Databeskyttelse for ansøgere

Information Obligations under Art. 13 and Art. 14 GDPR for Applicants

Protecting your personal data and being transparent about how it is processed are very important to us. We therefore inform you below about the processing of your personal data in accordance with Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR). Processing is carried out in compliance with the GDPR and any supplementary or stricter national data protection provisions of the applicable law.

The processing of your personal data gives you the following rights:

Right of access (see Art. 15 GDPR or Swiss FADP Art. 25)
Right to rectification (see Art. 16 GDPR or Swiss FADP Art. 32)
Right to erasure (see Art. 17 GDPR or Swiss FADP Art. 32)
Right to restriction of processing (see Art. 18 GDPR or Swiss FADP Art. 32)
Right to object (see Art. 21 GDPR or Swiss FADP Art. 32)
Right to data portability (see Art. 20 GDPR or Swiss FADP Art. 28)

Where processing is based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, you may withdraw any consent you have given at any time with effect for the future. The lawfulness of processing carried out before the withdrawal remains unaffected.

Contact details of the Data Protection Officer: Jasmin Muhmenthaler-Sturm, Datenbeschützerin GmbH, Unterer Sand 9, 94209 Regen, E-mail: info@datenbeschuetzerin.de, Phone: +49 9921 22 88 9000

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data is unlawful.

The companies named in this privacy notice process personal data in the context of the application procedure in part as joint controllers pursuant to Art. 26 GDPR, insofar as they jointly determine the purposes and means of the processing.

Controller

The controller responsible for data processing is:

glueckkanja AG

Kaiserstraße 39, 63065 Offenbach am Main, Germany
Phone: +49 69 4005520, E-mail: info@glueckkanja.com
Competent supervisory authority: The Hessian Commissioner for Data Protection and Freedom of Information, represented by Prof. Dr. Alexander Roßnagel, Gustav-Stresemann-Ring 1, 65189 Wiesbaden

glueckkanja Austria GmbH

Ungargasse 37, 1030 Wien, Austria
Phone: +43 676 4768313, E-mail: see above
Competent supervisory authority: Austrian Data Protection Authority, Barichgasse 40-42, 1030 Wien

glueckkanja Iberica SL

Eloy Gonzalo 27, 28010 Madrid, Spain
Phone: +34 680 225643, E-mail: see above
Competent supervisory authority: Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001 Madrid, Spain

glueckkanja Switzerland AG

Bahnhofplatz 10B, 3011 Bern, Switzerland
Phone: +41 31 5611900, E-mail: see above
Competent supervisory authority: Federal Data Protection and Information Commissioner (FDPIC), Data protection advisor, Feldeggweg 1, 3003 Bern, Switzerland

glueckkanja Pacific Pty Ltd

Level 63, 25 Martin Place, Sydney, NSW 2000, Australia
Phone: +61 2 9284 9749, E-mail: see above
Competent supervisory authority: Office of the Australian Information Commissioner (OAIC), GPO Box 5288, Sydney NSW 2001, Australia

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Personal data is transferred to third countries (countries outside the European Economic Area, EEA) only where this is necessary for the performance of the service contract, you have given us your consent, or it is otherwise permitted by law. In such cases, we take measures to ensure the protection of your data, for example by means of contractual arrangements. We transfer data exclusively to recipients who ensure the protection of your data in accordance with the GDPR provisions on transfers to third countries (Art. 44 to 49 GDPR).

Our contractual relationship is not decided by means of automated processing or profiling; that is, no automated individual decision-making within the meaning of Art. 22 GDPR takes place to establish, perform or conduct the contractual relationship. Should this procedure be used in individual cases, we will inform you separately where required by law.

As a rule, we collect your personal data directly from you. If data exceptionally originates from other sources, we will inform you separately.

1. Privacy Notice for Applicants

We are pleased that you are interested in us and are applying or have applied for a position at our company. Below, we inform you about the processing of your personal data in the course of the application procedure.

1.1 Handling of Applicant Data

You can apply to us (e.g. by e-mail, by post or via an online application form). Below, we inform you about the scope, purpose and use of the personal data we collect in the course of your application. We assure you that your data is collected, processed and used in accordance with the applicable data protection provisions and treated in strict confidence.

1.2 Scope and Purpose of Data Collection

When you send us an application, we process the associated personal data (e.g. contact and communication data, application documents and notes from interviews) to the extent necessary to decide on establishing an employment relationship.

The legal basis for this is Art. 6(1)(b) GDPR or Art. 31 FADP and, where you have given consent, Art. 6(1)(a) GDPR (under Art. 6 FADP, no consent is required for this). You may withdraw any consent you have given at any time.

Where processing is necessary to protect legitimate interests, it is based on Art. 6(1)(f) GDPR or Art. 31 FADP. Our legitimate interest lies in the efficient design and organization of the application process.

Within our company, your personal data is passed on exclusively to persons involved in processing your application.

If your application is successful, the data you have submitted will be stored in our data processing systems for the purpose of carrying out the employment relationship.

1.3 Retention Period

If we cannot offer you a position, you decline a job offer or you withdraw your application, we reserve the right to retain the data you have submitted for up to six months after the end of the application procedure, based on our legitimate interests pursuant to Art. 6(1)(f) GDPR or the overriding interest under Art. 31 FADP. Afterwards, the data will be deleted and any documents submitted will be destroyed. Retention serves in particular as evidence in the event of a legal dispute.

Longer storage takes place only if you have consented to it or if statutory retention obligations prevent deletion.

1.4 Inclusion in the Applicant Pool

If we cannot make you a job offer, it may be possible to include you in our applicant pool. In this case, the data submitted in the course of your application is stored so that we can contact you about suitable vacancies.

Inclusion in the applicant pool takes place exclusively on the basis of your express consent pursuant to Art. 6(1)(a) GDPR (under Art. 6 FADP, no consent is required for this). Giving this consent is voluntary and has no influence on the ongoing application procedure.

You may withdraw your consent at any time with effect for the future. In this case, your data will be deleted from the applicant pool, unless statutory retention obligations prevent this.

Data in the applicant pool is deleted no later than two years after consent was given.

1.5 Which Processors Do We Work With in Connection With Your Data?

As a Microsoft partner, we use Microsoft 365 based on a European tenant (see also https://www.glueckkanja.com/en/privacy). For application processes, we primarily use a specialized software provider: Personio (personio.com). Via its platform, it provides a data-protection-compliant software-as-a-service (SaaS) solution for managing personnel and application data.

In some application processes, data may also be stored and processed by the specialized SaaS providers Assessio (for aptitude diagnostics and assessments) and Deskpro (ticket system for communication with external recruiting service providers). Here, too, we ensure data security in accordance with legal requirements.

After your application is received, your application data is reviewed by the HR department. Suitable applications are then made available to the managers responsible for the respective position and other persons involved in the application process.

Within our company, only those persons who need access to your data for the proper conduct of the application procedure have access to it.

1.6 Services Used

Personio: AI functions of the applicant management software. The provider is Personio SE & Co. KG, Seidlstraße 3, 80335 Munich, Germany.
Microsoft 365 Copilot: The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.
Deskpro, Inc., 2021 E. 5th St, Suite 190, Austin, TX 78702, USA
HR Diagnostics AG, Königstr. 20, 70173 Stuttgart, Germany

We have concluded data processing agreements with all providers.

Further information on the providers' data protection can be found at:

Microsoft: https://www.microsoft.com/en/trust-center/privacy
Personio: https://support.personio.de/hc/en-us/articles/360000975025-Overview-of-data-privacy-and-security-at-Personio
Deskpro: https://deskpro.com/legal/privacy and https://deskpro.com/security
Assessio: https://assessio.com/trust-center/personal-data-processor/

2. Use of Artificial Intelligence (AI) in the Application Process

2.1 What We Use AI For

We use AI-supported functions as a working aid for our recruiting team, exclusively for the following purposes:

Summaries: Automated summaries of application documents and interview notes to make processing easier.
Analysis and structuring of application documents: To support our recruiting team, AI-supported functions can analyze information from application documents and structure it against the requirements of an advertised position. In particular, details on qualifications, skills, professional experience, education, language skills and location are evaluated, presented in a clear form and compared with the requirements of the respective position.
Wording suggestions: Suggestions for texts, e.g. for job advertisements, feedback or scheduling.
Statistics: Statistical evaluations of the application process (e.g. number of applications, duration of process steps). We analyze aggregated data and draw no conclusions about individual applicants.

2.2 No Automated Decision-Making

All decisions in the application process are made exclusively by people. This includes in particular pre-selection, invitations, rejections and hiring.

Our employees review every AI result before it is used.

AI-supported functions can analyze information from application documents and provide indications of how well it matches the requirements of a position. This information serves solely as support for the persons involved in the application process. No automatic selection, rejection or other automated decision about applicants takes place.

Data processed when using the AI systems is not used to train or improve the underlying AI models. Inputs and outputs serve solely to provide the respective services and are not used by the providers to develop, train or optimize their generative AI models.

Data processed in the AI module is deleted in accordance with the general retention periods for applicant data.