Data Protection Declaration

This Data Protection Declaration deals exclusively with data processing in connection with job applications. It thus adds to the data protection declaration that can be accessed here.

When an application is submitted via our online portal (including subscription to our talent pool), the personal data of the applicant and the documents contained in the application dossier are processed by us for the purpose of handling the application procedure. Legal basis for processing the data is art. 6 para. 1 lit. a GDPR (consent) and art. 6 para. 1 lit. b GDPR (steps prior to entering into a contract).

For the use of our application portal, we rely on the services of Greenhouse Software, Inc., 18 West 18th Street, 11th Floor, New York, NY 10011, USA. We expressly point out that the personal data is transferred to the USA, whose data protection is currently not assessed as adequate by the European Commission and the Federal Data Protection and Information Commissioner (FDPIC). Although we have taken certain contractual and technical measures (including encryption of data and data transmission), we cannot completely exclude risks in connection with this data transfer (government collection and processing) for the data subjects. Additionally, Adnovum's HR departments located in Switzerland, the EU, Singapore and Vietnam have access to the stored data. The aforementioned data transfer to third countries is based on the express consent of the applicant (art. 6 para. 2 lit. b FADP and art. 49 para. 1 lit. a GDPR, respectively).

If no employment contract is concluded, we automatically delete the data transmitted to us five years after notification of the rejection. However, the data is not deleted if it must be kept longer due to legal provisions or to defend claims. Legal basis in this case is art. 6 para. 1 lit. c or lit. f GDPR and specifically for Portugal article 32 of the Labor Code. With your express (and revocable) consent, we will keep your data stored to contact you as needed (subscription to talent pool) and/or to send you our newsletter. Legal basis in this case is art. 6 para. 1 lit. a GDPR. You are free to revoke your consent or contradict the processing of your data at any time (e.g. by withdrawing your application or unsubscribing from the newsletter).

If an employment contract is concluded after the application process, we store the data provided during the application in the data subject's personnel file in order to perform the usual legally required and contractually agreed tasks. From the date of termination of the contract, the data may be kept for one year, unless there have been judicial proceedings against the company. In this case, it adds six months after the sentence has become final. Legal basis for processing this data is, depending on the specific circumstances, art. 6 para. 1 lit. b and lit. c GDPR (performance of a contract and compliance with a legal obligation) and specifically for Portugal exemption authorization No. 4/99 from CNPD.

We distribute the newsletter via the US provider HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA, with whom we have concluded a contract on the processing of commissioned data. Via HubSpot, we also collect user-specific data on whether and when our newsletter is opened and whether the links contained therein are clicked on (success measurement by means of opening and click rates). The data collected in this way is used to further optimize our content in the future. More detailed information on the scope and handling of the processed data can be found in HubSpot's privacy policy: