Data Processing

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Data protection is paramount to all Appanion activities. A transparent process is very important to us when it comes to the way we process personal data. Here, you will find a description of how we process personal data. A description of our data processing is available at https://shipzero.com/privacy. For better legibility, we try not to use specific genders. Therefore, please note that the words they/them are intended to mean all genders.

General information – applicable for all of the following descriptions of data processing

Responsibility

The following party is responsible for all data processing described here:

Appanion Labs GmbH
St. Annenufer 2
c/o Digital Hub Logistics
20457 Hamburg
info@appanion.com

The data protection officer can be reached at the following address:

DataCo GmbH
Dachauer Str. 63
80335 Munich
datenschutz@dataguard.de 

Legal basis

Processing of applicants’ data:

  • 88 GDPR in conjunction with § 26 BDSG-neu (Federal Data Protection Act)
  • 6(1)(a) GDPR
  • 6(1)(b) GDPR

Processing of data of interested parties:

  • 6(1)(a) GDPR
  • 6(1)(b) GDPR
  • 6(1)(f) GDPR

Processing of client data:

  • 6(1)(b) GDPR
  • 6(1)(f) GDPR

Processing of supplier/service provider data

  • 6(1)(b) GDPR
  • 6(1)(f) GDPR

Rights of the data subject

  • If your personal data are processed, you have the right to receive information from the controller about your personal data which is stored (Art. 15 GDPR).
  • If inaccurate personal data are processed, you have the right to rectification (Art. 16 GDPR).
  • If the legal requirements allow, you can request the erasure or restriction of processing, and object to the processing (Art. 17, 18, and 21 GDPR).
  • If you have consented to the data processing or if there is a data processing contract in place, and the data processing is performed with the aid of automated processes, you may have a right to data portability (Art. 20 GDPR).
  • If you have consented, by means of a corresponding declaration, to the processing by the controller, you can withdraw this consent at any time with future effect. The lawfulness of the data processing carried out on the basis of the consent until the withdrawal will not be affected.
  • The data subject also has the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

Processing of applicants’ data

As part of the Appanion application process, Appanion collects the following personal data via the upload function provided on the careers page:

  • First name and surname
  • Salutation
  • Email address
  • Phone number
  • Availability
  • Expected salary
  • All personal data contained in the application (curriculum vitae, cover letter, certificates, etc.)

Appanion collects data from interested parties in the following manners:

  • Direct application via the Appanion careers page
  • Application via email, addressed directly to a Appanion employee
  • Postal application
  • LinkedIn Easy Apply

These personal data will be processed for the following purposes:

  • Implementation of the application process and decision on the justification of an employment contract 
  • Communication (telephone, email, videotelephony) 
  • Implementation of pre-contractual measures (initiation of employment) 
  • Recording of applicants’ data in an applicant pool 
  • Assertion, exercise, or defence of legal claims resulting from the application process 

Internally, only authorised employees will only receive access to an applicant’s data, via an authorisation process.

The following service providers are involved, as data processors, in our processing of personal data during the application process:

Personio GmbH – Munich, Germany: Appanion uses the Personio HR system as a central applicant life cycle management tool for the implementation of the application process. It serves as a central storage point for applicants’ data. Personio is integrated into our careers page. The above-mentioned personal data and other data uploaded by you will be stored and processed by Personio on our authority. Data will only be processed in German datacentres. A Data Processing Agreement has been concluded with the service provider. In the event that the application is cancelled by you or Appanion, your personal data will be erased within 10 weeks. On the basis of consent, an applicant can be included in a pool of applicants, and the applicant data which are transmitted will continue to be stored for this purpose. Consent will be obtained again each year via email. Should the applicant be hired, the personal data will continue to be processed in Personio as part of the employment relationship.

Microsoft Inc. – Redmond, USA: Appanion uses the Office 365 service, incl. Microsoft Teams, to carry out interviews via video telephony, and Outlook for communication via email. A Data Processing Agreement with Standard Contractual Clauses (in accordance with European Union specifications) has been concluded with the service provider as part of the Online Services Terms. Your personal data, which will be forwarded to the processor for the performance of the planning and the actual video call, will be erased within 3 weeks.

LinkedIn Inc. – Sunnyvale, USA: Appanion uses the Easy Apply service. Applications can be sent directly to Appanion via this service. A Data Processing Agreement with Standard Contractual Clauses (in accordance with European Union specifications) has been concluded with the service provider. The applications received via LinkedIn Easy Apply will be further processed in Personio upon receipt. We have no influence on how long LinkedIn itself stores the data you provide.

Processing of data of interested parties

Appanion collects and processes data of interested parties via various channels. Data of interested parties are all personal data of people interested in a Appanion service. The following data are processed in order to establish contact:

  • First name and surname
  • Salutation
  • Email address
  • Position within the company
  • Phone number

Appanion collects data from interested parties in the following manners:

  • Requests via the contact form on the Appanion website
  • Requests sent via messages to Appanion employees, e.g. via email, LinkedIn messages, XING messages, and other communication channels
  • Requests at trade fairs or other events where data are passed on to Appanion employees with the aim of establishing contact
  • Individual research about potential interested parties in business directories, contact information on websites, and professional networks
  • Individual booking of an appointment by an interested party

We will process your personal data for the following purposes:

  • To provide information about the services of the Appanion brand 
  • Quote generation 
  • Processing of queries from interested parties 
  • Preparation and implementation of pre-contractual measures, in particular the forwarding and agreement of contract terms with the aim of entering into a contract 
  • Establishment and implementation of a contractual relationship 
  • Inclusion in our contact database 
  • Establishing contact (email and telephone)

Data collection takes place in the first step on the basis of the legitimate interest. A balancing of interests hereby always takes place. In doing so, we balance the rights and freedoms of the data subject against the interests of Appanion. Consent will be obtained verbally in further communication, and stored in our CRM tool.

The following service providers are involved, as data processors, in our processing of personal data as part of the process for dealing with interested parties:

HubSpot Inc. – Cambridge, USA, with subsidiary in Ireland: Appanion uses HubSpot as a central marketing tool in which all data of interested parties from all channels are collected, where they are then qualified. A Data Processing Agreement with Standard Contractual Clauses (in accordance with European Union specifications) has been concluded. Personal data of interested parties who have objected to processing by Appanion or withdrawn their consent will be erased immediately, unless the data subject wishes to be included in a blacklist, in order not to be contacted again. In this case, we will store the subject’s surname, first name, and email address for this purpose. Should there be no interaction between the interested party and Appanion within 12 months, the personal data will be erased.

Processing of client data and data of their service providers

At Appanion, personal data are processed primarily in the data protection management platform provided to the clients. This platform was developed in-house by Appanion. The following personal data of employees who are employed by Appanion clients will be processed:

  • First name and surname
  • Title and academic degree
  • Gender
  • Email address
  • Position within the company
  • Phone number
  • Role assigned within the platform and the according authorisations
  • All personal data that are provided to us during communication with clients

Appanion collects data from people in the following manners:

  • Querying of the personal data after concluding a contract with Appanion from the persons themselves, or receipt of personal data via an employee of the client company. This could also concern employees of service providers used by a client’s company.
  • Entry of employees’ personal data by an administrative assistant of the client in the data protection platform

We will process your data for the following purposes:

  • Client management and client support – in particular the processing of client queries 
  • Direct marketing in the form of telephone calls and emails  
  • Issuing of invoices 
  • Performance of post-contractual measures 
  • Assertion, exercise, or defence of legal claims 
  • Establishment, implementation, and termination of a contractual relationship

Data processing takes place on the basis of the contractual relationship and on the basis of the legitimate interest. A balancing of interests hereby always takes place. In doing so, we balance the rights and freedoms of the data subject against the interests of Appanion, in the form of contract performance for our clients.

Data protection management platform: Appanion operates an emission data  management platform. Employees of clients are invited to access this platform by the relevant Appanion employees. It could also be the case that we process data of persons who assert their data subject rights against the clients of Appanion. For the platform, the privacy policy provided therein applies, in the respective valid version.

The following service providers are involved, as data processors, in our processing of client data:

Microsoft Inc. – Redmond, USA: Appanion uses the Office 365 service, incl. Microsoft Teams, to carry out audit phone calls via video telephony, and Outlook for communication of appointments via email. A Data Processing Agreement with Standard Contractual Clauses (in accordance with European Union specifications) has been concluded with the service provider as part of the Online Services Terms. Your personal data, which will be forwarded to the processor for the performance of the planning and the actual video call, will be erased as soon as the purpose of the storage no longer applies.

When processing data of clients and their service providers, we will generally always erase or block your personal data when the purpose of the storage no longer applies. Storage may also take place if required by legal standards to which we are subject, for example in relation to statutory retention and documentation obligations. In such cases, we will erase or block your personal data after the according standards cease to apply. 

Processing of supplier/service provider data

Appanion processes personal data of suppliers and service providers. This is necessary for our business operations. The following data are processed by suppliers:

  • First name and surname
  • Title
  • Gender
  • Email address
  • Phone number

Appanion collects data from people in the following manners:

  • Receipt of personal data directly from the data subject via establishment of contact by suppliers
  • Receipt of personal data directly from the data subject via establishment of contact by Appanion
  • Research in business directories or on websites
  • Receipt of personal data from third parties

We will process your data for the following purposes:

  • Performance of orders
  • Review and optimisation of processes for needs assessment 
  • Consultation and data exchange with credit agencies to determine credit and default risks 
  • Market and opinion research, provided that you have not objected to the use of these data for this purpose 
  • Assertion, exercise or defence of legal claims 
  • Measures for business management and further development of our products  

Data processing takes place to initiate or perform a contractual relationship, and on the basis of the legitimate interests of Appanion.

The following service providers are involved, as data processors, in our processing of supplier/service provider data:

Microsoft Inc. – Redmond, USA: For the forwarding of emails and storage of contact details of suppliers and service providers, Appanion uses services such as Outlook to store these contact details. These data are used exclusively for communication with service provider/suppliers. A Data Processing Agreement with Standard Contractual Clauses (in accordance with European Union specifications) has been concluded with the service provider as part of the Online Services Terms.