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

DATA PROTECTION STATEMENT

Online Job Application Process — Lexidy Careers Portal (Personio)

1. General Information

This data protection statement refers exclusively to the data collected as part of the online job application process, and includes information on the processing of the candidate's personal data collected during that process.

2. Data Controller

LEXIDY TECH S.L.

Address: Av. Diagonal, 442, 1st-1st, 08037 Barcelona (Spain)

Phone: +34 678 715 986

Email: compliance@lexidy.com

Registered with the Commercial Registry of Barcelona

Tax ID (NIF): B44886612 — Registration number: Volume 45549, Page 40, Sheet B-491463

Registration court: Commercial Registry of Barcelona

Data Protection Officer: not applicable. Lexidy Tech S.L. is not legally required to appoint a DPO, as it does not process data on a large scale nor does it process special categories of data as a core activity. Any data protection query may be directed to the email address above.

3. Processing of Personal Data in the Job Application Process

Personal data is information about the personal or material circumstances of an identified or identifiable natural person, such as name, address, telephone number and date of birth, but also information about their education, etc., which can be attributed to a specific person with reasonable effort. Any information that cannot be used to directly or indirectly determine the identity of a person does not constitute personal data.

4. Principles and Purposes of Processing

By submitting an application electronically, i.e. by email or through our online form, the candidate's personal data is collected and processed for the purpose of managing and carrying out the selection process and applying any corresponding pre-contractual measures.

By submitting an application through our recruitment page, the candidate explicitly indicates their interest in working with us. The personal data you provide in this context will be used and retained solely for the purpose of the job search and application.

In particular, we will collect the following data:

Full name
Email address
Phone number
LinkedIn profile (optional)
Channel through which you found out about us

In the course of the selection process, the candidate may also attach relevant documents, such as a cover letter, CV and qualifications, which may also contain personal data such as date of birth, address, etc.

Only authorised HR employees or employees involved in the selection process will have access to your data.

Personal data is stored exclusively for the purpose of filling the vacant position for which the application was submitted.

Candidate data will be retained for a period of 12 months after the selection process has concluded, in order to comply with legal obligations or to defend against claims. After that, we are required to block and, once the legal period has elapsed, delete or anonymise your data. From then on, the data will only be available as metadata with no direct personal reference, for statistical purposes (e.g. the percentage of women and men among applicants, number of applications per period, etc.).

In addition, we reserve the right to store candidate data in order to include it in our talent pool for 12 months after the selection process has concluded, in order to identify any other position that may be of interest to you. This also applies, for example, to applications for internships or trainee positions. By accepting the privacy policy, the candidate expressly consents to this possible additional retention period and to their inclusion in our talent pool.

If, during the selection process, the candidate receives and accepts a job offer, the personal data collected during the selection process will be retained for at least the duration of the employment relationship.

Data may be shared with other companies of the Lexidy Group (Lexidy Law Boutique S.L.P. and Lexidy Outsourcing S.L.) for the same recruitment purposes, subject to the candidate's prior express consent.

5. Disclosure of Data to Third Parties

The data provided as part of the application is transmitted using TLS encryption and stored in a database. This database is operated by Personio SE & Co. KG, which provides candidate and human resources management software (https://www.personio.com/legal-notice/). In this context, Personio acts as our data processor in accordance with Article 28 of the GDPR. The basis for this processing is the data processing agreement (DPA) entered into between us, as data controller, and Personio.

6. Data Subject Rights

To the extent that we, as the responsible body, process personal data, the candidate, as a data subject, has certain rights set out in Chapter III of the GDPR, depending on the legal basis and purposes of the processing involved, namely the right of access (Article 15 GDPR), the right to rectification (Article 16 GDPR), the right to erasure (Article 17 GDPR), the right to restriction of processing (Article 18 GDPR), the right to data portability (Article 20 GDPR) and the right to object (Article 21 GDPR). Where the processing of personal data is based on consent, pursuant to Article 7(3) GDPR, the candidate has the right to withdraw such consent at any time.

To exercise the rights described above in relation to the processing of data during the online job application process, please contact compliance@lexidy.com (see Section 2).

If the candidate believes that their rights have not been duly respected, they have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

7. Final Provisions

We reserve the right to amend this data protection statement at any time in order to comply with applicable legal requirements or to reflect changes made to the job application procedure or other similar processes. In such a case, if the candidate visits this recruitment page or submits an application again, the new data protection statement will apply.

In addition to this data protection statement, you can consult our general privacy policy at https://www.lexidy.com/privacy-policy/.

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.