Privacy Policy

Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Introduction

GoAusbildung, operated by Qogent Global ("we," "us," "our"), is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and marketplace platform (collectively, the "Platform").

GoAusbildung operates as a two-sided marketplace platform connecting international students with German employers offering Ausbildung opportunities. This Privacy Policy covers how we process your data both as a platform operator and how your data is shared with employers when you use our marketplace services.

By accessing or using GoAusbildung, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this policy, please discontinue use of our Platform immediately.

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us, including but not limited to:

• Full name, date of birth, nationality, and gender
• Contact information (email address, phone number, mailing address)
• Educational background (academic qualifications, transcripts, certificates)
• Professional information (work experience, skills, career goals)
• Language proficiency levels (German language test results)
• Identification documents (passport, visa documents, ID cards)
• Financial information (payment card details, billing address)
• Application materials (CVs, cover letters, motivation letters, video introductions)
• Profile photo and any uploaded documents

2.2 Marketplace-Specific Information

As a marketplace platform, we also collect:

• Profile Data: Professional headline, bio, preferred sectors, city preferences, availability dates
• Profile Visibility Settings: Your chosen privacy controls for profile sections (public/private settings)
• Profile Strength Data: Calculated score (0-100) based on profile completeness across 8 categories
• Job Application Data: Jobs you apply to, application timestamps, application status, withdrawal records
• Communication Data: Messages exchanged with employers through our platform
• Employer Interaction Data: Profile views by employers, application views, employer responses
• Search and Browse History: Jobs you view, search queries, filter preferences
• Video Introductions: Recorded video profiles visible to employers (if you create them)

2.3 Usage Data

We automatically collect certain information when you access our Platform:

• IP address, browser type, and operating system
• Device identifiers and mobile network information
• Pages visited, time spent on pages, and click patterns
• Referral sources and search queries
• Application usage data and feature interactions
• Performance data and error reports
• Job posting views and application funnel analytics

2.4 Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. For detailed information, please refer to our Cookie Policy.

2.5 Third-Party Information

We may receive information about you from third parties, including:

• Educational institutions and training providers
• Language assessment services (TestDaF, Goethe-Institut)
• German embassy and visa processing centers
• Verification services for document authentication
• Social media platforms (if you connect your accounts)
• Payment processors and financial institutions

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Marketplace Operations

• Job Discovery: Showing you relevant Ausbildung job postings from employers
• Application Processing: Submitting your applications to employers and tracking application status
• Profile Management: Creating, maintaining, and displaying your professional profile to employers
• Matching and Recommendations: Recommending jobs based on your profile, preferences, and qualifications
• Employer Recommendations: Showing your profile to employers based on job requirements and your profile strength
• Communication Facilitation: Enabling direct messaging between you and employers
• Profile Strength Scoring: Calculating your profile completeness score (0-100) to help you optimize your profile
• Verification Status: Displaying employer verification tiers to help you assess employer credibility

3.2 Service Provision

• Processing and managing your Ausbildung applications
• Matching you with suitable training programs and employers
• Facilitating communication with training providers and employers
• Providing personalized career guidance tools
• Delivering German language learning resources and assessments
• Managing your account and user profile
• Processing payments and managing subscriptions

3.3 Communication

• Sending application updates and status notifications
• Alerting you when employers view your profile or respond to applications
• Providing customer support and responding to inquiries
• Sharing important service announcements and policy updates
• Sending job recommendations and marketplace updates (with consent)
• Conducting surveys and collecting feedback

3.4 Legal and Compliance

• Complying with visa and immigration requirements
• Verifying your identity and eligibility for Ausbildung programs
• Preventing fraud and ensuring platform security
• Enforcing our Terms of Service and other agreements
• Responding to legal requests and protecting our rights
• Maintaining records as required by law

3.5 Analytics and Improvement

• Analyzing usage patterns to improve our Platform and marketplace algorithms
• Developing new features and services
• Conducting research and generating statistics (using anonymized data)
• Personalizing your experience and job recommendations
• Testing and optimizing platform performance
• Improving job-student matching accuracy

4. Legal Basis for Processing (GDPR Compliance)

Under the General Data Protection Regulation (GDPR), we process your personal data based on:

• Contract Performance: Processing necessary to provide our marketplace services to you (job applications, profile management, employer communication)
• Legal Obligation: Compliance with visa, immigration, and regulatory requirements
• Legitimate Interest: Improving our services, preventing fraud, ensuring security, and operating our marketplace effectively
• Consent: Marketing communications, optional data processing, and profile visibility settings (which you may withdraw at any time)

5. How We Share Your Information

IMPORTANT: Please read this section carefully to understand how your data is shared with employers.

5.1 Sharing with Employers (Marketplace Data Sharing)

When you apply for a job on our marketplace, we share your application materials and profile information with the employer for that specific job posting. The data shared includes:

• Your full name and contact information
• Profile information (headline, bio, photo, education, experience, skills, languages)
• Application materials (CV, cover letter, video introduction if created)
• Uploaded documents and certificates you've attached to your application
• German language proficiency level and assessment results
• Preferred cities, sectors, and availability dates
• Profile strength score (to indicate profile completeness)
• Application timestamp and any messages you send to the employer

When your profile is set to "Public" visibility, verified employers can:

• Search and browse your public profile
• View the profile sections you've chosen to make visible (based on your privacy settings)
• See your profile strength score and availability status
• Contact you through the Platform messaging system

When your profile is set to "Private" visibility, employers can only:

• View your profile after you apply to their specific job postings
• See information you explicitly include in your job applications

5.2 Granular Profile Visibility Controls

You have control over what employers see through our privacy settings. You can individually show/hide:

• Work experience details
• Skills and proficiencies
• Visa status and work authorization
• Availability date
• Preferred cities and locations
• Professional bio
• Headline and tagline

Important: Even with sections hidden, when you apply to a job, the employer will receive your full application materials (CV, cover letter, documents) as submitted.

5.3 What Employers Can Do With Your Data

Once shared with an employer, they can:

• Review and store: Your application materials for their hiring process
• Download: CVs, cover letters, and documents you submitted
• Contact you: Through our Platform messaging system or direct email (if you provided it)
• Share internally: With their HR team and hiring managers for evaluation
• Retain: Your application for the duration of their hiring process and legal retention requirements

Important: Once employers receive your application data, they become independent data controllers for that information. Their use of your data is governed by their own privacy policies and applicable employment laws. We are not responsible for how employers use, store, or protect your data after it's been shared through the application process.

5.4 Employer Data Processing Responsibilities

Employers on our platform are required to:

• Comply with GDPR and applicable data protection laws
• Use student data only for legitimate hiring purposes
• Maintain appropriate security measures for applicant data
• Respect student data rights (access, deletion, correction)
• Not share student data with third parties for marketing purposes

If you have concerns about how an employer is handling your data, you should contact them directly. We can assist in facilitating communication but cannot control employer data practices.

5.5 Training Providers and Educational Partners

We may share your application materials and educational background with German training providers when you apply for Ausbildung positions through our platform. This is essential for facilitating your application process.

5.6 Service Providers

We engage third-party service providers to support our operations, including:

• Cloud hosting and data storage providers (Supabase, Google Cloud Storage)
• Payment processors and financial services (Stripe)
• Email and communication platforms (Resend)
• Analytics and tracking tools (PostHog, Google Analytics)
• AI services (Google Gemini, OpenAI, OpenRouter, ElevenLabs)
• Document verification services
• Customer support platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify. They act as data processors on our behalf.

5.7 Government Authorities

We may share your information with German immigration authorities, embassies, and visa processing centers as required for visa applications and compliance with immigration laws.

5.8 Legal Requirements

We may disclose your information when required to:

• Comply with legal obligations, court orders, or government requests
• Enforce our Terms of Service and other agreements
• Protect the rights, property, or safety of GoAusbildung, our users, or the public
• Investigate and prevent fraud, security issues, or illegal activities

5.9 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity. We will notify you of any such change and provide options regarding your information.

6. Marketplace-Specific Data Processing

6.1 Profile Strength Scoring System

We calculate a profile strength score (0-100) based on the completeness of your profile across 8 categories:

• Basic Information (15 points)
• Legal & Availability (15 points)
• Professional Profile (20 points)
• Education (15 points)
• Languages (15 points)
• Experience (10 points)
• Skills (5 points)
• Documents & Verification (5 points)

This score is used to:

• Help you identify areas to improve your profile
• Show employers the completeness of your profile
• Recommend you to employers based on profile quality
• Provide "quick wins" suggestions for profile optimization

6.2 Job Matching Algorithms

We use algorithms to match students with suitable job postings based on:

• Your profile information (sectors, skills, education, experience)
• German language proficiency level
• Location preferences and availability dates
• Profile strength score
• Job posting requirements and preferences
• Previous application patterns and success rates

6.3 Employer Verification Data

We process employer data to assign verification tiers (Unverified, Verified, Trusted):

• Company registration documents
• Business licenses and tax information
• Contact person verification
• Company profile completeness
• Historical hiring data and response rates

This information is used solely to help students assess employer credibility. Verification status does not constitute our endorsement.

6.4 Communication and Messaging Data

Messages sent through our Platform between students and employers are:

• Stored on our servers for message delivery and history
• Accessible to both parties in the conversation
• Monitored for security, fraud prevention, and Terms of Service compliance
• Not used for marketing purposes
• Retained for 3 years for dispute resolution and compliance

6.5 Application Tracking and Analytics

We track your job application journey, including:

• Jobs viewed vs. jobs applied to (conversion rate)
• Application submission timestamps
• Application status updates (submitted, under review, shortlisted, interview, offer, accepted/rejected)
• Employer response times and rates
• Application withdrawal patterns

This data is used to:

• Provide you with application insights and recommendations
• Improve our matching algorithms
• Generate anonymized marketplace statistics
• Identify and address platform issues

6.6 Automated Translation Data

Job postings are automatically translated from German to English using AI services (Google Gemini 2.5 Flash). We process:

• Original German job posting text (created by employers)
• English translations (AI-generated for students)
• Translation metadata (timestamp, model used, accuracy indicators)

Important: Automated translations may contain errors. The German version is the authoritative version. We recommend verifying important details directly with employers.

7. International Data Transfers

As a global marketplace platform, your personal information may be transferred to and processed in countries outside your country of residence, including the United Arab Emirates, India, Germany, and the European Union.

We ensure that all international data transfers comply with applicable data protection laws, including GDPR. We implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions for countries with equivalent data protection standards
• Binding Corporate Rules and Privacy Shield frameworks (where applicable)
• Appropriate technical and organizational measures to ensure data security

Specific Data Processing Locations:

• Database: Supabase (Asia-Pacific South region - Singapore)
• File Storage: Google Cloud Storage (Germany and EU servers)
• Analytics: PostHog (US/EU regions), Google Analytics (Global)
• AI Processing: Google Gemini (Global), OpenAI (US), OpenRouter (US)
• Email Services: Resend (US/EU)
• Payment Processing: Stripe (Global with EU data residency)

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specific retention periods include:

• Account Data: Retained while your account is active and for 2 years after account closure
• Profile Information: Retained while your account is active; deleted upon account deletion request
• Job Application Records: Retained for 7 years from application submission (for visa and legal compliance purposes)
• Application Materials (CVs, Documents): Retained for 3 years or until you request deletion
• Communication Records: Retained for 3 years for quality assurance and dispute resolution
• Payment Information: Retained for 7 years as required by financial regulations
• Marketing Data: Retained until you withdraw consent or for 2 years of inactivity
• Analytics Data: Retained for 2 years in anonymized form
• Security Logs: Retained for 1 year for fraud prevention and security purposes

Important Note on Employer Data: Data shared with employers through job applications is retained by employers according to their own data retention policies. We cannot control or guarantee deletion of data once it has been shared with employers. You must contact employers directly to request deletion of data they hold.

After the retention period expires, we will securely delete or anonymize your personal information in accordance with our data retention policy and applicable laws.

9. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

9.1 GDPR Rights (European Union)

• Right to Access: Request copies of your personal data we hold
• Right to Rectification: Correct inaccurate or incomplete information
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restriction: Limit how we use your information
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent for data processing at any time
• Right to Lodge a Complaint: File a complaint with your local data protection authority

9.2 Marketplace-Specific Rights

As a marketplace user, you also have the right to:

• Control Profile Visibility: Set your profile to public or private at any time
• Granular Privacy Controls: Show/hide individual profile sections from employer view
• Withdraw Applications: Withdraw job applications (though employers may retain previously shared data)
• Export Application Data: Download all your job applications and communication history
• Delete Account: Request complete account deletion (see limitations below)

9.3 Limitations on Data Deletion

Please note the following limitations:

• Employer-Held Data: We cannot delete data that has been shared with employers through job applications. You must contact employers directly to request deletion of data they hold.
• Legal Retention: We must retain certain data for legal compliance (e.g., financial records for 7 years, application records for visa compliance)
• Anonymized Data: We may retain anonymized, non-identifiable data for analytics and research purposes
• Active Applications: Applications cannot be deleted while they are actively being reviewed by employers (you can withdraw them first)

9.4 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: privacy@goausbildung.com
• Subject line: "Data Privacy Request"
• Include: Your full name, registered email address, and specific request

We will respond to your request within 30 days (or as required by applicable law). We may require identity verification before processing your request to protect your data security.

9.5 Profile Privacy Settings

You can manage your profile visibility settings at any time in your account dashboard:

• Navigate to Settings → Privacy
• Choose between Public or Private profile visibility
• Toggle individual profile section visibility (10 granular controls)
• Review what employers can see based on your settings

9.6 Marketing Communications

You can opt out of marketing emails by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your communication preferences in your account settings
• Contacting us at hello@goausbildung.com

Please note that even if you opt out of marketing communications, we will still send you transactional and service-related messages (application updates, employer messages, account notifications, security alerts).

10. Data Security

We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

• SSL/TLS encryption for all data transmission (HTTPS)
• AES-256 encryption for data at rest
• Row-Level Security (RLS) policies on all database tables
• Regular security audits and vulnerability assessments
• Multi-factor authentication options for account protection
• Access controls and authentication mechanisms
• Employee training on data protection and confidentiality
• Incident response and breach notification procedures
• Regular backups and disaster recovery plans
• Rate limiting and DDoS protection
• Automated security monitoring and alerting

Account Security: You are responsible for maintaining the confidentiality of your account credentials. We recommend:

• Using a strong, unique password
• Not sharing your account credentials with anyone
• Logging out of public or shared computers
• Enabling multi-factor authentication if available
• Notifying us immediately of any unauthorized access

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information using commercially reasonable means, we cannot guarantee absolute security.

11. Children's Privacy

Our services are intended for users aged 18 and above. We do not knowingly collect personal information from individuals under 18 years of age without verifiable parental consent. If you are under 18, please do not use our Platform or provide any personal information without parental permission.

If we become aware that we have collected personal information from a child under 18 without proper parental consent, we will take steps to delete such information immediately. If you believe we have collected information from a child, please contact us at privacy@goausbildung.com.

12. Third-Party Links and Services

Our Platform may contain links to third-party websites, services, or applications that are not owned or controlled by GoAusbildung. This Privacy Policy does not apply to those third-party services.

Third-party services include:

• External job boards or recruitment platforms
• Language testing services (TestDaF, Goethe-Institut)
• Social media platforms
• Payment processors
• Educational institutions and training providers

We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party services before providing your personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email at your registered email address
• Display a prominent notice on our Platform
• Provide a reasonable period (at least 30 days) for you to review the changes
• Obtain your consent if required by applicable law
• Maintain an archive of previous policy versions

Your continued use of our Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated policy, you must discontinue use of our services and may request account deletion.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

15. EU Representative

For users in the European Union, we have appointed a GDPR representative as required by Article 27 of the GDPR. You may contact our EU representative for any data protection inquiries:

Email: eu-representative@goausbildung.com

16. Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with your local data protection supervisory authority if you believe we have violated your privacy rights under GDPR.

However, we encourage you to contact us first at privacy@goausbildung.com so we can address your concerns directly and attempt to resolve any issues before you involve the supervisory authority.