Data Controller:
The Controller of your personal data is Smart Paws GmbH with its registered office in Bad Schwartau (23611), Gutenbergstraße 3, Germany ("we”). In Switzerland, we operate through our branch: Smart Paws GmbH, Zweigniederlassung Basel, Innere Margarethenstrasse 5, 4051 Basel, Switzerland, serves as our representative in Switzerland within the meaning of Article 14 of the Federal Act on Data Protection of 25 September 2020 ("FADP"). You can contact us by writing to one of the addresses above or by e-mail at dataprotection@trupanion.eu.
(hereinafter referred to as ‘we’ or the ‘Company’).
Purpose of processing of your personal data and legal basis for processing:
Your personal data, necessary for you to participate in the recruitment process, will be processed by us on the basis of Article 6(1)(b) of the General Data Protection Regulation of 27 April 2016 ("GDPR") in conjunction with 26th section of Federal Data Protection Act (BDSG) and, in the case of Switzerland, in accordance with applicable employment laws, for the purpose of carrying out the recruitment process in which you are taking part, in particular:
to process your application;
to assess your qualifications and personal experience;
where applicable, for the initiation of an employment.
In the course of the recruitment process, we will process the data you actively provide to us including your name, contact information, CV, additional documents, work experience, qualifications and skills, as well as additional information that you provide us with further in the application process along with related information collected by us from you in the course of your interviews and assessments.
Where applicable, we may also inquire about:
- Your right to work in Germany/Switzerland,
- Whether you are over 18,
- Your preference for remote or in-office work,
- Salary expectations,
- Language skills.
In connection with your application, we may review publicly available professional information about you, such as data published on business and professional social networks or websites such as LinkedIn and Xing. For the avoidance of doubt, we do not collect, or process information contained in social networking or websites that are not in a business or employment related context.
Pursuant to Article 6(1)(a) GDPR, on the basis of your consent, we will process your personal data other than that which is necessary for us to take pre-contractual measures and which you have voluntarily provided to us on your own initiative in your application documents, e.g. regarding your passions and interests.
If the application documents you submit to us contain data referred to in Article 9(1) of the GDPR, your express consent to their processing will be required (pursuant to Article 9(2)(a) of the GDPR. Your consent may be revoked at any time.
You can also voluntarily fill in a form with the Diversity Screening Questions. Individuals seeking employment at Smart Paws are considered without regard to race, ethnicity, color, age, sex, religion, national origin, ancestry, pregnancy, sexual orientation, gender, gender identity, gender expression, genetic information, physical or mental disability, registered domestic partner status, caregiver status, marital status, veteran or military status, citizenship status, or any legally protected category. We may present you with a set of voluntary demographic questions. If you choose to complete them, your responses will be used in aggregate to help us identify areas for improvement in our programs. Your responses, or your choice not to respond, will not be considered in the hiring process.
Where applicable, we may also process for employment-related purposes special categories of personal data as referred to in Article 9(1) GDPR, if it is necessary to exercise rights or comply with legal obligations derived from labour law, social security and social protection law, and there is no reason to believe that the data subject has an overriding legitimate interest in not processing the data.
Where applicable, we will process the data on the basis of our legitimate interest, pursuant to Article 6(1)(f) GDPR - as reasonably necessary to establish or preserve a legal claim or defence.
Information about the recipients of your personal data:
Where appropriate, access to your personal information may be granted:
to persons authorised by us, our employees and associates who need to access the data to perform their duties,
to the processors to whom we outsource a certain task, including: the entities operating and supporting our IT systems and our servers; if you have applied to us via recruitment portals on which we have posted job vacancies - to the entity responsible for providing the services associated with the portal in question; to the recruitment agency - if you have applied to us via the entity providing the services in question, as well as to the Trupanion Group companies that support our processes internally;
to other entities when required to do so by law.
Data retention period:
Your personal data will be processed by us for the period necessary to complete the recruitment process, considering applicable statutes of limitation for claims. The standard adopted in our organisation is a period of 6 months following the end of the recruitment process. If you consent to the processing of your personal data for future recruitment, we will retain your data for the duration specified in your consent.
If your application is successful, the data you provide will become part of your employment file. You will receive separate information regarding the processing of your personal data in connection with employment.
With regard to data processed on the basis of your consent - you have the right to withdraw it at any time.
In relation to our processing of your personal data, you have the following rights, where applicable and within the limits of the law:
- the right of access and rectification, the right to restrict the processing of your data and the right to data portability,
- the right to request the erasure of your personal data, except where the processing is necessary to comply with our legal obligations and for the establishment, exercise or defence of legal claims,
- the right to object to the processing of personal data for purposes based on our legitimate interests,
- in the case of personal data processed on the basis of your consent, the right to withdraw your consent to our processing of that data, which does not affect the lawfulness of the processing of that data prior to the withdrawal of consent,
- under the GDPR, if you believe that the processing of your personal data is not in accordance with the applicable European data protection law, you may lodge a complaint with the data protection supervisory authority in the country where you have your habitual residence, place of work or where the alleged breach occurred. A list of the competent authorities in each Member State can be found on the Internet, or at under the heading 'Addresses and links'. Under FADP the (“FDPIC”) is responsible for tasks in the areas of data protection and the principle of freedom of information.
We will endeavour to deal with your request promptly and to answer any questions you may have regarding the processing of your personal data. We will respond within 30 days of receiving your request. If this period is extended due to the complexity of the request or the number of requests we receive, we will inform you of the extension and the reasons for it.
If we have reasonable doubt as to the identity of the person making the request - we may request additional information necessary to confirm the identity of the person making the request. It is not compulsory to provide this information, but failure to do so will result in the request being refused.
We keep information about the requests we receive to demonstrate compliance in line with the principle of accountability referred to in the GDPR and to establish, protect and pursue claims.
Provision of personal data as statutory or contractual requirement:
We may be unable to process your application if you fail to provide the personal data required for the recruitment process.
Transfers of data to third countries (outside the European Economic Area):
Your personal data may be transferred outside the EEA in connection with:
our use of Microsoft 365 services, including email. Microsoft complies with European data protection laws through standard contractual clauses and is certified under the EU-US Data Privacy Framework. Additionally, as part of our use of the tools and systems provided to us by Microsoft, we make use of the option to store data within the European Union;
the support of our internal processes by Trupanion Group companies, including in connection with the provision of recruitment systems to us. In this case, your data may be transferred in accordance with the relevant data protection safeguards:
to the United Kingdom on the basis of the European Commission/Federal Council decision finding an adequate level of protection under European/Swiss data protection law,
to the United States - on the basis of the applicable standard contractual clauses in accordance with the European Commission decision/ recognition by the FDPIC concluded between companies of the Trupanion Group,
to Canada on the basis of the European Commission/Federal Council decision finding an adequate level of protection under European/Swiss data protection law.
We may use other tools provided by US-based entities. If these providers participate in the ‘EU-US Data Privacy Framework,’ data transfers will rely on adequacy decisions. Otherwise, transfers will use standard contractual clauses. You may request a copy by emailing us at dataprotection@trupanion.eu.
For data processing subject to the FADP - Smart Paws is a company based in Germany, providing us with your personal data in connection with joining the recruitment process, you are transferring your personal data outside of Switzerland.
In the case of the processing of personal data subject to the FADP regulations, data transfers to Trupanion companies based in the European Union and to Microsoft Ireland Operations Limited will take place on the basis of the Federal Council adequacy decision.
The recruitment process is not subject to automated decision-making on the basis of the personal data received.