Data protection in the application process

This data protection notice is to inform you about the processing of your personal data when you apply for a position at LOYALTY PARTNER GmbH or its affiliated companies (see Section 1) either by letter, E-mail, or using the online application tool (collectively referred to below as the “application process”).

1. Parties responsible for data protection

LOYALTY PARTNER GmbH and the company to which you are applying for a position are jointly responsible for the application process under data protection law. The company may be one of the following: PAYBACK GmbH, LOYALTY PARTNER Solutions GmbH, or PAYBACK Austria GmbH. These companies have concluded agreements stipulating which of them fulfils which data protection obligations. LOYALTY PARTNER will provide the essential content of these agreements upon request. PAYBACK Austria has its registered office at Kärntner Str. 21 – 23, 1010 Vienna. All other companies are domiciled at Theresienhöhe 12, 80339 Munich, Germany, and are jointly referred to below as “LOYALTY PARTNER.” You may also reach LOYALTY PARTNER by email at karriere@loyaltypartner.com.

2. Your data when accessing the online application tool

When you access the online application tool, the LOYALTY PARTNER service provider’s web server collects the following data for technical reasons and stores it until it is automatically deleted: the page from which the online application tool was accessed (“referrer’), the content accessed, the date and time of the server request and access, the amount of data transferred, the access status (message indicating whether the request was successful, file transferred, file not found, etc.), a description of the type and version of the web browser used/recognition data of the browser and operating system used, and the IP address of the requesting computer. This data is referred to all together as log files.

Storing log files ensures the proper functioning of the online application tool and allows LOYALTY PARTNER to improve it. LOYALTY PARTNER cannot match the data to specific individuals, and no statistical evaluation of the data is currently undertaken. The data will also not be transmitted to third parties.

The legal basis for the associated data processing is Art. 6 Para. 1 f) GDPR (balance of interests – based on the interest of Loyalty Partner in providing interested parties with an online application tool).

3. Your data when submitting an application

3.1 Your application data

When you apply online for a position at LOYALTY PARTNER, you may send your application documents (e.g. cover letter, CV, certificates) either by E-mail or via the online application tool. In order to use the online application tool, you must create a personal account first. Your applications and profile are administered via this account in the application tool.

In order to process your application, LOYALTY PARTNER requires your full name, contact information (address, E-mail address, telephone numbers), curriculum vitae (esp. information on your education, course of studies, degrees, previous employers, and current employer if applicable), and suitable proofs of qualification (e.g. certificates, work samples). In addition, you may voluntarily provide LOYALTY PARTNER with additional information, such as your current and desired salary, for example in your cover letter.

All of this personal data is referred to together below as “application data.”

If file your application via E-Mail, by post or through a recruiter, your application data will be entered manually in the online application tool. This is necessary to enable the handling of these applications within the standard application process.

LOYALTY PARTNER processes your application data solely to conduct the application process. In particular, this includes LOYALTY PARTNER's collection of the application along with the applicant data; the review of your application; contact with you to invite you to an interview; a rejection or a request for further information about you; and a decision on a final acceptance or rejection regarding the specific position for which you have applied.

LOYALTY PARTNER will only disclose your application data to those employees who are directly involved in the application process, including the decision on filling the position.

A transfer of this data to third parties outside of LOYALTY PARTNER will take place only if and insofar as you have given your separate consent to such transfer.

3.2 Legal basis

The legal basis for the processing of your data described above is Art. 6 Para. 1 lit. b) in conjunction with Art. 88 Para. 1 GDPR in conjunction with § 26 Para. 1 BDSG (German Federal Data Protection Act; Data processing for employment-related purposes, in particular for hiring decisions).

4. Assessment Center und Selection Days

4.1 Implementation

For certain positions LOYALTY PARTNER carries out in addition to the application process so-called Assessment Center or Selection Days. These measures shall help us to get to know you better and to assess your suitability for the vacant position. In light of this, we use your contact information (E-Mail address, phone number) in order to invite you to the upstream online test. In the course of the Assessment Center or Selection Days we use your application data (e.g. CV) that allows us to better evaluate your qualification.

However, LOYALTY PARTNER will only disclose your application data to those employees who are directly involved in the application process, including the decision on filling the position.

4.2 Legal basis

The legal basis for the processing of your data described above is Art. 6 Para. 1 lit. b) GDPR in conjunction with Art. 88 Para. 1 GDPR in conjunction with § 26 Para. 1 BDSG (German Federal Data Protection Act; Data processing for employment-related purposes, in particular for hiring decisions).

5. Applicant pool

5.1. Your consent

If you consent to the inclusion of your data in the applicant pool, your personal data disclosed in the course of the application process shall be stored by LOYALTY PARTNER beyond the end of the application procedure at issue in a separate database, so-called applicant pool.

In this case all companies mentioned in Section 1 and jointly referred to as LOYALTY PARTNER can use this data in order to contact you subsequently and to proceed with the application procedure if you might be considered for another position in one of the companies.

Any transfer of data to third parties shall not occur.

For these purposes the data stated in the preceding sections submitted by you in the course of the application process (e.g. cover letter, CV, certificates) shall be processed by LOYALTY PARTNER. Provided that it concerns special categories of personal data according to Art. 9 GDPR (e.g. photo, revealing racial or ethnic origin, information concerning severe disability or marital status), your consent applies also to this data.

You have the right to withdraw such consent at any time. You can notify LOYALTY PARTNER or the companies mentioned in Section 1 in any form of such withdrawal, for example by telephone at (089) 99741-879, by e-mail to recruiting@loyaltypartner.com, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich. Any data usage in accordance with this Section shall not occur, if you have not consented thereto or if you withdraw the consent you have already given us. As a matter of course, the withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of the consent prior to its withdrawal.

5.2 Legal basis

The legal basis for the processing of your data described under 4.1 is Art. 6 Para. 1 lit. a) GDPR in conjunction with Art. 88 Para. 1 GDPR in conjunction with § 26 Para. 2 and Para. 3 BDSG (consent).

6. Storage period

LOYALTY PARTNER stores your personal data for the purpose of legal defense for up to six months after completion of the application process. If you have submitted the separate statement of consent to be admitted to the applicant pool, LOYALTY PARTNER will store your personal data for 24 months. LOYALTY PARTNER stores log files (see Section 2) for a maximum of 30 days.

7. Data processing by service providers

LOYALTY PARTNER employs various service providers (so-called contract processors) for support in conducting the application process, such as for providing the online application tool at https://www.loyaltypartner.com/de/karriere/jobs/stellenmarkt/. If necessary, these service providers also process personal data. The service providers are carefully selected and monitored by LOYALTY PARTNER.

8. Place of data processing

The processing of personal data takes place exclusively within the European Union. The data is not transferred to so-called third countries, nor does LOYALTY PARTNER intend to do so. Third countries are countries outside the European Union and the European Economic Area.

9. Your rights

LOYALTY PARTNER will be happy to inform you upon request whether and what data is stored about you. If the legal requirements are met, you have the right to have this data corrected, blocked or deleted. You also have the right to receive from us the data about you that you have provided to us in an organized, common, and ma-chine-readable format; you may also transmit this data to other recipients or have it transmitted by us. You also have the right to appeal to the competent supervisory data protection authority.

Soweit LOYALTY PARTNER Ihre Daten auf Basis der Interessenabwägung verarbeitet, steht Ihnen bei Vorliegen der gesetzlichen Voraussetzungen ein Widerspruchsrecht zu.

To the extent that LOYALTY PARTNER processes the data concerning you on the basis of legitimate interest, you have the right to object, in accordance with the statutory requirements, at any time to processing of such personal data. You may exercise your right to the correction, blocking, or deletion of your personal data as well as your right to the transfer of data vis-à-vis any of the persons responsible mentioned in Section 1 (cf. Art. 26 Para. 3 GDPR), for example by telephone at (089) 99741-879, by e-mail to karriere@loyaltypartner.com, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich.

10. Necessity of data processing

Providing your personal data is necessary for conducting the application process and thus for possibly establishing an employment relationship with LOYALTY PARTNER. You are not obliged to provide your personal data to LOYALTY PARTNER. However, if you are not prepared to do so, the application process can be completed only partially or not at all. In this case there can be no employment relationship between yourself and LOYALTY PARTNER.

Of course, this does not apply to the inclusion of your data in the applicant pool, which is done exclusively on the basis of your voluntary consent (see Section 3).

LOYALTY PARTNER does not carry out any statistical evaluation of the data or other observation of applicant behavior (profiling); in particular, there is no automated decision-making pursuant to Art. 22 Para. 1 and 4 GDPR.

11. Data protection officer

If you have any questions about data protection at LOYALTY PARTNER, please contact the Data Protection Officer: LOYALTY PARTNER Data Protection Officer, Theresienhöhe 12, 80339 Munich, Germany. You may also send questions and comments by E-mail to datenschutz@loyaltypartner.com.

Last update 04/2019