Privacy Notice for Applicants and Job Seekers

This privacy notice is to inform you about the processing of your personal data when you apply for a position or register for inclusion in our applicant pool 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 and are hereinafter collectively referred to as "LOYALTY PARTNER". 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. You may also reach LOYALTY PARTNER by email at karriere@PAYBACK.GROUP.
 

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 collectively referred to as "log data" and is stored in "log files".

The storage of log data in log files serves the purpose of the proper functioning of the online application tool and enables LOYALTY PARTNER to improve the application tool. LOYALTY PARTNER cannot match the log data to specific individuals, and no statistical evaluation of the data is currently undertaken. The data will also not be transmitted to third parties. Only persons entrusted with the technical support of the online application tool have access to the log files.

The legal basis for the associated data processing is Art. 6 Para. 1 lit. f) GDPR (legitimate interests – based on the interest of Loyalty Partner to ensure the functionality of the online application tool for applicants and to continuously improve it).

Note on the right to object

On grounds relating to your particular situation, you have the right to object to the data processing described above at any time, in accordance with Article 21 GDPR. We will then no longer process the personal data concerned, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the related person, or for the establishment, exercise or defense of legal claims.

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. You may create a personal account when using the online application tool. You can administer your applications profile 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 you file your application via E-Mail, by post or through a personnel consultant, 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.

If you apply via LinkedIn, we import the information you share on LinkedIn into the online application tool and subsequently synchronize the job and the status of your application process within our LinkedIn Talent Solutions portal.

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.

If your application is successful, your uploaded application documents (CV and any other documents) will be transferred to our electronic personnel file. Further details can be found in the "Data protection information for colleagues of PAYBACK GROUP companies". You will receive these together with our offer.

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) BDSG (German Federal Data Protection Act; Data processing in the employment context, in particular for recruitment purposes).
 

4. Assessment Center, Selection Days, Coding Challenges and Case Interviews

4.1 Implementation

For certain positions LOYALTY PARTNER carries out in addition to the application process as per Section 3 so-called Assessment Center, Selection Days, Coding Challenges or Case Interviews. 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, Selection Days, Coding Challenges or Case Interviews 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.

In the case of participation in Assessment Centers, Selection Days, Coding Challenges or Case Interviews, the resulting data will be stored for up to six months after sending the rejection in the case of a rejection for the purpose of legal defense, in the case of an acceptance we delete the data within 4 weeks after completion of the application process.

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 in the employment context, in particular for recruitment purposes).
 

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.

Furthermore, LOYALTY PARTNER offers you the opportunity to submit a speculative application independently of a specific job posting or to store your data in the applicant pool independently of an application. If you give your consent to be included in the applicant pool, you will be listed as a so-called prospect with LOYALTY PARTNER. In this case, LOYALTY PARTNER will also store the personal data that you provided as part of the unsolicited application or registration for the applicant pool in the applicant pool.

In the above-mentioned cases all companies mentioned in Section 1 and jointly referred to as LOYALTY PARTNER can use this data to contact you subsequently to follow up on the actual application process or to ask you to apply for a different position in one of the companies. LOYALTY PARTNER will also contact you regularly via e-mail with Information about other open positions, news, and events. LOYALTY PARTNER may ask you to extend your consent before the end of the storage period or delete your data in due time.

Your application data will only be disclosed to those LOYALTY PARTNER employees who are directly involved in the application process, including the decision to fill the position.

The transfer of this data to third parties outside LOYALTY PARTNER shall not occur unless and to the extent that you have separately consented to such transfer.

For these purposes the data stated in the preceding sections submitted by you in the course of the application process or when registering for the applicant pool (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 karriere@PAYBACK.GROUP, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 München. You may also use your optional account and withdraw consent on the career website under the option “My Profile”. If you have not declared your consent or if you revoke your consent, data storage and use in accordance with this section will not take place. As a matter of course, the withdrawal of consent has no effect on the current application process, in the context of which you may have transmitted your data to us in accordance with section 3. A revocation of consent does not affect the lawfullness of the data processing carried out on the basis of the consent until the revocation.

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. In the case of an unsolicited applications, your data will be deleted immediately if no suitable position is available or foreseeable.

If you have submitted the separate statement of consent to register to the applicant pool, LOYALTY PARTNER will store your personal data for 24 months. After 24 months your personal data will be deleted unless you have agreed to an extended storage. Should application procedures occur from your participation in the applicant pool, we will store your personal data in accordance with the rules for application procedures.

LOYALTY PARTNER stores personal data in log files (see Section 2) for a maximum of 30 days.
 

7. Source of the data

We either collect the personal data directly from the data subject or receive it from personnel consultants engaged by us or personnel consultants, who act on behalf of the applicants.

In addition, there are statements made by our employees commissioned internally to carry out assessments as part of the application process, such as the results from an Assessment Center.
 

8. 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://jobs.PAYBACK.GROUP. If necessary, these service providers also process personal data. The service providers are carefully selected and monitored by LOYALTY PARTNER.

If you are a member of the LinkedIn network and have activated the corresponding function in LinkedIn (see section 3.1 of this privacy policy), LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, also processes data on its own responsibility. You can find out more about this in LinkedIn's data protection information.
 

9. Place of data processing

The processing of personal data by us takes place exclusively within the European Union. The data is not transferred by us to so-called third countries, which in this context means countries outside the European Union and the European Economic Area.
 

10. 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, restricted in processing, 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 machine-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 a supervisory data protection authority, e.g. to the Bavarian State Office for Data Protection Supervision, Postfach 1349, 91504 Ansbach, www.lda.bayern.de.

To the extent that LOYALTY PARTNER processes your data on the legal basis of legitimate interest, you have the right to object, if the legal requirements are met. After an exercise of this right to object, we will no longer process the personal data concerned, unless we can demonstrate compelling legitimate reasons for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the purpose of asserting, exercising or defending legal claims.

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 those responsible as per Section 1 (cf. Art. 26 Para. 3 GDPR), for example by telephone at (089) 99741-879, by e-mail to karriere@PAYBACK.GROUP, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich.
 

11. Necessity of data processing

The provision of 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 based on your voluntary consent (see Section 5).

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.
 

12. 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@payback.de.

Last update 08/2023

I hereby consent to LOYALTY PARTNER GmbH storing my personal data, which I have provided during the application process, beyond the end of that process itself in a separate database called the applicant pool. This applies equally to applications for a specific position to be filled and to unsolicited applications. I agree that LOYALTY PARTNER GmbH and its affiliates listed below may use this data to contact me later, should I be considered for another position with one of the companies listed in addition to my original application. If I register for inclusion in the applicant pool independently of an application, I consent to my personal data being used to consider me for future job placements and to contact me for this purpose. I will also regularly receive e-mail updates from LOYALTY PARTNER GmbH and its affiliated companies regarding open positions, news, and career events.

I agree that LOYALTY PARTNER GmbH may contact me before the expiry of the storage period mentioned below to ask for an extension of this consent.

The companies affiliated with LOYALTY PARTNER GmbH are PAYBACK GmbH, PAYBACK Austria GmbH and LOYALTY PARTNER Solutions GmbH.

After submitting this declaration of consent, my data will be stored in the applicant pool for 24 months and then deleted, unless I agree to further storage of my data beyond this period. If I am still in an application process at that time, this data will be stored in accordance with the rules for application processes. There will be no transfer of my data to third parties, except the above-mentioned affiliates of LOYALTY PARTNER GmbH, which have access authorization.

The data stored may include all the information that I have provided during the application process or when registering for the applicant pool (e.g., cover letter, curriculum vitae, certificates). Should this include “special categories of personal data” within the meaning of Art. 9 GDPR (e.g., a photo disclosing my ethnic origin, information about a possible disability, or my marital status), my consent also extends to this data.

This consent is voluntary and has no effect on my chances in the original application process, provided I am in such when registering for the applicant pool. I may refuse consent without providing reasons and withdraw it freely at any time without fear of disadvantage. I may withdraw my consent in any form, such as by telephone at (089) 99741-879, by e-mail to karriere@PAYBACK.GROUP, or in writing to LOYALTY PARTNER GmbH, Theresienhöhe 12, 80339 Munich. I can also use my optional account and withdraw consent on the career website under the option “My Profile”. If I do not give my consent or if I withdraw my consent, my data will be deleted when no longer needed for the application process. If I have registered to the applicant pool independently of an application procedure, my data will be deleted immediately in the event of refusal or revocation of consent.

Last update: 08/2023