Graswald GmBH (referred to as "we," "us," or "our"), with its registered office in Germany, is committed to protecting the privacy and security of your personal data. This Data Privacy Statement describes how we collect, use, and process the personal data of job applicants for both domestic and international roles.2. Data Controller

The data controller responsible for the processing of your personal data is:

Graswald GmBH

Berckhusenstraße 89 30625 Hannover Germany

simon@graswald.ai

3. Data Collection and Types of Personal Data

We collect and process personal data that you provide to us directly during the application process, which may include:

Contact Information: Name, address, phone number, email address.
Application Documents: CV/résumé, cover letter, references, academic records, and professional certifications.
Job-Related Information: Current and desired salary, employment history, qualifications, and other information relevant to the application.
Identification Data (where legally required): Information necessary to verify your identity and your right to work in the relevant jurisdiction.
Special Categories of Data: In limited circumstances and where permitted by law, we may process data such as information about your health, trade union membership, or criminal records. This is only done where strictly necessary for the position, or with your explicit consent.

4. Purposes and Legal Basis for Processing (GDPR)

We process your personal data for the following purposes, based on the corresponding legal grounds under the GDPR:

Purpose of Processing	Legal Basis (GDPR)
Recruitment and Selection: Evaluating your suitability for employment, managing the hiring process, and communicating with you.	Art. 6(1)(b) GDPR (Performance of a contract or steps prior to entering a contract): Processing is necessary to take steps at your request prior to entering into an employment contract.
Compliance: Meeting legal and regulatory requirements (e.g., equal opportunity, visa requirements).	Art. 6(1)(c) GDPR (Legal obligation): Processing is necessary for compliance with a legal obligation to which we are subject.
Talent Pool: Retaining your application for future opportunities (with your permission).	Art. 6(1)(a) GDPR (Consent): We will seek your explicit consent to keep your data for this purpose.
Defense of Legal Claims: Establishing, exercising, or defending legal claims.	Art. 6(1)(f) GDPR (Legitimate interests): Our legitimate interest in protecting our legal rights.

5. Recipients of Personal Data

Your personal data may be shared with the following parties:

Internal Departments: Relevant employees, including the HR team, hiring managers, and interviewers.
Service Providers: Third-party providers who assist us with the recruitment process, such as Applicant Tracking System (ATS) providers, IT service providers, and background check providers. These parties are contractually bound to maintain confidentiality and comply with data protection laws.

6. International Data Transfers

As we recruit internationally, your personal data may be transferred to, and processed in, countries outside of the European Union (EU) or European Economic Area (EEA).

Adequacy: Where data is transferred to a country recognised by the European Commission as providing an adequate level of data protection, no further safeguards are necessary.
Lack of Adequacy: If data is transferred to a country not deemed adequate, we will implement appropriate safeguards, such as the European Commission's Standard Contractual Clauses (SCCs), or rely on a derogation, such as your explicit consent, to ensure your data receives the same level of protection as it would within the EU/EEA.

7. Data Retention

We will retain your personal data for the duration of the recruitment process.

If your application is successful, your data will be transferred to your employee file and retained in accordance with our employee privacy policy.
If your application is unsuccessful, we will delete or anonymise your data within [Specify a period, e.g., 6 months] after the application process is complete, unless:
- Retention for Talent Pool: We have obtained your explicit consent to retain your data for future vacancies, in which case we will retain it for up to [Specify a period, e.g., 2 years].
- Legal Necessity: We are required by law to retain the data for a longer period (e.g., to defend against legal claims).

8. Your Rights (Data Subject Rights under GDPR)

Under the GDPR, you have the following rights regarding your personal data:

Right of Access: To request a copy of the personal data we hold about you.
Right to Rectification: To request the correction of inaccurate or incomplete data.
Right to Erasure ("Right to be Forgotten"): To request the deletion of your personal data under certain conditions.
Right to Restriction of Processing: To request that we limit the way we use your data.
Right to Object to Processing: To object to the processing of your data, particularly when based on legitimate interests.
Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format.
Right to Withdraw Consent: Where we rely on your consent, you have the right to withdraw it at any time.

To exercise any of these rights, please contact the Data Protection Officer (DPO) or the contact person listed in Section 2.9. Data Protection Officer (DPO)

Graswald GmBH has appointed a Data Protection Officer who can be contacted for all questions and concerns regarding the processing of your personal data:

Data Protection Officer

simon@graswald.ai

You also have the right to lodge a complaint with a supervisory authority, particularly the one in the German federal state where our company is headquartered.

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