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Germany
Version: May 2020
We as the Intelligent Apps GmbH („FREE NOW“, „we“ or „us“) take data protection in general quite serious. In the following we will inform you about the personal data FREE NOW is processing and for what purpose we are processing your personal data when you apply for a job. Additionally, it explains your rights under the GDPR, including the right to object certain processing activities executed by FREE NOW. If additional information can be voluntarily shared, these are indicated as being “optional“.
This privacy policy applies in addition to our standard privacy policy where you will find general information on data processing relating to your visit on our website and our FREE NOW application.
Table of Contents
1. Information on the Data Controller
Data controller under Art. 4 (7) GDPR for your personal data is
Intelligent Apps GmbH („FREE NOW“)
Große Elbstraße 273
22767 Hamburg
Germany
E-Mail: career@free-now.com
The easiest way to reach our data protection officer is by sending an email to career@free-now.com or writing to the above address with the subject “Data Protection Officer”.
2. Definitions
“FREE NOW Group“ consists of Intelligent Apps GmbH, mytaxi Network Ltd., mytaxi Austria GmbH, mytaxi Network Ireland Ltd., mytaxi Italia Sr., mytaxi Polska Sp.z.o.o, mytaxi Portugal Unipessoal Lda., mytaxi Iberia S.L., Clever Tech Srl., Transcovo SAS, Transopco SAS, Transopco UK Ltd., Transopco Portugal Unipessoal Lda, BEAT Mobility Services Single Member Societe Anonyme
“Personal Data“ are all information which relates to an identified or identifiable natural person. This includes, e.g., items like the name, postal address, e-mail address or telephone number, but also usage data like your IP address.
“Processing“ is every process carried out with or without automated assistance or every sequence of such processes in connection with personal data, e.g. obtaining, capturing, organizing, ordering, saving, adjusting or modifying, sorting, accessing, using, disclosing by transmission, distributing or any other form of making available, comparing or connecting, limiting, deleting or destroying.
3. Categories of personal data and purposes of processing
When you apply for a job at FREE NOW, we process the data you provided us with. This data will solely be processed in order to enter an employment relationship with you. In the following paragraphs we will explain the purposes, the legal basis of the processing and which exact data is processed during the application process.
3.1. Greenhouse
FREE NOW is using Greenhouse as application management tool where internal/ external applicants upload their application documents and FREE NOW recruiters as well as hiring managers can view the applications. If you apply internally you may be forwarded to the internal job board of Greenhouse to hand in your application documents. The personal data will be processed during the FREE NOW application process are the following:
your contact details (name, address, phone number and email-address), your application documents (resume, cover letter, former professional experience, information on education, certificates), salary expectations, motivation to apply, the job title of the vacancy, the possible entrance date and as the case may be health data (like information about a disability) and for internal applications the current position at FREE NOW and information if your supervisor is informed about your application.
FREE NOW will process your data in order to enter an employment relationship with you and therefore do this on the basis of Sec. 26 Abs. 1 German Federal Data Protection Act in connection with Sec. 8 German Federal Data protection Act (new) as well as Sec. 22 Abs. 1 b) German Federal Data Protection Act. Greenhouse is incorporated in the United States of America (US). As this is a data transfer to a country outside the European Union, FREE NOW took all necessary measures to secure your data (e.g. EU standard contractual clauses) pursuant to Art. 46 GDPR to safeguard the data transfer.
Additionally, FREE NOW offers a so-called Referral Program to their employees. This means that FREE NOW employees can refer applicants and will receive a reward if the referred person is employed. There are two ways how you can get referred: Firstly, one of our employees will enter the above-mentioned applicant data in our Greenhouse tool for you after you gave your consent to do that or secondly, he or she will send you a special link to the application where you can enter all the information yourself. As a result of this, we will make a connection between you and the referrer to be able to reward the referrer when you are hired.
Further information on data privacy at Greenhouse can be found at: www.greenhouse.io/privacy-policy
3.2. Predictive Index
During the application process we may use a behavior-based personality analysis. This test is supplied by our partner Predictive Index, 101 Station Drive, Westwood, MA 02090, United States (PI). For this test, we will enter your name and email address into the PI tool to generate an invitation email which will be sent by Predictive Index.
During the test you will have to choose several attributes to answer some questions. The results will only be reviewed by our specially trained recruiters in regard to the vacancy you applied for. The Predictive Index is incorporated in the US. Since this is defined as a data transfer to a non-EU country, FREE NOW has set up all necessary measures (e.g. EU standard contractual clauses) to ensure an appropriate data protection level. Taking part in this online test is voluntary. Not taking part will at no point lead to a disadvantage in the application process. We would like to emphasise that no automated individual decision-making will take place at any time. A transfer to third parties is precluded. Legal basis for processing your personal data from the PI personality analysis is our legitimate interest in understanding the motivation of your application pursuant to Art. 6 (1) (f) GDPR. For further information how PI will process your personal data please see PI’s privacy policy on their website under: www.predictiveindex.com/privacy
3.3. Video Interviews
During the application process we may conduct video interviews and use the program Zoom by Zoom Video Communications Inc., 55 Almaden Blvd, 6th Floor, San Jose, CA 95113 United States. Since the data is transferred via servers located in the US and therefore is transferred to a non-EEA country, we took all necessary measures to ensure an adequate level of security.
At no point the interviews will be recorded by us. But we will take notes and assessments regarding internal criteria. We process your data for the initiation of an employment relationship according to Sec. 26 (1) German Federal Data Protection Act. Further information can be found on Zoom’s privacy policy under: zoom.us/privacy
3.4. EU regulations for combating terrorism
According to the EU regulations on combating terrorism no. 2580/2001 and no. 881/2002, requires that no customer, supplier, service provider or employee of FREE NOW may be a terror suspect named in the centrally managed lists (terrorism lists). Therefore, FREE NOW is obliged to check these terror lists prior to the realization of an employment relationship. Your data in this case are processed for the fulfilment of a statutory duty according to Art. 6 (1) (c) GDPR.
3.5. Relocation Service
FREE NOW works together with a relocation service provider to offer our employees a service which helps them with everything that is connected to the relocation to Germany. The service provider is bound by our instructions and we have obtained information about their technical and organizational measures for the secure processing of personal data. FREE NOW may forward your name, email-address and your pass, ID or visa to the provider for the relocation service. We will only transfer the data if you have given the explicit consent in writing. You have the right to withdraw the consent at any time. Please just contact us at the address given in section 1 of this Privacy Policy. The legal basis for processing your data is based on Art. 6 (1) (a) GDPR.
3.6. Social Media
FREE NOW may also obtain data from other sources, websites and other publicly accessible data on the internet. This includes data you manifestly made public in a social media online account like LinkedIn or Xing or when getting in touch with us via the social media platforms. This data may be your contact details (name, address, phone number and email-address), your application documents (resume, cover letter, former professional experience, information on education, certificates), your salary expectations, the job title of the vacancy, the possible entrance date and as the case may be certain skills you provided via the social media platform. We process for the initiation of an employment relationship according to Sec. 26 (1) German Federal Data Protection Act.
3.7. Defense against legal claims
Additionally, FREE NOW may process your data, if this is necessary for defense against legal actions against us resulting from the recruiting process pursuant to Art. 6 (1) (b) & (f) GDPR and restrict your data for half a year after your application has been rejected.
4. Data Exchange within the FREE NOW Group
To build up a group wide talent pool, we may transfer personal data of our applicants within the FREE NOW Group. FREE NOW will not disclose any of your personal data without your explicit consent given within the application process. You have the right to withdraw the consent at any time. Please just contact us at the address given in section 1 of this Privacy Policy. The legal basis for processing your data is based on Art. 6 (1) (a) GDPR.
5. Your Rights
You have the right to obtain confirmation as to whether or not personal data concerning you is being processed by us. Where this is the case, we will be pleased to give you access to the personal data and the information listed in Art. 15 GDPR.
In addition, you have the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR), subject to the relevant legal requirements. In addition, you have the right to object to the processing under the statutory conditions (Art. 21 GDPR) or to withdraw any consent you have given at any time with effect for the future (Art. 7 (3) GDPR).
In order to assert your rights against us, it is sufficient to send an e-mail to career@free-now.com or a postal letter to the address mentioned under “1. Information on the Data Controller”.
In addition, you may at any time lodge a complaint with a competent supervisory authority if you consider that the processing of your personal data infringes data protection regulations (Art. 77 GDPR).
6. Data transfer in-/outside the European Union or the European Economic Area
In some cases, we contract external service providers to process data (e.g. management of applications or personality analysis). Therefore, it is necessary to transfer your personal data to our contractors who process your data strictly bound to the respective reason we contracted them for. Our contractors are chosen with special care and instructed in writing. They are bound by our instructions and we assessed their technical and organisational measures to secure the security of any personal data that is transferred to them.
When the service providers are incorporated inside the EU and European Economic Area (EEA) we sign data processing agreements according to Art. 28 (3) GDPR with them.
Whenever personal data is processed by a service provider incorporated in a country outside the EU or EEA, this is only done, on the basis of decisions of the EU commission according to Art. 45 GDPR or data protection is guaranteed by other measures such as EU standard contractual clauses or binding corporate rules. FREE NOW has taken all necessary and appropriate measures to ensure the safety and privacy of your data when working with external service providers necessitates the special protection of your data.
7. Data Security
We have taken appropriate technical and organizational measures to guarantee data security, in particular to protect your personal data against access by third parties, as well as accidental or intentional modification, loss or destruction. Such measures are reviewed periodically and adapted in line with the state of the art.
8. Retention periods
The data provided by you to us is only stored for as long as is required (up to 12 months) to perform the respective purpose for which you have transmitted your data, or inasmuch as it is required for conformity with statutory or official requirements.
If you have given your consent to store the data for example for our internal talent pool, we may process them until you withdraw your consent for this processing.
If we enter a relationship of employment with you, your data will be processed by the means set forth in the privacy policy available on the internal FREE NOW confluence page.
9. Updates and Changes
We retain the right to modify this privacy policy at any time in the future in accordance with the applicable data protection regulations.
