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

General information

This data privacy statement, which refers exclusively to data collected as part of the online application process, is to inform you about how your personal data that is collected as part of the online application process is handled at our end.

The controller
The controller under data protection law is:
New Horizon GmbH
Neue Schönhauser Straße 2
13187 Berlin

Commercial register entry number: HRB 199884
Registration Court: Amtsgericht Berlin
Data Protection Officer: Spirit Legal, Neumarkt 16-18 Messehofpassage, Aufgang E, 04109 Leipzig

Personal data collected as part of the application process

Personal data means any information concerning the personal or material circumstances of an identified or identifiable individual. This includes information such as, for example, your name, address, telephone number and date of birth, but also data relating to your specific career etc. by reference to which a specific individual can be identified with reasonable effort. However, information which cannot be (in)directly associated with your real-life identity is not personal data.

Fundamentals and purposes of processing personal data collected from application documents and during the application process

If you apply to us electronically, i.e. via e-mail or using our online form, we will collect and process your personal data for the purpose of executing the application process and preparing contracts. By submitting an application via our recruitment website, you express your interest in taking up work with us. In this context, you transmit personal data, which we will use and store exclusively for the purpose of your job search / application process.
In particular, the following data is collected during this process:

name (first and last names)
e-mail address
phone number
LinkedIn profile (optional)
channel through which you found us
Salary expectation (optional)
Starting Date

Furthermore, you can choose to upload expressive documents such as a cover letter, your CV and reference letters. These may contain additional personal data such as date of birth, address etc. Only authorized HR staff and/or staff involved in the application process have access to your data. The personal data is stored, as a rule, exclusively for the purpose of filling the vacancy for which you have applied.

Your data will be stored for a period of 90 days after the application process has been concluded. This is usually done to fulfill legal requirements and/or defending ourselves against any claims arising from legal provisions. After this period, we are obligated to delete or anonymize your data. In case of anonymization, the data will only be available to us in the form of so-called metadata, without any direct personal reference, for statistical analysis (for example, share of male and/or female applicants, number of applications per specified period of time etc.).

Furthermore, we reserve the right to store your data for 120 days after the application process has been concluded for the purpose of adding it to our Talent Pool in order to identify any other vacancies that may be of interest to you. This includes, for example, applications for apprenticeships or internships. By accepting the data privacy statement, you consent to any further storage of your data as well as its inclusion in our Talent Pool.
Should you be offered and accept a position with us during the application process, we will store the personal data collected as part of the application process for at least the duration of your employment.

Disclosure of data to third parties

Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. This database is operated by Personio GmbH, which offers a human resource and applicant management software solution (https://www.personio.com/legal-notice/). In this context, Personio is our processor under article 28 of the GDPR. In this case, the processing is based on an agreement for the processing of orders between us as the controller and Personio.

Rights of data subjects

If we as the 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 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 during this online application process, please refer to our Data Protection Officer (see item 2).

Concluding provisions

We reserve 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 application process or other processes. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application. In addition to this data privacy statement, please view our general data privacy statement at https://www.timeless.investments/datenschutz

Application procedure

We process the data necessary for the online application process (name, email address and location) as well as data you have sent us in connection with your application in order to check your suitability for the position (or any other open positions in our company) and to carry out the application process.
Legal basis for the processing of your personal data in this application procedure is primarily § 26 BDSG in the version valid from 25.05.2018. Accordingly, the processing of the data required in connection with the decision on the establishment of an employment relationship is permissible. Should the data be necessary for legal prosecution after completion of the application procedure, it may be processed on the basis of the requirements of Art. 6 DSGVO, in particular to safeguard legitimate interests pursuant to Art. 6 para. 1 lit. f) DSGVO. Our interest then lies in the assertion or defence of claims.
Candidate data will be deleted after 6 months in the event of rejection. In the event that you have agreed to further storage of your personal data, we will transfer your data to our applicant pool. There the data will be deleted after two years. If you have been awarded a position as part of the application process, the data will be transferred from the applicant data system to our personnel information system.

We use a specialized software provider for the application process. This provider acts as a service provider for us and may also obtain knowledge of your personal data in connection with the maintenance and servicing of the systems. We have concluded a so-called order processing contract with this provider, which ensures that the data processing is carried out in a permissible manner.

Your applicant data will be viewed by the personnel department after receipt of your application. Suitable applications will then be forwarded internally to the department managers responsible for the respective open position. The rest of the process is then coordinated. In the company only those persons have access to your data who need it for the proper course of our application procedure.

You have the possibility to object to the processing of your data at any time. Your right to object exists for reasons arising from your particular situation, unless we can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, and also if the processing serves to assert and exercise or defend against legal claims (Art. 21 para. 1 DSGVO).

A right of objection exists in particular if the processing is not necessary for the fulfilment of a contract with you, which is described by us in the previous description of the functions. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out our compelling reasons worthy of protection on the basis of which we will continue the processing. 

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.