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


I. General Information
The protection of your personal data is of utmost importance to the NFON Group. We act in accordance with applicable data protection regulations to safeguard the data collected during the application process. This privacy policy supplements our general privacy policy and informs you about how your data is handled during the application process.

II. Data Controller 
The entity responsible for processing your data in connection with the application process is:

Zielstattstraße 36
81379 München
NFON AG
Germany,

represented by the Head of Human Resources, together with the company mentioned in the job posting. A list of all NFON Group companies and their respective local responsibilities can be found in Section VII.
If you apply to NFON AG, NFON AG alone is responsible for data processing.
You can contact our Data Protection Officer, Claudia Standke, either by mail at the address above (attn: Data Protection Officer) or by email at datenschutz@nfon.com.

III. Data Processing
1. Contacting us
You have the option to contact us through various means, such as email, phone, social media platforms, or mail. If you contact us, we will process the personal data you voluntarily provide for the sole purpose of responding to your inquiry and communicating with you.
The legal basis for processing your data as part of your specific application is the pre-contractual employment relationship in accordance with Art. 6 (1) b) GDPR.
For general inquiries that are not directly related to a contractual relationship, data processing is based on our legitimate interest in responding to your inquiry quickly and efficiently, as per Art. 6 (1) f) GDPR.

2. Application Process 

When you apply to us—whether through our career page, email, This includes: mail, or a recruitment agency—we process the data necessary for registering and handling your application.


- First and last name
- Date of birth
- Email address
- Address
- Phone number
- Application-related documents, such as a cover letter, CV, diplomas, work certificates, details of previous employment history, and additional qualifications mentioned in your documents
- Optional application photo
- Salary expectations
- Availability information
- Any other details included in the documents you submit

The legal basis for this data processing is the execution of pre-contractual measures within the framework of the recruitment process, in accordance with Art. 6 (1) b) GDPR in conjunction with national data protection laws.
If your application documents contain special categories of personal data as defined in Art. 9 (1) GDPR (e.g., health data, disability status, ethnic background) or if you voluntarily disclose such information during the recruitment process, we process this data for the purpose of exercising rights or fulfilling obligations under labor law, social security, and social protection laws. The legal basis for this is Art. 6 (1) a) and c) GDPR in conjunction with Art. 9 (2) b) GDPR.

3. Conducting Interviews 
For digital job interviews, we use the Zoom platform, operated by Zoom Video Communications, Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA ("Zoom"), or conduct interviews via telephone.
For Zoom interviews, we provide you with a link in advance that allows you to join the video conference. Depending on the nature of the conversation, personal data may be processed, including your name, email address, technical connection data (e.g., IP address), and video/audio recordings if you activate your camera or microphone. Please note that Zoom acts as an independent data controller. You can find more information about how Zoom processes data in its Zoom privacy policy.
For telephone interviews, we process your contact details (e.g., phone number) to conduct the conversation.
The data you provide is used solely for the purpose of planning, conducting, and following up on the job interview and for the duration of the application process.
The legal basis for this data processing is Art. 6 (1) b) GDPR.

4. Use of the “JOIN” applicant management platform
We use the JOIN recruiting platform (Eichenstrasse 2, 8808 Pfäffikon SZ, Switzerland) to publish our job advertisements and to receive and initially process incoming applications. JOIN enables us to record and pre-sort applications in a structured manner. The documents submitted via JOIN are then manually transferred to our applicant management system Personio. The data is processed for the purpose of carrying out and managing application procedures via the JOIN platform on the basis of Art. 6 para. 1 lit. b) GDPR. In particular, personal master data (such as name, salutation, title, date of birth, telephone number and e-mail address), contents of the application documents (such as CV, cover letter, references and certificates), messages sent via JOIN as part of the application process and metadata-related information on the course of the application process (e.g. duration of the process or number of applications received) are processed. JOIN acts as a processor within the scope of this processing in accordance with Art. 28 GDPR. A corresponding contract for order processing has been concluded, which ensures data protection-compliant processing and compliance with suitable technical and organizational measures to protect your data.

Further information on data processing by JOIN can be found in JOIN's privacy policy.

5. Further Data Processing

If you receive a job offer, your data will be transferred to the regular personnel management process, where it will be stored and retained in accordance with legal requirements. If your application is unsuccessful, your data will generally be deleted 180 days after rejection, unless you consent to being included in our applicant pool under Art. 6 (1) a) GDPR. For unsolicited applications, your data will be stored for a maximum of six months. If no offer is made or no further activity occurs within this period, your data will be automatically deleted.
 
IV. Recipients of Your Data

We generally do not share your data with third parties unless required by law (e.g., in response to a request from law enforcement authorities) or necessary for carrying out the application process.
We use Personio SE & Co. KG, Seidlstraße 3, 80335 Munich ("Personio") to operate our career platform. Personio provides software for processing and managing application data and processes the data solely on our behalf.
Additional service providers (e.g., HR management tools) or members of the NFON Group may be involved in evaluating applications.
In principle, your personal data is not transferred to a third country. If such a transfer is necessary, it will only occur in compliance with the GDPR, for example, through EU Standard Contractual Clauses.

V. Data Retention and Deletion

Your application will be deleted from our applicant management system 180 days after a decision has been made. If we wish to store your application for a longer period, we will first obtain your consent via email.

VI. Your Rights

You have 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) and the right to data portability (Art. 20 GDPR) under the respective legal requirements. You also have the right to object to and withdraw your consent to data processing. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).
If you wish to exercise one of these rights, please send an informal letter to the contact address listed below. If you wish to exercise your right of objection or withdrawal, the data processing carried out up to this point remains lawful and unaffected.

NFON-Group Companies:

NFON AG
Zielstattstraße 36
81379 München
Germany

NFON ITALIA SRL
Cso Magenta 82
Milano -20123
Italy

NFON GmbH
Linzer Straße 55
3100 St. Pölten
Austria

NFON Polska Sp. z o.o.
Ul. Przeskok 2
00-032 Warszawa
Poland

NFON France
81 Rue Réaumur
75002 Paris
France
 
NFON UK Ltd.
The Atrium
1 Harefield Road
Uxbridge UB8 1PH
United Kingdom

NFON IBERIA SL
Paseo de la Castellana 135,
7ª Planta (Madrid – 28046)
Spain

botario GmbH
Konsul-Smidt-Straße 8p
28217 Bremen
Germany
 
NFON Developments, Unipessoal, Lda.
R. Barata Salgueiro 37 5 Piso,
1250-044 Lisboa
Portugal
 
NFON Hub sh.p.k
St. Xhevdet Doda, Dukagjini Center, Floor II, No.7, 10000 Prishtine
Kosova


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.