Data Privacy

PRIVACY POLICY

Version: 2026-02-HK03 | Status: 16.02.2026

Information for data subjects pursuant to Articles 13 and 14 of the EU General Data Protection Regulation (GDPR) and the EU AI Act.

1. General Information

Details of the Responsible Body (Controller)

  • Company: Horwood-Köhler GmbH
  • Legal Representatives: Agnes Horwood-Köhler, Richard Horwood-Köhler
  • Address: Schopenhauerstraße 2, 85579 Neubiberg, Germany
  • Commercial Register: HRB 236813, Local Court (Amtsgericht) Munich
  • Contact: kontakt@horwood-koehler.de | Tel: +49 (0) 89/20928356

Data Protection Officer Agnes Horwood-Köhler | Email: kontakt@horwood-koehler.de

2. Hosting and Security on this Website

External Hosting Our website is hosted by an external service provider (hoster). Personal data collected on this website (e.g., IP addresses, metadata) is stored on the hoster’s servers. The use of this provider is for the purpose of contract fulfillment towards our customers (Art. 6 (1) (b) GDPR) and in the interest of a secure provision of our online services (Art. 6 (1) (f) GDPR). We have concluded a Data Processing Agreement (DPA) with our hoster.

SSL or TLS Encryption For security reasons and to protect the transmission of confidential content, such as applications or inquiries you send to us, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the “https://” and the lock symbol in your browser bar.

 

3. Data Processing and Use of Artificial Intelligence (AI)

As part of our recruiting services, we use modern, AI-supported technologies (e.g., CV parsing, matching algorithms) to make application processes more efficient.

  • Type of use: Automated analysis of qualifications and matching with requirement profiles.
  • Transparency (EU AI Act): We use AI systems exclusively as decision-making support for our recruiters.
  • No automated individual decision-making: In accordance with Art. 22 GDPR, no purely automated decisions are made. Every final selection decision is made by a qualified employee of Horwood-Köhler GmbH (Human-in-the-loop).
  • Right to Explanation: In accordance with the requirements of the EU AI Act, you have the right to receive an explanation regarding the role of the AI system in the selection process and the main parameters that led to a specific recommendation or pre-selection.
  • Legal basis: Art. 6 (1) (b) GDPR (contract initiation) as well as our legitimate interest in efficient processes (Art. 6 (1) (f) GDPR).

4. Specific Information on the Application Process

  • Data concerned: Master data, qualifications, certificates, and communication data.
  • Purpose of processing: Placement of specialists and executives (Recruiting Services).
  • Duration of data storage:
    • Ongoing process: Until the vacancy is filled.
    • After rejection: Storage for 6 months (pursuant to the General Act on Equal Treatment – AGG).
    • Talent Pool: With your explicit consent, we store your data for 24 months.
  • Recipients: Potential employers (clients) following prior consultation with you.

5. Analysis Tools, Cookies, and Social Media

Special Note on Third-Party Platforms (e.g., LinkedIn, XING):

Where technical platform limitations prevent the permanent deletion of message threads, Horwood-Köhler GmbH considers these records as “archived at source.” The company’s policy is to never process or download attachments (such as CVs) from these threads once the 1-year retention period has expired, nor to transfer them into internal systems.

Cookie Consent (Consent Management) We use a consent management tool (cookie banner) to obtain your consent for the storage of certain cookies. Cookies are only set after your active consent (Art. 6 (1) (a) GDPR), unless they are technically necessary for the operation of the WordPress site.

Google Analytics 4 (GA4) & Google Ads We use GA4 and Google Ads for analysis and success measurement. IP anonymization is activated by default. Data transfer to the USA takes place on the basis of the EU-U.S. Data Privacy Framework.

Social Media (LinkedIn & XING) We only use static links to our profiles. Data is only transferred to the platform operators once you click the link and leave our website.

6. Processing of Customer, Supplier, and Employee Data

  • Purpose: Contract execution, invoicing, and statutory reporting obligations.
  • Storage period: The duration depends on statutory retention periods. For customer and contract data, this is generally 8 years (aligned with German commercial and tax law/HGB requirements).
  • Third-country transfer: Ensured through EU Standard Contractual Clauses (SCCs).

7. Your Rights as a Data Subject

You may assert the following rights against Horwood-Köhler GmbH:

  1. Access (Art. 15 GDPR)
  2. Rectification (Art. 16 GDPR)
  3. Erasure / Right to be forgotten (Art. 17 GDPR)
  4. Restriction of processing (Art. 18 GDPR)
  5. Data portability (Art. 20 GDPR)
  6. Objection to processing (Art. 21 GDPR)

To exercise your rights, or for your Right to Explanation regarding AI use, please contact: kontakt@horwood-koehler.de. You also have the right to lodge a complaint with the competent supervisory authority (Bayerisches Landesamt für Datenschutzaufsicht).

Document ID: HK-DSGVO-2026-02-16-V4-EN

Valid from: 16.02.2026

This privacy policy is the property of Horwood-Köhler GmbH.