the “trackPageview” feature, meaning that only page views and events are transmitted so SIXT can see which pages are accessed and what actions were performed on those pages. No personal data whatsoever is transmitted to Google. The information generated on how you use the platform is anonymised and transmitted to a Google server in the USA, where it is stored. Google will use this infor-mation in order to evaluate how you use the platform, to compile reports on platform activity on behalf of SIXT and to provide other services relating to app activity and internet usage. Google may also transfer this information to third parties where this is permissible by law, or where such third parties process the information on Google's behalf. Google will not associate your IP ad-dress with any other data held by Google. For more detailed information in this regard, please go to www.google.com/intl/policies/privacy (general information on Google Analytics and data pro-tection).

We only use Google Analytics when IP anonymisation is activated. This means that Google will shorten your IP address within the member states of the European Union or other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP ad-dress be transmitted to a Google server in the US and shortened there. The user’s IP address as transmitted by the user’s browser is not associated with other Google data.

You may refuse the use of such cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use all the features on this web-site.

You can further prevent Google Analytics from analysing data on this website by downloading and installing the browser plugin available from: tools.google.com/dlpage/gaoptout.

You can deactivate Google Analytics’ data analysis on this website by directly going to the follow-ing link:

Deactivate Google Analytics

 

3. Use of Google Tag Manager

The platform uses the Google Tag Manager. This service helps to manage website tags all on one user interface. The Google Tag Manager only implements tags, meaning that no cookies are used and no personal data are recorded. The Google Tag Manager triggers other tags that might, in turn, record data, but the Google Tag Manager does not access these data. Any deacti-vation in the settings at domain or cookie level remains in place for all tracking tags, provided they were implemented with the Google Tag Manager.

 

4. Use of Google Maps

For the users of our Android and BlackBerry App (and our SIXT website): This app uses Google Maps APIs. Google’s terms of service are available at www.google.com/policies/terms. Google’s privacy policy is available at www.google.com/intl/policies/privacy. We use Google Maps in order to display the matching map section for the surrounding area. The transfer of location data to Google invariably takes place in anonymised form; no further information is provided to Google. Google cannot identify you only because you use the “my location” feature in Google Maps. Mobile devices are generally anonymous. Google does not record any personal data, such as your name or telephone number, when you use Google Maps on your mobile phone. Therefore, Google does not know the identity of smartphone owners or users.

 

5. Use of Remarketing or “Custom Audience” Features and DoubleClick of Google Inc.

We use the Remarketing or “custom audience” and the DoubleClick features of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) on this website. These features help us to address you with customised marketing by displaying personalised, interest-based advertisements whenever you visit other websites within the Google Display Network. In order to analyse how the website is used, which is a prerequisite of displaying interest-based advertisements, Google uses so-called cookies. Cookies are small text files with a number code that Google stores in the website user’s browsers. This number code is used to record the visits to the website and anonymous data on how the website is used. The personal data of the web-site users is not stored. Whenever you visit another website within the Google Display Network, you will see advertisements that are highly likely to take account of previously searched products or topics. You can permanently deactivate Google’s use of cookies by downloading and installing the plugin that is provided under the following link: https://www.google.com/settings/ads/plugin. Alternatively, you can also deactivate the use of cookies by third parties by going to the deactiva-tion page of the Network Advertising Initiative at http://www.networkadvertising.org/choices/ and by following the opt-out information provided on that site. For more information on Google Re-marketing and the Google privacy policy, please go to http://www.google.com/privacy/ads/.

 

6. Facebook

The website http://www.sixt.jobs contains so-called Social Plugins (e.g. “Like” buttons) of the social network Facebook, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). Whenever you interact with the plugins, for instance by clicking a “Like” button, you–as a registered Facebook user–can automatically leave a note in your Face-book profile to inform your network that you like the contents of the website you visited.

In this respect, our websites enable continuous exchange of information with Facebook. Please note that data is exchanged and linked as soon as you access our website and does not need to be triggered by activating the social plugin/“Like” button and does not depend on you being logged into Facebook. If you do not wish Facebook to prepare a personal geo location profile, you need to log out of Facebook. It does not suffice to just shut down the Facebook site. Please go to http://www.facebook.com/policy.php for more information on the purpose and scope of data collection and the further processing and use of the data by Facebook as well as your relat-ed rights and setting options to protect your privacy.

 

7. Use of Facebook Remarketing

On our career site, we use the “Custom Audiences” remarketing feature of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). This feature helps us address web-site users with customised marketing by displaying personalised, interest-based Facebook ads whenever they visit the social network Facebook. In order to implement the feature, the Face-book remarketing tag is placed on the operator’s website.

This tag establishes a direct connection to the Facebook servers when the website is accessed. The tag discloses to the Facebook servers which of our websites you visited. Facebook allo-cates this information to your personal Facebook account. More information on how Facebook collects and uses data, on your related rights and how to protect your privacy is available in the data privacy policy of Facebook at https://www.facebook.com/about/privacy/. If you do not want Facebook to directly attribute the collected data to your Facebook user account, you can use the following link to deactivate this remarketing feature “Custom Audiences”: https://www.facebook.com/ads/preferences. You need to be logged on to Facebook to do so.

 

The legal basis for data processing at SIXT

Legal basis for the above processing 

Art. 6 (1) point (a) of the General Data Protection Regulation (GDPR): Pursuant to this provision, the processing of your personal data is lawful if and to the extent that you have given your con-sent to such processing. 

Art. 6 (1) point b) GDPR: Pursuant to this provision, the processing of your personal data is law-ful if such processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract (like in the application pro-cess). 

Art. 6 (1) point f) GDPR: Pursuant to this provision, the processing of your personal data is law-ful if such processing is necessary for the purposes of the legitimate interests pursued by the controller, i.e., SIXT, or by a third party, except where such interests are overridden by the in-terests or fundamental rights and freedoms of the data subject, i.e., you yourself. This also in-cludes the processing of personal data for marketing purposes. 

 

Legitimate interest, to the extent that Art. 6 (1) point f) GDPR applies to the type of processing concerned

Our legitimate interest in processing the personal data concerning you lie in the fact that we want to improve our services and increase the attractiveness of our offering. 

 

Transfer of data by SIXT

Categories of recipients of your data

We only transfer your data to service providers whom we work within the scope of managing job applicants. Provided that this is admissible under data protection law, we may share the data concerning you with affiliated companies within the Group.

 

Transfer to third countries

The transfer of your data to a third country is based on an adequacy decision by the European Commission. If no adequacy decision by the European Commission exists for the respective third country, then the transfer to that third country will take place subject to appropriate safe-guards as per Art. 46 (2) GDPR. We can also transfer your data to a third country subject to the conditions set forth in Art. 49 GDPR. You can request copies of the aforementioned safeguards from SIXT by writing to the address specified above (see → Controller). Third countries are countries outside the European Economic Area. The European Economic Area comprises all countries of the European Union as well as the countries of the so-called European Free Trade Association, which are Norway, Iceland and Liechtenstein.

 

Storage duration/criteria for storage duration

SIXT stores your personal data until they are no longer necessary in relation to the purposes for which they were collected or otherwise processed (see → Purposes of data processing at SIXT). Where SIXT is under legal obligation to store personal data, it will store personal data for the preservation period stipulated by law. The preservation period for commercial documents, which include bookkeeping documents and accounting records (including invoices), is 10 years (Section 257 (4) of the German Commercial Code). During this period, your data may be subject to restricted use within day-to-day operations if its processing serves no further purposes. 

 

Your rights

Rights pursuant to Art. 15 – 18 and 20 GDPR

You have the right to, at reasonable intervals, obtain information about your personal data under storage (Art. 15 GDPR). The information you are entitled to includes information about whether or not SIXT has stored personal data concerning you, about the categories of personal data concerned, and about the purposes of the processing. Upon request, SIXT will provide you with a copy of the personal data that are processed. 

You also have the right to obtain from SIXT the rectification of inaccurate personal data concern-ing you (Art. 16 GDPR). 

You furthermore have the right to obtain from SIXT the erasure of personal data concerning you (Art. 17 GDPR). We are under obligation to erase personal data in certain circumstances, includ-ing if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, if you withdraw the consent on which the processing is based, and if the personal data have been unlawfully processed. 

Under certain circumstances, you have the right to have the processing of your personal data restricted (Art. 18 DSGVO). These include circumstances in which you contest the accuracy of your personal data and we then have to verify such accuracy. In such cases, we must refrain from further processing your personal data, with the exception of storage, until the matter has been clarified. 

Should you opt to change to a competitor of SIXT, you have the right either to receive, in a ma-chine-readable format, the data that you provided to us based on your consent or on a contrac-tual agreement with us, or to have us transmit, also in a machine-readable format, such data to a third party of your choice (Right to data portability, Art. 20 GDPR). 

 

No contractual or legal obligations to provide data/consequences of failure to provide data

You are not contractually or legally obliged to provide us with your personal data. Please note, however, that you cannot enter into a contract for our services if we are not permitted to collect and process the data as required for the purposes specified in the foregoing (see → The pur-poses of data processing at SIXT) 

 

Right to object pursuant to Art. 21 GDPR

If the processing of your data by SIXT is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (Art. 6 (1) point e) GDPR) or if it is necessary in the legitimate interests of SIXT, then you have the right to object at any time, on grounds relating to your particular situation, to the processing of your data. SIXT will then end the processing, unless we can present compelling legitimate grounds for such processing that supersede the grounds for end-ing the processing.

You may object, at any time and without restriction, to the processing of your personal data for purposes of direct advertising. 

 

Right to withdraw consent at any time

If data processing at SIXT is based on your consent, then you have the right to, at any time, withdraw the consent you granted. The withdrawal of consent shall not affect the lawfulness of processing between the time consent was granted and the time it was revoked. 

 

Right to lodge a complaint with the supervisory authority

You have the right to lodge complaints with the supervisory authority responsible for SIXT. Please send such complaints to the following address: 

Bayerisches Landesamt für Datenschutzaufsicht 

Promenade 27 (Schloss)

91522 Ansbach

Germany