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Recruitment Privacy Notice

Usercentrics (“We”, “Us”) is committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with our recruitment processes. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) as well as United States Consumer Privacy Laws the data controller is the Usercentrics group entity that is advertising the relevant position and acting as the hiring entity (“Hiring Entity” see below).

I. Data Controllers and Contact Details

The following Usercentrics group entities may act as the Hiring Entity and data controller for recruitment purposes:

  1. Data Controller for applicants of Usercentrics GmbH

    Usercentrics GmbH
    Sendlinger Straße 7
    80331 Munich, Germany
    Company registration: Munich, Regional Court Munich, HRB 241272 
    Managing Directors: Donna Dror, Ea Luise Andersen
    Phone:+49 89 21 54 01 20 
    Mail: contact@usercentrics.com

    Contact details of the data protection officer:
    SECUWING GmbH & Co. KG Maximilian Hartung, Frauentorstr. 9, 86152 Augsburg, Germany,
    epost@datenschutz-agentur.de  Tel. +49 (0) 821 907 86 450
  2. Data Controller for applicants of Usercentrics A/S 

    Usercentrics A/S 
    Havnegade 39
    DK-1058 Copenhagen K
    Denmark
    Company registration (CVR number): DK34624607
    Managing Directors: Donna Dror, Ea Luise Winther Andersen
    Phone: +45 50 333 777
    Mail: mail@cookiebot.com
  3. Data Controller for applicants of Usercentrics Unipessoal

    Usercentrics Unipessoal Lda
    R MARGARIDA ABREU 11
    1 ESCRITORIO C
    1900-314 LISBOA
    Managing Directors: Jose Felix
    Phone:+49 89 21 54 01 20
    Mail: contact@usercentrics.com
  4. Data Controller for applicants of Usercentrics s.r.o.

    Usercentrics s.r.o.
    Street: Hvězdova Number: 1716/2b
    14000 Municipality: Praha 4 – Nusle
    Managing Directors: Donna Dror, Jaroslaw Kruszewski
    Phone:+49 (89) / 21540120
    Mail: contact@usercentrics.com
  5. Data Controller for applicants of Usercentrics Inc.

    Usercentrics Inc.
    Street: 251 Little Falls Drive,
    Wilmington, Delaware 19808
    United States of America
    Managing Directors: Donna Dror
    Phone:+49 (89) / 21540120
    Mail: contact@usercentrics.com

(in the following referred to as “Usercentrics Group” or “Usercentrics”)

Contact details of the Information Security Officer for the whole Usercentrics Group:

COGNISYS GROUP LTD Joe Thomas – Information Security Officer, joe.thomas@cognisys.group 
(+44) 0113 531 1700.

We use Workable Software Limited, 83 Victoria Street, London SW1H 0HW, United Kingdom Workable Legal page), as our applicant tracking system provider. Workable processes personal data strictly on our behalf and in accordance with a Data Processing Agreement pursuant to Article 28 GDPR.

In the course of providing its services, Workable may engage affiliated group companies, including Workable Inc., 225 Franklin St, 19th Floor, Boston, MA 02110, United States, as well as authorized subprocessors.

Workable is only entitled to process your personal data in accordance with our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to our processing of your personal information in addition to our other Privacy Notice which has been provided to you separately or is available on our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

II. Your Personal Information

1. Information We collect from you

We collect and process some or all of the following types of information from you:

  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
  • In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.
  • If you contact Us, We may keep a record of that correspondence.
  • A record of your progress through any hiring process that We may conduct.
  • Details of your visits to Workable’s Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s Website and the resources that you access.
  • Your video interview in case your interview was performed through the video interview feature.
  • Interview transcripts if applicable.
  • We might schedule reference calls via Workable and capture feedback from previous employers or other applicable references.

2. Information We collect from other sources

Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles or channels.

Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way We will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Uses made of your information

3. Lawful basis for processing

We process your personal data primarily for the purpose of taking steps at your request prior to entering into an employment contract (Article 6(1)(b) GDPR). Where processing is not strictly necessary for this purpose, we rely on our legitimate interest in conducting an efficient and lawful recruitment process (Article 6(1)(f) GDPR). Where required by law, or where we retain your data for inclusion in a talent pool beyond an ongoing recruitment process, processing is based on your consent (Article 6(1)(a) GDPR).

Purposes of processing

We use information held about you in the following ways:

  • To consider your application in respect of a role for which you have applied.
  • To consider your application in respect of other roles.
  • To communicate with you in respect of the recruitment process.
  • To enhance any information that We receive from you with information obtained from third party data providers.
  • To find appropriate candidates to fill our job openings.

4. Automated decision making/profiling

We may use Workable’s recruitment platform to support and streamline our application screening and recruitment processes. As part of this process, we may use automated tools to pre-screen and organize applications, for example by:

  • collecting and evaluating answers provided in the application form (such as relevant professional experience, familiarity with specific tools or technologies, willingness to work on-site, or readiness to relocate); and
  • assessing the degree of alignment between an applicant’s profile and the job description (e.g. through matching or relevance scores generated by the system).

These automated processes are used solely to support and prioritize the review of applications. They may help us identify candidates whose profiles more closely match the role or filter applications based on clearly defined, job-related criteria (for example, willingness to relocate).

No decisions producing legal effects or similarly significant effects are made solely on the basis of automated processing. All applications are subject to human review, and all final hiring decisions are made by human decision-makers.

5. Disclosure of Your Information

As set out above, We pass your information to our third party service providers, including Workable, who use it only in accordance with our instructions and as otherwise required by law.

When you use one of the job boards to apply to one of our open positions, you will be redirected to our Usercentrics career page where you will be able to apply to the position of your choice. When doing so the information mentioned previously under “Your Personal Information”.

These are the following job boards that might be used to apply to one of our open positions:

a. Indeed Apply functionality

Where you have applied for a job opening through the Indeed Apply functionality, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). For this we use Indeed Ireland Operations Limited, Block B, Capital Dock, 80 Sir John Rogerson’s Quay, Dublin 2, D02 HE36, Ireland. Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

b. LinkedIn Apply functionality

Where you have applied for a job opening through the LinkedIn Apply functionality, We will disclose to LinkedIn certain personal data that We hold, including but not limited to a unique identifier used by LinkedIn to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).

For this purpose, we use LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

LinkedIn’s Privacy Policy regarding its use of the Disposition Data is available on LinkedIn’s website.

c. Glassdoor Apply functionality

Where you have applied for a job opening through the Glassdoor application functionality, We will disclose to Glassdoor certain personal data that We hold, including but not limited to a unique identifier used by Glassdoor to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).

For this purpose, we use Glassdoor Hiring Solutions Ireland Ltd., 70 Sir John Rogerson’s Quay, Dublin 2. D02 R296.

Glassdoor’s Privacy Policy regarding its use of the Disposition Data is available on Glassdoor’s website. You can also reach out to gdpr@glassdoor.com.

d. Adzuna Apply functionality

Where you have applied for a job opening through the Adzuna application functionality, We will disclose to Adzuna certain personal data that We hold, including but not limited to a unique identifier used by Adzuna to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).

For this purpose, we use Adzuna Ltd, 212 New Kings Road, London, SW6 4NZ, United Kingdom.

Adzuna’s Privacy Policy regarding its use of the Disposition Data is available on Adzuna’s website. You can also reach out to dataprotectionofficer@adzuna.com.

e. XING Apply functionality

Where you have applied for a job opening through the XING application functionality, We will disclose to XING certain personal data that We hold, including but not limited to a unique identifier used by XING to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”).

For this purpose, we use New Work SE, Am Strandkai 1, 20457 Hamburg, Germany.

XING’s Privacy Policy regarding its use of the Disposition Data is available on XING’s website. You can also reach out to datenschutzbeauftragter@xing.com.

f. Other Apply providers

Where you have applied to a job opening through another service provider that is not listed above, We may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

6. How We store your personal data

a. Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where We store your personal data

Personal data submitted as part of your application may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States.

In particular:

  • personal data may be accessible to Workable’s staff located in the United States for the purpose of providing technical, operational, or support services; and
  • data may be hosted and stored by Workable’s infrastructure providers (including AWS and Google Cloud), which may operate data centers inside or outside the EEA.

Where personal data is transferred to recipients outside the EEA, such transfers take place in accordance with Articles 44 et seq. GDPR and are safeguarded through appropriate mechanisms, including:

  • certification under the EU-US, Swiss-US and UK-US Data Privacy Frameworks (DPF), for organizations that are certified; and
  • the European Commission’s Standard Contractual Clauses (SCCs), where required.

These safeguards provide an adequate level of protection and ensure that enforceable rights and effective legal remedies are available to data subjects.

Further information about Workable’s data processing practices is available in Workable’s Privacy Notice: https://www.workable.com/privacy

You can find a list of Workable´s sub-processors under the following link: Workable’s Sub-processors page

If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

How long We keep your personal data

We store your personal data for the duration of the recruitment process. If your application is unsuccessful, your data will generally be deleted no later than six (6) months after completion of the recruitment process, unless longer retention is required to defend against legal claims. Where you have consented to the inclusion of your data in our talent pool, we will retain your data for a longer period in accordance with the scope of your consent. You may withdraw your consent at any time.

Your personal information will be deleted on one of the following occurrences:

  • deletion of your personal information by you (or by another person engaged by you); or
  • receipt of a written request by you (or another person engaged by you) to us; or
  • Automatic deletion after 6 months after completion of the recruiting process if you have not given your consent for longer storage.

III. Your rights

1. European Union

Subject to local data protection laws and in particular under the GDPR, you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
  • require Us to correct any mistakes in your information which We hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal data
  • otherwise restrict our processing of your personal data in certain circumstances
  • claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please:

  • contact Us under jobs@usercentrics.com
  • let Us have enough information to identify you,
  • let Us have proof of your identity and address, and
  • let Us know the information to which your request relates.

How to complain

We hope that We can resolve any query or concern you raise about Our use of your information.

The European General Data Protection Regulation  and the also give you right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

2. U.S. State Privacy Rights

In addition to the information provided above, this section applies to residents of U.S. states that have enacted comprehensive consumer privacy laws. These laws provide residents with certain rights regarding their personal information, subject to applicable limitations and exceptions.

For purposes of this section, “personal information” (or “personal data,” where applicable) has the meaning assigned under relevant state law.

a. Your Privacy Rights

Depending on your state of residence and subject to verification and statutory exceptions, you may have the following rights:

Right to Confirm and Access

You have the right to confirm whether we are processing your personal information and to access such personal information.

This may include:

  • The categories of personal information processed
  • The purposes for processing personal information
  • The categories of personal information shared with third parties
  • The categories of third parties with whom personal information is shared
  • A copy of the personal information you previously provided to us
Right to Delete

You have the right to request deletion of personal information we have collected from or obtained about you, subject to certain legal exceptions (such as where retention is required to comply with legal obligations, exercise legal claims, detect security incidents, or fulfill contractual obligations).

Upon verification of your request, we will delete your personal information and direct our processors or service providers to do the same, unless an exception applies.

Right to Correct

You have the right to request correction of inaccurate personal information that we maintain about you or update the information we have on file.

Right to Data Portability

You have the right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance.

Right to Opt Out

Depending on your state of residence, you may have the right to opt out of:

  • The sale of your personal information
  • The sharing of personal information for cross-context behavioral advertising
  • The processing of personal information for targeted advertising
  • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you

Usercentrics does not sell personal information, including personal information of minors under the age of 16.

Where applicable, you may exercise your opt-out rights by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of the page or by contacting us as described above.

Right to Non-Discrimination For The Exercise Of Your Privacy Rights

We will not discriminate or retaliate against you for exercising your privacy rights. This means we will not deny goods or services, charge different prices, provide a different level or quality of services, or otherwise penalize you because you exercised your rights.

Right to Limit the Use of Sensitive Personal Information

Certain states grant the right to limit the use or disclosure of sensitive personal information. Usercentrics does not process sensitive personal information for purposes that would require offering such a limitation right under applicable law.

b. How To Submit a Request to Exercise Your Right to Know, Delete, or Correct

You may submit your request by sending an email to jobs@usercentrics.com. We will verify your identity before processing your request. Verification may require you to provide additional information that allows us to reasonably confirm you are the individual about whom we collected personal information or an authorized representative. Authorized agents may submit requests on behalf of a consumer where permitted by law and subject to verification requirements.

c. Response Timing and Format

We will respond to verifiable consumer requests within the timeframe required by applicable state law, generally within forty-five (45) days of receipt.

If additional time is required (up to 90 days where permitted), we will notify you in writing and explain the reason for the extension.

Where required by law:

  • Responses may cover the 12-month period preceding receipt of the request unless a longer period is required.
  • We will explain the reasons if we cannot comply with a request.
  • Data portability responses will be provided in a readily usable format.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If a fee is permitted and warranted, we will inform you of the reason and provide a cost estimate before completing your request.

d. Children Under the Age of 16

Usercentrics does not knowingly collect or disclose the personal information of children under the age of 16. As stated above, Usercentrics also does not sell or share personal information, including personal information, of children under the age of 16.

IV. 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://usercentrics.com/privacy-policy/.

Contact

All questions, comments and requests regarding this Privacy Notice should be addressed to jobs@usercentrics.com