Processing of (personal) data by the entity in charge of the online application process
tech11 GmbH
Dear Applicant,
Thank you for your interest in our company. In accordance with Art. 13, 14 and 21 of the General Data Protection Regulation (GDPR), we hereby inform you about the processing of the personal data you provide to us as part of the application process, as well as any data we may collect, and about your related rights. To ensure that you are fully informed about the processing of your personal data during the application process, please take note of the following information.
1. Controller within the meaning of data protection law
tech11 GmbH
Beethovenstraße 1a
97080 Würzburg, Germany
+49 931 49738966
mail@tech11.com
2. Contact details of our Data Protection Officer
Markus Rheindt
Data Protection Officer
Beethovenstraße 1a
97080 Würzburg, Germany
markus.rheindt@tech11.com
3. Purposes and legal bases of processing
We process your personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), to the extent this is necessary for the decision to establish an employment relationship with us. The legal basis is Art. 88 GDPR in conjunction with Sec. 26 BDSG for purposes of the employment relationship, where this is necessary for the decision to establish an employment relationship.
Furthermore, we may process your personal data where this is necessary to fulfil a legal obligation (Art. 6(1)(c) GDPR) or to defend or assert legal claims. The legal basis in this case is Art. 6(1)(f) GDPR. Our legitimate interest is, for example, a duty to provide evidence in proceedings under the German General Act on Equal Treatment (AGG).
If you give us your explicit consent to process personal data for specific purposes, the lawfulness of this processing is based on your consent pursuant to Art. 6(1)(a) GDPR, Sec. 26(2) BDSG. Consent given may be withdrawn at any time with effect for the future (see Section 9 of this privacy notice).
If an employment relationship is established between you and us, we may, pursuant to Art. 88 GDPR in conjunction with Sec. 26 BDSG, continue to process the personal data already received from you for purposes of the employment relationship, to the extent this is necessary for carrying out or terminating the employment relationship, or for exercising or fulfilling rights and obligations of employee representation arising from a law, a collective bargaining agreement, or a works or service agreement (collective agreement).
4. Categories of personal data
We only process data that relates to your application. This may include general personal data (name, address, contact details, etc.), information about your professional qualifications and education, information about further professional training, and any other data you provide to us in connection with your application.
5. Sources of the data
We process personal data that we receive from you by email in the course of making contact or submitting your application, or that you provide to us via job postings at tech11 GmbH.
6. Recipients of the data
We share your personal data within our company only with those departments and individuals who need this data to fulfil contractual and statutory obligations or to pursue our legitimate interests.
We may transfer your personal data to affiliated companies, to the extent permitted within the purposes and legal bases set out in Section 3 of this privacy notice.
Your personal data is processed on our behalf on the basis of data processing agreements pursuant to Art. 28 GDPR. In these cases, we ensure that the processing of personal data complies with the provisions of the GDPR. The categories of recipients in this case are providers of internet services as well as providers of applicant management systems and software.
In connection with the application process, we also use AI-based software to support internal processes, including the AI assistant Claude, provided by Anthropic (under an Enterprise agreement), as well as the talent screening agent within our applicant management system, Personio. These systems are used solely to support our employees in assessing applications; no automated decision regarding your application is made (see Section 11 in this regard). Your data is not further used by these providers to train AI models. Processing in each case takes place on the basis of a data processing agreement pursuant to Art. 28 GDPR.
Otherwise, your personal data is disclosed to recipients outside the company only where legal provisions permit or require this, where disclosure is necessary to fulfil legal obligations, or where we have your consent.
7. Transfer to a third country
In connection with the application process, it may be necessary for personal data of applicants to be viewed or processed by employees in Accra, Ghana. As Ghana is a third country within the meaning of the GDPR and there is currently no adequacy decision by the European Commission, we ensure that appropriate safeguards are in place.
In connection with the use of the AI assistant Claude (provider: Anthropic, USA), your personal data may also be processed in a third country, as Anthropic, being a US company, is not covered by an adequacy decision of the European Commission. Data is stored in the USA.
In these cases, the transfer takes place on the basis of the Standard Contractual Clauses of the European Commission, together with supplementary measures to protect the data. Further information on these safeguards is available on request.
Unless other legal grounds exist, we obtain applicants' explicit consent prior to any transfer to a third country.
8. Duration of data storage
We store your personal data for as long as necessary for the decision regarding your application. Your personal data and application documents will be deleted no later than six months after the application process has ended (e.g. notification of a rejection decision), unless a longer retention period is legally required or permitted. We furthermore store your personal data only to the extent legally required or, in a specific case, necessary to assert, exercise, or defend legal claims for the duration of the dispute.
Should you have consented to a longer storage period for your personal data, we will store it in accordance with your declaration of consent.
If the application process results in an employment, training, or internship relationship, your data will, where necessary and permissible, initially continue to be stored and subsequently transferred to the digital personnel file.
You may subsequently receive an invitation to join our talent pool following the application process. This allows us to consider you for suitable vacancies in future applicant selection processes. If we have your corresponding consent, we will store your application documents in our talent pool in accordance with your consent or any future consent you may give.
9. Your rights
Every data subject has the right to access under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR, the right to notification under Art. 19 GDPR, and the right to data portability under Art. 20 GDPR.
You furthermore have the right to lodge a complaint with a data protection supervisory authority under Art. 77 GDPR if you believe that the processing of your personal data is unlawful. This right to complain exists without prejudice to any other administrative or judicial remedy.
Where processing of data is based on your consent, you are entitled under Art. 7 GDPR to withdraw your consent to the use of your personal data at any time. Please note that withdrawal only takes effect for the future. Processing carried out prior to the withdrawal is not affected. Please also note that we may be required to retain certain data for a specific period in order to comply with statutory requirements (see Section 8 of this privacy notice).
Right to object:
Insofar as the processing of your personal data is carried out under Art. 6(1)(f) GDPR to safeguard legitimate interests, you have the right, pursuant to Art. 21 GDPR, to object at any time to the processing of this data for reasons arising from your particular situation. We will then no longer process this personal data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.
To exercise your rights, you may contact us using the contact details provided in Section 1.
10. Necessity of providing personal data
The provision of your personal data as part of application processes is voluntary. However, we can only make a decision regarding the establishment of an employment relationship, or establish an employment relationship with you, if you provide such personal data as is necessary for carrying out the application.
11. Automated decision-making
The decision on your application is not based solely on automated processing. Accordingly, no automated decision-making in individual cases within the meaning of Art. 22 GDPR takes place. The use of AI-supported tools such as Claude or the Personio talent screening agent does not change this: these systems merely provide an assessment as a decision-support aid for our employees. The final decision on your application is always made by a human.