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

Recruiting Privacy Policy – Smoobu GmbH

Last updated: August 1, 2025


Data Privacy at Smoobu

Data privacy is a matter of trust and your trust matters to Smoobu GmbH. It is therefore important to us that your personal data is protected and that its collection, processing and use comply with the law.

General information

This Privacy Policy, which refers exclusively to personal data collected as part of the online and offline application process, is to inform you about how your personal data is handled at our end during the recruitment procedure.

The Controller

The Controller under applicable data protection law is:
Smoobu GmbH, Pappelallee 78/79, 10437 Berlin
Contact: recruiting@smoobu.com
Data Protection Officer: Waterside DS GmbH, Alter Wandrahm 9 (Block W), 20457 Hamburg, privacy@smoobu.com

In addition, you may also contact the supervisory authority responsible for Smoobu, the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59-61, 10555 Berlin, Germany, Phone: +49 (0) 30 13889-0, Fax: +49 (0) 30 2155050, email: mailbox@datenschutz-berlin.de.

Personal Data Collected During the Application Process

Personal data means according to applicable data protection law (GDPR) 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, experiences, salary expectation, etc. by reference to which an individual can be identified. However, information which cannot be (in)directly associated with your real-life identity is not personal data.

Legal basis and purposes of processing personal data collected from application documents and during the application process

If you apply to us electronically, i.e. via email or using our online form, or if we are in contact with you and you have given your consent by submitting your application, getting in contact with us or sending an application letter, we will collect and process your personal data for the purpose of executing the application process, including but not limited to share internally to conduct interviews, case studies (tests) as well as evaluating and assessing the results and preparing contracts for the hiring process, § 26 Abs.1 BDSG. By submitting an application via our recruitment website or by confirming your interest with consent, 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.

As part of the application process, we may also use transcription tools powered by artificial intelligence (AI), such as Google Gemini, to generate text-based transcripts of virtual interviews. The purpose of this processing is to support the documentation and evaluation of interviews in a structured and consistent manner and for quality assurance and improvement of the selection process. The recordings and transcripts are not used for any automated decision-making, will not be passed on to unauthorised third parties and are accessible only to Smoobu employees directly involved in the recruitment process. It will be deleted after completion of the procedure, unless longer storage is required by law.

The use of such transcription tools is based on your explicit consent in accordance with Art. 6 (1) (a) GDPR. You will be asked to provide this consent in advance, typically via the interview invitation email. Participation in a transcribed interview is voluntary and does not affect the progress of your application. If you do not provide consent, no transcription will be done from the recorded interviews. You may withdraw your consent at any time with effect for the future by notifying us via privacy@smoobu.com. In such cases, any existing transcripts will be deleted unless further retention is legally justified.

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

  • name (first and last names)

  • email address

  • age and gender (optional)

  • earliest starting date

  • education level and respective certificates

  • business experiences

  • salary expectations (optional)

  • phone number

  • LinkedIn profile (optional) or other professional profiles

  • any reference by 3rd parties, e.g. former employer, other key stakeholder (if applicable)

  • a channel through which you found us

  • application-related job interview notes, case study results and evaluation

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 and who have a need-to-know can access your data. The personal data is stored, as a rule, for the purpose of filling the vacancy for which you have applied and additionally for similar open positions fitting your skills and experiences that might be interesting for you. Your data will be stored for a period of 6 months after the application process has been concluded. This is usually done to fulfil legal requirements and/or defend ourselves against any claims arising from legal provisions. After this period, we delete or anonymise your data unless you agree to extend the length of time we retain your data by another 180 days. 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 male and/or female applicants, 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.

Disclosure of data to third parties

With all EU providers that we use for data processing, there is a corresponding Data Processing Agreement in place according to Art. 28 sec. 3 GDPR ("DPA") with a legally defined guarantee of the required measures for the protection of personal data.

Corresponding agreements have been concluded with all providers based outside the EU, so-called third countries, which comply with the EU standard (“Standard Contractual Clauses - SCC”) and - if necessary - fulfil all further guarantees for secure processing. In particular, for the processing of personal data by providers located in the USA, providers are carefully selected and proven that they are subject to the EU-US Data Protection Framework (DPF).

Further information on how the processing of personal data is handled by the vendor, it can be found in the respective vendor´s privacy policy.

Data transmitted as part of your application will be shared with:

Rights of data subjects

If we as the Controller process personal data, you as the Data Subject as defined in the GDPR have certain rights under Chapter III (GDPR), depending on the legal basis and the purpose of the processing, in particular the rights of access (Article 15 GDPR) and to rectification (Article 16 GDPR), erasure (Article 17 GDPR), restriction of processing (Article 18 GDPR), and data portability (Article 20 GDPR), as well as the right to object (Article 21 GDPR).

If the personal data is processed with your consent, you have the right to withdraw this consent under Article 7 (3) GDPR.

To assert your rights as a data subject in relation to the data processed during this online application process, please refer to our email privacy@smoobu.com

Group

Smoobu is a company of the HomeToGo Group. We may share your personal data with our associated companies within the HomeToGo Group on an occasional basis. The HomeToGo Group includes all (current and future) entities that are directly or indirectly controlled by HomeToGo GmbH (“HomeToGo”) or are under common control of HomeToGo. The transfer of data within the HomeToGo Group takes place for the following purposes:
a) Provision of our intercompany services, especially Human resources & recruiting services
b) Provision of further support services
c) Compliance with laws and regulations

The legal basis for the transfer of data within the HomeToGo Group is Article 6 (1) (f) GDPR. Sharing this data enables us to fulfill our obligations for group affiliates.

Privacy Policy changes

The further development of the Internet and our services may also affect our Recruiting Privacy Policy. We reserve the right to change this recruiting-specific Recruiting Privacy Policy from time to time in the future in order to comply with current legal requirements or to reflect additions or changes to our recruitment services. The current version of this Recruiting Privacy Policy linked herein applies to your recruitment process.

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.