Privacy policy for applicants

Privacy NOTICE FOR APPLICANTS

This Privacy Notice is to inform you about the processing of your personal data when you apply to LOYALTY PARTNER GmbH or its affiliated companies (see Section 1) via letter, email or the online application tool (collectively referred to below as the “application process”).

1. Parties responsible for data protection

LOYALTY PARTNER GmbH and the company to which you are applying are jointly responsible for data protection in the application process. This may include the following companies: PAYBACK GmbH, LOYALTY PARTNER Solutions GmbH, and PAYBACK Austria GmbH. The companies have entered into agreements specifying which of them fulfills which data protection obligations; LOYALTY PARTNER will provide the essential content of these agreements upon request. PAYBACK Austria GmbH has its registered office at Kärntner Str. 21 - 23, 1010 Vienna; all other companies have their registered office at Theresienhöhe 12, 80339 Munich and are collectively referred to below as “LOYALTY PARTNER.” You can reach LOYALTY PARTNER by email at Karriere@PAYBACK.GROUP.

2. Your data when accessing the online application tool

When you access the online application tool, the following data is recorded for technical reasons by the web server of LOYALTY PARTNER’s service provider and stored until it is automatically deleted: The page from which the online application tool was accessed, the content accessed, the date and time of the server request and the access, the amount of data transferred, the access status (request successful, file transferred, file not found, etc.), a description of the type and version of the web browser used/identification data of the browser and operating system used, and the IP address of the requesting computer. This data is collectively referred to as “log files.”

Data storage as log files ensures the proper functioning of the online application tools and enables LOYALTY PARTNER to improve the application tool. LOYALTY PARTNER is not able to assign the log files to specific persons, nor is there any statistical analysis of this data at this time. This data is also not transmitted to third parties.

The legal basis for the data processing described above is in each case Art. 6 para. 1 f) GDPR (balancing of interests – based on Loyalty Partner’s interest in providing potential employees with an online application tool).

3. Your data when submitting an application

3.1 Your application data

When you apply online for a position at LOYALTY PARTNER, you may send your application materials (e.g. cover letter, CV, certificates) either via email or using the online application tool. To use the application tool, it is first necessary to create a personal account. This account can be used to manage your applications and profile in the application tool.

In order to process your application, LOYALTY PARTNER requires your full name, contact information (address, email address, telephone numbers), your CV (in particular information on training, studies, degrees, previous employers and current employer, if applicable) and suitable proof of your qualifications (e.g. certificates, work samples). In addition, you can voluntarily provide LOYALTY PARTNER with further information, for example in your cover letter, such as your current salary and your desired salary.

All of this personal data is collectively referred to below to as “application data.”

If you apply via letter, email or an HR consultant, your application data will be entered manually by LOYALTY PARTNER into the online application tool. This is necessary so that these applications can also be handled using the standardized application process.

LOYALTY PARTNER processes your application data exclusively for conducting the application process. In particular, this includes LOYALTY PARTNER’s collecting and reviewing the application as well as contacting you to invite you to an interview, requesting further information about you if necessary, or determining the final acceptance or rejection regarding the specific position for which you have applied.

Your application data will only be disclosed to those LOYALTY PARTNER employees who are directly involved in the application process, including the decision to fill the position.

This data will only be transmitted to third parties outside LOYALTY PARTNER if and insofar as you have separately consented to such transmission.

3.2 Legal basis

The legal basis for the data processing described above is Art. 6 para. 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG (German Federal Data Protection Act; data processing for purposes of the employment relationship, in particular for the decision on establishing an employment relationship).

4. Assessment center and selection days

4.1 Conducting

For some positions, LOYALTY PARTNER conducts so-called assessment centers or selection days in addition to the application process as described in Section 2. These serve to help us get to know you better and assess how well you fit the open position. In this context, we use your contact data (email address, telephone number) to invite you to take the preliminary online test. When conducting the assessment center or selection days, we use your application data (e.g. CV) to better assess your qualifications.

Your application data will only be disclosed to those LOYALTY PARTNER employees who are directly involved in the application process, including the decision to fill the position.

4.2 Legal basis

The legal basis for the data processing described above is Art. 6 para. 1 lit. b) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG (German Federal Data Protection Act; data processing for purposes of the employment relationship, in particular for the decision on establishing an employment relationship).

5. Applicant pool

5.1 Your consent

If you have given your consent to be included in the applicant pool, your personal data that you provided during the application process will be stored by LOYALTY PARTNER in a separate database, the so-called applicant pool, beyond the end of the specific application process.

In this case, all of the companies mentioned in Section 1 and collectively referred to as LOYALTY PARTNER may use this data to contact you later and continue the application process should you be considered for another position at one of the companies mentioned.

The data will not be passed on to third parties.

For these purposes, LOYALTY PARTNER processes the data mentioned in the preceding paragraphs that you have provided during the application process (e.g. in cover letters, CVs and certificates). Should this include “special categories of personal data” within the meaning of Art. 9 GDPR (e.g. a photo that reveals your ethnic origin, information about any severe disability or your marital status), your consent also applies to such data.

You may freely revoke this consent at any time. You may declare your revocation in any form to LOYALTY PARTNER GmbH or to any of the other responsible parties named in Section 1, for example by telephone at 089/ 99741-879, by email to Karriere@PAYBACK.GROUP, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich. If you have not given your consent or if you revoke your consent, the data will not be used as stated in this section. Of course, this will have no effect on the current application process, in the context of which you have provided us with your data in accordance with Section 2. A revocation of consent does not affect the lawfulness of the data processing carried out on the basis of the consent up until the revocation.

5.2 Legal basis

The legal basis for the data processing described above in Section 5.1 is Art. 6 para. 1 lit. a) GDPR in conjunction with Art. 88 para. 1 GDPR in conjunction with § 26 para. 2 and 3 BDSG (consent).

6. Storage duration

LOYALTY PARTNER stores your personal data for the purpose of legal defense for up to six months after the end of the application process. If you have provided us with the separate Declaration of Consent to be Included in the Applicant Pool, LOYALTY PARTNER will store your personal data for 24 months. LOYALTY PARTNER stores log files (see Section 2) for a maximum of 30 days.

7. Data processing by service providers

LOYALTY PARTNER uses various supporting service providers (so-called order processors) in carrying out the application process, e.g. in providing the online application tool at www.payback.group/de/jobs. To the extent necessary, these service providers also process personal data thereby. The service providers are carefully selected and monitored by LOYALTY PARTNER.

8. Place of data processing

The processing of personal data takes place exclusively in the European Union. The data will not be transferred to third countries outside the European Union and the European Economic Area.

9. Your rights

Upon request, LOYALTY PARTNER will inform you whether and which data is stored about you. Insofar as the legal requirements are met, you have the right to have this data corrected, blocked or deleted. You also have the right to receive from us the data you provided to us concerning you in a structured, common and machine-readable format; you may also transmit this data to other entities or have it transmitted by us. You also have the right to lodge a complaint with the competent supervisory authority for data protection.

Insofar as LOYALTY PARTNER processes your data on the basis of the balancing of interests, you have a right of objection if the legal requirements are met.

You may exercise your rights to the correction, blocking or deletion of your personal data, as well as the right to data portability, by contacting any of the responsible parties named in Section 1 (cf. Art. 26 para. 3 GDPR), for example by telephone at 089/ 99741-879, by email to Karriere@PAYBACK.GROUP or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich.

10. Necessity of data processing

Providing your personal data is necessary for conducting the application process and thus for possibly establishing an employment relationship with LOYALTY PARTNER. Although you are not obliged to provide LOYALTY PARTNER with your data, if you are unwilling to do so the application process cannot be carried out completely or at all. In this case, an employment relationship cannot be established between you and LOYALTY PARTNER.

Of course, this does not apply to the inclusion of your data in the applicant pool, which is based exclusively on your voluntary consent (see Section 4).

LOYALTY PARTNER does not conduct any statistical analysis of the data or other observation of applicant behavior (profiling); in particular, no automated decision-making pursuant to Art. 22 para. 1 and 4 GDPR takes place.

11. Data Protection Officer and contact

Questions regarding data protection at LOYALTY PARTNER may be addressed to the Data Protection Officer: LOYALTY PARTNER Data Protection Officer, Theresienhöhe 12, 80339 Munich. You may also send questions and comments by email to Datenschutz@PAYBACK.GROUP.

Status 04/2019