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

Data Privacy Statement

Recruitment & Online Application Process - COMO Digital Life

Controller: COMO DL S.A. (Payment Institution), trading as COMO Digital Life
Address: 1 Rue De l’Innovation, L-1896 Kockelscheuer, Luxembourg
RCS Luxembourg: B 208 603 | VAT ID: LU28975358 | CSSF Licence: Z00000013
Data Protection Officer: dpo@como-dl.com
Compliance Team: compliance@como-dl.com

1. General Information

This data privacy statement refers exclusively to personal data collected as part of the online application process via the COMO Digital Life recruitment website, powered by Personio. It informs you about how COMO DL S.A. collects, uses, and stores your personal data in this context, in accordance with the EU General Data Protection Regulation (GDPR).

2. The Controller

The controller under data protection law is:
COMO DL S.A. (Payment Institution), trading as COMO Digital Life
1 Rue De l’Innovation
L-1896 Kockelscheuer
Luxembourg
RCS Luxembourg: B 208 603
VAT ID: LU28975358
CSSF Licence: Z00000013
Data Protection Officer: dpo@como-dl.com
Compliance Team: compliance@como-dl.com

3. Personal Data Collected During the Application Process

Personal data means any information relating to an identified or identifiable natural person. This includes information such as your name, address, telephone number, date of birth, and professional background — any data by which a specific individual can be identified with reasonable effort. Information that cannot be directly or indirectly linked to your real-life identity does not constitute personal data.

4. Legal Basis and Purposes of Processing

If you apply to us via our recruitment website, we collect and process your personal data on the basis of Article 6(1)(b) GDPR (processing necessary for pre-contractual measures) for the purpose of conducting the application process and, where applicable, preparing an employment contract.
By submitting an application, you express your interest in joining COMO Digital Life. The personal data you provide will be used and stored exclusively for the purpose of your job application. Only authorised HR staff and individuals directly involved in the recruitment process have access to your data.
In particular, the following data is collected during the application process:

Name (first and last)
Email address
Phone number
LinkedIn profile (optional)
Channel through which you found us

You may also choose to upload supporting documents such as a cover letter, CV, and reference letters, which may contain additional personal data such as date of birth, address, and academic and professional history.

5. Data Retention

Your personal data will be stored for a period of 90 days after the conclusion of the application process. This period serves to fulfil legal obligations and to defend against any claims arising from applicable law. After this period, we are obligated to delete or anonymize your data. In case of anonymization, data will only be available to us as statistical metadata (e.g., number of applications per period, breakdown by source) without any personal reference.
In addition, we reserve the right to retain your data for a further period of 90 days after the conclusion of the application process for the purpose of including it in our Talent Pool, in order to identify other vacancies that may be of interest to you. By accepting this data privacy statement, you consent to such further storage and inclusion in our Talent Pool.
Should you be offered and accept a position with COMO Digital Life, the personal data collected during the application process will be retained for at least the duration of your employment and in accordance with applicable Luxembourg labour law thereafter.

6. Disclosure of Data to Third Parties

Data submitted as part of your application is transferred using TLS encryption and stored in a database operated by Personio GmbH, which provides our human resources and applicant management software (https://www.personio.com/legal-notice/). Personio acts as our processor under Article 28 GDPR. Processing is governed by a data processing agreement between COMO DL S.A. as controller and Personio as processor.
No other transfer of your personal data to third parties takes place, unless required by law or with your explicit consent. Data is stored on secure servers located in the European Union, in compliance with GDPR requirements.

7. Rights of Data Subjects

As a data subject, you have the following rights under Chapter III of the EU General Data Protection Regulation (GDPR):

Right of access (Article 15 GDPR)
Right to rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to data portability (Article 20 GDPR)
Right to object (Article 21 GDPR)

Where processing is based on your consent, you have the right to withdraw that consent at any time under Article 7(3) GDPR, without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise your rights, please contact our Data Protection Officer at dpo@como-dl.com. We will respond to your request within 30 days.
You also have the right to lodge a complaint with the competent supervisory authority. In Luxembourg:
Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz, L-4370 Belvaux
https://www.cnpd.lu

8. Security

We have implemented appropriate technical and organizational security measures to protect the security of your personal information. Data is transmitted using TLS encryption. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. While we do our best to protect your personal information, transmission to and from our recruitment website is at your own risk.

9. Concluding Provisions

We reserve the right to update this data privacy statement at any time to reflect changes in legal requirements or in our application process. The version published at the time of your application applies.

For our general data privacy statement, please visit: https://www.como-dl.com/legal-hub/privacy-policy
Questions about this statement? Contact our Compliance Team: compliance@como-dl.com
Or by post: COMO DL S.A., 1 Rue De l’Innovation, L-1896 Kockelscheuer, Luxembourg

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.