개인정보 처리방침

Last updated: 1 October 2026. This Privacy Policy explains the processing of personal data when visiting otoko.com, making enquiries and applying for jobs through this website. Services we perform in customer systems are also governed by the relevant contracts and data protection agreements.

The controller is OTOKO® GmbH, Salierring 42, 50677 Cologne, Germany, represented by managing director Yahya Zahad.

For privacy questions and to exercise your rights, contact info@otoko.com, call +49 221 29 26 23 7 or write to the address above marked “Data protection”.

We process data to provide and secure this website, respond to enquiries, prepare contracts and handle applications. The applicable legal basis depends on the activity:

• Article 6(1)(b) GDPR: steps taken at your request before entering a contract and performance of a contract with you.
• Article 6(1)(f) GDPR: our legitimate interests in a functioning, secure website, handling business communications and establishing or defending legal claims. Communication with a company’s representatives generally relies on this basis.
• Article 6(1)(a) GDPR: voluntarily enabled additional services and consent, particularly optional statistics, recordings and feedback.
• Article 6(1)(c) GDPR: compliance with legal obligations, such as retention of business records.
• Section 26(1) BDSG: deciding whether to establish an employment relationship; voluntary inclusion in the applicant pool additionally relies on consent under Article 6(1)(a) GDPR and section 26(2) BDSG.

Storage of information on your device, or access to that information, is additionally governed by section 25 of the German TDDDG. Non-essential activities require consent under subsection 1; strictly necessary activities may fall within the exception in subsection 2.

We use Cloudflare with European infrastructure within its international network to deliver and protect our website. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. Cloudflare supports secure delivery and protection against attacks. See ‘Service providers and international processing’ for information on international processing.

Requests involve processing IP address, time, requested address, HTTP status, transferred volume, browser and operating-system information and, where applicable, the referring page. These data support delivery, troubleshooting and attack detection. The legal basis is Article 6(1)(f) GDPR, reflecting our interest in availability and security.

Technical logs are needed only for as long as necessary for operation, troubleshooting and investigation of specific security incidents. The logs generated and their availability at the provider also depend on the Cloudflare function and configuration used. Logs relating to a particular incident may be required for longer to investigate it and preserve legal claims.

Further information: Cloudflare Privacy Policy.

Our consent dialogue leaves optional services disabled initially. You can change or withdraw your selection at any time through Cookie settings in the footer. Refusing statistics, recordings or feedback does not affect reading the website or handling your enquiry.

Your selection, timestamp, expiry and version are saved in your browser’s local storage for up to 180 days. Material changes may require a new decision. If storage is blocked, the choice remains available only for the current visit. Saving the choice is necessary to respect your privacy decision.

With separate permission to save preferences, accessibility settings can be retained locally. Without this permission, the settings can be used during the current visit. Withdrawal or expiry removes the persistently saved setting.

For enquiries, we process the contact and company details you provide, your topic, message and any project details such as technical environment, timeline and budget. Following a topic-specific contact button may prefill the originating page or topic in the form and include it in the submission, helping us route the enquiry appropriately.

Required fields are marked. Without the information needed to respond and process the submission, we cannot handle the enquiry through the form. You can alternatively contact us directly by email or telephone. Please do not send passwords, private keys or unnecessary confidential documents.

We use the data to handle your request and, where relevant, prepare a contract. An enquiry does not automatically subscribe you to marketing communications. Legal bases are Article 6(1)(b) or (f) GDPR; statutory retention relies on Article 6(1)(c).

Contact enquiries and applications, including submitted documents, are forwarded to the responsible people in our company. We use contracted providers for business email communication and its secure operation. They receive the data necessary to deliver and store these messages. The legal basis follows the relevant enquiry or application process. Stored messages and documents are subject to the retention and deletion criteria described below.

When using an available application form, we process your name, contact details, address, date and place of birth, professional history, qualifications, skills, languages, availability, salary expectations and selected vacancy, to the extent requested in the form. This also includes submitted documents such as your CV, cover letter and certificates and the technical delivery information.

These data are used to assess and communicate about your application. Required and optional fields are identified in the form. Please provide information relevant to the position, and avoid unnecessary sensitive information, particularly about health, religion, political views or other private circumstances. A missing optional consent does not affect the assessment of your application.

The legal basis is section 26(1) BDSG and, where applicable, Article 6(1)(b) GDPR. Access is restricted to people involved in recruitment and necessary technical service providers. This website does not make automated recruitment decisions or perform applicant scoring.

For positions with special security requirements, the form may ask for general information about an existing security clearance level and willingness to undergo an official vetting procedure. This does not replace an official security check and does not establish entitlement to access classified information.

Do not send complete security declarations, clearance documents, criminal-record certificates or detailed travel and contact information through the general form. Any legally required additional examination must take place separately through suitable procedures. Processing criminal-conviction data is subject to the particular requirements of Article 10 GDPR and cannot be justified merely by a general consent checkbox.

Inclusion in our applicant pool is voluntary, independent of the current application and limited to up to six months from consent. With your permission, we retain the application and documents for consideration for other suitable positions and may contact you about them. You can withdraw at any time by emailing info@otoko.com. Without consent, the data are used only for the current application.

After the current recruitment process, retention depends on whether data are still needed for handling the application, establishing or defending claims, or complying with statutory obligations. When these purposes end, the data must be deleted unless another legal basis applies. Pool consent does not permit indefinite retention.

The internal application email records the consent and pool review/deletion date. Removal from mailboxes, archives and backups requires the corresponding operational deletion process; the form itself does not automatically delete those records after six months.

Our forms use Cloudflare Turnstile to limit automated abuse. Enabling the form protection may transmit technical data such as IP address, browser and device characteristics and interaction signals to Cloudflare. Turnstile returns a verification token, which our server validates before accepting a submission. Depending on configuration, a clearance cookie such as cf_clearance may also be used.

The optional form protection is loaded following your consent under Article 6(1)(a) GDPR and, where required, section 25(1) TDDDG. Server-side verification also protects against abusive requests. Without permission, Turnstile is not loaded and submission through the protected form is unavailable. Email and telephone remain available as alternatives.

Further information: Cloudflare Turnstile Privacy Policy. This is separate from the Cloudflare website-operation security described above.

We use our own web resources and contracted media-hosting and content-delivery providers to supply images, logos, fonts and editorial content. When your browser requests files directly, the provider receives your IP address, technical browser information and the requested file. The legal basis is our legitimate interest in a functioning website under Article 6(1)(f) GDPR.

The optional read-aloud function loads external audio content only after your consent under Article 6(1)(a) GDPR. You can withdraw this consent at any time through Cookie settings.

For optional website analytics, we use only the EU version, PostHog Cloud EU, hosted in Frankfurt am Main. The provider is PostHog, Inc. The service loads only after your statistics consent. Without this consent, no analytics data are sent to PostHog.

Statistics include pseudonymous session identifiers, page views, page type and language, technical device/browser information, link targets, reading depth, video usage, performance metrics and sanitised generic error events. For forms, only form type, progress step, submission attempt and success or failure are recorded. Names, email addresses, messages, application contents, filenames and uploads are not transmitted as analytics events. URL query parameters and fragments are removed. This integration does not link activity to customer or applicant profiles.

The pseudonymous identifier is held in the browser tab’s session storage; the integration is not designed for persistent recognition across browser sessions. IP storage for analytics and creation of person profiles are disabled. A technical connection nevertheless requires transmission of an IP address.

With statistics consent, feature flags and code-based A/B tests may display approved variants and evaluate their use. Without consent, the default presentation is used. The legal basis is Article 6(1)(a) GDPR and, for non-essential device access, section 25(1) TDDDG.

After you consent to analytics, we also record the referring website only as its domain, without its path or search parameters, and approved campaign attributes from a restricted list of values. The technical browser user agent helps distinguish automated traffic. Visible engagement time and reading depth are measured without input contents. For validation problems, only the affected field group is recorded, not the individual field or its value. Full URL query parameters, search terms and unrestricted campaign values are not transmitted.

Masked session recordings and heatmaps require additional consent beyond statistics. Public editorial page content and navigation are visible. Unapproved content and inputs are masked; forms, upload fields, videos, canvas content and embedded third-party pages are excluded from recording. Contact and application pages are not recorded. Heatmaps contain sanitised page addresses and interaction coordinates. Console logs and network-request bodies and headers are not recorded.

Rating surveys also require separate feedback consent. The integration sends only numerical ratings, not free-text answers. These functions remain disabled without statistics consent.

Withdrawal stops further collection and removes related local analytics storage. It does not retrospectively retrieve data previously transmitted lawfully; statutory erasure rights remain unaffected. Server-side analytics data are needed only to evaluate and improve the service; retention must be limited by deletion periods configured for the project.

Further information: PostHog Privacy Policy. You can change your selection through Cookie settings in the footer.

With the same additional consent, we may use PostHog Replay Vision to analyse approved recordings with AI for visible usability issues and navigation flows. Analysis uses recordings already protected in the browser and associated usage events. PostHog uses AI model providers, particularly Google Gemini. An EU project location does not imply that this AI processing occurs exclusively in the EU. Before activation, we review the current data processing terms, subprocessors and required transfer safeguards. This analysis does not take place without recording consent.

Links to maps, social networks, manufacturers, certificate records or our portals lead to separate services. A simple link does not load their content as an embedded map or social plugin. The destination receives the necessary connection data when you follow the link. Its own privacy information applies to processing on that service.

In addition to responsible OTOKO® staff, IT, hosting, communications and maintenance providers may receive data as necessary for their tasks. Processing on our behalf must meet Article 28 GDPR requirements. Disclosure may also be necessary to fulfil legal obligations or pursue legal claims.

We use PostHog Cloud EU and European Cloudflare infrastructure. International service providers may also involve processing or support access outside the EU/EEA. Using European infrastructure alone does not rule this out. Transfers must meet Articles 44 et seq. GDPR, for example through an applicable adequacy decision or appropriate safeguards such as EU Standard Contractual Clauses and necessary supplementary measures. Contact us for information about safeguards used for a particular processing activity.

Personal data should be retained only as long as needed for the relevant purpose. Criteria include the duration of an enquiry or contract, statutory retention duties, applicable limitation periods and any legal dispute. When the purpose ends and no further legal basis exists, the data must be deleted; where retention remains legally required, use must be restricted to that purpose.

The website uses encrypted HTTPS connections. Access to enquiries and applications must be restricted to responsible persons. Mailboxes, archives and backups must be included in deletion and access-control procedures; deleting browser cookies does not change these records.

Subject to the statutory conditions, you have rights of access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction (Article 18) and data portability (Article 20). Consent can be withdrawn at any time for the future. Lawfulness of earlier processing remains unaffected.

Where processing relies on Article 6(1)(e) or (f) GDPR, you may object under Article 21 on grounds relating to your particular situation. You may object to processing for direct marketing at any time.

Write to info@otoko.com. Reasonable information may be needed to verify identity and handle the request; please do not send unsolicited identity-document copies. Solely pseudonymous analytics data may not be attributable to you without additional information you provide.

You may also complain to a supervisory authority, particularly in your place of residence, workplace or the place of the suspected infringement. For our company in Cologne, a relevant authority is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2–4, 40213 Düsseldorf, Germany, poststelle@ldi.nrw.de, www.ldi.nrw.de.

We use structured Cloudflare logs for operation and fault diagnosis. When external export is enabled, these may also be processed in PostHog Cloud EU. Our application records contain technical event codes, sanitised code locations (file, line and column), the build identifier, route templates, status and duration, plus a random identifier for an individual request. We do not add form contents, documents or filenames, IP addresses, credentials, URL query parameters or raw exception messages to these records. Cloudflare may process additional platform metadata. These operational records are not linked to PostHog person profiles or session replays. Necessary operation and security logging relies on our legitimate interest under Art. 6(1)(f) GDPR. Access and retention must be limited to the operational purpose. Optional visitor analytics continues to require your consent.

When configured, we use Cloudflare Web Analytics only after statistics consent. It measures page views, technical browser/device information, load times and Core Web Vitals without analytics cookies. Query strings and fragments are removed from page and referrer addresses transmitted by the beacon. Our integration does not pass form fields or uploaded content. Loading the script and sending measurements involves technical connection data being received by Cloudflare. Provider details and international processing information appear above.

Installation is manual and controlled by consent. Automatic beacon injection in the Cloudflare dashboard must be disabled. Without statistics consent our beacon is not requested; withdrawal blocks its delivery and reloads the page. The legal basis is Article 6(1)(a) GDPR and, for non-essential device access, Section 25(1) TDDDG. Required Cloudflare operational/security logs are separate from this optional analysis.

After you consent to analytics, we load Google Analytics 4 directly through the Google tag (gtag.js). For users in the European Economic Area, the provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The service analyses the approved analytics events from our website. Loading it discloses your IP address and technical connection information to Google. Processing outside the EU, particularly in the United States, cannot be ruled out. Google’s privacy policy describes its processing and transfer mechanisms.

Optional activation relies on your consent under Art. 6(1)(a) GDPR and, where information is stored on or accessed from your device, section 25(1) TDDDG. We do not request the Google tag without consent. Our consent signals keep advertising storage, advertising user data and ad personalization disabled. This integration does not authorize arbitrary additional services: their purposes, providers and relevant retention periods must be considered before enabling additional tags.

The website passes the page path and language to the event interface, without form contents, uploads, URL query parameters or fragments. You can withdraw analytics consent in cookie settings. The page then reloads to discard the running Google tag code, and accessible first-party Google Analytics cookies are removed. This does not retroactively delete data already transmitted. No Google noscript iframe is loaded when JavaScript is disabled.

After analytics consent, Google Analytics 4 analyses pseudonymous page views, language, sanitised link destinations, reading depth, video interactions and generic form steps/submission status. Google Analytics may set first-party statistics cookies, particularly _ga and _ga_*. Their lifetime depends on the published tag configuration and must be limited to the analytical purpose. Google also receives technical connection data; processing in the United States cannot be excluded. Our consent signals and tag requirements disable advertising storage, ad personalisation and Google Signals. Account settings and published tags must comply with those requirements. No messages, contact details, application documents or free-text fields are passed through our event interface. The legal basis and withdrawal options are those of the statistics consent described above. Further information: Google Analytics privacy.

We update this policy when website functions, service providers or legal requirements change. Materially new optional processing is not enabled through an old consent. The date of this version appears at the beginning of the policy.