We are pleased that you would like to apply for a job with us. Below we explain how we process your personal data in the context of an application and what rights you have in this regard.

 

1.    WHO IS THE CONTROLLER AND DATA PROTECTION OFFICER?
The controller within the meaning of Art. 4 No. 7 GDPR for the processing of your personal data described in more detail below is PACE GmbH, Am Bahnhof Westend 13, 14059 Berlin. You can contact us by telephone on 030/29362-0 or by email at info@pace.de.  

 

2.    WHICH PERSONAL DATA DO WE COLLECT?
As part of your application, we process the data you provide yourself (see detailed description below).

If you do not provide us with the data (in particular your name and contact details, information on your educational and/or professional background), we will not be able to process your application, or at least not completely.

  • master and contact data such as: Name and address; telephone number and e-mail address;

  • data on educational and/or professional background, such as: Education, work experience, current position or role in the company, most recent salary, if available;

  • other personal data that may be contained in the CV submitted to us;

  • data that enables a connection to a recruitment form, such as user ID, connection data: User ID, connection data.

In principle, we do not process any special categories of personal data (such as data on health status or membership of a trade union association).

If you yourself provide information in this regard, the data will either be deleted or only processed if the requirements of Art. 9 (2) GDPR are also met, for example in order to exercise rights arising from labor law or social security and social protection law or to comply with our obligations in this regard. 

Please note that we may also request further information (not mentioned in the application) if this is deemed necessary in relation to the position in question, for example to check for any conflicts of interest that may arise in connection with the activities envisaged for the position.

 

3.    WHO PROVIDES US WITH PERSONAL DATA?
Personal data that we do not receive directly from you is communicated to us by the following bodies and/or collected by or through these bodies:
- head hunters and specialised recruitment companies;
- other TXT Group companies;
- Universities, schools, educational institutions, training institutions or organizations with which we work.

 

4.    FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA AND ON WHAT LEGAL BASIS DOES THIS PROCESSING TAKE PLACE? HOW LONG IS THE DATA BEING STORED?
The processing of personal data serves the purposes described below.

Case A

Recruitment and selection and/or management of (i) spontaneous requests for recruitment or to evaluate your professional profile (ii) requests based on job offers that we publish via the website and/or Linkedin.

Art. 88 GDPR in conjunction with § 26 (1) in conjunction with (8) sentence 2 BDSG

We store your personal data for as long as is necessary to make a decision about your application.

If an employment relationship is not subsequently established between you and us, we will store your personal data for a further six months, insofar as this is necessary for the defense against possible legal claims.

Your personal data will then be deleted unless you expressly consent to further storage of your data. In this case, we will delete your data after two years, unless you request us to delete it beforehand.


Case B

Processing requests for information submitted via the form available on our website at the e-mail address privacy@txtgroup.com.  

Art. 88 GDPR in conjunction with § 26 (1) in conjunction with (8) sentence 2 BDSG

We store your personal data for as long as is necessary to make a decision about your application.

If an employment relationship is not subsequently established between you and us, we will store your personal data for a further six months, insofar as this is necessary for the defense against possible legal claims.

Your personal data will then be deleted unless you expressly consent to further storage of your data. In this case, we will delete your data after two years, unless you request us to delete it beforehand.


Case C

Processing of applications containing special categories of personal data in order to exercise our rights under employment law or social security and social protection law arising from such an application or to fulfill our obligations in this regard.

Art. 9 (2) lit. b) GDPR

We store your personal data for as long as is necessary to make a decision about your application.

If an employment relationship is not subsequently established between you and us, we will store your personal data for a further six months, insofar as this is necessary for the defense against possible legal claims.

Your personal data will then be deleted unless you expressly consent to further storage of your data. In this case, we will delete your data after two years, unless you request us to delete it beforehand.


Case D

Assertion, exercise or defense of our rights.

Art. 6 (1) lit. f) GDPR Should a legal dispute arise in connection with your application, we have a legitimate interest in the defense and exercise of our rights and the processing of your personal data required for this purpose.

We store your personal data for as long as is necessary to make a decision about your application.

If an employment relationship is not subsequently established between you and us, we will store your personal data for a further six months, insofar as this is necessary for the defense against possible legal claims.

Your personal data will then be deleted unless you expressly consent to further storage of your data. In this case, we will delete your data after two years, unless you request us to delete it beforehand.

 

If we use personal data for any other purpose that is incompatible with the purposes for which such personal data was originally collected or authorized, we will inform you in advance and, where necessary, obtain your consent for the additional processing activities.

 

5.    HOW DO WE PROCESS PERSONAL DATA?
With regard to the above-mentioned purposes, the processing of personal data may consist of the activities referred to in Article 4 (1) No. 2 GDPR, i.e. the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, interconnection, erasure and destruction of personal data.

In addition, your personal data will be 
- processed in accordance with the principles of lawfulness, fairness and transparency;
- for the above-mentioned lawful purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- stored in a way that enables the data subject to be identified for a period of time that does not exceed the achievement of the purposes defined in more detail in section 4 above; 
- processed in such a way that appropriate security against the risk of destruction, loss, alteration, disclosure or unauthorized access is ensured by technical and organizational security measures.

Processing may be carried out by manual, computerized or telematic means with logic strictly related to the purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data itself and compliance with the specific obligations laid down in the applicable data protection legislation in force.

 

6.    TO WHOM DO WE DISCLOSE PERSONAL DATA?
Your personal data will only be forwarded internally to the responsible contact persons who will decide on filling the position you have applied for. If you do not apply for a specific vacancy (unsolicited application), we will use your data for all vacancies at the time of application that meet your requirements or your stated wishes.

Insofar as this is necessary to achieve the purposes described above (or you give your consent for this), we may also pass on your personal data to other recipients in their capacity as independent data controllers or joint controllers within the meaning of Art. 28 GDPR, including but not limited to:
- Company of the TXT Group;
- specially commissioned service providers involved in the recruitment, selection and evaluation of personnel;
- Service providers specifically appointed to manage and/or maintain the Company's websites and the electronic and IT tools used by the Company and/or the other companies in the TXT Group.

Your personal data may also be disclosed to third parties in the following cases:  
(i) when disclosure is required by applicable laws and regulations in relation to legitimate third party recipients of communications, such as public authorities and public bodies that process your data as autonomous data controllers for their respective institutional purposes; 
(ii) in the event of extraordinary corporate activity (e.g. mergers, acquisitions, business transfers, etc.).

A full list of the recipients of your personal data, including further details of the location of these recipients, is held at our head office and will be provided to you on request.

 

7.    DO WE TRANSFER PERSONAL DATA TO COUNTRIES OUTSIDE THE EU?
The personal data is managed and stored on our servers in the European Union.

As part of an international group, we inform you that in order to process your personal data for the purposes mentioned in point 4, some personal data may be transferred to companies of the TXT Group located outside the European Union (among the countries we mention: Switzerland, United Kingdom, United States of America).

In view of the fact that some of the countries mentioned above do not offer an adequate level of protection of personal data compared to the level of protection guaranteed in the European Union, we have taken measures to ensure that the transfer of your personal data to these countries is carried out exclusively in compliance with the conditions laid down in Articles 45 and 49 GDPR, in particular:
- in Switzerland: COMMISSION DECISION of July 26, 2000
- in the United Kingdom: COMMISSION DECISION of June 28, 2021
- in the United States: COMMISSION DECISION of July 10, 2023
- in Canada: COMMISSION DECISION of December 20, 2000.

If we intend to transfer your personal data to countries outside the EU other than those mentioned above, such a transfer will only take place in compliance with the conditions set out in Articles 45 and 49 GDPR.

 

8.    WHAT RIGHTS DO YOU HAVE IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA, HOW CAN YOU EXERCISE THEM AND HOW CAN YOU CONTACT US?
You have the following rights in connection with the processing of your personal data by us:

a. Right to withdrawal of consents granted
You can withdraw any consent given to us at any time with effect for the future.

b. Right to access
In accordance with Art. 15 GDPR, you have the right to request confirmation from us as to whether or not we are processing personal data concerning you. If we process personal data concerning you, you are also entitled to information about the information listed in Art. 15 GDPR and to receive a copy of the data in accordance with Art. 15 (3) and (4) GDPR.

c. Right to rectification and Erasure
You also have the right to rectification of inaccurate personal data and completion of incomplete personal data in accordance with Art. 16 GDPR and erasure of your personal data if the requirements of Art. 17 GDPR are met.

d. Right to restriction of the processing
You can restrict the processing of your personal data under the conditions set out in Art. 18 GDPR.

e. Right to data portability 
Furthermore, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right, insofar as this is technically feasible, for us to transfer this data to another controller on your instructions. The right to data portability only applies to personal data where the processing is based on consent pursuant to Art. 6 (1) lit. a) GDPR or on a contract pursuant to Art. 6 (1) lit. b) GDPR and the processing is carried out by automated means. The right to transfer data to another controller is excluded if this would adversely affect the rights and freedoms of other persons (e.g. personal data of third parties, our business and trade secrets or copyrights).

f. Right of objection
In accordance with Art. 21 GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation, insofar as this is done on the basis of Art. 6 (1) lit. e) or lit. f) GDPR. In the event of such an objection, we will no longer process this data unless we can prove that there are compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. The assertion of all of the above rights is generally free of charge for you.

However, in the case of manifestly unfounded or - especially in the case of frequent repetition - excessive requests regarding the rights under b. to f., we may, in accordance with Art. 12 (5) GDPR, either
aa.    charge a reasonable fee, taking into account the administrative costs of providing the information or notification or implementing the requested measure, or
bb.     refuse to take action on the basis of the application.

To exercise your rights, please use the contact addresses given above.

g. Right of appeal
If you are of the opinion that we are not properly fulfilling our data protection obligations, you can contact the data protection supervisory authorities at any time.
You can contact the state data protection officer responsible for us as follows:
Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
Phone: 030/138 89-0
E-mail: mailbox@datenschutz-berlin.de

 

9.    OBLIGATION TO PROVIDE DATA
There is no legal or contractual obligation to provide us with personal data. However, the provision of data that is absolutely necessary for the provision of the respective service (see above) is necessary if you wish to make use of these services.

 

10.    CHANGES TO THE PRIVACY POLICY
This privacy policy may be amended and supplemented over time. We recommend that you check its content regularly. 


Document updated in March 2024