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

Privacy Policy for the Online Application Process

General Information

This privacy policy refers exclusively to the data collected during the online application process. It is intended to inform you about how we handle your personal data collected during your application.

Responsible Entity

Surf Spirit GmbH & Co. KG
Am Lenkwerk 7
D - 33609 Bielefeld
Germany
Phone: +49 156 79 505600
Email: smile@surf-spirit.com
Registered with the District Court of Bielefeld, A16517
General Partner: Surf Spirit Geschäftsführungs-GmbH
Managing Director: Nils Schlüter
VAT ID: DE310916264

Personal Data in the Application Process

Personal data refers to information relating to an identified or identifiable natural person. This includes, for example, your name, address, phone number, date of birth, and details about your professional background, which can reasonably be linked to you. Information that cannot be directly or indirectly associated with your real identity is not considered personal data.

Legal Basis and Purpose of Processing Personal Data in Applications

If you apply to us electronically, via email or through our web form, we collect and process your personal data for the purpose of managing the application process and taking pre-contractual measures.
By submitting an application via our recruiting page, you express your interest in working with us. You provide us with personal data, which we use and store exclusively for the purpose of your job search/application.
The following data in particular may be collected:

First and last name
Email address
Phone number

You may also upload relevant documents such as a cover letter, resume, and certificates, which may contain additional personal data (e.g., date of birth, address, etc.).
Only authorized personnel from our HR team or individuals involved in the application process will have access to your data.
The data will be stored strictly for the purpose of filling the vacancy you applied for.
We retain your data for a period of 90 days after the end of the application process, typically to comply with legal obligations or to defend against potential claims under legal regulations. After this period, your data will be deleted or anonymized. In that case, the data will only be available to us in the form of so-called metadata, without direct reference to a person, for statistical purposes (e.g., gender ratio, number of applications within a given time frame, etc.).
We also reserve the right to store your data in our "Talent Pool" for 150 days after the end of the application process in order to identify any other suitable positions for you. This also applies to applications for internships or apprenticeships. By accepting this privacy policy, you consent to the extended storage of your data and inclusion in our Talent Pool.
If you receive and accept an offer of employment with us, your personal data collected during the application process will be stored at least for the duration of your employment.

Disclosure of Data to Third Parties

The data you submit in your application will be transmitted via TLS encryption and stored in a database. This database is operated by Personio GmbH, which provides a human resources and applicant management software (https://www.personio.de/impressum/).
In this context, Personio acts as our data processor in accordance with Article 28 of the GDPR. The processing is based on a data processing agreement between us as the controller and Personio.

Your Rights as a Data Subject

If we process your personal data, you as a data subject have specific rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and purpose of processing. These include, in particular:

Right to 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 (Art. 21 GDPR)

If the processing is based on your consent, you also have the right to withdraw that consent at any time (Art. 7 (3) GDPR).
To exercise your rights regarding the data processed as part of this online application procedure, please contact our data protection officer (see section 2 above).

Final Provisions

We reserve the right to update this privacy policy at any time to reflect changes in legal requirements or adjustments to our application procedures. The updated version will apply to any future visits to this recruiting page or future applications.

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.