Privacy Policy for the WhatsApp-based BCG Recruiting Chatbot

Welcome to the service provided by The Boston Consulting Group GmbH, Ludwigstraße 21, 80539 Munich, which you can access through WhatsApp.

The protection of your privacy is our highest priority. We collect and use your personally identifiable data exclusively within the framework of the applicable data protection regulations. Our employees and representatives are obliged to comply with data protection regulations in accordance with legal requirements.

Below can find a description of the type, scope, and purpose of the collection and use of personal information. Personal information generally includes all data that can be related to you personally, such as your name, address, e-mail addresses, or user behavior.

You can access this information at any time on the website or in the chatbot. This information refers to the use of the service through WhatsApp.

1. CONTACT DETAILS OF THE RESPONSIBLE PARTY FOR USE OF THE BCG RECRUITING CHATBOT

The Boston Consulting Group GmbH
Ludwigstraße 21
80539 Munich
(hereinafter also “BCG”)

Authorized representative
Matthias Tauber, Managing Director and Senior Partner, Chairman of the Management Team for Germany and Austria

Using this service requires installation of the WhatsApp app. The provider Facebook is solely responsible for the provision and data protection of WhatsApp. Please refer to Facebook’s privacy policy for details on the purpose and scope of data collection by Facebook, the further processing and use of personal data there, and the related rights and setting options to protect your privacy. By using WhatsApp, you agree to Facebook’s privacy policy, in which case Facebook is the sole party responsible for data protection.

If you use the BCG Recruiting Chatbot through WhatsApp, BCG processes your personal data and is the data controller in this case.

2. GENERAL DATA PROCESSING INFORMATION

BCG collects and uses your personal data only to the extent necessary to provide our content and services. The collection and use of your personal data is voluntary. An exception applies in cases in which the processing of the data is permitted by legal regulations.

3. OVERVIEW OF THE SCOPE OF DATA COLLECTION AND STORAGE

BCG allows you to communicate with BCG through the WhatsApp app provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Furthermore, BCG provides a chatbot that holds information about the working environment at BCG in general, the application process at BCG, and recruiting events of BCG Germany & Austria.

3.1 Communication with BCG through WhatsApp

BCG has set up the BCG Recruiting Chatbot on WhatsApp to communicate with prospective applicants through this channel. The use of this channel is voluntary. You will not suffer any disadvantages if you do not use this service, as you can receive relevant information or contact opportunities through other channels. Using this service requires installation of the WhatsApp app.

If you use the BCG Recruiting Chatbot through WhatsApp, BCG processes your personal data and is the data controller for personal data processed through the BCG Recruiting Chatbot. The following personal data is collected and processed: your phone number, conversation content, and analytics data. The data is stored in a contact profile so that we can determine whether we have already had contact with you within the chatbot.

According to Facebook, all messages are fully encrypted end-to-end and are therefore available in plain text only to BCG and on your device.

3.2 Chatbot

BCG provides a recruiting chatbot that can be accessed through WhatsApp. In the chatbot, BCG answers users’ frequently asked questions about the working environment at BCG in general, the application process at BCG, and recruiting events of BCG Germany & Austria. BCG uses an automated process that allows users to retrieve information tailored to their needs based on their own input.

In the process, personal data is processed as described in the following:

Your phone number, conversation content, and analytics data. The data is stored in a contact profile so that we can determine whether we have already had contact with you within the chatbot.

You are not required to provide us with any personal information to use the BCG Recruiting Chatbot. This is only transmitted when you independently enter and send personal data or information to the chatbot.

Users who no longer wish to use the service can delete the chatbot’s phone number at any time and request the deletion of their personal data collected in the chat.

3.3 DeepL

DeepL is integrated into the Chatbot for speech recognition. The tool is provided by the following company:

DeepL SE
Maarweg 165
50825 Cologne
Germany
Fax: +49 221 95491533
info(at)deepl.com

To recognize the language of the message, DeepL captures the first four words of the message. For this reason, in order to prevent the transmission of personal data to DeepL, the user shouldn`t mention any personal data in the first four words.

3.4 Legal basis

The services are operated on the basis of our legitimate interest in a modern and easily accessible information and interaction opportunity (article 6(1)(f) GDPR).

If you are asked for consent to data processing, the legal basis of the processing is article 6(1)(a) GDPR. You can revoke your consent at any time in the chat. However, in case of a revocation, the chatbot cannot be used further, as the data processing is necessary for the functioning of the service. Revoking your consent does not affect the lawfulness of processing prior to such revocation.

3.5 Service providers

When you communicate with BCG through the WhatsApp-based BCG Recruiting Chatbot, metadata is processed by the following service providers:

  • WhatsApp: WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
  • Tyntec: tyntec Ltd, 20 Farringdon Street, London EC4A 4AB, United Kingdom

The following metadata is collected and processed:


Key

Description

messageId

The internal ID of the sent message.

channel

Is "whatsapp" in this case.

from

The WhatsApp user's mobile phone number. (e.g. 4915142326635)

to

The WhatsApp for Business mobile phone number that is used to send messages in Cognigy.AI.

receivedAt

When the message arrived at Tyntec (ISO-Date).

content

Contains the contentType and text of the message. This information is not important, since the incoming text message is stored under input.text in Cognigy.

event

Is "MoMessage" when the user sent a message back to Cognigy.

whatsapp.senderName

The WhatsApp user's name they configured in the WhatsApp settings.

timestamp

The ISO-Date of the incoming message.

In addition, your telephone number and the conversation content communicated by you in the chatbot will be stored on a SaaS platform of Cognigy GmbH, Speditionstraße 1, 40221 Düsseldorf, Germany, for the purpose of optimizing the chatbot and the user experience. This data is accessible only to BCG and other employees working on the “BCG Recruiting Chatbot” project who have been authorized by BCG to access the project.

3.6 Other

There is no legal or contractual obligation to provide the personal data. Please note that we cannot provide the corresponding services in this case. There is also no automated decision-making, including profiling.

3.7 Deletion periods
Users who no longer wish to use the service can delete the chatbot's phone number at any time and request the deletion of the collected personal data in the chat.

4. RIGHTS OF DATA SUBJECTS

4.1 Right to information

According to article 15 GDPR, you can request information about your personal data that BCG processes.

4.2 Right to object under article 21(1) GDPR

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data that is carried out on the basis of article 6(1)(f) GDPR. If you should object, the data processor will no longer process your personal data unless it can prove compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms, or unless the processing serves the assertion, exercise, or defense of legal claims. The collection of data to provide the services is indispensable for the operation of these services.

4.3 Right to rectification and completion

If the information you have provided is not (or no longer) correct, you can request a rectification in accordance with article 16 GDPR. If your personal data is incomplete, you can request that it be completed.

4.4 Right to erasure

You can request the erasure of your personal data according to article 17 GDPR.

4.5 Right to restriction of processing

According to article 18 GDPR, you have the right to request a restriction of the processing of your personal data.

4.6 Right to lodge a complaint

If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority under article 77(1) GDPR. This also includes the data protection supervisory authority responsible for the controller:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 27 (Schloss)
91522 Ansbach
Email: poststelle@lda.bayern.de
Phone: +49 981 53-1300, Fax: +49 981 5398-1300, Website: www.lda.bayern.de

4.7 Right to data portability

In the event that the conditions of article 20(1) GDPR are met, you have the right to have your personal data processed by BCG handed over to you or to third parties.

To exercise your rights described above, you can communicate your request directly in the chatbot.

5. DATA PROTECTION OFFICER

The Boston Consulting Group GmbH
Stephan Thiel
Ludwigstraße 21
80539 Munich
Datenschutz@bcg.com