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

This Privacy Policy sets out how The Phoenix Games Holding GmbH GmbH, Kaiserstr. 146 – 148, 76133 Karlsruhe, Germany (“Phoenix Games Holding GmbH”) uses data from candidates that apply for or that Phoenix Games Holding GmbH considers for a position at Phoenix Games Holding GmbH. Candidates may either register as user with a user account at the Phoenix Games Holding GmbH career site (“User Account”) or apply for a particular job by using this site or otherwise interacting with Phoenix Games Holding GmbH human resources department verbally or in writing (“Application”).

We may modify this Privacy Policy with future effect. For official notifications of material changes, we will place a notice letting you know when they will take effect. Your continued use of your User Account after such notice will indicate your acceptance of such changes. Phoenix Games Holding GmbH will not enforce material changes without your explicit consent.

1. What personal data do we collect?
Personal data are information which contain details of your personal or material circumstances, such as your name, address, e-mail address and date of birth. We collect your personal data as follows:

Personal data which you submit on registration for a User Account or when applying for a particular position at Phoenix Games Holding GmbH, such as your name, e-mail address, date of birth, telephone number, IP address, device ID, curriculum vitae, photograph, references and certificates or other information from which your identity is discernible.
Information we collect from third party public sources, such as LinkedIn or Xing or other career networking services.

2. Registration with a User Account
2.1 By registering with a User Account at Phoenix Games Holding GmbH and by releasing your profile, you explicitly confirm that you are interested in an employment at Phoenix Games Holding GmbH. You therefore voluntarily provide your personal data to be used for recruiting purposes, in particular for filing and matching your profile with any and all open positions at Phoenix Games Holding GmbH, including beyond those for which you specifically applied.
2.2 If there is a job opportunity at Phoenix Games Holding GmbH which matches your profile, Phoenix Games Holding GmbH may forward your data to the responsible Phoenix Games Holding GmbH managers in order to contact you for interviews. The personal data will be processed in the form of databases and will be collected in secured personal files.
2.3 You may view and update your User Account and/or request correction/amendment or deletion of your personal data at any time. Please either use the online possibilities to update your profile by accessing your User Account or alternatively refer to the following contact e-mail with your request: jobs@phoenixgames.com
2.4 Please use only private e-mail addresses for requests and communication. Phoenix Games Holding GmbH will only send information to your private address.

3. Application for a particular job opportunity without a User Account
3.1 You also have the possibility to apply solely for one defined job opportunity without getting up a User Account.
3.2 By applying for a specific job opportunity, you explicitly confirm that you are interested in an employment at Phoenix Games Holding GmbH for this particular position. You therefore voluntarily provide your personal data to be used for recruiting purposes, in particular for filing and matching your profile with the position at Phoenix Games Holding GmbH for which you specifically applied. You are responsible for ensuring that the personal data provided by you is correct and true.
3.3 You have the option of withdrawing your application at any time.
3.4 Please use only private addresses for requests. Phoenix Games Holding GmbH will only send information to your private address.

4. Submitted Material
4.1 You may choose to submit digital materials demonstrating your skills and abilities for review by Phoenix Games Holding GmbH (“Material(s)”). Please note that Materials are not generally required. If submitted, we will use your Material only for evaluation purposes and will not distribute any copies of the Material to any third parties. We will return or destroy all copies of your Material upon completion of our review or upon your earlier request.
4.2 Phoenix Games Holding GmbH engages in a continuous program to develop new products and ideas internally and we also regularly receive other submissions for consideration. The products, ideas or concepts that Phoenix Games Holding GmbH develops internally or that others submit may be similar to your Material. As a result, we cannot agree to treat as confidential any Material you submit, even if it is marked as confidential or proprietary. Our acceptance or review of your Material does not imply that we will use, develop or market your Material. Our review of your Material does not prevent us from using, developing, or marketing technologies, ideas or products that may be similar in concept or idea to your Material.

5. How do we use your data?
Phoenix Games Holding GmbH will use your personal data

to manage your relationship with us and process your job application(s),
to contact you (including by e-mail) about suitable job opportunities as they arise, if and in so far you have registered with a User Account.
to assess your eligibility for the particular position you have applied for or, if and in so far you have registered with a User Account, for available positions at Phoenix Games Holding GmbH.
to invite you to Phoenix Games Holding GmbH recruitment events (including by e-mail).

6. Does Phoenix Games Holding GmbH share your data?
6.1 We use reasonable safeguards to limit access to your personal data to those employees at Phoenix Games Holding GmbH seeking/considering a candidate for a position.
6.2 As part of the application process and for successful candidates during your employment, we may share your data as follows:

With third parties that work with Phoenix Games Holding GmbH to organize and manage data on our behalf (“Service Providers”). In these circumstances your personal data will not be used by Service Providers for any other purpose and Service Providers will use reasonable security precautions.
In circumstances where we are legally required to do so.
In the event of a reorganization, divestiture, merger or sale, we may transfer all personal data we collect to the relevant third party and will obtain your consent to do so if required by law.

7. Where will your personal data be stored and for how long?

Personal data we collect may be stored and processed for the purposes set out in this Privacy Policy in Germany where the company is situated.
Security is a priority at Phoenix Games Holding GmbH and we take a range of measures to help protect personal data including encryption and access control. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your personal data and do not assume any responsibility for the unauthorized use or access to your personal data under our control.
Phoenix Games Holding GmbH retains your personal data for as long as your User Account remains active; if you do not log into your User Account within a period of two years, Phoenix Games Holding GmbH may send you an e-mail to ask you to update your profile. If you do not log into your profile by the given deadline, your profile including your personal data will be deleted.
If you have applied for a particular job opportunity without registration of a User Account, your data will be deleted in accordance with the applicable laws once the application process ends or if you withdraw your application.
On deletion of your personal data we may retain limited personal information to ensure that we do not contact you again in the future and where there is a legal requirement to do so.

How can you contact us?
You may contact us at any time if you want your profile and related personal data to be corrected, blocked or deleted. Moreover, we will at any time disclose to you which data are stored, what the origin of the data is, who the recipient of the data is, and the purpose for which data are stored. If you have any questions concerning data protection, please contact us at:

Phoenix Games Holding GmbH, Kaiserstr. 146 – 148
76133 Karlsruhe, Germany
e-mail: jobs@phoenixgames.com

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.