Privacy Policy

ENGLISHJOBS Employer Dashboard


1. Introduction

This Privacy Policy explains how Ninibe GmbH ("we", "us", "our") collects, uses, shares, and protects personal data when you use the ENGLISHJOBS Employer Dashboard at englishjobs.com (the "Dashboard"). The Dashboard is the employer-facing platform through which direct employers and hiring agencies create, manage, and publish job postings across our European market websites.

This policy applies exclusively to employer and Dashboard users. A separate privacy policy governs the processing of job seekers' personal data on our market websites.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable national data-protection legislation.

2. Data Controller

Ninibe GmbH
Travemünder Allee 4
23568 Lübeck, Germany

Registered at Amtsgericht Lübeck, HRB 25076 HL
VAT ID: DE 341 629 390
Managing Director: Victor Ruiz

For privacy-related inquiries, contact us at: [email protected]

3. Personal Data We Collect

3.1 Account Registration Data

When you create an account or are invited to join an organization, we collect:

  • User ID and internal account identifiers
  • Full name
  • Email address
  • Password (stored in hashed form only — we never store plaintext passwords)
  • Role within the organization account (Admin, Editor, or Viewer)

3.2 Business and Organization Data

To set up and maintain your employer profile, we collect:

  • Company or business name
  • Billing email address
  • Business address (country, region, city, postal code, street)
  • VAT identification number
  • Company size category
  • Company website URL and LinkedIn URL
  • Company description
  • Company logo (uploaded image file)
  • Contact email address (if provided in the employer profile)
  • Contact phone number

3.3 Billing and Payment Data

For subscription management and invoicing, we process:

  • Selected subscription plan
  • Billing cycle and payment history
  • Payment method details (processed and stored by our merchant of record, Paddle — we do not store card numbers or bank details directly)
  • Invoice records
  • Paddle identifiers (customer ID, subscription ID, transaction IDs)
  • Billing details used for tax and VAT handling (business entity and address identifiers stored by Paddle)

3.4 Content and Activity Data

When you use the Dashboard, we collect data related to your activity:

  • Job postings you create (titles, descriptions, salary information, and other posting fields)
  • Application details included in job posts (application URL, application email, application instructions)
  • Employer profiles and location data
  • Team member invitations sent
  • Activity logs recording actions performed (creation, edits, deletions) with timestamps
  • Search queries within the Dashboard
  • Export and syndication settings (e.g., whether "allow export" is enabled for a job post)

3.5 Hiring Agency and Represented Employer Data

If you operate as a hiring agency, we additionally collect:

  • Represented employer identifiers and profile data managed under your agency account
  • Relationship metadata (which agency account manages which represented employer profiles)
  • Evidence of authorization to publish on behalf of a represented employer, where requested for compliance or dispute handling

3.6 Technical and Usage Data

When you access the Dashboard, our systems automatically collect:

  • IP address
  • Browser type and version
  • Device information
  • Pages visited within the Dashboard and time spent
  • Referring URLs
  • User-Agent string
  • Session data and authentication tokens/cookies
  • Server-side session records (session ID, expiry time, IP address, user agent)
  • Security and abuse-prevention signals (login attempts, lockout events, CSRF tokens, WAF and rate-limiting data)

3.7 Support and Sales Communication Data

When you contact us, we collect:

  • Support requests submitted via the Dashboard (subject, message content, and related context such as account and employer identifiers)
  • Enterprise and sales inquiries (email address, company or agency name, phone number, number of clients/employers, message content)

3.8 Browser Storage (LocalStorage and SessionStorage)

To improve your experience, the Dashboard may store data locally in your browser:

  • Draft data for job posts (including form fields such as descriptions and application details) to prevent accidental loss
  • UI preferences and convenience flags (sidebar state, onboarding selections, dismissed notifications)

This data remains on your device and is not transmitted to our servers unless you explicitly submit it (e.g., by publishing a job post).

4. How We Use Your Personal Data

4.1 Service Provision

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR)

We process your data to:

  • Create and authenticate your account
  • Manage your subscription and process billing
  • Publish your job postings across our European market websites
  • Manage team members and enforce role-based access control
  • Maintain employer profiles and locations
  • Operate agency plans, including management of multiple represented employers under one account
  • Handle support inquiries submitted via the Dashboard

4.2 Service Improvement

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)

We process usage and activity data to:

  • Analyze usage patterns to improve the platform
  • Debug issues and resolve errors
  • Monitor performance
  • Conduct product quality and operational analytics based on internal audit and activity logs

We do not use third-party analytics cookies in the Dashboard.

4.3 Security and Abuse Prevention

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR); legal obligation (Art. 6(1)(c) GDPR) where applicable

We process data to:

  • Prevent unauthorized access, account takeover, and fraud
  • Enforce CSRF protection, rate limiting, and web application firewall (WAF) rules
  • Maintain audit trails of key administrative actions

4.4 Communication

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR); legitimate interest (Art. 6(1)(f) GDPR)

We send:

  • Transactional emails (account confirmation, password reset, billing notifications, subscription status changes, team invitations) — these are necessary for the operation of the service and cannot be opted out of.
  • Product-related communications to account administrators (feature updates, tips, and other non-essential messages) — you may opt out of these at any time by using the unsubscribe link included in each such email.

4.5 Legal Compliance

Legal basis: Legal obligation (Art. 6(1)(c) GDPR)

We process data to:

  • Maintain tax and accounting records as required by law
  • Prevent fraud
  • Respond to lawful requests from competent authorities
  • Verify and handle claims related to agency authorization and representation

5. Data Sharing and Third Parties

5.1 Payment Processor — Paddle

Our merchant of record is Paddle.com Market Limited. When you subscribe to a paid plan or manage your billing, we share billing data with Paddle, including your billing email, business address, VAT ID, and payment details. Paddle processes and stores payment method details (e.g., card numbers) directly — we do not have access to this information. When you use the embedded checkout, Paddle's own scripts (Paddle.js) are loaded and may process additional technical data in accordance with Paddle's Privacy Policy.

5.2 Sub-Processors

We use the following sub-processors to operate the Dashboard:

Provider Purpose Location
Hetzner Online GmbH Infrastructure and server hosting EU (Germany)
Cloudflare, Inc. CDN, DDoS protection, and DNS USA (EU Standard Contractual Clauses)
Mailgun Technologies, Inc. Transactional email delivery USA (EU servers; EU SCC)
Paddle.com Market Limited Merchant of record UK (London)
Google Cloud EMEA Limited Job data processing, support email EU (Ireland)
Mistral AI Job data processing EU (France)
Anthropic, PBC Job data processing USA (EU Standard Contractual Clauses)
OpenAI, LLC Job data processing USA (EU Standard Contractual Clauses)

We review our sub-processors regularly and will update this list when changes occur. Where data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, such as EU Standard Contractual Clauses (SCCs).

5.3 Job Seekers (Published Content)

Job postings and employer profile information that you publish through the Dashboard are publicly visible on our European market websites. This is the core purpose of the service. Depending on the posting setup and applicable legal requirements, published information may identify a direct employer, a hiring agency, or both.

5.4 Publication Partners and Syndication

If you enable export or syndication for a job post (e.g., by selecting "allow export"), we may share that job post's content and associated employer profile data with third-party job boards and aggregators for wider publication and promotion. Disabling export stops future sharing; however, previously shared content may persist on partner platforms for a limited time and in search engine caches.

5.5 Within Your Organization

Administrators of your organization account may access and manage team member accounts, roles, and invitations. Authorized users within your organization may view audit and activity logs and job/employer data relevant to your account.

5.6 Legal and Regulatory Disclosures

We may disclose personal data to:

  • Competent authorities when required by law
  • Legal advisors when necessary for dispute resolution or the exercise or defence of legal claims

5.7 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify affected users of any such transfer and any changes to the applicable privacy policy.

5.8 External Links and Application Destinations

Job posts may include application URLs or email addresses that direct candidates to external websites or systems controlled by you (the employer or agency) or by third parties. Once a user leaves ENGLISHJOBS via an external link, the third party's privacy practices apply. We are not responsible for the privacy practices of external sites.

6. International Data Transfers

Your personal data is primarily stored and processed within the EU/EEA (Germany and Finland). Where data is transferred outside the EEA (for example, to Cloudflare in the USA), we rely on one or more of the following safeguards:

  • EU Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions issued by the European Commission for the recipient country

7. Data Retention

7.1 Active Accounts

  • Account and business data is retained for the duration of your active account and subscription.
  • Authentication sessions expire after 24 hours (or 30 days if you select "Remember me"). Expired sessions are deleted automatically by the database engine and on-demand when accessed.
  • Billing event records (Paddle webhook data used for billing audit and troubleshooting) are retained for as long as your account remains active and are deleted when your account is deleted.
  • Activity logs are retained for as long as your account is active.

7.2 After Account Deletion

When you request account deletion:

  1. Grace period: Deletion is scheduled with a 48-hour grace period during which you may cancel the request.
  2. Execution: After the grace period, account data is deleted within 14 days.
  3. Billing and tax records are retained for the statutory retention period — typically 10 years under German commercial and tax law (§§ 147 AO, 257 HGB).
  4. Published job posts may be retained in anonymized form for platform statistics.
  5. Agency-representation metadata may be retained as needed for the exercise or defence of legal claims, audits, or dispute resolution.
  6. Backups and disaster recovery copies may persist for up to 30 days after deletion before being overwritten.

7.3 Team Members

When a team member is removed from an organization account:

  • The team member's personal data (name, email, credentials) is deleted promptly.
  • Activity logs attributed to the removed member are anonymized.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encryption in transit using TLS/HTTPS for all connections
  • Encryption at rest for sensitive data stored on our servers
  • Password hashing using bcrypt
  • Role-based access control within the Dashboard
  • Regular security updates and system monitoring
  • Incident response and breach notification procedures in accordance with GDPR Art. 33 and Art. 34

No system is completely secure. If we become aware of a security breach that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours and, where required, inform affected users without undue delay.

9. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

Right Description GDPR Article
Access Obtain a copy of the personal data we hold about you Art. 15
Rectification Correct inaccurate or incomplete data Art. 16
Erasure Request deletion of your data ("right to be forgotten") Art. 17
Restriction Request that we restrict processing of your data Art. 18
Data portability Receive your data in a structured, machine-readable format Art. 20
Objection Object to processing based on our legitimate interests Art. 21
Withdraw consent Where processing is based on consent, withdraw it at any time Art. 7(3)

How to exercise your rights:

  • By email: Send your request to [email protected]
  • In-app: You can delete your account directly from the Dashboard settings

We will respond to your request within one month. If we need additional time due to the complexity or number of requests, we will inform you within the initial one-month period, and the extension will not exceed an additional two months.

If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is:

Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD)
Holstenstraße 98
24103 Kiel, Germany
Website: https://www.datenschutzzentrum.de

10. Cookies and Tracking

The Dashboard uses only strictly necessary cookies for authentication and security. These cookies are essential for the operation of the service and do not require consent under Art. 5(3) of the ePrivacy Directive.

Cookie Purpose Duration
Session cookie Authenticates your session 24 hours (or 30 days with "Remember me")
CSRF cookie Protects against cross-site request forgery attacks Session

We do not use analytics cookies, advertising cookies, or any third-party tracking cookies in the Dashboard.

If we introduce non-essential cookies in the future, we will update this policy and implement an appropriate consent mechanism before activation.

Browser storage: The Dashboard may use your browser's LocalStorage and SessionStorage for draft data and UI preferences (see §3.8). This data is not shared with third parties.

11. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you within the meaning of Art. 22 GDPR.

Automated security measures (such as WAF rules and rate limiting) may block or challenge suspicious traffic to protect the service. These measures are based on technical signals and are not targeted at individuals.

12. Data Processing Roles

The roles of data controller and data processor depend on the processing context:

  • Ninibe GmbH as controller: We are the controller for processing that is necessary for the operation, security, billing, and legal compliance of the Dashboard (e.g., account management, security logs, billing records).

  • Ninibe GmbH as processor: For customer-submitted content (such as job postings and employer profiles) and associated user accounts, we may act as a data processor on your behalf, as governed by a Data Processing Agreement (DPA) where applicable.

  • Direct employers are typically the controller for any applicant data they receive through the platform.

  • Hiring agencies are typically the controller for their recruitment operations. The represented employer may be an independent or joint controller depending on the arrangement between the agency and the represented employer.

If you require a Data Processing Agreement, please contact us at [email protected].

13. Children's Privacy

The Dashboard is a business service intended for use by professionals. It is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a person under 18, we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by email and/or by a prominent notice within the Dashboard.

The updated policy will take effect on the date indicated at the top of the document. We encourage you to review this policy periodically.

15. Contact Information

For any questions or concerns about this Privacy Policy or our data processing practices:

Ninibe GmbH
Travemünder Allee 4
23568 Lübeck, Germany

Email: [email protected]

Supervisory authority:
Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD)
Holstenstraße 98, 24103 Kiel, Germany
https://www.datenschutzzentrum.de