We handle your private data with care


This Data Privacy Policy explains to users how, which and for what purpose personally identifiable information is collected and used on this website by the responsible provider (hereafter “website”/”provider”).

Implico GmbH
Weidestrasse 120 b
22083 Hamburg

Phone: +49 (0)40 / 27 09 36-0
Fax: +49 (0)40 / 27 09 36-46

Registered as Implico GmbH at the Hamburg Local Court, HRB 30975
VAT registration number: DE 118681926
Tax number: 43/734/01485

Managing directors:
Tim Hoffmeister (CEO)
Dr. Volker Braun

The applicable data privacy regulations are contained in the General Data Protection Regulation (GDPR), the New German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG (new) and the German Federal Telemedia Act (Telemediengesetz – TMG).

We have appointed S-CON Datenschutz, Dr. Timo Bittner, as the Data Protection Officer for our company. You can contact our Data Protection Officer as follows:

S-CON Datenschutz, Dr. Timo Bittner
Kriegerstraße 44
30161 Hannover
511 270744  0

General information on data privacy

We process your personally identifiable information exclusively in conformity with the above-named laws regarding data privacy and protection. The following policy provides you with information on the nature, scope and purpose of the collection, processing and use of personally identifiable information. This Data Privacy Policy applies solely to the content of our website. If you are directed to other websites via links found on our website, please be sure to seek out information there on how those sites handle your data.

How collected data is used

We adhere to the principle of data economy, which means that all of the information collected is required by us in order to fulfill a given purpose. No other use will be made of that information.

Personally identifiable information is information that can be used to identify an individual, i.e., information that can be traced back to a particular person. Such information includes a person’s name, e-mail address and phone number, but information about preferences, hobbies, memberships, or what websites a person has viewed is also considered personally identifiable information.

Your personally identifiable information will not be disclosed to third parties without your express consent or a legal reason. If we are obligated to store information or if there are risks that obligations to produce evidence will arise at a later date, further use of the information will be blocked. Provided you have not consented to the further use of your information, it will be deleted once the applicable provisions of tax and commercial law no longer apply.

Accessing the website/application

The following describes how we process your personal data when you access our services. In particular, please note that the transfer of data regarding access to third-party content providers (see b. below) is unavoidable due to the technical process of transferring information over the Internet.

Informationen about processing

Data category



Legitimate interest, if applicable

Retention period

Access data

Establishing a connection, displaying the content of the service, detecting attacks on our site through unusual activity, error diagnosis

Art. 6 (1) f) GDPR

Proper functioning of the services, data and business process security, prevention of misuse, protection against damage caused by interference with information systems

7 days


Recipient(s) of personal data

Recipient category

Data affected

Legal basis of transfer

Legitimate interest, if applicable

Third-party content providers that supply content (e.g., images, videos, embedded posts on social media, advertising banners, fonts, update information) required to display the service

Access data

Processing on behalf of a controller (Art. 28 GDPR)

Proper functioning of the services, accelerated display of content

Provider(s) of IT security services

Access data

Processing on behalf of a controller (Art. 28 GDPR)

Prevention of attacks conducted by exploiting security gaps/vulnerabilities



If you contact the provider (for example, using a contact form or by e-mail), your user information will be stored for purposes of processing your inquiry or in case you have follow-up questions. After the issue has been settled, your information is deleted.

Access data/server log files

The provider (or that provider’s webspace host, as the case may be) collects data every time the website is visited (so-called server log files). Access data includes:

the name of the website visited, file, date and time of the visit, volume of data transmitted, notification of successful access, type of browser including the version, the user’s operating system, the referrer URL (site previously visited), IP address, and the requesting provider.

The provider uses the protocol data solely for statistical analyses for purposes of operating, maintaining the security of and optimizing the website. However, the provider reserves the right to review the protocol data at a later date if there is a reasonable suspicion of unlawful use on the basis of specific indicators.

SSL encryption

This website uses SSL encryption for general security reasons and to protect the transmission of confidential content – such as queries that you send to us as the site operators. To check if your connection is encrypted, look at the URL shown in your browser’s address bar: the “http://” will change to “https://” and a padlock icon will also appear.

If SSL encryption is active, third parties will be unable to ‘eavesdrop’ on the data transmitted to us by your browser.




What are cookies?

As is common practice with almost all professional websites, this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored. However, this may downgrade or 'break' certain elements of the sites functionality.

How we use cookies

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of this site. Therefore, it is recommended that you do not disable cookies.

The Cookies we set

This site offers newsletter or e-mail subscription services, and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users. When you submit data to through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third-party cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. Third-party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how much time you spend on the site or pages you visit, which helps us to understand how we can improve the site for you.
In some cases, we may provide you with custom content based on what you tell us about yourself either directly or indirectly by linking a social media account. These types of cookies simply allow us to provide you with content that we feel may be of interest to you.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, the following social media sites including Twitter, Linkedin, XING, Pinterest and Youtube will set cookies through our site, which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

More information

If you are looking for more information, you can contact us via E-Mail:

Comments and posts

When users post comments on a blog or leave other posts, their IP addresses are saved. This is done for the security of the provider, in case someone writes unlawful content in comments or posts (defamatory content/insult, prohibited political propaganda, etc.). In such cases, it is the provider who could be prosecuted for the comment or post, so the provider has a legitimate interest in the identity of the author.

Comment notifications

Users can subscribe to be notified of future comments. The user receives a confirmation e-mail, which is sent to verify that the user is the account holder for the e-mail address entered. Users can unsubscribe from comment notifications at any time. The confirmation e-mail contains more information on this subject.


Our newsletter provides you with information about us and the services we offer. To receive the newsletter offered, you need to provide us with two pieces of information: first, we need a valid e-mail address and second, we need a way of confirming that you are the owner of the e-mail address specified or that the address owner approves the receipt of our newsletter. No other information is collected. This information will only be used for mailing the newsletter and will not be disclosed to third parties.

When you sign up for the newsletter, we store your IP address and the date you signed up. We do this solely to preserve evidence in case a third party abuses an e-mail address and signs up to receive the newsletter without the knowledge of the legitimate e-mail account holder.

This is what happens with your personal data when you subscribe to our newsletter:

Information about processing

Data category



Legitimate interest, if applicable

Retention period


Registration verification (double opt-in), sending newsletter

Art. 6 (1) a) GDPR


Duration of newsletter subscription

Newsletter user profile data

Designing the newsletter to align with your interests

Art. 6 (1) f) GDPR

Improving our service, advertising purposes

Duration of newsletter subscription


Recipient(s) of personal data

Recipient category

Data affected

Legal basis for transfer

Legitimate interest, if applicable

Service provider for newsletter distribution

All the above mentioned data

Processing on behalf of a controller (Art. 28 GDPR)


You can revoke your consent to the storage of the information, the e-mail address and its use for purposes of sending the newsletter at any time. You can revoke your consent via the link in the newsletters themselves, through your profile area, or by sending a notification to the contact options given above.

Job application

We process your personal data in the following way during the job application process:

Information about processing

Data category



Legitimate interest, if applicable

Retention period

Address, contact information

Identification, establishing contact, communication for purposes of initiating a contract

Art. 6 (1) b) GDPR


6 months

Personal master data

Identification, establishing contact, verifying age

Art. 6 (1) b) GDPR


6 months

Application information

Applicant selection

Art. 6 (1) b) GDPR


6 months


Recipient(s) of personal data

Recipient category

Data affected

Legal basis for transfer Legitimate interest, if applicable

Service provider for application management

all data mentioned above

Processing on behalf of a controller (Art. 28 GDPR)  



For our application management, we use the platform of the service provider Recruitee B.V., Johan Huizingalaan 763A, 1066 VH Amsterdam, Netherlands. In order to ensure that personal data are processed in compliance with data protection regulations, we entered into an agreement regarding data processing on behalf of a controller with the service provider in accordance with Art. 28 (1) GDPR.


Implico Academy (

All your personal data and other information that you provide to us within the Implico Academy will only be collected and processed for the purpose of your registration on the basis of Art. 6 (1) paragraph 1 lit. b) GDPR. If this information is not provided, you will unfortunately not be able to use the Implico Academy.
An automated decision-making process will not be carried out.
A transfer of your personal data to external third parties is made to Epignosis UK Limited (TalentLMS), which provides the software for the Learning Platform.
A transfer of personal data provided by you to a third country or an international organization takes place to the extent that it is transferred to our external service provider Epignosis UK Limited.
Your personal data that you provide to us in our Implico Academy will be stored by us until you delete your user account or have it deleted and, if applicable, in accordance with a statutory retention period.

Internal travel management

We might collect, process and transmit the personal data provided by you as part of our internal travel management. These include booking and contact data (last name, first name, address, e-mail address, phone number), if applicable, the data contained in travel documents (passport number, passport data, date of birth), if applicable, the data concerning payment methods in connection with payments as well as other data provided by you for the fulfillment of our contractual obligations and the processing of your trip. The data may be transferred to third parties, e.g. tour operators, hotels or other partners. The collection, processing, use and transmission of personal data is carried out in accordance with the legal basis of Art. 6 (1) b) GDPR, if applicable Art. 6 (1) c) GDPR. 

Integration of third-party services and content

On occasion, the content we provide online may also include third-party content, for example videos from YouTube, material from Google Maps, RSS feeds, or graphics from other websites. In order for this to happen, the providers of such content (“third-party providers”) need to have access to users’ IP addresses, because the content cannot be sent to the respective user’s browser without the IP address. In other words, the IP address is required in order to display the content. We make every effort to use only the content of providers who themselves use IP addresses exclusively to deliver content, however we have no influence over whether third-party providers store the IP address, for example for statistical purposes. Whenever we are aware of the purpose, we will disclose this to the users.

Google Maps

We use the ‘Google Maps’ component provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (‘Google’) on our website.

Every time the Google Maps component is accessed, Google sets a cookie, which is used to process user settings and data when displaying the page containing the embedded Google Maps component. Typically, this cookie is not deleted when the browser is closed but expires after a set period of time; you can also delete the cookie manually before this expiry date.

If you do not want your data to be processed in this way, you have the option of disabling the Google Maps service, which will prevent any data from being transmitted to Google. To do so, you will need to disable JavaScript in your browser. Please be advised, however, that this will either limit or prevent your use of Google Maps on this site.

The use of Google Maps and the information collected by Google Maps is governed by the Google Terms of Service ( and the additional Terms of Service for Google Maps:


To protect data entry forms on our website, we use the ‘reCAPTCHA’ service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (‘Google’). By using this service, we can accept input that has been entered by human users while simultaneously rejecting any abuse of our forms by automated programs (‘bots’).

The IP address identified as part of the reCAPTCHA procedure is not aggregated with other data held by Google unless you happen to be logged onto your Google account while using the reCAPTCHA plug-in. If you want to prevent the transmission and storage of your personal data and data about your use of our website by Google, then you must log out of your Google account before visiting our website and before using the reCAPTCHA plug-in.

Use of the information collected by the reCAPTCHA service is governed by the Google Privacy Policy:


Our website contains plugins from the social networking site LinkedIn, LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (“LinkedIn”). You will recognize LinkedIn plugins by the corresponding logo or the “Recommend” button. Please note that when you visit our website, the plugin establishes a connection between your Internet browser and the LinkedIn server. This means that LinkedIn will be informed that a device with your IP address visited our website. If you click on the LinkedIn “Recommend” button while you are also logged into your LinkedIn account, you will be able to link content from our webpages to your LinkedIn profile page. When you do this, you are enabling LinkedIn to associate your visit to our website with you individually or, respectively, your user account. Please note that we do not receive any information whatsoever regarding the content of the data transmitted and its use by LinkedIn.

To learn more about the information collected, your legal rights, as well as settings options available to you, please see LinkedIn’s privacy policy at

Source: Flegl Rechtsanwälte GmbH


This website uses the XING “Share” button. Consequently, when you visit this website, a connection is established with the servers of XING AG, Gänsemarkt 43, 20354 Hamburg, Germany. This allows sharing functions (such as the display of counter numbers) to operate. Your personally identifiable information is not stored when you visit this website. In particular, XING does not store any IP addresses, nor does it analyze your usage patterns. You can read the latest information regarding data privacy and protection for the “Share” button and other information relevant to this topic at

Source: Flegl Rechtsanwälte GmbH


This website uses Twitter buttons, which are provided by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. You will recognize these when you see terms such as “Twitter” and “Follow” together with a stylized blue bird. These buttons make it possible for you to share a post or page from this website on Twitter or to follow the provider on Twitter.

When a user visits a page of this website that contains one of these buttons, the user’s browser will establish a direct connection with Twitter servers. The content from the Twitter button will be transmitted by Twitter directly to the user’s browser. Consequently, the provider has no influence over the scope of the data collected by Twitter with the help of this plugin and hereby provides notice of what is currently known, which is that when the button is included, only the user’s IP address is communicated along with the URL of the respective website, and only for purposes of displaying the button.

If you would like more information, please see Twitter’s privacy policy at


Our website uses HubSpot software provided by HubSpot Inc., an American software company with a business location in Ireland (HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, phone: +353 1 5187500). This software is used in the field of so-called inbound marketing and helps us to better coordinate and optimize our marketing strategy by means of statistical analyses and analyses of recorded user behavior, among other things, based on the stored IP-Adress. Cookies are used (see above). You can block cookies from being stored on your computer or delete cookies already stored there at any time by means of a corresponding setting in your browser software. Please note that if you block cookies, this may prevent you from being able to fully utilize the services provided on our website. You can find out more by reading the HubSpot Inc. terms of use and privacy policy at and If you do not want the information about your visit to be used for the purposes described, you are welcome to notify us of this via e-mail or postal mail.


This website contains at least one plugin from YouTube, which is owned by Google Inc., located in San Bruno, California, USA. As soon as you visit pages from our website that feature a YouTube plugin, a connection is established with YouTube servers. When this happens, the YouTube server will be informed of which particular page from our website you visited. If you are logged into your YouTube account at the same time, you will be enabling YouTube to directly associate your surfing behavior with your personal profile. If you would like to avoid this association, you will need to first log out of your account. More information on how YouTube collects and uses your information is available in the privacy policy notice on its website,

Source: Flegl Rechtsanwälte GmbH

Rights of the data subject

Right to object

If we process your personal data for direct marketing purposes, you have the right to object, at any time with future effect, to the processing of your personal data for purposes of such marketing insofar as it is related to that type of direct marketing.

You also have the right, on grounds relating to your particular situation, to object at any time with future effect to the processing of your personal data in accordance with Art. 6 (1) e) or f) GDPR.

You can exercise the right to object free of charge.

We can be contacted at

Right of access

You have the right to find out whether your personal data is processed by us, which personal data is being processed (if any), and other information in accordance with Art. 15 GDPR. If you have any questions, please contact us:

Right to rectification

You have the right to request rectification without undue delay of any personal data relating to you that is inaccurate (Art. 16 GDPR). Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (“right to be forgotten”)

You have the right to request that we erase your personal data without undue delay on any of the grounds listed in Art. 17 (1) GDPR if the processing is not required for one of the purposes governed by Art. 17 (3) GDPR.

Right to restriction of processing

You are entitled to request restriction of processing of your personal data on any of the grounds listed in Art. 18 (1) a) to d) GDPR.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format. Furthermore, you have the right to transmit those data to another controller without hindrance from us or to have your personal data transmitted directly by us, where technically feasible. This shall always apply when the processing is based on consent or on a contract, and the data is processed automatically. It does not apply to data stored only in paper form.

Right to withdraw consent

To the extent that data processing is based on your consent, you have the right to withdraw this consent at any time. The proceeding does not affect the lawfulness of processing based on consent up to the point consent is withdrawn.

Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority.

Right to make changes

We reserve the right to change this Data Privacy Policy at any time in compliance with the legal requirements.

Hamburg, March 2022