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Processing of (personal) data by the entity in charge of the online application process

General Information

We provide you with this Privacy Policy, which applies exclusively to data collected as part of the online application process, to inform you about how we handle the personal data collected from you during the recruitment process.

Data Controller

The data controller within the meaning of applicable data protection law is:
Eberlein und Kunz GmbH & Co. KG
Wollenberger Str. 4
13053 Berlin
Germany
Phone: +49 30 64316795
Registered in the Commercial Register
Registration number: HRA 65857 B
Register court: Berlin-Charlottenburg

Data Protection Officer:
WS Datenschutz GmbH
Phone: +49 30 88720788-4
Email: eberleinundkunz@ws-datenschutz.de


Personal Data Collected During the Application Process

Personal data refers to any information relating to an identified or identifiable natural person. This includes information such as your name, address, telephone number and date of birth, as well as details of your professional background and career history that can be attributed to a specific individual with reasonable effort.
Information that cannot be directly or indirectly linked to your actual identity is not considered personal data.

Legal Basis and Purposes of Processing Personal Data During Recruitment

If you apply for a position with us electronically, either by email or via our online application form, we collect and process your personal data for the purpose of managing the recruitment process and taking steps prior to entering into an employment contract.
By submitting an application through our recruitment website, you express your interest in working for our company. In this context, you provide us with personal data that we use and store exclusively for purposes related to your job application and the recruitment process.
In particular, we collect the following information:
  • Full name (first and last name)
  • Place of residence
  • Email address
  • Telephone number
  • Salary expectations
  • German language proficiency
  • Source through which you learned about us
You also have the option to upload supporting documents, such as a cover letter, CV and certificates. These documents may contain additional personal data, including your date of birth, address and other personal information.
Access to your data is restricted to authorized employees in the Human Resources department and other employees involved in the recruitment process.
As a general rule, your personal data is stored exclusively for the purpose of filling the vacant position for which you have applied.
Your data will be retained for a period of 180 days after the recruitment process has ended. This is generally necessary to comply with legal obligations or to defend against potential legal claims.
After this period, we are required to delete or anonymize your data. Once anonymized, the information will only be available to us as non-personally identifiable metadata for statistical analysis, such as the proportion of female and male applicants or the number of applications received within a given period.
If you receive and accept an offer of employment during the recruitment process, we will retain the personal data collected during your application for at least the duration of your employment relationship.

Inclusion in Our Talent Pool

If we would like to consider your profile for future job vacancies, we will separately ask for your consent to include you in our talent pool.
Inclusion in the talent pool takes place exclusively on the basis of your voluntary consent in accordance with Art. 6(1)(a) of the General Data Protection Regulation (GDPR) in conjunction with Section 26(2) of the German Federal Data Protection Act (BDSG).
Your decision to give or withhold consent will have no impact on your ongoing application process.
If you provide your consent, we will store your application data for a period of 12 months so that we can contact you regarding suitable future job opportunities.

You may withdraw your consent at any time with effect for the future.
Following withdrawal of your consent or expiry of the retention period, your personal data will be deleted or anonymized from the talent pool, unless statutory retention obligations require otherwise.

Disclosure of Data to Third Parties

The data submitted as part of your application is transmitted using TLS encryption and stored in a database.
This database is operated by Personio GmbH, a provider of human resources management and applicant tracking software (https://www.personio.de/impressum/).
In this context, Personio acts as our data processor in accordance with Art. 28 GDPR.
The legal basis for this processing arrangement is a data processing agreement concluded between us, as the data controller, and Personio.


Use of AI-Assisted Recruitment Technologies

To review incoming applications efficiently, we use AI-assisted technologies for selected job vacancies to support the employees involved in the recruitment process.
These technologies analyze the personal data contained in your application, particularly your CV and the qualifications, skills, professional experience, education, language proficiency and location relevant to the respective vacancy.
They provide our employees with a structured overview of this information, together with an indication of how closely your profile matches the requirements of the position.
As part of selected recruitment processes, we also use MADITA, an AI-assisted interview solution provided by HeyJobs GmbH.
MADITA conducts structured voice interviews based on job-related criteria. In doing so, it processes audio recordings, transcripts generated from these recordings and structured assessments.
HeyJobs processes this data on our behalf as a data processor in accordance with Art. 28 GDPR.
The purpose of this processing is to conduct and evaluate the recruitment process. The legal basis is Section 26(1) BDSG in conjunction with Art. 6(1)(b) GDPR.

The results support our recruitment team in assessing your application.
No decisions are made solely through automated processing within the meaning of Art. 22 GDPR. Decisions regarding the further course of the recruitment process are made by our employees.
As part of the technical processing, audio recordings and transcript content may also be temporarily processed in the United States.
The necessary safeguards for such processing are provided through the EU-US Data Privacy Framework, supplemented by Standard Contractual Clauses (SCCs).

Applicant data is generally deleted six months after completion of the recruitment process and is not used to train the AI models employed.

Rights of Data Subjects

Where we process personal data as the data controller, you, as a data subject, have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and purpose of the processing.
These rights may include, in particular:
  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
Where the processing of personal data is based on your consent, you have the right to withdraw that consent at any time in accordance with Art. 7(3) GDPR.
To exercise your rights regarding personal data processed as part of this online application process, please contact our Data Protection Officer using the contact details provided in the "Data Controller" section above.

Final Provisions

We reserve the right to amend this Privacy Policy at any time to ensure that it complies with current legal requirements or to reflect changes to our recruitment process or other relevant circumstances.
If you visit our recruitment website again or submit a new application, the updated Privacy Policy will apply.
In addition to this Privacy Policy, you can find our general Privacy Policy at:
https://eberleinkunz.de/datenschutz

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.