Privacy Policy for the Application Process

1. General Information

We provide this privacy policy to inform you about how we handle your personal data collected during the application process. This policy applies exclusively to data collected as part of our online application process.

2. Data Controller

User Rights GmbH

Wrangelstraße 4

10997 Berlin, Germany

Commercial Register

Registration number: HRB 263898 B

Registry court: Amtsgericht Charlottenburg (Local Court of Charlottenburg)

No data protection officer has been appointed.

3. Personal Data in the Application Process

Personal data means any information relating to an identified or identifiable natural person. This includes information such as your name, address, phone number and date of birth, as well as data about your career history that can be attributed to a specific person with reasonable effort.

4. Purpose and Legal Basis for Processing

If you apply to us by email or via our web form, we collect and process your personal data for the purpose of conducting the application process and implementing pre-contractual measures (Art. 6(1)(b) GDPR).

In particular, the following data is collected:

• Name (first and last name)

• Email address

• Phone number

• LinkedIn profile (optional)

• Channel through which you became aware of us

• Relevant documents such as cover letter, CV and references (potentially containing additional personal data such as date of birth, address, etc.)

Access to your data is restricted to authorised HR staff and employees involved in the application process.

5. Retention Period

Your data will be stored for the duration of the application process. Following the conclusion of the process, your data will be retained for a further 6 months. This serves to fulfil legal obligations and to defend against any claims arising from statutory provisions. Thereafter, your data will be deleted or anonymised.

If you receive and accept an offer of employment during the application process, the personal data collected during the application process will be retained for at least the duration of the employment relationship.

6. Disclosure of Data to Third Parties

Data submitted as part of your application is transmitted using TLS encryption and stored in a database operated by Personio SE & Co. KG, a company providing HR management and applicant tracking software (https://www.personio.de/impressum/). Personio acts as our data processor in accordance with Art. 28 GDPR. The basis for this processing is a data processing agreement between User Rights GmbH as controller and Personio.

Your data will not be disclosed to any other third parties unless we are legally obliged to do so or you have given your express consent.

7. Your Rights as a Data Subject

To the extent that we process your personal data, you have the following rights as a data subject:

• 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 to processing (Art. 21 GDPR)

• Right to withdraw consent (Art. 7(3) GDPR)

To exercise your rights, please contact us directly:

User Rights GmbH, Wrangelstraße 4, 10997 Berlin, Germany

Email: info@user-rights.com

You also have the right to lodge a complaint with a supervisory authority. The supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit).

8. Changes to this Privacy Policy

We reserve the right to update this privacy policy at any time to ensure it complies with current legal requirements or to reflect changes to our application process. The version of the privacy policy in force at the time of your next visit to our recruiting page or your next application will apply.

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