Privacy Policy

The following notes give an overview of what happens to your personal data when you visit our website or use our services. Personal data is any data that can be used to identify you personally.

Controller

GTB Global Talent Bridge GmbH, Volker Hollmichel, Donaustr. 44, 12043 Berlin, Germany. Email: volker.hollmichel@wandel.com

How do we collect your data?

Your data is collected when you actively provide it to us (for example via a contact form, a Meta ad or in a conversation with our AI agent Sophia). In addition, technical data is recorded automatically when you visit our website.

Your rights

You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data, as well as the right to rectification, erasure or restriction of processing. Where you have given consent, you can withdraw it at any time. You also have the right to lodge a complaint with the competent data protection supervisory authority.

Wandel uses an AI-based voice agent called Sophia to get in touch with candidates. In line with the requirements of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689) and the GDPR, this section informs you about the nature, purpose and scope of this AI-based processing.

What is Sophia?

Sophia is an automated AI conversation system operated on the ElevenLabs platform. Sophia conducts initial phone conversations with candidates, asks qualifying questions and, based on the answers, creates a candidate profile for our recruiting processes.

Disclosure obligation under the EU AI Act

Under Article 50 of the EU AI Act, we are obliged to inform you when you are interacting with an AI system. Sophia will expressly tell you at the start of every conversation that she is an AI agent. An interaction with Sophia only takes place if you have consented to being contacted beforehand.

Purpose of the AI-based processing

Sophia is used to:

• conduct initial conversations with candidates efficiently and at scale;
• record qualifying information (for example professional experience, availability, salary expectations);
• create candidate profiles automatically from the content of the conversation;
• inform candidates about open positions and initiate the next steps.

Legal basis

Personal data in the context of AI-based communication is processed on the basis of your explicit consent under Article 6(1)(a) GDPR, which you gave beforehand via our Meta ad.

Risk classification

The Sophia system is classified as a limited-risk AI system within the meaning of the EU AI Act. No automated decisions with legal effect are made on the basis of AI processing alone. The selection and assessment of candidates always rests with human Wandel staff.

3.1 Meta (Facebook/Instagram) – ads and lead capture

Candidates usually first get in touch with us via ads on Meta platforms (Facebook, Instagram). In doing so, we collect the contact details you provide (name, phone number, email address) and your explicit consent to further contact by Wandel, including contact by our AI agent Sophia.

Legal basis: Article 6(1)(a) GDPR (consent). Third-party provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland. Meta's privacy policy is available at https://www.facebook.com/privacy/policy/.

3.2 Phone contact by the AI agent Sophia

Once your consent has been received, Sophia may contact you by phone. At the start of the conversation, Sophia will introduce herself as Wandel's AI agent.

Call recording and transcription: Phone conversations with Sophia are recorded and transcribed automatically. The transcript is used solely to create your candidate profile and for internal quality assurance. Audio recordings are deleted after transcription and quality review, and at the latest after 30 days. Transcripts and the candidate profiles created from them are stored for the duration of the application process, but no longer than 12 months, unless statutory retention obligations require otherwise.

Legal basis: Article 6(1)(a) GDPR (consent to recording); Article 6(1)(b) GDPR (pre-contractual measures). Third-party provider: ElevenLabs, Inc. (AI voice system). Data may be processed in third countries; appropriate safeguards under Article 46 GDPR are in place.

3.3 WhatsApp communication

In some cases we first contact you via WhatsApp to arrange a suitable time for the conversation with Sophia. Your phone number and the content of the messages are processed in the process.

Legal basis: Article 6(1)(a) GDPR (consent). Third-party provider: WhatsApp Ireland Ltd. (Meta Platforms). Data may be processed in third countries.

Based on the information collected in conversations with Sophia, we automatically create a candidate profile. This profile contains details of your professional experience, qualifications, availability and other information relevant to the recruiting process.

The candidate profile is used exclusively for recruitment purposes and is only shared with companies for which we are actively searching for candidates and in which you have expressed interest. It is not shared with third parties for other purposes without your explicit consent.

Legal basis: Article 6(1)(a) GDPR (consent); Article 6(1)(b) GDPR (pre-contractual measures).

5.1 Access, rectification and erasure

You have the right at any time to obtain information free of charge about the personal data we hold about you, to request its rectification or to demand its erasure. To have your data deleted, please contact volker.hollmichel@wandel.com. We will comply with your request within 30 days.

5.2 Withdrawal of consent

Where processing is based on your consent, you may withdraw it at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out up to that point. To withdraw consent, please contact volker.hollmichel@wandel.com or tell our AI agent directly during the conversation.

5.3 Objection (Article 21 GDPR)

Where data is processed on the basis of Article 6(1)(e) or (f) GDPR, you have the right to object at any time on grounds relating to your particular situation. Where your data is processed for direct marketing, you have the right to object at any time.

5.4 Right to data portability

You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit it to another controller.

We use service providers based outside the EU/EEA (in particular ElevenLabs, Inc. and Meta Platforms). Transfers are based on the European Commission's standard contractual clauses under Article 46(2)(c) GDPR or other appropriate safeguards. Please note that third countries may not guarantee a level of data protection comparable to that of the EU.

This website is hosted by Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg (AWS). As AWS may also process data in the USA, the transfer is based on standard contractual clauses under Article 46(2)(c) GDPR. A data processing agreement under Article 28 GDPR is in place. Processing is based on Article 6(1)(f) GDPR. Further information: https://aws.amazon.com/privacy/.

Our website uses cookies. Technically necessary cookies are stored on the basis of Art. 6(1)(f) GDPR. For all other cookies (e.g. analytics cookies) we obtain your consent in accordance with Art. 6(1)(a) GDPR and Section 25(1) TDDDG. You can configure your browser to reject cookies or to delete them when the browser is closed.

Consent management

On your first visit, a consent banner asks whether you allow analytics cookies. Your choice is stored in a cookie so that we do not have to ask again on every visit. The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR. You can change or withdraw your consent at any time with effect for the future via the “Cookie settings” link in the footer.

Google Tag Manager

We use Google Tag Manager provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager is how we manage the analytics tools on our website. It is only loaded once you have agreed to statistics cookies. In doing so, your IP address is transmitted to Google in order to deliver the script. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG).

Google Analytics 4

With your consent we use Google Analytics 4 provided by Google Ireland Limited to understand how our website is used, for example which pages are viewed and which links and buttons are clicked. For this, Google Analytics sets cookies (e.g. “_ga”) and processes information about your device, browser, approximate region, pages viewed and interactions. Google Analytics 4 does not store IP addresses. Data may be transferred to Google LLC in the USA. Google is certified under the EU-US Data Privacy Framework, for which an adequacy decision of the European Commission of 10 July 2023 exists. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). The data is deleted after 14 months. More information: https://policies.google.com/privacy

Personal data is only stored for as long as is necessary for the respective processing purpose or as required by statutory retention obligations. The following periods apply:

• Audio recordings of conversations with Sophia: up to 30 days after recording
• Conversation transcripts and candidate profiles: up to 12 months after the end of the application process
• Contact details from Meta campaigns: up to 6 months after first contact if no active process exists
• Server logs (website): 7 days

For all questions about data protection, for access, rectification and erasure requests and for withdrawing your consent, please contact:

GTB Global Talent Bridge GmbH, Volker Hollmichel, Donaustr. 44, 12043 Berlin, Germany. Email: volker.hollmichel@wandel.com, phone: +49 (0) 15257542028