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

General Information

We provide you with this privacy policy, which relates exclusively to data collected as part of the online application process, to inform you about how we handle your personal data collected during the application procedure.

Data Controller

The data controllers within the meaning of data protection law for the respective application processes are the companies to which you specifically apply:

Kalkhoff Werke GmbH, Europa-Allee 26, 49685 Emstek, Germany Tel.: 04473 9317 0 Commercial Register | Registration Number: HRB 150368 Registration Court: Oldenburg
FOCUS Bikes GmbH, Europa-Allee 26, 49685 Emstek, Germany Tel.: +49 (0)711 2484880 Commercial Register | Registration Number: HRB 150337 Registration Court: Oldenburg

A currently valid overview of these companies and their registration details can be found in the legal notices (Impressum) on the websites of our brands: www.kalkhoff-bikes.com and www.focus-bikes.com.

Email Data Protection Officer: privacy@pon.com

Personal Data in the Context of the Application Process

Personal data means any information relating to the personal or factual circumstances of an identified or identifiable natural person. This includes information such as your name, address, telephone number, and date of birth, but also data regarding your specific career history, etc., which can be assigned to a specific person with reasonable effort. Information that cannot be linked (directly or indirectly) to your real identity is, however, not considered personal data.

Legal Basis and Purposes for Processing Personal Data in Applications and the Application Process

If you apply to us electronically, i.e., by email or via our web form, we collect and process your personal data for the purpose of handling the application process and implementing pre-contractual measures. The legal basis for this processing is Section 26 (1) of the German Federal Data Protection Act (BDSG) in conjunction with Art. 6 (1) (b) GDPR (initiation of an employment relationship).

By submitting an application on our recruiting page, you express your interest in seeking employment with us. In this context, you transmit personal data to us, which we use and store exclusively for the purpose of your job search/application.

In particular, the following data is collected:

Name (first and last name)
Email address
Telephone number
The channel through which you became aware of us

In addition, you have the option to upload supporting documents such as a cover letter, your CV, and certificates. These may contain further personal data such as your date of birth, address, etc.

Only authorized employees from the HR department or employees involved in the application process have access to your data.

As a general rule, the storage of personal data takes place exclusively for the purpose of filling the vacant position for which you have applied.

Your data will be stored for a period of 180 days beyond the conclusion of the application process. This is generally done to fulfill legal obligations or to defend against any claims arising from statutory regulations. The legal basis for this storage after completion of the process is Art. 6 (1) (f) GDPR. Subsequently, we are obliged to delete or anonymize your data. In this case, the data is only available to us as so-called metadata without direct personal reference for statistical evaluations (for example, the proportion of women or men in applications, number of applications per period, etc.).

Furthermore, we offer you the opportunity to store your data for inclusion in a joint "Talent Pool" of the above-mentioned companies for 365 days after the conclusion of the application process, in order to identify any other interesting positions for you within these companies. This also applies, for example, to applications for an apprenticeship or internship. Provided you have given us a separate, voluntary consent for this, the legal basis for this processing is Art. 6 (1) (a) GDPR. You have the right to withdraw this consent at any time with effect for the future (see section on Data Subject Rights).

If you receive and accept an offer of employment from us during the application process, we will store the personal data collected during the application process at least for the duration of the employment relationship pursuant to Section 26 (1) BDSG.

Joint Data Processing

We use a central, shared applicant management system for our recruiting processes. Within this system, the HR departments of the above-mentioned companies work together. Provided it is useful for reviewing employment opportunities at one of the other participating companies, the HR departments may view your application data. The companies jointly decide on the purposes and means of this data processing. Your primary contact partner for all rights (e.g., access or erasure) remains the company to which you originally applied. The legal basis for this joint system operation and the bed-by-bed (on-demand) disclosure for efficient personnel selection is our legitimate interest pursuant to Art. 6 (1) (f) GDPR.

Disclosure of Data to Third Parties

The data transmitted as part of your application is transferred via TLS encryption and stored in a database. This database is operated by Personio GmbH, which offers HR management and applicant management software (https://www.personio.de/impressum/). In this context, Personio is our data processor pursuant to Art. 28 GDPR. The basis for the processing is a data processing agreement between us as the data controller and Personio.

Data Subject Rights

If personal data is processed by us as the data controller, 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 purpose of the processing. This includes, where applicable, the right of access (Art. 15 GDPR), right to rectification (Art. 16 GDPR), right to erasure (Art. 17 GDPR), right to restriction of processing (Art. 18 GDPR), right to data portability (Art. 20 GDPR), and right to object (Art. 21 GDPR). If the processing of personal data is based on your consent, you have the right to withdraw this consent under data protection law pursuant to Art. 7 (3) GDPR.

Please contact our Data Protection Officer to assert your data subject rights in relation to the data processed in this online application process. In addition, you have the right to lodge a complaint with a data protection supervisory authority (e.g., The State Commissioner for Data Protection of Lower Saxony, Hanover).

Closing Provisions

We reserve the right to adapt this privacy policy at any time so that it always complies with current legal requirements or to reflect changes in the application process or similar. The new privacy policy will then apply to any subsequent visit to this recruiting page or any new application.

In addition to this privacy policy, you can view the respective general privacy policies on the websites of our brands at https://www.kalkhoff-bikes.com/en_gb/privacy-policy or https://www.focus-bikes.com/de_en/service/privacy-policy.

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.