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

Data protection notice for applicants of Wildling Shoes GmbH via Personio
Status 21.11. 2022
We are pleased that you are interested in working with Wildling.
Transparency and trustworthy handling of your personal data is an important basis for our good
future cooperation.
Therefore, we would like to inform you about our data processing.
 
Responsible
Who is responsible for data processing?
Wildling Shoes GmbH
Walbach 9
51766 Engelskirchen
Managing Directors: Anna and Ran Yona
Further information about our company and the persons authorised to represent it can be found
in our imprint https://www.wildling.shoes/pages/impressum.
How do you contact the Data Protection Officer?
If you have any questions about data protection, please contact our data protection officer by e-
mail at data (at) wildling.shoes.
   
What data is processed?
Legal basis for data processing
In the course of our business, we process personal data on the basis of the following legal
grounds:
• Consent (Art. 6 para. 1 lit. a) GDPR)
• for the fulfilment of contracts (Art. 6 para. 1 lit. b) GDPR)
• on the basis of a balancing of interests (Art. 6 para. 1 lit. f) GDPR)
• for the fulfilment of a legal obligation (Art. 6 para. 1 lit. c) GDPR)
We will refer to the relevant terminology in relation to each processing operation so that you can
understand the basis on which we process personal data.
If personal data is processed on the basis of your consent, you have the right to revoke your
consent at any time with effect for the future.

If we process data on the basis of a balance of interests, you as the data subject have the right
to object to the processing of personal data, taking into account the requirements of Article 21 of
the GDPR.
Nature of the data, categories and purpose
The following data or categories of data may be processed in order to carry out your application
procedure:
• Identity data (first name, last name, title, e-mail address, telephone number, address, date of
birth, citizenship)
• Qualification data (covering letter, letter of motivation, CV, previous activities, professional
qualifications and competences)
• Voluntary information, such as an application photo, details of severely disabled status or other
information that you voluntarily provide to us in your application or upload voluntarily.
• Our notes, comments and evaluations from the various application steps.
• Special categories of personal data: If you provide information that contains special categories
of personal data within the meaning of Article 9 (1) of the GDPR (e.g. information that allows
conclusions to be drawn about your sexual orientation; information about your health;
information that allows conclusions to be drawn about your ethnic origin or your religion), we will
also only process this data to the extent permitted by law.
 
This data is provided by you. The written, electronic communication between you as an applicant
and Wildling is processed and stored via Personio.
Data processing for purposes of the employment relationship - Art. 6 para. 1 lit. b GDPR:
Your personal data will be processed for the purpose of personnel selection to fill vacancies, i.e. to
initiate an employment contract (and for the purpose of the employment relationship (§ 26 BDSG).
Consent - Art. 6 para. 1 lit. a and Art. 9 para. 2 lit. a GDPR:
In the following cases, we process your personal data on the basis of your consent:
• Consent to the processing of data when uploading data to the application tool
• Inclusion in the pool of applicants, i.e. we store the application documents beyond the current
application procedure, if desired, for consideration in later application procedures.
Data processing based on our legitimate interest - Art. 6 para. 1 lit. f GDPR:
In certain cases, we process your data to protect a legitimate interest of us or of third parties. A
legitimate interest exists, for example, if your data is required for the assertion, exercise or defence
of legal claims in the context of the application process (e.g. claims under the Equal Treatment
Act). In the event of a legal dispute, we have a legitimate interest in processing the data for
evidence purposes.

Who else sees your data?

Your data will mainly be processed by our People and Culture department, management and team
leaders.
We use Personio GmbH as an external service provider https://www.personio.de/impressum/ .
Personio operates the e-recruiting system Personio via which we can place job advertisements
and receive and manage applications.
Within the scope of these activities, Personio only processes personal data on behalf of you and is
therefore a so-called order processor who may only do so on instruction and in compliance with
confidentiality.
In the case of a postal or e-mail application, your data may also be transferred to the e-recruiting
system with your consent.
Delete data
We store your personal data for as long as it is necessary for the decision on an application. If an
employment relationship between us does not materialise, we may also continue to store data
insofar as this is necessary for the defence against possible legal claims. As a rule, applicant data
is deleted or anonymized within six to seven months after the end of the application process and a
rejection. In case of anonymization, the data will only be available to us in the form of so-called
metadata, without any direct personal reference, for statistical analysis (for example, share of male
and/or female applicants, number of applications per specified period of time etc.).
If no employment relationship is established, but you have given us permission to continue storing
your data, your data will be stored until you revoke this permission, but for a maximum of 24
months. If there is a specific reason, we may also store your data for a longer period for the
purpose of defending against possible legal claims.
If you withdraw your application before the end of the application process, i.e. delete your data and
your account, the stored data will be blocked for the period of the application process that is still
ongoing and finally deleted after six months after the end of the application process.
If you no longer use your applicant profile and have not given your consent to the longer storage of
data in the applicant pool, the data will be deleted within seven months of the end of the application
process.
You yourself can delete your profile and your application documents at any time or submit a
request for deletion or have the processing restricted.
    
Your rights as a data subject
You have the right to information about the personal data concerning you. You can contact us
for information at any time.
In the case of a request for information that is not made in writing, we ask for your understanding
that we may require proof from you that you are the person you claim to be.
You also have a right to rectification or erasure or to restriction of processing where you are
entitled to do so by law.
Finally, you have a right to object to processing within the framework of the legal requirements.
A right to data portability also exists within the framework of data protection law.
Right of appeal to a supervisory authority

If you wish to complain, you can contact any supervisory authority, e.g. the State Commissioner
for Data Protection and Freedom of Information of North Rhine-Westphalia, Kavalleriestr. 2-4,
40213 Düsseldorf, telephone: 0211/38424-0, fax: 0211/38424-10, e-mail: poststelle@ldi.nrw.de.
Concluding provisions
We reserve 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 application process or other processes. In this case, the new data privacy statement applies
to any later visit of this recruitment website or any later job application.
In addition to this data privacy statement, please view our general data privacy statement at
https://www.wildling.shoes/en/pages/datenschutzerklarung

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.