Privacy Policy for Applications

Before you enter your data in our application portal or submit your data to us, we ask you to please carefully read the following data protection declaration for applications. The data protection declaration will inform you on how we process the personal data that you provide to us as part of your application. Unless otherwise agreed, our general Privacy Policy applies, which you can access here. By activating the checkbox(es) placed on our applicant portal and sending us your data, you expressly agree that Tourlane GmbH Köpenicker Str. 126, 10179 Berlin (hereinafter referred to as “Tourlane”) may process and use the data you have submitted for the purpose of carrying out both the recruiting and application process. If you do not wish to use the application portal, you may also send us your application in writing or by e-mail to the following address: Tourlane GmbH, Köpenicker Str. 126, 10179 Berlin, Germany, e-mail: hr@tourlane.de. This Privacy Policy also applies to applications sent by post or e-mail.

1. Party Responsible for Data Processing

Tourlane is responsible for the processing of your personal data. Tourlane GmbH, Köpenicker Str. 126, 10179 Berlin, AG Berlin-Charlottenburg, (HRB 170081B), Tel: 030 - 555 708 92, e-mail: hr@tourlane.de

2. Data Protection Officer

You can contact Tourlane's data protection officer as follows: Tourlane GmbH, Data Protection Department, Köpenicker Str. 126, 10179 Berlin, Email: datenschutz@tourlane.de.

3. Data collected by us in the Application Portal

3.1 Application Data

The Tourlane application portal allows us to offer you a fast and simple way of applying to us. In addition to entering data manually and uploading documents, you can also import your data from your XING or LinkedIn profile. The information we need from you is marked with an asterisk on the application form (first and last name, e-mail address, cover letter and CV, including information). We recommend that you upload the relevant documents in a common file format (e.g. PDF, TIF, JPG or Microsoft Word). Additionally, you have the option of voluntarily submitting additional information via the form, such as information about your personal goals or career path.There is no legal or contractual obligation to provide your data. However, we will not be able to process your application without the information marked as mandatory in the form.

3.2 Automatically Collected Technical Data

Your IP address is automatically saved for technical reasons upon use of the application portal. However, the aforementioned data will be deleted immediately after your session on our website has been terminated. We only store access data without personal reference, such as the name of your Internet service provider; the website visited prior to the session; date and time of the request; content of the request (specific page); amount of data transferred; website from which the request originated; browser, and any log files such as the operating system and its interface, language, and version of the browser software. This data, which is anonymous to us, is used exclusively to improve our application portal and does not allow any conclusions to be drawn about your person. This data will not be merged with other data sources. When using the applicant portal, so-called “session cookies” are used. These cookies are deleted again at the end of your visit. The cookies are intended to enable or facilitate the use of certain functions within the portal. Cookies are small data packages that contain certain information (e.g. the time of the server request, the operating system used, the website visited prior to the request, the IP address, etc.) and are stored on the user’s computer when the user visits a website. If you call up the corresponding server again, your browser sends the previously stored cookie back to the server. You have the option of generally preventing cookies from being stored on your computer by configuring the appropriate browser settings; you may also delete a cookie once it has been set at any time. You can find out how this works from your browser’s instruction manual and from the additional information in our data protection policy. If your browser does not accept cookies, however, it is possible that certain functions of the applicant portal cannot be used.

4. Data Collected by Us When Applying by Post or Email

If you do not wish to apply to us via the application portal, but rather by post or e-mail, you should send us your full name, your postal or electronic contact address, a cover letter and your CV at the very least. There is no legal or contractual obligation to provide this data. However, we will not be able to process your application if you do not provide this data.

5. Data storage for future job offers for those in the Talent Pool

If you have consented to the storage and use of your data for our talent pool, we will store your application and the submitted documents for a period of up to an extra 12 months. If necessary, we will process your data again in order to both compare the data you have previously submitted with new job openings and to contact you in the event of suitable vacancies. This consent is of course voluntary and can be revoked at any time. Just send us an e-mail with your full name to hr@tourlane.com. hr@tourlane.de.

6. Purposes of processing and legal basis

The data you provide in your application will be processed exclusively for the purpose of processing your application. The legal basis for this is Art. 6 para. 1 lit. b of the GDPR and, as far as special categories of personal data (e.g. information on your health, religion, ethnic origin, political orientation or other “sensitive” data) are concerned, your consent is pursuant to Art. 9 para. 2 lit. a of the GDPR. If you wish to exclude the processing of such special categories of data by us from the outset, we recommend that you either do not transmit such information, remove it from your documents, or make it unrecognisable. You can revoke your consent at any time in whole or in part with effect for the future. All you need to do is send a simple e-mail with your full name to hr@tourlane.com. You can, of course, also send us your revocation by post: Tourlane GmbH, Köpenicker Str. 126, 10179 Berlin. Please note that if you revoke your consent, we will subsequently no longer be able to consider your application in the form submitted. Our goal is to give our applicants a relaxed start at Tourlane. For this purpose, we support some applicants in the preparation for their employment: For example, we are happy to help with the search for accommodation or with necessary official procedures, e.g. to obtain a work visa. In order to both prepare for starting employment and to carry out the relevant necessary measures, the data provided to us in the application process may be processed on the basis of Art. 6 Para. 1 lit. B of the GDPR. If your application is successful and you become part of our Tourlane team, the data you provide in your application may also be used for personnel matters within the scope of employment. The legal basis for this is Art. 88 of the GDPR i.V.m. § 26 BDSG (new). In addition, data processing is carried out in accordance with Art. 6 Para. 1 lit. f of the GDPR in order to safeguard our legitimate interests for the following purposes: - The technical data collected when using the application portal is necessary to ensure the stable and secure operation of the platform. - Mutual legal claims may arise in connection with the application process (e.g. claims under the AGG, pre-contractual claims for damages). The processing of personal data may therefore be necessary for the assertion or defence of such claims.

7. Recipient of Your Data

Your application (be it online, by post or e-mail) will only be considered and processed by responsible members of the HR team. All employees entrusted with data processing are obligated to maintain the confidentiality of your data. The application portal is provided on our behalf by Greenhouse Software Inc., 455 Broadway, New York NY, 10013 USA (hereinafter referred to as “Greenhouse”), so-called contract processors pursuant to Art. 28 of the GDPR. For this purpose, your data will be stored and processed on Greenhouse servers in the USA. Greenhouse is certified according to the “Privacy Shield Framework“ and thus meets the European standards for legally compliant order data processing. In addition, before commissioning we were and remain confident that Greenhouse offers enough guarantees for secure and legally compliant data processing. Your data is first transferred via an encrypted connection to Greenhouse’s servers where it is temporarily stored. All data is encrypted based on the SSL procedure. Your data is then transferred to our internal servers via an encrypted connection and finally deleted from the Greenhouse servers. Your data will not be passed on to other third parties. We use the HireVue software solution, a service of HireVue Inc., 10876 South River Front Pkwy #500, South Jordan, UT 84095 USA (hereinafter: “HireVue”), to carry out the application process. The data collected in this method (video recordings of the interview, the assigned tasks, their results, the data provided specifically, etc.) are processed and stored on HireVue’s servers in the USA. HireVue processes this data as an order processor within the meaning of Art. 28 of the GDPR exclusively in accordance with our instructions and not for its own purposes. HireVue is certified according to the “Privacy Shield Framework” and thus meets the European standards for legally compliant order data processing. In addition, prior to commissioning HireVue, we were confident that HireVue offers sufficient guarantees for secure and legally compliant data processing. Your data is first transferred via an encrypted connection to the HireVue servers where it is temporarily stored. All data is encrypted using the SSL method. Your data is then transferred to our internal servers via an encrypted connection and finally deleted from the HireVue servers. Your data will not be passed on to other third parties. If you do not agree with this method of data processing, please let us know. In addition, we will only disclose your personal data to third parties if and insofar as this is necessary and legally permissible or if there is a corresponding legal or statutory obligation to do so, e.g. if we are obliged to do so by a court.

8. Duration of data storage

The processing of your personal data transmitted in the form of an application is generally carried out for the duration of the application process. If we are unable to offer you any employment, we will store the data you have provided for up to six months after the end of the application process (dispatch of the rejection) in order to answer questions in connection with your rejection and to be able to comply with the burden of proof under the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG). If you have given us your consent and your application is of fundamental interest, we will store your data for up to 12 months in order to contact you with new job offers if necessary. You can withdraw your application at any time. In this case your data will be deleted immediately. However, we reserve the right to store certain data for a period of up to six months in order to comply with statutory provisions, in particular the above-mentioned obligations to provide evidence under the AGG. If your application is successful, the data you provided can be used for personnel matters within the scope of your employment. In this case, your data will be stored for the duration of the employment relationship and will be deleted at the end of the employment relationship or after expiry of the statutory periods of limitation or exclusion under the employment contract at the latest.

9. Revocation, disclosure and other rights

You have the right, pursuant to Art. 15 of the GDPR, to obtain information about the personal data we process. In particular, you may request information on the processing purposes, the types of data processed, the categories of recipients, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection to processing, the existence of a right to appeal, the origin of your data if it has not been collected from us, as well as the existence of an automated decision-making process including profiling and, if applicable, meaningful information on its details.

Furthermore, pursuant to Art. 16 of the GDPR, you have the right to correct incorrect data and, if necessary, complete incomplete data. According to Art. 17 of the GDPR you also have the right to delete your personal data stored by us if one of the reasons for deletion according to Art. 17 of the GDPR is given (if the data is no longer necessary for the purposes for which it was processed, if you have revoked your consent and there is no other legal basis for processing, if you have a legitimate objection to the processing according to Art. 17 of the GDPR). Article 21 O of the GDPR if the data have been unlawfully processed or if the deletion is necessary to fulfil a legal obligation incumbent upon us), unless the processing is necessary for the exercise of our right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims.

Furthermore, according to Art. 18 of the GDPR you have the right to restrict the processing of your data if you dispute the accuracy of the data; the processing is unlawful; you refuse its deletion and we no longer need the data, but you need it to assert, exercise or defend legal claims; or you have objected to the processing according to Art. 21 of the GDPR. In addition, according to Art. 20 of the GDPR, you have the right to obtain the personal data that you provided to us in a structured, common and machine-readable format or to request transmission to another responsible person.

Furthermore, you can object to data processing - insofar as this is carried out on the basis of safeguarding our legitimate interests pursuant to Art. 6 lit. F of the GDPR - pursuant to Art. 21 of the GDPR, insofar as there are reasons for doing so which result from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to objection which is permissible without stating a particular situation.

Additionally, in accordance with Art. 7 para. 3 of the GDPR, you can revoke your consent to us at any time. As a result, we may no longer continue the data processing in the future.

Please address your requests for information and any other inquiries as well as your objection or revocation, stating your full name, to Tourlane GmbH, Köpenicker Str. 126, 10179 Berlin, Germany, AG Berlin-Charlottenburg, (HRB 170081B), Tel: 030 - 555 708 92, e-mail: hr@tourlane.de or datenschutz@tourlane.de.


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