Draft. The final version will follow.
Privacy policy
Controller
The controller for the processing of personal data on this website is Regalis GbR, Graureiherweg 20, 59519 Möhnesee-Körbecke, Germany.
The company is represented by its partners, Doris von Sayn-Wittgenstein, Martin Schaefer. You can reach us by email at info@regalis-personal.com and by telephone on +49 (0) 2924 879 26 40.
We have not appointed a data protection officer. As matters stand today, we are not required to do so.
Hosting and server logs
This website is hosted by Cloudflare. The provider supplies the servers and the network and processes data on our behalf.
When a page is called up, technical log data arises. This includes the shortened or processed IP address, the date and time, the address requested, the referring page and details of browser and operating system.
This data serves the operation and security of the site and the defence against attacks. The legal basis is our legitimate interest under Article 6(1)(f) of the General Data Protection Regulation.
Log data is kept for a short time only and is then deleted or anonymised.
When you call up the start address, we forward you to one language version. The country of the request decides which one, and Cloudflare derives it from the IP address. The endpoint /api/geo returns only that country code and the matching language. On our servers nothing is stored and nothing is logged. Your choice of language is kept in the cookie named lang for one year.
Cookies and storage in your browser
We use technically necessary cookies only. We set no advertising or analytics cookies.
The cookie named lang stores your choice of language. It makes sure you see the website in the language you picked.
After you sign in we set a session cookie. It identifies your access and is invalidated when you sign out.
While you fill in a form, your browser stores your entries locally. This temporary copy never leaves your device. It is deleted once the form is sent and it also ends when you close the tab.
For the language hint your browser remembers the suggested language and your decision about it. That entry also lasts as long as the tab and ends when you close it. No cookie is set for it, and the entry is not transmitted.
If you have access to the administration area or to the partner area, your browser additionally remembers the chosen interface language and whether the filter bar is open. These two entries stay on the device until they are deleted. They hold nothing else and are not transmitted.
Contact form and email
If you write to us through the contact form, we process your name, email address, telephone number, subject and message.
We use these details to deal with your enquiry. The legal basis is Article 6(1)(b) of the General Data Protection Regulation for pre-contractual enquiries, otherwise point (f).
To fend off misuse we store a shortened check value instead of your IP address. It stands in for the address, but it is not an anonymous value: whoever holds our database could work the address out from it. We use it only to spot mass submissions.
Call back requests
Through the call back form we process your name, your company, your telephone number, the time window you prefer and, if you wish, your industry.
We use these details only to call you back and discuss your request. The legal basis is Article 6(1)(b) of the General Data Protection Regulation for pre-contractual enquiries, otherwise point (f).
To fend off misuse we store a shortened check value instead of your IP address. It stands in for the address, but it is not an anonymous value: whoever holds our database could work the address out from it. We use it only to spot mass submissions.
Internally we note who handled the call. Once your request is settled, we delete the entry.
Booking an intro call
On the intro call page you can book an appointment. For this we process your name, your telephone number and the time you picked.
The company, the email address and a line about the topic are optional. You can book without an email address as well.
We use these details to call you at the appointment and to prepare the conversation. The legal basis is Article 6(1)(b) of the General Data Protection Regulation for pre-contractual enquiries, otherwise point (f).
To fend off misuse we store a shortened check value instead of your IP address. It stands in for the address, but it is not an anonymous value: whoever holds our database could work the address out from it. We use it only to spot mass submissions.
If you gave an email address, we send a confirmation. It carries the appointment as a calendar file for your calendar program.
The calendar file names the start, the length and your contact person. You reach the file only through the link with your character string.
The cancellation link contains a random character string. Of that string we store a check value only.
Anyone without the link can neither see nor cancel your appointment. The reference number alone is not enough for that.
Internally we note the status of the appointment and, where needed, a short remark. Once the matter is settled, we delete the entry.
Requests from employers
In the employer questionnaire we collect details about the company, the contact person, the job, the terms and the accommodation.
The personal data is chiefly the contact details of the contact person. We process them in order to initiate and carry out the placement.
The legal basis is Article 6(1)(b) of the General Data Protection Regulation. In addition we rely on our legitimate interest in orderly processing.
Details about the job are passed on to candidates who come into consideration. Contact details of the contact person are released only after agreement with you.
Candidate profiles and documents
When you create a candidate profile, we process your details on person, residence, training, work experience, languages, driving licence, passport validity (optional) and job wishes.
We also process the documents you upload. These include your CV, school reports, certificates and, if you wish, a photo.
A short video introduction is voluntary. Only Regalis and the employers you are presented to can see the video. You can delete it in your profile at any time.
Once a placement case is opened, we also process proposed and confirmed interview times. The papers that belong to the case are included, such as the offer and the employment contract.
This data serves the review of your profile and the placement with employers. The legal basis is Article 6(1)(b) of the General Data Protection Regulation.
Please do not upload documents containing health data or other specially protected details unless we expressly ask you to.
Documents are stored separately from the remaining data. Access is limited to signed-in users with the necessary rights.
If Regalis or a local partner corrects your details, we record what was there before and after, who made the change and when. We delete this record together with your profile; if you ask for access to your data, we include it.
Pre-selection of matching positions
A fixed set of rules compares your profile with the employer's requirements. From that comparison it forms a ranking for our internal list of fitting profiles.
The comparison uses the occupational group, the industry, language skills, work experience, education, driving licence, willingness to move, preferred countries, salary expectation and the earliest possible start.
Every score is explained and can be traced in detail. We do not store it; it is worked out when the list is opened and is gone afterwards.
A person always decides whether you are presented to an employer. There is no automated decision within the meaning of Article 22 of the General Data Protection Regulation.
We also compare profiles with one another in order to spot duplicate entries of the same person and to find profiles similar to a given one. That comparison uses name, year of birth, phone number, email address and the details about the occupation.
The legal basis is Article 6(1)(b) of the General Data Protection Regulation.
Expiry dates of documents
For a document you can enter an expiry date, for example on a language certificate or a driving licence. This entry is optional.
We use the date for a reminder only. When a document expires soon, you see it in your profile, and we get in touch.
We do not read the content of your documents automatically for this. We use no text recognition.
The legal basis is Article 6(1)(b) of the General Data Protection Regulation. The date is deleted together with the document.
The CV print view
In your profile you can turn your details into a CV for printing. It is created in your browser only.
No data is transferred to us or to third parties in the process. We do not learn whether or when you use the view.
Whether you print the page or save it as a file is up to you in the print dialogue of your device. The file stays with you.
Quick application
The quick application is a short form for a first contact. We process your first and last name, your telephone number and your preferred way to be reached. We also process your country of residence, the job you want, the occupational group and your level of German.
The email address is optional here. If you give one, we also create an access for you and send you a sign-in link.
Without an email address no access is created. Your details are then handled only by Regalis and the responsible local partner.
The legal basis is Article 6(1)(b) of the General Data Protection Regulation. If you complete your profile later, the same purpose applies to those further details.
Internally we mark these entries as a quick application. That shows us which details are still missing for a placement.
Disclosure to employers
We pass your profile to employers only if you have expressly consented in the form. The legal basis is Article 6(1)(a) of the General Data Protection Regulation.
What is passed on are the details needed for the job and the documents you have provided.
You can withdraw your consent at any time with effect for the future. A short message to our email address is enough.
Candidate pool
With your consent we add your profile to our candidate pool. Companies in Germany that we have given access to search there for matching profiles.
The legal basis is your consent under Article 6 paragraph 1 letter a of the General Data Protection Regulation. Without consent your profile does not appear in the pool.
Shown are occupation, occupational group, industry, country and age range. Added to that are qualification level, qualifications, language skills and work experience. Also preferred regions, willingness to relocate, driving licence, the earliest start and your short text. Of your proofs we name the kind and the number only.
Name, address, contact details, year of birth, reference number and your files do not appear there. A company sees a reference only.
For your photo we need a second, separate consent. Without that consent we show no picture, even if one is on file. The picture is redrawn in your browser before the upload. Details about place and device fall away in the process.
Recipients are companies in Germany that we have given access to the pool. We grant that access one by one and by hand.
Every view is logged. These records name the company and the reference of the profile. We delete them after 180 days.
You can withdraw both consents at any time for the future, separately. In your profile you remove yourself with one click. After that companies can no longer see your profile.
Public candidate pool (anonymised short profile)
If you agree, we show an anonymised short profile of you on our website so that companies can see which skilled workers are available. You give your consent with a separate box when you register, through an institution that supports your application, or on the consent form (second box). It is voluntary; without it you do not appear in the public pool, and your application continues as before.
We show only: a reference number that does not identify you, occupation and occupational group, type and duration of training (without the name of the school), years of experience in bands, skills from a fixed list, German (level, with or without certificate), other languages, age group in ten-year bands, region (country; an area only if at least five profiles come from it), driving licence categories, month of availability and preferred sectors. We never show your name, photo, contact details, date of birth, place of residence, documents or former employers. We check every profile before it is published. Profile pages are excluded from search engines (noindex); the overview is not.
The legal basis is your consent under Art. 6(1)(a) GDPR. If a company asks about your profile, we reply with the profile and a draft agreement; a company receives your contact details only after a placement agreement has been signed and only for the purpose of placement.
You can withdraw your consent at any time without giving reasons, by e-mail to info@regalis-personal.com, through the institution or in your candidate account. We then remove the profile from the pool at once; after two working days at the latest it has also disappeared from all caches. The withdrawal does not affect the lawfulness of the display before it. Without a withdrawal we show the profile while your application with us is active; once it is completed, cancelled or inactive, we remove it. Profiles that have not been updated for six months are checked again.
Partners in the countries of origin
For approaching and supporting candidates we work with partners in the countries of origin, at present in Türkiye and in Uzbekistan. Candidate data is therefore transferred to countries outside the European Union. If further countries of origin are added, we update this statement.
There is no adequacy decision of the European Commission for Türkiye or for Uzbekistan. A level of protection equal to that in the European Union cannot be assured in every case.
The transfer is necessary to prepare and carry out the placement. We base it on Article 49(1)(b) of the General Data Protection Regulation and on contractual arrangements with our partners.
If you do not want this transfer, please tell us. In many cases a placement is then not possible.
Referral code and agents
Local partners and other people who recommend us receive a referral code from us. It sits in a personal link and appears in the form in the field named referral code.
We do not store the code on your device. We set no cookie for it and keep nothing in your browser. The code travels in the address of the page and stays visible in the form.
If you enter a valid code, we assign your registration or your request to that agent. What we store is the code and the time.
The purpose of the assignment is the commission statement with the agent. The legal basis is our legitimate interest under Article 6(1)(f) of the General Data Protection Regulation.
The agent learns that something has arrived through the code. The message to them names the reference number only. If a local partner with their own access looks after you, they see your profile as part of that task.
How often a personal link was opened is counted per day and per code. That figure holds no details about individual people. Every call is counted; we do not recognise that you opened the same link twice.
Instead of your IP address we briefly process a check value. It limits mass calls from the same line and is deleted after a short time. It is not an anonymous value: whoever holds our database could work the address out from it.
Of the agents themselves we process the name, contact details, country, code and the details for the statement. The basis is the agreement with the agent in question.
Candidates can also create a referral code in their own access and pass it on. We then store the code and its link to the profile. The check page shows no name for such a code.
The field is voluntary. Without a code we handle your details in just the same way.
Applying as a referral partner
Through the form for referral partners you can apply to become an agent. For this we process your name, your email address, your telephone number and your description of your contacts.
Naming a company is optional. We do not need names or contact details of third parties at this point.
We use these details to review the application and to talk to you. The legal basis is Article 6(1)(b) of the General Data Protection Regulation.
If we approve the application, we list you as an agent. The section on the referral code then applies in addition.
If you apply with an address we already know, no second entry is created. If we decline, we delete the application.
Campaign parameters in the address
Addresses from adverts, letters or posters sometimes carry additions such as utm_source or utm_campaign. These additions name the channel and the campaign, not you as a person.
When you send a form, we store them together with your enquiry. That shows us which channel leads to enquiries.
We store nothing on your device for this. The additions only travel in the address while you move around our website.
No user profile is built from them. We still set no advertising or analytics cookies.
The legal basis is our legitimate interest in advertising that pays for itself, under Article 6(1)(f) of the General Data Protection Regulation.
Short links
For letters, posters and business cards we use short addresses that start with /go/. Opening one redirects you to the matching page of this website.
We only count how often a short link was opened on a given day. That figure holds no details about individual people.
Every call is counted; we do not recognise that you opened the same short link twice. Instead of your IP address we briefly process a check value that limits mass calls from the same line. It is deleted after a short time and it is not an anonymous value. Nothing is placed on your device.
The legal basis is our legitimate interest in measuring the success of our advertising, under Article 6(1)(f) of the General Data Protection Regulation.
Anonymous notices of open jobs
On the candidate pages we show notices of open jobs. This happens only where the employer has agreed in the questionnaire.
Visible are then the occupational group, the industry, the federal state and the German level required. We also show the number of people wanted as a size band, the preferred start as a month and whether accommodation through the company is possible. The company name, the town, the pay and the reference number stay out of it.
The legal basis is the employer's consent under Article 6(1)(a) of the General Data Protection Regulation. It can be withdrawn at any time with effect for the future.
For employers we also state the number of candidates per occupational group. We do so only from a minimum number upwards, so that no conclusion about individual people is possible.
Introducing our local partners
We introduce our local partners on the website. This covers the name, photo, town, languages, industries and a short text.
This happens only with their written consent. The legal basis is Article 6(1)(a) of the General Data Protection Regulation.
Every partner can withdraw that consent at any time with effect for the future. We then take the introduction off the website.
Messages in the internal area and in the portals
Our partners, our staff and our local partners write messages to each other in the internal area. This keeps cases, documents and questions in one place.
We store the content of the message, the sign-in address and the display name of the sender, the time and who has read it.
For our own accounts the legal basis is our legitimate interest in orderly cooperation under Article 6(1)(f) of the General Data Protection Regulation.
For local partners the legal basis is the preparation and performance of the contract under Article 6(1)(b) of the General Data Protection Regulation.
The messages are stored encrypted in our database. We say openly what this protection does.
The messages are protected against anyone who reaches the database without holding the key. That covers a database export, a backup and outside access to it.
They are not protected against anyone with access to our Cloudflare account, because the key is kept there.
Nor are they protected against a member account that has been taken over: whoever can sign in reads the history.
Every internal account therefore needs its own password or a passkey.
The owner of Regalis can view all conversations. This serves supervision and traceability. The legal basis is our legitimate interest under Article 6(1)(f) of the General Data Protection Regulation. Every view is logged.
Local partners can hold one-to-one conversations with each other. The owner of Regalis can also view these conversations for traceability; every view is logged.
Candidates can write to their local partner and to Regalis in the candidate portal, and employers can write to Regalis in their portal. We store the messages encrypted. The owner of Regalis can view them for traceability; every view is logged. When we delete the profile or the account, we also delete the messages.
A deleted or changed message therefore remains available for 24 months in its previous version. After that we clear it away.
We keep the messages as long as the cooperation lasts. After that we delete them, unless a retention duty stands in the way.
You can object to processing based on legitimate interests. A message to info@regalis-personal.com is enough.
Records of consents and contracts
We keep signed papers in digital form. This covers consents of our local partners, consents of applicants and placement contracts.
We store the file itself, its kind, a title, the date on the paper, a note and the link to the person or the case.
The legal basis is our legal obligation under Article 6(1)(c) and the contract under Article 6(1)(b) of the General Data Protection Regulation.
Only our own accounts can look into these records. Local partners and employers never reach them, not even the paper that concerns them.
We keep the papers as long as we need the proof. If we delete a person, we also remove the papers about that person.
Profile of our local partners
Every local partner shapes their public page themselves. They write the texts, pick languages and industries and upload their photo.
We review the draft and release it. Without our release none of it appears online.
Name and photo appear in public only if we hold the written consent of the person. The legal basis is Article 6(1)(a) of the General Data Protection Regulation.
The consent can be withdrawn at any time with effect for the future. The page then goes offline.
A partner can also take the page offline without asking us.
Support in the partner area
This section applies to our local partners.
To provide support, the owner of Regalis can open your partner area on your behalf. Every change is then logged with the owner's name and the note “on behalf of”. The owner cannot write messages on your behalf while doing so.
Signing in without a password
For access to your profile or your requests we send a sign-in link by email. For the sign-in link we store your email address and a check value of the link. A passkey is possible as a second way.
To fend off misuse we store a shortened check value instead of your IP address. It is not an anonymous value: whoever holds our database could work the address out from it. When the link expires, that check value goes as well.
The link is valid for a short time only and works once. After you sign in we store the session with the time and the browser identifier.
This processing is needed for the secure operation of your access. The legal basis is Article 6(1)(b) and point (f) of the General Data Protection Regulation.
Signing in with a passkey
A passkey is an access that your device unlocks with a fingerprint, your face or a PIN. You need no password for it.
For this we store the public key, an identifier of the key, the method, a counter value and the transport paths. We also store the label you gave the device and the times of creation and of last use.
The secret part of the passkey stays in your device and never reaches us. Each sign-in creates a short task for your device. Of that task we keep only a check value for five minutes.
We keep these details until you delete the passkey or your access. The legal basis is Article 6(1)(b) and point (f) of the General Data Protection Regulation.
Signing in with a password
Accounts that Regalis hands out can additionally sign in with an email address and a password. That covers our own accounts and the accounts of the local partners, not the accounts of candidates and employers.
We never store the password itself in clear text. We store a random extra value and a check sum derived from it, the method used, the number of rounds and the times of creation and of the last change.
We count failed attempts. After ten failed attempts in a row the address is locked for half an hour, even for the correct password. On top of that the attempts per line are limited.
Sign-in, failed attempt, lock, change and removal of the password are recorded in our internal log, with the address and the time.
We keep these details for as long as the account exists. The legal basis is Article 6(1)(b) and point (f) of the General Data Protection Regulation.
Changing the address you sign in with
At your request we change the email address you sign in with. That helps after a change of provider or of employer.
After the change only the new address leads to your access. If the new address is already taken, we decline.
We end open sessions in the process. That way nobody keeps an open access through the old address.
We write to the old and to the new address. That makes it noticeable if the change did not come from you.
We record the step in our internal log. The legal basis is our legitimate interest in secure access, under Article 6(1)(f) of the General Data Protection Regulation.
Viewing and ending your sessions
Inside your access you can see your open sessions. We show the start, the last use and a rough note about the device.
The note about the device comes from the browser identification your browser sends anyway. It helps you spot a session that is not yours.
You can end all other sessions with one click. That is useful if you have lost a device.
The legal basis is our legitimate interest in secure access, under Article 6(1)(f) of the General Data Protection Regulation.
Sending email
For confirmations, sign-in links and internal notifications an email delivery service is planned. It will then process the recipient address and the content of the message on our behalf.
At the moment this delivery is not set up: no automatic messages go out. The website tells you so at the places where a confirmation would otherwise arrive.
Before delivery starts we will conclude a data processing agreement with the service. It may then not use the data for its own purposes.
Newsletter
For the newsletter we process your email address, the chosen language, the time of the sign-up and of the confirmation and a check value of your IP address.
Signing up takes two steps. Only the link in the confirmation email adds you to the list.
If the confirmation does not follow, we delete the sign-up by itself after two days, and the link stops working. Without a confirmation there is no consent.
The legal basis is your consent under Article 6(1)(a) of the General Data Protection Regulation.
Every message carries an unsubscribe link. After you unsubscribe we note the time and stop writing to you.
Protection against automated access
To protect the forms against misuse we may use a bot protection service from Cloudflare. It checks technical features of the access without building a user profile.
It is used only when this function is switched on. The legal basis is our legitimate interest in secure forms under Article 6(1)(f) of the General Data Protection Regulation.
Storage periods
We store personal data only as long as it is needed for the purpose in question.
Contact enquiries with no further course are deleted once the matter is settled. Candidate profiles stay stored for as long as you want a placement.
If we hear nothing from you, we review the profile after two years and delete it when there is no further interest. At your request we delete it sooner.
Data that we must keep because of statutory retention duties is excluded from deletion.
Recipients of the data
Within Regalis, only those people have access who need it for their task.
The hosting provider and the email delivery service act as processors. Employers and partners receive data only within the scope described.
Your rights
You have the right to information about the data stored about you. You can ask for incorrect data to be corrected.
You can ask for erasure or for the restriction of processing, unless retention duties stand in the way.
You have a right to data portability. You can withdraw consent at any time with effect for the future.
You can object to processing based on legitimate interests. For all such matters a message to info@regalis-personal.com is enough.
Right to complain
You can complain to a data protection supervisory authority. The authority at your place of residence or the one at our registered office is competent.
For Regalis this is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia.
Status of this policy
This version is a draft. The final version will follow.
We adapt the policy when our processing or the legal requirements change. Version: September 2026.