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

1. Controller

The controller responsible for the processing of your personal data in the context of the recruitment procedure is:

Transfermarkt GmbH & Co. KG
Wandsbeker Zollstraße 5a
22041 Hamburg
Phone: +49 40 6704821-20
E-Mail: jobs@transfermarkt.de

This Privacy Notice informs you, in accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR), about how we process your personal data in the context of a recruitment procedure.

2. Purposes of Processing and Legal Bases

We process your personal data in the context of the recruitment procedure for the following purposes in particular:

to process and administer your application
to assess your professional and personal suitability for the advertised position
to communicate with you during the recruitment procedure
to conduct job interviews and other selection procedures
to make decisions regarding the establishment of an employment relationship
to comply with legal obligations and to assert, exercise or defend legal claims

The processing of your personal data in the context of the recruitment procedure is carried out in particular on the basis of Section 26 (1) sentence 1 of the German Federal Data Protection Act (BDSG), insofar as the processing is necessary for the decision on the establishment of an employment relationship.

Insofar as the processing is necessary for the implementation of pre-contractual measures, Article 6 (1) (b) GDPR may also serve as a legal basis.

Insofar as we are required to process personal data due to legal obligations, the processing is based on Article 6 (1) (c) GDPR.

Insofar as the processing is necessary for the assertion, exercise or defence of legal claims, the processing is based on Article 6 (1) (f) GDPR.

If we process personal data on the basis of consent, the processing is based on Article 6 (1) (a) GDPR. You may withdraw your consent at any time with effect for the future. The lawfulness of processing carried out on the basis of consent prior to its withdrawal remains unaffected.

Talent Pool

If you expressly consent to being included in our Talent Pool, we process your application data beyond the specific recruitment procedure in order to consider and contact you for suitable future job opportunities.

The processing within the Talent Pool is based on your consent pursuant to Article 6 (1) (a) GDPR.

Providing this consent is voluntary and is not a prerequisite for conducting the specific recruitment procedure.

You may withdraw your consent at any time with effect for the future.

3. What Personal Data Do We Process?

In the context of the recruitment procedure, we process the personal data that you provide to us in connection with your application.

This may include, in particular:

first and last name
contact details, in particular email address, telephone number and address
application documents, in particular CV, cover letter, references and certificates
information on education, qualifications and professional experience
information on language skills and other qualifications relevant to the respective position
information provided by you as part of screening questions
information and assessments documented as part of job interviews and other selection procedures
other information that you voluntarily provide to us as part of your application

As a general rule, we only process data that is relevant to the recruitment procedure or that you voluntarily provide to us.

Please note that special categories of personal data within the meaning of Article 9 GDPR are generally not required for the recruitment procedure. These include, for example, health data, information relating to religious or philosophical beliefs, trade union membership or data concerning sexual orientation.

If special categories of personal data are required in an individual case for the recruitment procedure or are voluntarily provided by you, they will only be processed if the requirements of Article 9 GDPR and the relevant provisions of the BDSG are met.

4. Recipients of Your Personal Data

Within our company, only those persons who require access to your personal data for the purpose of conducting the recruitment procedure will have access to it.

These include, in particular, employees of the HR department as well as the respective responsible departments and managers.

For the technical implementation of our recruitment procedure, we use the recruiting software Personio.

Personio processes personal data on our behalf on the basis of a data processing agreement pursuant to Article 28 GDPR.

In addition, we may use other carefully selected service providers where this is necessary for the operation and implementation of our recruitment process. These service providers process personal data only in accordance with the applicable legal requirements and, where required, on the basis of a data processing agreement.

Your personal data will only be disclosed to other third parties if this is legally permissible or necessary, if we are legally obliged to do so, or if you have expressly consented to this.

5. Transfer of Data to Third Countries

We endeavour to process your personal data primarily within the European Union or the European Economic Area.

If, as part of the use of our service providers or for other reasons, it is necessary to transfer personal data to a country outside the European Union or the European Economic Area, this will only take place in compliance with the legal requirements of Articles 44 et seq. GDPR.

A transfer may take place in particular on the basis of an adequacy decision of the European Commission or appropriate safeguards, in particular the Standard Contractual Clauses adopted by the European Commission.

Further information on the service providers used and any existing transfers to third countries can be obtained from us using the contact details provided below.

6. Retention Period and Talent Pool

We generally store your personal data only for as long as this is necessary for the recruitment procedure.

If your application does not result in employment, your application data will generally be deleted or anonymised no later than 180 days after the conclusion of the recruitment procedure, unless statutory retention obligations prevent this or longer storage is necessary for the assertion, exercise or defence of legal claims.

The specific retention period generally begins upon completion of the respective recruitment procedure.

If you have expressly consented to being included in our Talent Pool, we may store your application data beyond the conclusion of the specific recruitment procedure in order to consider you for suitable future job opportunities.

Storage in the Talent Pool is carried out exclusively on the basis of your consent pursuant to Article 6 (1) (a) GDPR.

You may withdraw your consent at any time with effect for the future. Following receipt of the withdrawal, your data will be deleted from the Talent Pool unless statutory retention obligations or other legal reasons prevent deletion.

7. Your Rights

Subject to the statutory requirements, you have, in particular, the following rights:

Right of access pursuant to Article 15 GDPR
Right to rectification of inaccurate personal data pursuant to Article 16 GDPR
Right to erasure of your personal data pursuant to Article 17 GDPR
Right to restriction of processing pursuant to Article 18 GDPR
Right to data portability pursuant to Article 20 GDPR, insofar as the statutory requirements are met
Right to object to certain processing pursuant to Article 21 GDPR
Right to withdraw consent with effect for the future

Withdrawal of Consent

If we process your personal data on the basis of your consent pursuant to Article 6 (1) (a) GDPR, you may withdraw this consent at any time with effect for the future.

The lawfulness of processing carried out on the basis of consent prior to its withdrawal remains unaffected.

Right to Object

If we process your personal data on the basis of Article 6 (1) (f) GDPR, you have the right to object to this processing at any time on grounds relating to your particular situation.

You may submit your withdrawal of consent or objection at any time informally by contacting

datenschutz@transfermarkt.de

or in writing to the address stated under Section 1.

8. Obligation to Provide Personal Data

The provision of your personal data is voluntary.

However, for the purpose of conducting the recruitment procedure, we require certain information that is necessary to assess your application and make a decision regarding the establishment of an employment relationship.

If you do not provide the information required for the recruitment procedure, we may be unable or only partially able to consider your application.

9. Data Protection Contact

If you have any questions regarding the processing of your personal data or wish to exercise your data protection rights, you can contact us at any time:

Transfermarkt GmbH & Co. KG
Wandsbeker Zollstraße 5a
22041 Hamburg

E-Mail: datenschutz@transfermarkt.de

10. Automated Processing in the Recruitment Procedure

As part of our recruitment procedure, we use functions of our recruiting software Personio that allow applications to be automatically reviewed based on predefined, position-specific screening criteria.

This may include the use of screening questions that ask about certain mandatory requirements for the respective position. The screening questions are defined by us for the respective position and may relate, for example, to specific qualifications, professional experience or other mandatory requirements.

If automatic screening is activated for a position and you select an answer to a screening question that meets one of the exclusion criteria defined for the respective position, your application may be automatically rejected and moved to the corresponding recruitment stage. Depending on the configuration, a rejection email may also be sent automatically.

The automated decision is made exclusively on the basis of the screening criteria defined for the respective position and the information you provide in response to these questions. No automated assessment of your personality or other personal characteristics takes place as part of this screening.

Such an automated rejection may result in your application not being included in the further individual review process. The decision may therefore have significant effects on the further course of your recruitment procedure.

Insofar as a decision based solely on automated processing within the meaning of Article 22 GDPR is involved, it will only be made in compliance with the statutory requirements of Article 22 GDPR.

Pursuant to Article 22 (3) GDPR, you have the right to request human intervention on the part of the controller, to express your own point of view and to contest the decision.

To exercise these rights, you can contact jobs@transfermarkt.de or datenschutz@transfermarkt.de.

An automated rejection can technically be reversed by Transfermarkt at a later stage. The application concerned can then be returned to the regular recruitment process and processed in the same way as any other application.

11. Right to Lodge a Complaint and Updates to This Privacy Notice

You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates data protection regulations.

The competent supervisory authority for Transfermarkt GmbH & Co. KG is generally:

The Hamburg Commissioner for Data Protection and Freedom of Information

You may also contact another data protection supervisory authority, in particular the supervisory authority at your habitual place of residence or place of work.

This Privacy Notice is dated September 23, 2026.

We reserve the right to amend this Privacy Notice if legal requirements, our recruitment process, the systems we use or the nature of the processing of personal data change.

The version published at the time of your application shall apply.

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.