Privacy Policy

1. Information We Collect

Personal Information You Provide

• Full name, date of birth, nationality, and passport details
• Contact information: email address, phone number, home address
• Professional information: education, work experience, qualifications
• German language proficiency level
• Supporting documents: CV, diplomas, certificates, ID documents
• Account credentials (password stored using bcrypt encryption)
• Payment information (for non-Healthcare program applicants)

Information Collected Automatically

• IP address, browser type, device information
• Pages visited, time spent, referring URLs
• Session data for security and fraud prevention

2. How We Use Your Information

• To evaluate your eligibility for employment programs in Germany
• To match your profile with suitable German employers
• To communicate with you about your application status
• To schedule and conduct interviews
• To coordinate visa applications and relocation support
• To comply with German labor law and immigration requirements
• To improve our platform and services
• To send service-related emails (application updates, document requests)

3. Sharing Your Information

We share your information only in the following circumstances:

• German Employers: With your explicit consent, we share your anonymized or identified profile with potential employers in Germany for placement purposes. Employer names are kept confidential until a match is confirmed.
• Service Providers: Trusted third-party providers who assist with email delivery, hosting, and payment processing — bound by confidentiality agreements.
• Legal Requirements: When required by law, court order, or government authority in the US, Germany, or Pakistan.
• Business Transfers: In the event of a merger or acquisition, your data may be transferred with appropriate notice.

We never sell your personal data to third parties.

4. Data Retention

We retain your personal data for:

• Active applicants: for the duration of the placement process
• Placed applicants: 5 years after placement (legal compliance)
• Rejected/withdrawn applicants: 2 years, then securely deleted
• Uploaded documents: deleted within 90 days of account closure upon request

5. Your Rights (GDPR)

If you are located in the European Union or your data is processed in connection with Germany, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restriction: Limit how we process your data
• Right to Portability: Receive your data in a machine-readable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: At any time, without affecting prior processing

To exercise any of these rights, contact us at info@iwcommission.com.

6. Data Security

We implement industry-standard security measures including:

• HTTPS encryption for all data transmission
• bcrypt password hashing (cost factor 12)
• HTTP-only, secure session cookies
• Regular security audits and penetration testing
• Access controls limiting staff access to necessary data only
• Audit logging of all administrative actions

7. Cookies

We use cookies for session management, language preferences, and analytics. See our Cookie Policy for full details.

8. International Transfers

Your data may be processed in the United States (HQ), Germany (EU), and Pakistan. For transfers from the EU, we rely on Standard Contractual Clauses (SCCs) as approved by the European Commission.

9. Children's Privacy

Our platform is not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware of such collection, we will delete the data immediately.

10. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or a prominent notice on our website. Your continued use of the platform after changes constitutes acceptance.

11. Contact Us