Candidate privacy notice

This notice sits under the Berlitz Privacy and Cookies Policy and adds the detail that applies to hiring. Where the two differ, tell us, because they should not.

1. Who is responsible for your data

The controller of your personal data is Berlitz Corporation, a corporation registered in New York under number 1382993, with headquarters at 116 Village Boulevard, Suite 305, Princeton, New Jersey 08540, United States.

Berlitz operates in more than 70 countries. If you apply for a role held by one of the affiliates listed in section 7, that company may act as controller or joint controller for your application. The job posting names the hiring entity. Ask us if it is not clear.

Our Data Protection Officer is Barbara Schneider, at datenschutz@berlitz.de.

2. What we collect

When you submit an application, we collect your name, address, telephone number, email address, preferred workplace, previous work experience, skills, referral information, and the application documents you choose to send us. We use that information for recruitment, and only to process and handle your application.

Running the process also means we hold:

Interview records. Interviewer notes, scores against the role's criteria, assessment or exercise results, and debrief summaries.
Your right to work. Whether you hold the right to work in the country of the role, and what visa or sponsorship you would need. We ask for passport or permit documents only if we offer you a job.
References and checks. What referees tell us, and the results of any background check that the role and the local law allow.
Pay expectations. Your expectations and, where the law lets us ask, your current package. Some US states and other jurisdictions prohibit asking about salary history, and we do not ask there.
How you use this site. When you visit, we log the pages you open, the date and time, the data volume transferred, your operating system, the referring URL, your IP address, and your access provider. We use this to run the site and keep it secure, and we keep it for seven days.

This site sets no cookies. It carries no analytics, no advertising tags, and no tracking scripts, so there is nothing to consent to and you will not see a cookie banner. The open roles list reads a public job board feed, and the images load from a content delivery network. Neither stores anything on your device. The log described above is a server record, not a cookie. If that ever changes we will publish a cookie policy and ask for your consent before setting anything.

If you join us, we collect the wider set of employment data that the berlitz.com policy calls Human Resources Data, which includes your employment and academic history, financial information, age, gender, nationality, date and place of birth, marital status, language skills, employee and government IDs, income, dates of employment, and tax information.

Please do not send us more than we ask for. A resume does not need your date of birth, marital status, photograph, national ID number, or religion, and we would rather not hold data we have no use for.

3. Where we get it

Most of it comes from you. We also collect data from:

Professional networks and public profiles, such as LinkedIn, when our recruiters look for candidates.
Recruitment agencies and search firms that put you forward.
Employees who refer you, who tell us your name and contact details.
Referees you name.
Background check providers, where a check applies and you have been told about it.

If a third party gives us your data, we tell you within one month of receiving it, and this notice explains what happens next.

4. Why we use it, and our legal basis

The first two rows below are the bases the berlitz.com policy states for recruitment. The rest cover steps that policy does not break out.

What we do	Legal basis
Facilitate recruitment	Our legitimate interest in the proper functioning of our commercial activity (Art. 6(1)(f) GDPR)
Process job applications and human resources data, for administration and communication and to meet labor law requirements	Establishing and performing an employment relationship (Art. 6(1)(b) GDPR), and our legitimate interest in staffing current and future open positions and, after the application procedure, in exercising or defending possible legal claims (Art. 6(1)(f) GDPR)
Verify your right to work, and run background checks	Legal obligation, and our legitimate interest in a reliable process
Keep your details for future roles	Your consent (Art. 6(1)(a) GDPR)
Collect diversity data	Your explicit consent, or a legal obligation where one applies
Make adjustments for a disability or health condition	Employment law obligations, and your explicit consent
Record website visits in a log file	Providing the service, and our legitimate interest in the site working properly and securely (Art. 6(1)(b) and (f) GDPR)

Berlitz considers the risk to your data protection rights from processing based on legitimate interests to be neither excessive nor overly intrusive. You can ask us for that assessment, and you can object to the processing. Section 11 explains how.

Giving us your data is not a statutory requirement, but some of it we need in order to consider you for a role. If you withhold it, we may not be able to process your application.

5. Diversity and health data

Some data needs more protection, including data about your racial or ethnic origin, health, disability, religion, sexual orientation, and gender identity. The GDPR calls this special category data.

We ask for it in two situations only.

Diversity monitoring. Some application forms ask optional diversity questions. Answering is voluntary, the answers do not reach the people who decide on your application, and we report only aggregated numbers. Skipping the questions costs you nothing.

Adjustments. If you tell us you need an adjustment to interview, we use that information to arrange it. We share only what the people arranging it need to know.

In the United States, federal law requires some employers to invite candidates to self-identify their race, gender, veteran status, and disability. Where that applies, the form says so, and the answers stay separate from hiring decisions.

6. AI and automated decisions

There is no automated decision-making, including profiling. A person makes every hiring decision at Berlitz, and no software decides your outcome on its own.

We use software to sort, search, and manage applications, which includes keyword search across resumes. A recruiter reviews the results and decides what happens next.

If we ever introduce a tool that scores or ranks candidates, we will tell you before you apply, explain what it looks at, and give you a route to a human review. Where the law gives you the right not to be subject to a decision made only by automated means, we honor it.

We do not record interviews without telling you first and asking your permission.

Berlitz affiliates. We share your data with entities that control us, are controlled by us, or sit under common control with us. Those affiliates process it on our instructions, under this notice and appropriate confidentiality and security measures. As of January 1, 2024 they are:

Berlitz Austria GmbH
Berlitz Corporation
Berlitz Columbia S.A.
Berlitz Deutschland GmbH
Berlitz France Holdings SAS
Berlitz Mexico S.A. de C.V.
Berlitz Holdings
Berlitz Hungary Nyelviskola KFT
Berlitz Languages, Inc.
Berlitz Investment Corporation
Berlitz Franchising Corporation
ELS Educational Services, Inc. (ELS)
World Wide Speaking SARL (World Speaking)
Second Language Testing, Inc. (SLTI)
Training Management Corporation (TMC)
Berlitz (U.K.) Limited
Berlitz Poland Sp.zo.o
Berlitz (Israel) Ltd.
Berlitz Party Services, Ltd.
Berlitz Japan, Inc.

Within those companies, access goes to the hiring managers, interviewers, recruiters, and the HR and IT staff who support them.

Service providers. We use outside companies to run parts of the process, including our applicant tracking system Ashby, assessment platforms, interview scheduling and video tools, background check providers, and IT hosting and support. Each one agrees to process your data on our instructions and in line with this notice, and to use it only for the service we asked for.

Recruitment agencies, where an agency introduced you.

Authorities and advisers. We may share your data in response to subpoenas, court orders, or other lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share it to enforce our rights and agreements, or to protect the rights, property, or safety of our business, our sites, or our people.

We do not disclose or sell personal data to third parties for direct marketing.

8. Sending data between countries

Berlitz Corporation sits in the United States, so applying from outside the US means your data crosses a border, into a country whose data protection law may differ from your own.

For personal data from the European Union, the European Economic Area, the United Kingdom (and Gibraltar), or Switzerland, Berlitz and the affiliates listed in section 7 handle it under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework, administered by the US Department of Commerce. Where this notice conflicts with the DPF Principles, the Principles win. You can read about the program and see our certification at dataprivacyframework.gov.

Berlitz stays responsible under the Principles if a third party it engages processes your data in a way that breaks them, unless Berlitz shows it was not responsible for what caused the damage.

9. How long we keep it

If we do not hire you: six months after we tell you the outcome. Our recruiting system deletes it at that point.
If you join us: we move the relevant records into your employee file, and the employee privacy notice takes over.
Website log files: seven days, unless we need them longer as evidence of a specific infringement that came up in that window.
If you agree to join our talent pool: six months, after which we delete your data or ask whether you want to stay.
Diversity data: six months, and in aggregated form once reporting is done.

Six months gives us long enough to answer a question about your application and to defend a claim, without holding your data for years after a decision.

You can ask us to delete it sooner. Email talent@berlitz.com and we will remove your data ahead of the six months, unless we have a legal reason to keep something. Asking costs you nothing and does not affect any future application.

While we hold your data we process it under this notice. Once we no longer need it, we securely erase it or anonymize it.

10. How we protect it

We use physical, electronic, and managerial procedures to prevent unauthorized access, keep data accurate, and make sure it gets used correctly, with security measures consistent with industry standards. Sending information electronically always carries some risk, so we cannot promise perfect security. If a breach puts your rights at risk, we notify you and the relevant regulator as the law requires.

11. Your rights

These rights are not absolute, and each has exceptions. Depending on where you live, you can ask us to:

Show you whether we process your data, how we use it, and give you a copy, usually free of charge. We can refuse where answering would expose someone else's personal data, or where a request is repetitive and excessive.
Correct anything inaccurate or incomplete.
Delete your data, where we have no compelling reason to keep using it. This is not a general right, and it does not apply where we need the data to defend a legal claim or meet a legal obligation.
Restrict our use of your data while we assess a correction request, or as an alternative to deletion. We can still store it, but we will not use it further without your consent, except to establish, exercise, or defend legal claims, or for important public interest reasons.
Port the data you gave us, where we process it with your consent or to perform a contract and we do so by automated means. We provide it in a structured, commonly used, machine-readable format, or send it directly to another controller where that is technically possible.
Object to processing based on our legitimate interests, on grounds relating to your situation. We can continue if we show compelling legitimate grounds that override your interests, or if we need the data for legal claims. If you object to direct marketing, we stop.
Withdraw consent where you gave it. Withdrawing does not affect processing that already happened lawfully.

Email privacy@berlitz.com at any time to use these rights. To delete your application data before the six months in section 9, write to talent@berlitz.com, which reaches the recruiting team directly. Data that cannot identify you, such as data anonymized for analysis, falls outside these rights. Using them costs you nothing and does not count against your application.

You can also complain to any competent data protection authority. Berlitz publishes a list at bfdi.bund.de.

Berlitz resolves complaints internally first. If you live in the EU, the EEA, the UK (and Gibraltar), or Switzerland and that does not satisfy you, you can take the complaint to the American Arbitration Association, the independent recourse mechanism Berlitz has selected. Berlitz is subject to the investigatory and enforcement powers of the US Federal Trade Commission.

For complaints about data received under the DPF, Berlitz refers unresolved cases to the ICDR-AAA DPF IRM Service at no cost to you. See go.adr.org/dpf_irm.html.

If you are a past or present Berlitz employee in the EU, the EEA, the UK (and Gibraltar), or Switzerland, Berlitz cooperates with the data protection authorities, the UK Information Commissioner's Office, and the Swiss Federal Data Protection and Information Commissioner on unresolved complaints about human resources data. A binding arbitration option is also available for complaints nothing else resolves.

12. How to contact us

Controller: Berlitz Corporation, 116 Village Boulevard, Suite 305, Princeton, NJ 08540, United States
Telephone: +1 609 497-6571
Privacy requests: privacy@berlitz.com
Recruiting team, including early deletion: talent@berlitz.com
Data Protection Officer: Barbara Schneider, datenschutz@berlitz.de
European representative: Berlitz Deutschland GmbH, Hahnstrasse 68-70, 60528 Frankfurt am Main, Germany. Tel. +49 (0)69 666 08 90
Legal department: legaldept@berlitz.com

13. Country-specific terms

Local law adds to this notice in some places, and the local terms win where they conflict with anything above. We expect appendices for:

California. The notice at collection that the CCPA and CPRA require, covering the categories we collect, why, how long we keep them, and the rights to know, delete, correct, and limit. Berlitz does not sell personal data or share it for cross-context behavioral advertising.
Other US states with their own privacy laws, including Colorado, Connecticut, Texas, and Virginia.
Germany, where section 26 of the Federal Data Protection Act governs hiring data and the works council may have agreed additional terms.
Japan, Brazil, Mexico, and other markets with their own consent and notice rules, given the affiliates in section 7.

Ask us at privacy@berlitz.com for the appendix that applies to you.

Berlitz does not knowingly collect personal data from anyone under 13. We do not accept applications from anyone below the minimum working age for the role's country.

14. Changes to this notice

We update this notice when our hiring practices or the law change. The version number and date at the top tell you where we are. If a change matters to you and we hold your contact details, we will tell you directly.