Processing of Personal Data in the Context of Recruitment

Privacy Notice for Job Applicants

1. Introduction

This Privacy Notice explains how U Fund Services S.à r.l. (the “Company”, “UFS”, “we” or “us”) processes personal data relating to individuals who apply for a position with us (“you” or “your”). We appreciate your interest in working with UFS and your application submitted via our careers page.

This Privacy Notice applies to all candidates who apply through our recruitment channels, including our online recruitment platform operated by Personio.

If an employment relationship is established, the processing of your personal data will be governed by a separate privacy notice applicable to employees.

2. Identity of the Controller

The controller within the meaning of Article 4(7) of the GDPR is:

U Fund Services S.à r.l.

76 rue de Merl

L‑2146 Luxembourg

Grand Duchy of Luxembourg

R.C.S. Luxembourg: B273543

E‑mail: dataprotection@ufundservices.com

UFS acts as Data Controller and determines the purposes and means of processing applicants’ personal data in accordance with its Data Protection Policy adopted by the Board.

3. Data Protection Governance

UFS has appointed a Data Protection Responsible Person / Data Protection Officer in accordance with the GDPR and Luxembourg data protection law.

Data Protection Responsible Person

Name: Youssef Oussine

E‑mail: dataprotection@ufundservices.com

You may contact the Data Protection Responsible Person at any time with questions regarding this Privacy Notice or the processing of your personal data.

4. Categories of Personal Data Processed

In the context of recruitment, we may process the following categories of personal data:

Identification and contact details (e.g. name, address, email address, telephone number)
Application documents (CV, cover letter, certificates, diplomas, references)
Employment and education history
Interview notes, evaluation results, assessments, and aptitude tests
References and information obtained from referees, where applicable
Information from publicly accessible professional sources where relevant for the position
Administrative and technical data generated during the recruitment process

We only process personal data that is relevant, adequate, and limited to what is necessary for the recruitment process, in accordance with the principles of data minimisation and purpose limitation.

5. Purposes of Processing

Your personal data is processed exclusively for recruitment‑related purposes, in particular:

assessing your suitability for the position applied for;
conducting and managing the recruitment and selection process;
communicating with you throughout the recruitment process;
deciding on the establishment of an employment relationship;
complying with legal and regulatory obligations; and
defending or asserting legal claims, where necessary.

Where you expressly consent, your personal data may also be processed for inclusion in a talent pool, allowing us to consider you for future vacancies within UFS.

6. Legal Basis for Processing

Your personal data is processed on one or more of the following legal bases under Article 6 of the GDPR:

Article 6(1)(b) – processing necessary for taking steps at your request prior to entering into an employment contract;
Article 6(1)(c) – compliance with legal and regulatory obligations applicable to the Company;
Article 6(1)(f) – legitimate interests pursued by the Company, including the efficient organisation of recruitment processes and safeguarding business operations; and
Article 6(1)(a) – consent, where applicable (e.g. inclusion in the talent pool).

Where processing is based on your consent, you may withdraw that consent at any time with effect for the future. The provision of personal data as part of the application process is not a statutory or contractual requirement. However, failure to provide information necessary for the recruitment process may result in our inability to properly assess or continue your application. We do not use automated decision‑making or profiling within the meaning of Article 22 GDPR as part of the recruitment process.

7. Retention Periods

Personal data relating to unsuccessful applications is retained for six (6) months after completion of the recruitment process, unless a longer retention period is required by law or justified for the establishment, exercise, or defence of legal claims.

If you consent to inclusion in our talent pool, your personal data will be retained for a maximum of two (2) years, after which it will be securely deleted.

If an employment relationship is established, applicant data will be transferred to the personnel file and retained in accordance with applicable employment and retention laws.

8. Recipients of Personal Data

Access to your personal data is restricted to authorised persons who require such access for recruitment purposes, including:

Human Resources personnel,
Hiring managers, and
Relevant internal decision‑makers acting on behalf of UFS.

Use of Processors

We use Personio SE & Co. KG, Seidlstraße 3, 80335 Munich, Germany, as a recruitment software provider. Personio acts as a data processor within the meaning of Article 28 GDPR and processes personal data solely on our documented instructions. A data processing agreement is in place.

Personal data is hosted on servers located within the European Economic Area (EEA). No transfers to third countries are intended.

9. Applicant Rights

Subject to applicable law, you have the following rights:

Right of access (Article 15 GDPR)
Right to rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object (Article 21 GDPR)
Right to withdraw consent at any time (Article 7 GDPR)

To exercise your rights, please contact the Data Protection Responsible Person. Proof of identity may be required.

10. Complaints

You have the right to lodge a complaint with the Luxembourg supervisory authority:

Commission Nationale pour la Protection des Données (CNPD)

Website: https://www.cnpd.lu

We encourage you to contact us first so that we can address your concerns directly.

11. Updates to this Privacy Notice

This Privacy Notice may be updated from time to time to reflect legal, regulatory, or operational changes. The version applicable at the time of your application shall apply.

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