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

Last updated: 30.07.2018

General information
Your online application process is managed by Adsquare GmbH, Saarbrücker Str. 36, 10405, Berlin, Germany, http://www.adsquare.com/) ("Adsquare" or "we", "our" and "us") and we have issued this Privacy Notice ("Notice") to describe how we handle personal data that we hold about individuals applying for employment as well as all types of contingent and non-permanent positions, including agents, independent contractors, consultants, temporary contract workers, professional advisors and interns ("you").

This Notice sets out the personal data that we process about you during the application and recruitment process and the purposes of the processing and the rights that you have in connection with it.

Please also read the information below that is provided by the recruitment website operator (Personio GmbH) and our Privacy Policy (http://www.adsquare.com/privacy/) which explains the rights that you have in connection with our processing in more detail.

The controller
When you submit your online application, Adsquare is the "Controller" of your personal data as defined by the General Data Protection Regulation ("GDPR").
If you have any questions or concerns about our use of your personal information please contact our Data Protection Officer at privacy@adsquare.com.

Types of personal data we collect
During the application- and recruitment process at Adsquare, we may process contact information that you provide us such as your name, email address and phone number, date of birth, national ID/passport information, immigration status, nationality, signature, image, academic and professional data and job history.

We may also process further job application information such as the roles for which you are applying, your job application and related documentation/communications, cover letters, information from interviews and phone screenings, compensation/benefits requests, relocation information and information relating to previous applications you may have made to Adsquare and/or any previous employment history at Adsquare.

As a general rule, we do not process any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, genetic or biometric information, or information about your health/sex life or sexual orientation during the recruitment process, unless authorized by law or where necessary to comply with applicable laws.

If you submit application documents that contain such "special categories of personal data" (Article 9 GDPR), please note that you are not legally required to do so in the vast majority of cases and please refrain from providing such information unless it is specifically requested by Adsquare.

Purposes of personal data processing

We process personal data relating to your job application to manage and administer the application and carry out our recruitment process and selection procedures, or to comply with any relevant legal or regulatory obligations (such as non-discrimination regulations).

Consequently, Adsquare may use your personal data in relation to:

  • the evaluation and selection of applicants including for example setting up and conducting interviews and tests,
  • evaluating and assessing the results thereto and as is otherwise needed in the recruitment process including the final recruitment,
  • communicating with you during the recruitment process,
  • verifying your information and carrying our reference checks or background checks (where applicable), and
  • putting in place necessary arrangements for your future employment.
We may also collect information from third parties, for example, to obtain work references or to carry out background or criminal record checks (where permissible and in accordance with applicable laws).

If you are accepted for a job at Adsquare the information collected during the recruitment process will form part of your ongoing employment record.

Legal basis for processing your of personal data
The legal basis for processing the information described above will depend on the information concerned and the specific context in which we process your personal data but in general terms it will be derived from Article 6 GDPR (Lawfulness of Processing) as amended by any applicable national legislation such as - for Germany - Article 88 GDPR (Processing in the context of employment) and Section 26 German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG).

As a rule, the legal basis for the processing of your personal data is Article 6 para 1 lit. b) GDPR, Section 26 para. 1 BDSG ("performance of a contract") as we're taking steps prior to entering an employment contract with you where you are considered for employment.

However, in certain cases, the legal basis for the processing of your personal data is also Adsquare's legitimate interest (Art. 6 para 1 lit. f) GDPR) to carry out recruitment and to manage the hiring process and/or to protect the rights and interests of Adsquare, our employees, applicants and others, as required and permitted by applicable law (Article 6 para 1 lit. d) GDPR).

If you submit "special categories of personal data" (Article 9 GDPR) the legal basis for the processing of such data is your consent (Article 6 para. 1 lit. a) GDPR, Section 26 para. 2 and para. 3 BDSG).

Who do we share your information with?
If you have applied for a position, your personal data will be disclosed to adsquare's human resources department and your prospective superior for the role.

When you apply for several jobs in different adsquare affiliate companies, each adsquare human resources department may receive information about your simultaneous applications. In this case, your personal data will only be shared with the other adsquare affiliates if this is necessary for the efficient processing of your applications.

Your personal data will be stored by the recruitment website operator (Personio GmbH, please see below) and its hosting provider Amazon Web Services (AWS). The data will be stored on servers in Frankfurt and Karlsruhe, Germany and only accessed if this is necessary to maintain the system (in particular maintenance and repair work) and to ensure data security. All authorized persons who have access to your personal data are required to maintain confidentiality in accordance with the statutory provisions.

If your personal data is transferred to other parties and/or to recipients in countries other than the country in which you are resident, the international data transfer will be protected in accordance with our Privacy Policy (http://www.adsquare.com/privacy/ - please see section 'International Data Transfer').
Furthermore, your data will only be shared with third parties (e.g. authorities) insofar as this is legally permissible, for example if the processing is necessary for compliance with a legal obligation to which adsquare is subject (Article 6 para. 1 lit. c GDPR).

How long do we keep your information?
We retain your personal data as long as it is required for the above-mentioned purposes and to comply with the applicable legal, tax or accounting requirements.

When you are hired, your personal data will be entered into our human resources system for further processing.

If your application is not successful, we will delete your personal data at the latest 6 months after the completion of the application process for the respective position. The 6 months period does not apply if your personal data is subject to applicable legal, tax or accounting requirements which require adsquare to retain the data or you consent to a longer storage period, for example to contact you in connection with other positions that might be of interest to you in the future.

Your data protection rights
You have various rights with respect to our use of your personal data, for example the right to request information about the personal data that we hold about you. Details about your data protection rights are explained in our Privacy Policy (http://www.adsquare.com/privacy/ - please see section 'Your data protection rights').

To exercise these rights, please contact our Data Protection Officer at privacy@adsquare.com and we will consider your request in accordance with the applicable data protection laws.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

Changes and Contact details
We may update this Notice from time to time in response to changing legal, technical or business developments. When we update this Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws.

You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.

If you have any questions or requests relating to our processing of your personal data, please contact us at privacy@adsquare.com or by letter to:

adsquare GmbH
Saarbrücker Str. 36
10405 Berlin
Germany

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.