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


1. General Information

This data privacy statement, which refers exclusively to data collected as part of the online application process, is to inform you about how your personal data that is collected as part of the online application process is handled at our end.

2. The Controller

The controller under data protection law is:

Blockbrain GmbH 
Marienstraße 37, 70178 Stuttgart 
Commercial register entry number: HRB 785056 
Registration Court: Stuttgart Local Court (Amtsgericht Stuttgart)

Data Protection Officer: 
Wittmann Legal Services

Via Giuseppe Govone 39

20155 Milano, Italy

+49 1520 1983763


If you have any questions regarding the processing of your personal data in connection with the application process, please contact our Data Protection Officer at the address above.

3. Legal Basis for Processing

The processing of your personal data in connection with the application process is based on the following legal grounds:

  • Article 6(1)(b) GDPR in conjunction with Section 26 of the German Federal Data Protection Act (BDSG): Processing is necessary for the performance of pre-contractual measures, namely the execution of the application process.

  • Article 6(1)(f) GDPR: We have a legitimate interest in retaining application data after the conclusion of the application process for the purpose of defending against potential legal claims, in particular under the German General Act on Equal Treatment (AGG).


4. Personal Data Collected as Part of the Application Process

Personal data means any information concerning the personal or material circumstances of an identified or identifiable individual. This includes information such as, for example, your name, address, telephone number and date of birth, but also data relating to your specific career etc. by reference to which a specific individual can be identified with reasonable effort. However, information which cannot be (in)directly associated with your real-life identity is not personal data.

5. Fundamentals and Purposes of Processing

If you apply to us electronically, i.e. via e-mail or using our online form, we will collect and process your personal data for the purpose of executing the application process and preparing contracts.

By submitting an application via our recruitment website, you express your interest in taking up work with us. In this context, you transmit personal data, which we will use and store exclusively for the purpose of your job search / application process.

In particular, the following data is collected during this process:

  • Name (first and last names)

  • E-mail address

  • Phone number

  • LinkedIn profile (optional)

  • Channel through which you found us

  • CV

Furthermore, you can choose to upload expressive documents such as a cover letter, your CV and reference letters. These may contain additional personal data such as date of birth, address etc.

Only authorized HR staff and/or staff involved in the application process have access to your data.

The personal data is stored, as a rule, exclusively for the purpose of filling the vacancy for which you have applied.

Your data will be stored for a period of 90 days after the application process has been concluded. This is done to fulfill legal requirements, in particular to defend ourselves against potential claims under the German General Act on Equal Treatment (AGG). After this period, your data will be anonymized automatically. In case of anonymization, the data will only be available to us in the form of so-called metadata, without any direct personal reference, for statistical analysis (for example, share of applicants by gender, number of applications per specified period of time etc.).

Should you be offered and accept a position with us during the application process, we will store the personal data collected as part of the application process for at least the duration of your employment.

6. Automated Pre-Screening of Applications

As part of our application process, we use automated pre-screening to check whether certain mandatory requirements for the advertised position are met. This may include, depending on the role:

  • A valid work permit for Germany

  • Willingness to work on-site at one of our locations at least three days per week

  • Required language skills (e.g. German at B2 level or above)

These criteria are based solely on objective, job-related requirements as stated in the respective job posting. Applications that do not meet these mandatory requirements may be declined automatically at this stage.

No automated decision is made regarding your professional qualifications, personality, or cultural fit. These assessments are always carried out by authorized HR staff. If you believe an automated decision was made incorrectly, you have the right to request a manual review by contacting our Data Protection Officer (see section 2).

The legal basis for this processing is Article 6(1)(b) GDPR in conjunction with Section 26 BDSG.

7. Disclosure of Data to Third Parties

Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. This database is operated by Personio GmbH, which offers a human resource and applicant management software solution (https://www.personio.com/legal-notice/). In this context, Personio is our processor under Article 28 of the GDPR. The processing is based on a data processing agreement between us as the controller and Personio.

Additionally, the following processors may be involved in the application process:

  • Microsoft Corporation (Microsoft 365, including Microsoft Teams for video interviews, Microsoft Outlook for e-mail communication, and Microsoft Bookings for interview scheduling). Microsoft acts as a processor under Article 28 GDPR. Data processing is governed by the Microsoft Products and Services Data Protection Addendum. Microsoft may process data in the EU/EEA; where data is transferred to the United States, this is covered by the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses pursuant to Article 46(2)(c) GDPR.

We do not share your application data with any other third parties unless we are legally required to do so.

8. Transfer of Data to Third Countries

Where personal data is transferred to countries outside the EU/EEA (e.g. in connection with the use of Microsoft services), appropriate safeguards are in place in accordance with Article 46 GDPR, including the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses. You may request a copy of these safeguards by contacting our Data Protection Officer (see section 2).

9. Rights of Data Subjects

If we as the controller process 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 GDPR)

  • The right to rectification (Article 16 GDPR)

  • The right to erasure (Article 17 GDPR)

  • The right to restriction of processing (Article 18 GDPR)

  • The right to data portability (Article 20 GDPR)

  • The right to object (Article 21 GDPR)


If the personal data is processed with your consent, you have the right to withdraw this consent at any time under Article 7(3) GDPR. The withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.

In connection with automated pre-screening (see section 6), you have the right under Article 22 GDPR to request human intervention, to express your point of view, and to contest the decision.

To assert your rights as a data subject in relation to the data processed during this online application process, please contact our Data Protection Officer (see section 2).

Right to lodge a complaint with a supervisory authority: 
You have the right to lodge a complaint with a data protection supervisory authority under Article 77 GDPR. The competent supervisory authority is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg 
Lautenschlagerstraße 20, 70173 Stuttgart 
Website: https://www.baden-wuerttemberg.datenschutz.de

10. Concluding Provisions

We reserve 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 application process or other processes. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.

In addition to this data privacy statement, please view our general data privacy statement at https://blockbrain.ai/en/privacy-policy

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.