We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.
2. Collection of personal data
We are responsible for the processing of the personal data that the Users contributes to the Service, or for the personal data that we in other ways collects with regards to the Service.
When and how we collect personal data
We collect personal data about Users from Users when Users;
- make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and
- use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
- provides identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;
We collect data from third parties, such as Facebook, Linkedin and through other public sources. This is referred to as “Sourcing” and be manually performed by our employees or automatically in the Service.
The types of personal data collected and processed
The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.
Purpose and lawfulness of processing
The purpose of the collecting and processing of personal data is to manage recruiting. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment.
Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.
The consent of the data subject
The User consents to the processing of its personal data with the purpose of Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;
- make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and
- when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
The User also consents to the Controller collecting publically available information about the User and compiles them for use in recruitment purposes.
The User consents to the personal data being collected in accordance with the above a) and b) will be processed according to the below sections Storage and transfer and How long the personal data will be processed.
The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under 9. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.
Storage and transfers
The personal data collected through the Service is stored and processed inside the EU/EEA, such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully complies with the lawfulness of third country transfers (as Privacy Shield) or to other supplies where the adequate safeguards are in order to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such adequate safeguards, contact us using the Contact details listed in 10.
How long the personal data will be processed
If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. Note that an applicant (User) may be interesting for future recruitment and for this purpose we may store Users’ Personal Data until they are no longer of value as potential recruitments. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 10.
3. Users’ rights
Users have the right to request information about the personal data that is processed by us, by notifying in writing, us using the contact details below under paragraph 10 below. Users have the right to one (1) copy of the processed personal data which belongs to them without any charge. For further demanded copies, Controller has a right to charge a reasonable fee on the basis of the administrative costs for such demand.
Users have the right to, if necessary, rectification of inaccurate personal data concerning that User, via a written request, using the contact details in paragraph 10 below.
The User has the right to demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances.
The User has the right to revoke any consent to processing that has been given by the User to Controller. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.
The User has under certain circumstances a right to data portability, which means a right to get the personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of others.
User has the right to lodge a complaint to the supervisory authority regarding the processing of personal data relating to him or her, if the User considers that the processing of personal data infringes the legal framework of privacy law.
However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret.
5. Transfer of personal data to third party
We will not sell or otherwise transfer Users’ personal data to third parties.
We may transfer Users’ Personal Data to;
- our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
- authorities or legal advisors in case criminal or improper behaviour is suspected; and
- authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.
We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to suppling the Service.
6. Aggregated data (non-identifiable personal data)
We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.
For questions, further information about our handling of personal data or for contact with us in other matters, please contact Rene Meyer (internal contact person concerning data protection) at firstname.lastname@example.org.
Datum: November 2020
Job applications not submitted via Teamtailor shall be sent to email@example.com or by post to the following address. Please note that sending your application by e-mail could involve risks regarding data security.
Below you shall find information concerning data processing during the application process.
Controller of data processing
Tracks GmbH, The DRIVERY GmbH, Mariendorfer Damm 1, 12099 Berlin
Represented by CEO
Amtsgericht Charlottenburg (HRB 193697 B)
Personal data and the purpose of processing
We process only the personal data you send us regarding your application and publicly available information to verify your qualifications for the specific position or other vacancies in our company.
The legal basis for processing your personal data regarding your application is Art. 6 para. 1 (b) GDPR in connection with § 26 Federal Data Protection Act (BDSG). According to Article 26, personal data shall be processed for the purposes of an employment relationship, if necessary, for the establishment of the relevant employment relationship.
After the application procedure, Art. 6 para. 1 (f) GDPR shall be the legal basis for data processing. The legitimate interest could include for example raising or rejecting legal claims.
In case of a negative reply, your application documents will be kept for one year. After this period, they will be completely destroyed according to data protection regulations.
Upon your consent to a further storage and use of your application documents, we shall include you into TRACKS applicant pool. In this case your personal data will be deleted after max. 1 ½ years.
In case of a positive reply, your application documents will be saved into TRACKS applicant tracking and personnel management system.
Transfer of your data
Your personal data will be transferred only to persons involved in the application procedure. This includes the personnel department, the respective department and, if necessary, the management/executive office. TRACKS will transfer your personal data only to our Applicant Tracking System (ATS) for the selection procedure (for more information, please look above). Your personal data is protected from any unauthorized access or data loss through suitable technical and organizational measures.suitable technical and organizational measures.
For further questions, please contact Rene Meyer (internal contact person concerning data protection) at firstname.lastname@example.org.