Candidate privacy notice

Last modified 12 March 2021

This privacy notice describes how Avaloq Group AG and its affiliates may process your personal data when you decide to apply for a job at Avaloq.

We may modify this privacy notice from time to time and will place any updates on this website.

1. RESPONSIBLE PARTY FOR THIS SERVICE

In this privacy notice we explain how we collect your personal data, what we do with it, for what purposes and on what legal basis this is done, and your associated rights and entitlements. The term ‘we’, ‘us’ or ‘our’ means the Avaloq entity with whom you are interacting, for example the entity managing the Service you are using.

2. SUBPROCESSORS

You will find a list of our subprocessors in Annex 1.

3. SERVICE DESCRIPTION

The easiest way to apply for a job is a direct application for a position advertised on our career portal, where you may enter your data in the candidate profile created individually for the advertised position. You hereby have the possibility to send us the data by connecting to a social network, by a manual input and/or by using “CV Parsing” (Transferring some data from your CV to our career portal). If you decide to apply for a job vacancy posted by us, these privacy notice provisions will apply to our processing of your personal data. The application data is treated confidentially and strictly in accordance with the statutory provisions.

You must create an account by entering a personal username and password to submit your job application. The information marked with an asterisk is required for us to consider your application for a job vacancy you have applied for. You can decide whether to enter other personal data using the optional fields to better match your application data with the respective job vacancy or provide us with a link to your online profile in case of any further relevancy to the application.

4. SELF-SERVICE

You can edit or erase your profile at any time on your own. You can access your own profile here.

5. DEFINITION OF PERSONAL DATA

Personal data is any information relating to an identified or identifiable individual (e. g. a name, an address, a telephone number, date of birth or an email address).

6. PERSONAL DATA RELATING TO YOUR JOB APPLICATION

We may obtain and process personal data when you submit your job application, including:

  • your name and contact details (e.g. salutation, first name and last name, email address, phone number, city and ZIP code, country of residence, nationality);
  • your account details (such as username and password);
  • your CV data (e.g. qualifications, experience, information relating to your employment history, skills and experience);
  • your correspondence details if you contact us;
  • organizational data in case of internal applications (e.g. email address);
  • video recording in the selection process using WePow;
  • traffic data (such as your internet usage); and
  • information on your use of the Service.

Additional personal data may be collected should you wish to provide further information to better match your application data with the job vacancies listed on the Service.

7. PERSONAL DATA RELATING TO OUR HIRING DECISION

We may obtain and process hiring-related personal data to determine your qualifications for employment and to make a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying out reference and background checks (where applicable and legally permissible) and generally managing the hiring process and communicating with you about it.

8. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

The personal data processing takes place at your request during the Service particularly for the purpose of preparation for an employment relationship with us.

We also rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interest is the recruitment of staff for our business purposes.

Staffing of particularly sensitive job positions may require further background checking. Our background checking is executed in compliance with applicable laws and regulations. The copies of your criminal records and debt register extracts will be thereafter screened accordingly and stored in the country of the position you applied to.

If you become a member of one of our talent pools upon invitation, you have the option to publish your data entered by you including all the applications in the respective country for all the team members of the recruiting team, also across the region. By becoming a member of the talent pool, you consent to be informed about interesting open positions and events.

9. RECIPIENTS AND PURPOSES OF PROCESSING

Only the people involved in the application process (e.g. line managers and associates of the recruiting department, HR associates and associate representatives) have access to your personal data for the purposes mentioned above within our legal entity to which you have applied.

We will only collect your personal data for our recruiting and hiring purposes.

We use information held about you in the following ways:

  • to consider your application in respect of a role for which you have applied;
  • to consider your application in respect of other roles;
  • to communicate with you in respect of the recruitment process;
  • to assess your skills, qualifications and background for a particular role; and
  • to help us improve our Service.

In case of your appointment, your data is transferred from our application management system to our HR-administration systems. In this process, your data may be transferred to a different legal entity and will thereafter be processed as employee data. An exchange of your personal data with our other legal entities takes place especially in order to fulfil the contracts as well as due to our legitimate interest to organize the internal workflows.

10. ERASURE AND STORAGE OF DATA

The use of the Service or the recruitment process can be discontinued by us or you at any time.

Your personal data will be completely and permanently erased within three (3) months after the job vacancy you have applied for has been filled unless you have consented to a longer retention period. Hired candidates’ personal data will be completely and permanently erased within 12 months after the job vacancy applied has been filled. Alternatively, you can visit the Login website and delete your profile (in the submenu ‘options’) or submit an erasure request to jobs@avaloq.com. Your data will be erased pursuant to our erasure practices. Any personal data in the Service will be erased without undue delay. Any erasure undertaken will anonymize your data and render it unidentifiable.

Personal data that must be retained by us for legal reasons will be blocked in accordance with the applicable data protection regulations.

11. COOKIES

Information on the cookies used and their functions are directly provided as part of the application tracking system.

12. INFORMATION SECURITY

We use a variety of technical and organizational security measures, including encryption, to maintain the security of your personal data.

Your personal data is transmitted over a secure connection with state-of-the-art encryption methods and contained behind secured networks, and is only accessible by a limited number of people who have special access rights to these systems.

We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

13. INTERNATIONAL DATA TRANSFERS

The personal data we collect or process in the context of this Service will be stored in Germany.

Some of the recipients with whom we share your personal data may be located in countries other than the country in which your personal data was originally collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, we will protect that personal data as described in this privacy notice and in compliance with applicable law.

We do not sell, rent or trade your personal data.

14. YOUR RIGHTS

To the extent required by applicable law and subject to legal limitations, you have the right to:
(i) have access to your personal data
(ii) have inaccurate data corrected or removed;
(iii) the erasure of your personal data;
(iv) restrict the processing of your personal data;
(v) lodge a complaint with a competent data protection authority;
(vi) object to the processing of your personal data on compelling legitimate grounds relating to your situation.

If you would like to exercise your rights, please:

  • login at https://my.smartrecruiters.com; or
  • contact us using our contact details below and:
    • let us have enough information to identify you;
    • let us have proof of your identity and address; and
    • let us know the information to which your request relates.

15. FEEDBACK

If you wish to provide feedback or if you have questions or concerns, or wish to exercise your rights related to your personal data, please contact our Data Protection Officer at: dataprotection@avaloq.com.

Annex 1: Subprocessors

Service Provider Processing
SmartRecruiters GmbH Dircksenstraße 47 10178 Berlin
SmartRecruiters SP. Z o.o.
Fabryczna 20, 31-553 Krakow, Poland
SmartRecruiters Inc.
225 Bush Street, San Francisco, CA 94104, USA
Provision and development of the cloud platform for the above purposes. Processing of the provided personal data.
Talentry GmbH Nymphenburger Str. 86, 80636 München, Germany Provision and development of the cloud platform for the above purposes. Processing of the provided personal data.
WePow, Inc. One Galleria Tower
13355 Noel Road
Suite 1500
Dallas, TX 75240
Video Interviewing Software
DocuSign, Inc. San Francisco
221 Main St.,
Suite 1550
San Francisco, CA 94105
Electronic signature solutions.
SmartRecruiters, Inc.
225 Bush Street
Suite #300
San Francisco CA 94104, US
Sole shareholder of SmartRecruiters GmbH. The agreements with the other listed subprocessors are in place with SmartRecruiters, Inc.
SmartRecruiters Inc.
(SPOLKA AKCYJNA)
Oddzial w Polsce
(SmartRecruiters,
Inc. Branch)
ul. Fabryczna 20a,
31-553 Krakow, Poland
Operation, maintenance, support and testing of the e- Recruiting system.
Amazon Web Services Inc. 10 Terry Avenue
North Seattle, WA 98109-5210
USA
Hosting of the data.
Hosting location is the cluster AWS Germany (Frankfurt, Germany, EU); the exact address is not disclosed by AWS.
SendGrid Inc. 1801 California Street, Suite 500 Denver Colorado 80202 USA This subcontractor is used to power the sending and receiving of emails from the platform to the candidate/applicant and users of Customer. The contents of that email can be partly templated by Customer to include tags to personalize (e.g. First Name, title, job applied for etc.).
Textkernel BV Nieuwendammerkade 28 A 17
Amsterdam
Noord-Holland 1022 AB
The Netherlands
This subcontractor will take a candidate’s uploaded CV/documents and parse the data into the database (so it scans the document for first name and adds that data to the database field etc).
Google Analytics 1600 Amphitheatre Parkway,
Mountain View, California,
United States
Google Analytics by Google LLC (US) is used to gather behavioral analytics on how users use the SmartRecruiters platform to help improve and guide product development. Google Analytics is also used to support customers to understand how candidates engage with their SmartRecruiters hosted job ads and career websites. SmartRecruiters will not use the data to identify individual users and will not merge the data with other data to identify individual users, nor will such data ever be shared with customers requesting summary understanding of their job ad performance.