Twinner® – More than you can see

Privacy Policy for Applicants

We are pleased that you are interested in us and that you are applying or have applied for a position in our company. With the following information we would like to inform you about as to why we collect, use and process certain data from you and the rights to which you are entitled.


1. Who is responsible for data processing and whom can I contact?

The following party is the controller:

TWINNER GmbH
Edmund-von-Lippmann-Str. 13-15
06112 Halle (Saale)
Phone: +49 345 213868-0
E-Mail: info@twinner.com

You can reach our company data protection officer at:

Dr. Andreas Melzer
kelobit IT-Experts GmbH
Phone: +49 345 132553-80
E-Mail: dsb@kelobit.de

2. Which sources and data do we use?

We process the data that you have sent us in connection with your application in order to check your suitability for the position (or other open positions in our company, if applicable) and to carry out the application process.

The personal data processed by us include the following:

  • Contact information (name, address, etc.)
  • Data regarding your personal skills (apprenticeship, professional experience, language skills and other data regarding your education)

3. Why do we process your data (purpose of processing) and on what legal basis?

The legal basis for the processing of your personal data in this application process is primarily Section 26 of the Federal German Data Protection Act (Bundesdatenschutzgesetz, short BDSG), which allows the processing of personal data for the application processes.

If an employment relationship is established between you and us, we can, in accordance with Section 26 (1) BDSG, process the personal data already received from you for the purpose of the employment relationship, if this is for the implementation or termination of the employment relationship or for the exercise or fulfilment the rights and obligations arising from a law or a collective agreement, a works or service agreement (collective agreement) for the representa-tion of the interests of the employees are required.

It may happen that we cannot consider you directly for filling a position, but still want to keep your application in order to be able to contact you quickly if necessary. If this occurs, we will ask for your consent in accordance with Section 26 (2) BDSG to be able to include your application in our application pool for a certain period of time. If you give us this consent, it can be revoked informally at any time.

If your data should be required for legal prosecution after the application process has been completed, processing can take place on the basis of the requirements of Art. 6 GDPR, in partic-ular to safeguard legitimate interests according to Art. 6 Para. 1 lit. f GDPR. Our interest then lies in the assertion or defence of claims, for example in the context of the burden of proof in a procedure under the General Equal Treatment Act (AGG).

4. Who will receive my data?

Your applicant data will be viewed by the HR department after your application has been re-ceived. Suitable applications are then forwarded internally to the department heads for the respective open position. The further procedure will then be coordinated. In principle, only those people in the company have access to your data who need it for our application process to run properly.

5. Is data transferred to a third country or to an international organization?

As a rule, data is not transferred to bodies in countries outside the European Economic Area (so-called “third countries”). Nevertheless, a transfer of data to third countries may take place in individual cases, to the extent that:

  • it is required by law
  • you have given us your consent, or
  • this is justified by a legitimate interest in terms of data protection law and no higher in-terests of the data subject worthy of protection conflict with this.

Furthermore, we do not transfer any personal data to third countries or international organizations.

However, for certain tasks we use service providers who typically also use service providers who may have their headquarters, parent company or data centres in a third country. A transfer is permissible if the European Commission has decided that an adequate level of protection exists in a third country (Art. 45 GDPR), In the absence of such a decision by the Commission, we or our service providers may transfer personal data to a third country only if appropriate safeguards are in place (for example, standard data protection clauses adopted by the EU Commission or the supervisory authority in a particular proceeding) and enforceable rights and effective reme-dies are available.

We have concluded appropriate contracts with our service providers and have also contractually agreed that there must always be data protection guarantees with their contractual partners in compliance with the European level of data protection. We will provide you with a copy of these guarantees upon request.

6. How long will my data be stored?

We store your data as long as we need to decide in the application process. If we would accept you for a position in our company we will transfer your data in our staff-data-system.

If we cannot consider you for a position and you consent to a longer storage of your data we will transfer your data into our application-pool. There your data will be deleted after a predeter-mined amount of time (regularly 12 month if not otherwise agreed) or if you withdraw your consent.

If we do not employ you, your data can be stored to our assertion of rights. This storage will last regularly 6 month after the announcement of the rejection of your application or until the end of the litigation.

7. What data protection rights do I have?

Every data subject has the right of access under Article 15 GDPR, the right of rectification under Article 16 GDPR, the right of erasure under Article 17 GDPR, the right to restrict processing un-der Article 18 GDPR, the right of objection under Article 21 GDPR and the right of data portability under Article 20 GDPR. With regard to the right of access and the right of erasure, the restrictions according to Section 34 and Section 35 of the German Federal Data Protection Act (Bundesdatenschutzgesetz) apply. Furthermore, there is a right of appeal to a competent data protection supervisory authority (Article 77 GDPR).

You can revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the General Data Protection Regulation came into force, that is, prior to 25 May 2018. Please note that a revocation is only effective for the future. Processing operations that took place prior to the revocation are not affected.

8. Is there a duty to provide data?

Initially, the provision of your personal data is not required by law or contract, nor are you obliged to provide such data. However, if you want to want to be employed by us, you must provide us with the personal data required to establish and maintain the employment contract and to fulfill the associated contractual duties. Without such data, we will usually have to refuse to conclude the employment.

9. To what extent is there automated decision-making?

We do not use fully automated automatic decision-making in accordance with Article 22 GDPR to establish, continue and terminate employment. If we use such procedures in individual cases, we will inform you of this and of your rights in this regard separately, insofar as this is required by law.

10. Does profiling take place?

We do not process your data with the objective of automatically evaluating certain personal aspects.

11. Information on your right of objection under Article 21 GDPR

11.1 Right of objection based on individual cases

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out on the basis of Art. 6, para. 1, letter f GDPR (data processing based on a balancing of interests). This also applies to profiling based on this provision within the meaning of Art. 4, no. 4 GDPR.

If you file an objection, we will no longer process your personal data, unless we can prove compelling reasons for processing that are worthy of protection and outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

11.2 Recipient of an objection

The objection can be made in any form with the subject “Objection”, stating your name, your address and your birthdate and should be send on the same channel as the application. Please address the objection as written in section 1 of this privacy policy.

12. Revision of this privacy policy

We revise this data protection information in the event of changes in data processing or other occasions that make this necessary. The current version can always be found on this website.

Date: 14 July 2021