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

Privacy and Security Statement for the Online Application Process

1. General Information
This data privacy and security statement applies exclusively to the processing of personal data collected as part of the online application process. Its purpose is to inform you about how we handle, process, store, and protect your personal data when you submit an application through our recruitment website or HR system.

2. Controller
The controller responsible for processing your personal data is:
COBBS Industries B.V. 
Vrije Geer 3
1066EG Amsterdam
The Netherlands
Phone:+31 (0)88 532 34 00 
KvK number: 34245108
Security Officer:
Romy Pannekoek
You may contact our Security Officer for all questions related to data protection within the application process.

3. Personal Data Processed
Personal data means any information relating to an identified or identifiable person. In the context of the application process, this may include:
  • Name, address, email, phone number
  • Information contained in your CV (career history, education, skills, etc.)
  • Optional documents such as motivation letters, diplomas or reference letters
  • Any information voluntarily provided by you during interviews or communication
Special categories of personal data (Article 9 GDPR)—such as health information, religious beliefs, racial or ethnic origin—are not required.
We ask you not to include such sensitive information in your application.

4. Legal Basis for Processing
We process your personal data on the following legal bases:
  • Article 6(1)(b) GDPR – Processing is necessary to take steps at your request prior to entering into an employment contract.
  • Article 6(1)(f) GDPR – Processing is necessary for our legitimate interests, such as defending legal claims during or after the recruitment process.
  • Article 6(1)(a) GDPR – If you voluntarily give consent for your data to be stored in our Talent Pool beyond the application process.
You may withdraw your consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

5. Purpose of Processing
We process your data for the following purposes:
  • Managing and executing the application process
  • Assessing your qualifications for a position
  • Communicating with you during the recruitment process
  • Preparing an employment contract if you are selected
  • Maintaining our Talent Pool (only with your consent)
  • Fulfilling legal obligations and defending legal claims
Only authorized HR personnel and hiring managers with a legitimate need have access to your data (role‑based access and least‑privilege principles).

6. Data Storage and Retention Periods
Your data is stored only for as long as necessary for the purposes stated above.
  • Standard retention: 4 weeks after the recruitment process has concluded.
  • Extended retention with your consent: Up to 1 year (Talent Pool).
  • Hired candidates: Data will become part of your employee file and is stored for at least the duration of your employment. After the retention period expires, your data is automatically deleted or irreversibly anonymized.
7. Disclosure to Third Parties
Your personal data is stored in our HR and applicant management system operated by:
Personio GmbH
(https://www.personio.com/legal-notice/)
Personio acts as a processor under Article 28 GDPR. All processing is governed by a valid Data Processing Agreement (DPA).
No other third parties receive your data unless:
  • required by law, or
  • you have provided consent.
We do not sell or share applicant data for commercial purposes.

8. International Data Transfers
Personio stores data within the European Union.
However, Personio may use carefully selected sub‑processors located outside the European Economic Area (EEA).
In such cases, international transfers are secured with EU Standard Contractual Clauses (SCCs) or equivalent safeguards as required by Articles 44–49 GDPR.

9. Security Measures
We implement appropriate technical and organizational measures to protect your personal data, including:
  • Data encryption in transit and at rest
  • Secure hosting environments within the EU
  • Role‑based access controls
  • Multi‑factor authentication for authorized personnel
  • Access logging and monitoring
  • Regular security audits and compliance checks
These measures ensure that your data remains confidential, secure, and protected against unauthorized access.

10. Rights of Data Subjects
Under the GDPR, you have the following rights:
  • Right of access (Article 15)
  • Right to rectification (Article 16)
  • Right to erasure (Article 17)
  • Right to restriction of processing (Article 18)
  • Right to data portability (Article 20)
  • Right to object (Article 21)
  • Right to withdraw consent (Article 7(3))
You can exercise your rights by contacting our Security Officer.
Right to lodge a complaint:
If you believe your data is being processed unlawfully, you have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

11. Changes to This Privacy Statement
We reserve the right to update or adjust this privacy statement at any time to comply with legal requirements or reflect changes in our recruitment process.
The updated version applies to all subsequent visits and applications.

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.