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

Introduction

We are committed to protecting the personal data of candidates who apply for positions with us. This Candidate Privacy Notice explains how we collect, use, and protect your personal data during our recruitment and selection process.
This notice applies to all candidates applying for roles at Multiverse Group Ltd (UK) and Stackfuel GmbH (Germany), including employees and contractors. This is a unified privacy notice, with jurisdiction-specific requirements clearly marked where applicable. Once you become an employee of Multiverse or Stackfuel, our separate Employee Privacy Notice will apply.
You can locate the defined terms contained in this notice at the end of this document.


1. What personal data do we collect about you?

During the recruitment process, we collect information about you to assess your suitability for the role. We refer to this information as "Personal Data" and it includes any information that may be used to identify you individually. Below outlines the Personal Data we may collect from you during recruitment.  The following is a description of the Personal Data that may be collected from you throughout the recruitment process.
  • Personal Details - Name, address, phone number, email address, date of birth
  • Recruitment  Information - CV, cover letter, LinkedIn profile (optional), application form responses, qualifications and certificates, references (post-offer), salary expectations
  • Assessment Data - Interview recordings and notes, test results, assessment scores, feedback from interviewers
  • Special Categories of Data (optional) - Diversity and inclusion information (age, ethnicity, disability status, sexual orientation, religion), Health information for reasonable adjustments 
  • DBS check (UK only) - basic or enhanced dependant on role
  • Right to Work eligibility - confirmation on your eligibility to work in the UK, Germany or contracted country as applicable (evidence is requested at point of employment)
  • Communication Records- Email correspondence

2. How do we use your personal data?

We collect and process your information for the following recruitment purposes:
  • Managing the Recruitment Process: Reviewing applications, conducting interviews, assessments and tests, communicating with you about your application, making hiring decisions, conducting reference checks, performing background checks post-offer and pre-employment (where required, such as DBS checks), providing feedback
  • Legal Compliance: Conducting right to work checks, performing DBS checks (where required), complying with equality legislation, maintaining records for potential employment tribunal claims
  • Reasonable Adjustments: Making necessary adjustments to our recruitment process to ensure accessibility and equal opportunities
  • Candidate Leads: We may collect your personal information from third-party sources, such as LinkedIn, to consider you for relevant opportunities. In these instances of indirect collection, we will provide you with our privacy information at the earliest opportunity and, in any event, within 30 days of adding your details to our systems. 
  • Future Opportunities (Talent Pool): With your consent we retain your CV and contact details on file in our talent pool to inform you about suitable future vacancies. This consent is valid for two years from the date you provide consent, after which we will contact you to request re-consent if you wish to remain in our talent pool. If you do not re-consent, your data will be anonymised. You can withdraw your consent at any time.

3. Use of Artificial Intelligence (AI) in Recruitment

We use AI-powered tools to support our recruitment process, including Ashby (for applicant tracking and CV screening), Brighthire (for interview transcription and analysis), and other AI systems to assist with candidate assessment. These tools help us process applications more efficiently and identify suitable candidates. However, all AI outputs are subject to meaningful human review and oversight.   Our recruitment team reviews all AI-generated recommendations and makes independent decisions at every stage of the process.     

If you have any questions about AI use in your application, please contact our Privacy team at datenschutz@stackfuel.com


4. Our legal basis for processing your personal data

We need a lawful reason to collect your personal data. We process your information based on:
  • Legitimate Interests: To assess your suitability for the role, manage our recruitment process and to help us better understand, analyse and improve our recruitment processes.
  • Legal Obligation: To comply with employment law requirements such as right to work checks
  • Consent: Where you have agreed to us processing your data for specific purposes, such as keeping your details for future opportunities
  • For candidates applying to Stackfuel (Germany): Section 26(1) of the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG) in conjunction with Article 6(1)(b) GDPR for processing necessary to decide on establishing an employment relationship
For Special Categories of Data, we rely on:
  • Explicit Consent(Article 9(2)(a) GDPR): Where you have specifically agreed to provide diversity information or health data for reasonable adjustments
  • Employment Law Obligations(Article 9(2)(b) GDPR): Where processing is necessary for employment law, social security, and social protection law purposes
  • For Germany: Section 26(3) BDSG in conjunction with Article 9(2)(b) GDPR for processing special categories of data necessary for employment purposes

5. Who do we share your personal data with?

We may share your personal data with:
  • Internal Teams: Hiring managers, HR team, interview panel members, and other Multiverse employees involved in the recruitment process
  • Legal Requirements: Regulatory bodies or law enforcement where required by law
Access to your personal data is limited to those who have a need to know the information for recruitment purposes.


6. How long do we keep your personal data?

We retain your personal data for different periods depending on the outcome of your application:
  • Successful Candidates: Your recruitment data will be transferred to your employee file and retained in accordance with our Employee Privacy Notice
  • Unsuccessful Candidates:  We will retain your data for 2 years after the recruitment process ends to handle any queries or potential employment tribunal claims under UK law or under the German General Equal Treament Act (AGG). 
If you do not re-consent, your data will be deleted or anonymised. 

We will securely delete or anonymise your personal data once the retention period expires, unless we have a legal obligation to retain it longer. 


7. Your rights

You have various rights regarding your personal data:
  • Access: Request a copy of the personal data we hold about you
  • Rectification: Ask us to correct inaccurate or incomplete information
  • Erasure: Request deletion of your personal data in certain circumstances
  • Restriction: Ask us to limit how we use your information
  • Objection: Object to our processing of your personal data
  • Portability: Request your data in a portable format
  • Withdraw Consent: Where we rely on consent, you can withdraw it at any time
To exercise these rights, please contact the Privacy Team at datenschutz@stackfuel.com


8. International transfers

We may transfer your personal data to countries outside the UK and European Economic Area (EEA), including to the United States where some of our service providers (processors) are located. When we transfer your data internationally, we ensure appropriate safeguards are in place to protect your information, including: the Data Privacy Framework,  UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses approved by the European Commission, for transfers to countries without an adequacy decision. We rely on the UK adequacy decision for transfers between our UK and EU operations. 
For further information, please see our processor list - https://trust.multiverse.io/subprocessors 


9. How we keep your data secure

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. This includes secure storage systems, access controls, and staff training on data protection and information security.


10. Changes to this notice

We may update this Candidate Privacy Notice from time to time. Any significant changes will be communicated to active candidates before the changes take effect.


11. How to contact us

If you have any questions about this notice or how we handle your personal data, please contact:

For Multiverse Group Ltd (UK) - 
Data Protection Officer - privacy@multiverse.io 

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you are concerned about how we process your personal data. Contact details can be found at ico.org.uk.

For Stackfuel GmbH (Germany) - 
Data Protection Officer - datenschutz@stackfuel.com 

You also have the right to lodge a complaint with the German supervisory authority: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, Germany.


Definitions

Controller: The organisation that determines when, why and how to process personal data.

Personal Data: Any information identifying a candidate or information relating to a candidate that we can identify (directly or indirectly) from that data alone or in combination with other identifiers.

Processing: Any activity that involves the use of personal data, including collecting, storing, using, sharing or deleting it.

Special Categories of Personal Data: Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation.


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.