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

Processing of Personal Data by the Data Controller Responsible for the Online Application Process 

General Information 
 
We are providing 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 we collect from you during the application process.   
 
Data Controller  
 
octonomy AI GmbH 
Hansaring 61 
50670 Cologne 
Germany 


Registration in the Commercial Register
Registration number: HRB119283  
Court of Registration: Cologne 

Data Protection Officer:dpo@octonomy.ai 
 
Personal Data in the Context of the Application Process 

Personal data refers to information about the personal or factual circumstances of an identified or identifiable natural person. This includes information such as your name, address, phone number, and date of birth, as well as details about your specific career history, etc., which can be reasonably linked to a specific person. Information that is  not (directly or indirectly) linked to your actual identity, however, is not considered personal data.   
 
Legal Basis and Purposes for Processing Personal Data in Job Applications and during the Application Process 

If you apply to us electronically – that is, via email or through our web form – we will collect and process your personal data for the purpose of handling the application process and carrying out pre-contractual measures. 
The legal basis for this is Art. 6(1)(b) of the GDPR (conducting the application process as a pre-contractual or contractual measure). Providing the information marked as required fields is necessary for the conduct of the application process; without this information, we cannot consider your application. To the extent that you voluntarily provide us with special categories of personal data (such as information regarding a severe disability or health data), we will process this data exclusively to the extent permitted under Art. 9(2) of the GDPR. If processing is based on your consent, the legal basis is Art. 6(1)(a) of the GDPR; to the extent that we process data to assert, exercise, or defend legal claims (such as under the AGG), we base this on Art. 6(1)(f) of the GDPR. 

By submitting an application on our recruiting page, you are expressing your interest in seeking employment with us. In this context, you provide us with personal data, which we use and store exclusively for the purpose of your job search or application. 
In particular, the following data is collected: 

  • Name (first and last name) 
  • Email address 
  • Phone number 
  • Salary expectation
  • Starting date
  • LinkedIn profile (optional) 
  • Channel through which you learned about us (optional) 
  • Github profile (optional)
You also have the option to upload relevant documents such as a cover letter, your resume, and certificates containing additional personal information. 
Only authorized employees from Human Resources or those involved in the application process have access to your data.  
Personal data is stored exclusively for the purpose of filling the vacant position for which you have applied.  
Your data will be stored for a period of 6 months following the conclusion of the application process. This is generally done to fulfill legal obligations or to defend against any claims arising from legal regulations. We will then delete your data. In this case, the data will only be available to us as so-called metadata – without any direct personal reference – for statistical analysis (for example, the proportion of female versus male applicants, the number of applications per time period, etc.).  
In addition, we offer you the option to have your data stored in our “Talent Pool” for 12 months after the application process ends, in order to identify any other positions that may be of interest to you. This also applies, for example, to applications for an apprenticeship or internship. 

Inclusion in our Talent Pool is based exclusively on your separate, voluntary consent (Art. 6(1)(a) GDPR), which we will obtain from you prior to inclusion. You may revoke this consent at any time with future effect; in the event of revocation, as well as upon expiration of the specified retention period, we will delete your data stored in the Talent Pool. If you do not give your consent, this will not result in any disadvantages for you. 
If, as part of the application process, you receive and accept an offer of employment from us, we will store the personal data collected during the application process for at least the duration of the employment relationship.   
 
Disclosure of Data to Third Parties 

The data you submit as part of your application is transmitted using TLS encryption and stored in a database. This database is operated by Personio GmbH, which provides human resources and applicant tracking software (https://www.personio.com/legal-notice/). In this context, Personio is our data processor pursuant to Art. 28 of the GDPR. The legal basis for this processing is a data processing agreement between us, as the data controller, and Personio.   
 
Use of External Service Providers in the Application Process 
 
In addition to Personio, we sometimes use other external service providers to carry out and support the application process (such as specialized recruitment agencies that assist us with hiring). To the extent that these service providers process personal data on our behalf, we select them carefully and bind them to our requirements through a data processing agreement pursuant to Art. 28 of the GDPR; they process your data exclusively in accordance with our instructions and for the purposes specified in this Privacy Policy. To the extent that services are used that involve the transfer of personal data to a third country outside the EU or the EEA (in particular to the U.S.), such transfers take place only if an adequacy decision by the European Commission (such as the EU-U.S. Data Privacy Framework) is in place or if appropriate safeguards within the meaning of Art. 46 of the GDPR (in particular standard contractual clauses) exist. If we receive your data from such service providers or from publicly accessible professional networks, we process it for the same purposes as data collected directly from you. 
 
Recording and Transcription of Conversations 

If conversations (such as video or telephone interviews) are recorded or transcribed as part of the selection process, this is done exclusively on the basis of your prior, separate, and voluntary consent (Art. 6(1)(a) of the GDPR). We will inform you of this before the recording begins. You may refuse to give your consent and may withdraw it at any time with future effect without this resulting in any disadvantage to you in the application process. 
 
Automated Decision-Making 
 
No decision within the meaning of Art. 22 of the GDPR based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you will be made during the application process. 
 
Data Subject Rights 

 
To the extent that we, as the data controller, process 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 purpose of the processing; these may include, in particular, the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR), the right to data portability (Art. 20 GDPR), and the right to object (Art. 21 GDPR). If the processing of personal data is based on your consent, you have the right to withdraw this consent under Art. 7(3) GDPR. In addition, you have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data (Art. 77 GDPR). 
To exercise your rights as a data subject with regard to the data processed in this online application process, please contact our Data Protection Officer (see Section 2).   
 
Final Provisions 

We reserve the right to amend this Privacy Policy at any time to ensure it always complies with current legal requirements or to reflect changes to the application process or similar matters. The new Privacy Policy will then apply to any subsequent visit to this recruiting page or any subsequent application. 
In addition to this privacy policy, you can view our general privacy policy at Privacy - octonomy. Additional information regarding data processing by the operator of the recruiting page (Personio) can be found in the section below.

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.