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

Privacy policy of BetterDoc GmbH regarding employment applications 


We are pleased that you would like to apply to BetterDoc GmbH. In the following, we explain how we process your personal data in the context of an application and provide further relevant information in this regard. 



1. Who is responsible for processing your personal data? 

BetterDoc GmbH, Kaiser-Wilhelm-Ring 30-32, 50672 Cologne, Germany (hereinafter referred to as "we") is the data controller within the meaning of the EU General Data Protection Regulation ("GDPR"). 

For inquiries about data protection, you can reach us at the mail address datenschutz@betterdoc.org.

2. Data protection officer 

For all questions related to the processing of your personal data and the enforcement of your rights under the GDPR, you can consult our data protection officer Mr. Andreas Schmidt of TÜV Saarland / tekit Consult Bonn GmbH (http://www.tekit.de). 


3. For what purposes and on what legal basis do we process personal data? 

We process your personal data for the purpose of your application for an employment relationship, insofar as this is necessary for the decision on the establishment of an employment relationship with us. The legal basis for this is Section 26 (1) in conjunction with (8) sentence 2 of the Federal Data Protection Act (“BDSG”). As special categories of personal data pursuant to Art. 9 (1) GDPR, the indication of a severe disability may be processed in the context of your application. The legal basis for this is Art. 9 (2) b) GDPR in conjunction with. § 26 para. 3 BDSG in conjunction with para. 8 p. 2 BDSG. Furthermore, we may process personal data about you insofar as this is necessary for the defense of asserted legal claims against us arising from the application process. The legal basis for this is Art. 6 (1), f) GDPR; the legitimate interest is, for example, a duty to provide evidence in proceedings under the General Act on Equal Treatment (AGG). Insofar as an employment relationship arises between you and us, we may further process the personal data already received from you for the purposes of the employment relationship in accordance with Section 26 (1) BDSG if this is necessary for the implementation or termination of the employment relationship or for the exercise or fulfillment of the rights and obligations of the employee representation resulting from a law or a collective agreement, a works agreement or a service agreement (collective agreement).


4. What categories of personal data do we process? 

We process data that is related to your application. This may be general data about you (such as name, address and contact details), information about your professional qualifications and school education or information about professional training or other information that you provide to us in connection with your application. In addition, we may process job-related information that you have made publicly available, such as a profile on professional social media networks. 


5. What categories of recipient data are there? 

We may transfer your personal data to companies affiliated with us, insofar as this is permissible within the framework of the purposes and legal bases set out in Section 3. Furthermore, personal data is processed on our behalf on the basis of contracts in accordance with Art. 28 GDPR, this particularly by host providers or providers of job applicant management systems. 

Your data will be reviewed by the HR department after receipt of the application. Suitable applications will be forwarded internally to the team leaders responsible for the respective open position. If the application is also suitable for another related position that matches the requirement and task profile, the application may also be forwarded to other team leaders. In cases where legal regulations require consent to do so, this will be obtained from you. 

As a matter of principle, only persons who require your data for the course of our application process will have access to it.


6. Is the transfer to a third country intended?

A transfer to a third country is not intended. 


7. How long will your data be stored? 

We store your personal data for as long as it is necessary to make a decision about your application. Insofar as an employment relationship between you and us does not come about, we may continue to store data beyond this, insofar as this is necessary for the defense against possible legal claims. In this case, the application documents are deleted two months after notification of the rejection decision, unless longer storage is required due to legal disputes.


8. What rights do you have? 

As an applicant with us, you have the following data protection rights, depending on the situation in the individual case. For the exercise of the rights you can contact us or our data protection officer at any time using the data specified in Section 1 and 2: 


a. Information

You have the right to obtain information about your personal data processed by us and to request access to and/or copies of your personal data. This includes information about the purpose of the use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration; 


b. Correction, deletion or restriction of processing

You have the right to request that we correct any inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, possibly by means of a supplementary declaration. Your request will be processed without undue delay, and in any case within one month of receipt of the request, cf. Art. 12(3) GDPR.


c. Right of objection 

Insofar as the processing of personal data concerning you is carried out on the basis of Art. 6 (1) letter (f) GDPR, you have the right to object to the processing of this data at any time for reasons arising from your particular situation. We will then no longer process this personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. 

d. Right of withdrawal 

If the processing is based on consent, you have the right to revoke the consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until the revocation. To do so, you can contact us or our data protection officer at any time using the above data. 


e. Right to deletion 

You have the right to request that we erase personal data concerning you, and we are obliged to erase personal data without undue delay, in any case within one month after receipt of the request cf. Art. 12 (3) GDPR if one of the following reasons applies: - The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.

- You object to the processing in accordance with point 8.c above and there are no overriding legitimate grounds for the processing. 

- The personal data has been processed unlawfully. 

- The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which we are subject. 

This does not apply insofar as the processing is necessary: 

- for compliance with a legal obligation which requires processing under Union or Member State law to which we are subject. 

- for the assertion, exercise or defense of legal claims. 


f. Right to restriction of processing 

You have the right to request us to restrict processing if one of the following conditions is met: 

- the accuracy of the personal data is contested by you for a period enabling us to verify the accuracy of the personal data, 

- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data; 

- we no longer need the personal data for the purposes of processing, but you need it for the establishment, exercise or defense of legal claims, or 

- you object to the processing pursuant to 8.c above, as long as it has not yet been determined whether our legitimate grounds outweigh yours. If processing has been restricted pursuant to this point (e), such personal data may - apart from being stored - only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State. If you have obtained a restriction on processing, we will inform you before the restriction is lifted. 


g. Right of appeal 

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you believe that the processing of your personal data  infringes the GDPR .




9. Necessity of providing personal data 

The provision of personal data is neither legally or contractually required, or are you obliged to provide the personal data. However, the provision of personal data is necessary for the conclusion of a contract on an employment relationship with us. This means that if you do not provide us with personal data when applying for a job, we will not enter into an employment relationship with you. 





10. Talent pool 

If you agree to be included in our talent pool, your data will continue to be stored by us so that we can consider it for future job postings, the legal basis for this is Section 26 (2) in conjunction with (8) sentence 2 of the BDSG. If you are considered for a vacant position, your application documents will be forwarded to the relevant internal departments if necessary and the contact details you have provided will be used to contact you. Your documents will not be forwarded to external third parties. Inclusion in the talent pool is completely voluntary and participation can be terminated at any time.


a. Data concerned 

All data that you have sent to us as part of your application will be stored. This therefore includes: 

- Personal data such as name, address, contact details, etc. 

- Information about your education, such as information about your school and university degrees 

- If applicable, information about your work experience, such as information about your previous employment relationships In addition, the documents you upload, such as cover letters and resumes, will be stored by us. 


b. Period 

If you agree to be included in our talent pool, your data will be stored for two years. If your contact details, under which we can reach you, change, we ask you to inform us so that we can continue to contact you without any problems. For this purpose, you can simply send an informal e-mail to karriere@betterdoc.de. If we have not offered you a job after these two years, you have the option to remain in our talent pool for another two years. You will receive an email in this regard, to which you can respond informally. You can request the deletion of your data from the talent pool at any time by sending an informal e-mail to karriere@betterdoc.de. We will then remove your data from the talent pool and delete it. 


c. Data protection rights 

You are of course still entitled to the rights under the GDPR. You can view these in section 8 (What rights do you have?).


11. Otto Group Talent Pool System

In some cases, we offer you the opportunity to be included in the Otto Group's internal Talent Pool System. The Otto Group Talent Pool System serves to identify, retain and promote talented individuals and to ensure succession by actively promoting internal mobility within the Otto Group. If you have consented to the transfer of your data to the other Otto Group companies and have therefore decided to store your data in the Otto Group Talent Pool System, we will transfer the data you provided when creating your profile to Otto (GmbH & Co KG) (hereinafter OTTO), which will store it in the Otto Group Talent Pool System. With regard to the inclusion of your person in the internal Otto Group Talent Pool System and the provision of the Otto Group Talent Pool System, we are jointly responsible with Otto (GmbH & Co KG) and the other Otto Group companies that participate in the internal Otto Group Talent Pool System. We are primarily responsible for the collection, transmission and registration of your data and OTTO for the storage of your data and provision of the Otto Group Talent Pool System. After Otto (GmbH & Co KG) has transmitted your data to the companies participating in the Otto Group Talent Pool System, the Group companies process this data as data controllers under data protection law, e.g. for the purpose of establishing contact. A potential application process then normally takes place directly via the company's processes.

Data processing is based on your consent (Article 6(1)(a) GDPR). You can revoke your consent at any time by sending an email to yournextmove@ottogroup.com.

We and OTTO are available to you with regard to the processing under joint responsibility as central contact persons in their own area of activity. If you have any questions regarding data protection and to assert your rights as a data subject, please contact yournextmove@ottogroup.com. You can also assert your rights against us. If you contact us, we will coordinate with you in accordance with the joint controllership agreement in order to respond to your request and ensure the implementation of your data subject rights.

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.