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

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.


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.