Privacy Policy for Our Online Application System

When using our online application system, we want you to feel safe and comfortable. The protection of your privacy is of great importance to us, because we understand that data protection is not only important to customers, but also to applicants and employees. The following data protection principles inform you about how the Kaufland Group handles the processing of personal data obtained from users of the application system and visitors to our website.

1. The Responsible Organization According to Section 3.2 of the Australian Privacy Principles (APPs)

Kaufland Australia Pty Ltd.

ABN: 86 616 591 667

Level 2, 327 Ferntree Gully Road, Mount Waverley 3149

Phone: 03 9863 6340

Email: recruiting@kaufland.com.au

2. Contact Form/Email Contact/Telephone Contact

Purpose of Data Processing and Legal Basis: Personal information that you provide via filling out contact forms, telephone calls or email communication, will be treated confidentially. We use your data exclusively for the specific purpose of processing your request. The legal basis for this data processing is Section 3.2 APPs, as it is reasonably necessary for Kaufland Group to answer customer requests to maintain and promote their satisfaction. The kind of data we collect depends on the dealings you have with us, but is likely to include your name, date of birth, address, telephone number, e-mail address.

Recipients /Categories of Recipients: As a matter of principle, we do not transfer data to third parties outside the Kaufland Group. However, in exceptional cases data is processed by data processors on our behalf, in Australia and overseas. These service providers are carefully selected, audited by Kaufland Group and contractually bound to uphold specific data privacy standards. However, despite these reasonable steps it is not always possible to ensure that third parties comply with privacy laws and you will not have recourse against us for any such breaches by any data processors.

Furthermore, it may be necessary for us to forward extracts of your request to other Kaufland companies in Australia and overseas (e.g. the Kaufland company to which your request relates) in order to process your request. In these cases, however, the request will be anonymized beforehand, so that the respective Kaufland company is unable to relate the request back to you. If it is necessary, in individual cases, to pass on your personal information, we will inform you in advance and obtain your consent.

You agree that we may disclose your data in these circumstances and that we are not liable for any privacy breaches of any third party where we have dealt with your data under this policy.

Retention Period/Criteria for Defining the Retention Period: All personal data you provide us with through enquiries via this website or by e-mail will be deleted or anonymized at the latest 2 years after the final reply to you. The reason for the 2 years retention period is website visitors often contact Kaufland Group multiple times, regarding the same issue, sometimes even after an answer is received. Therefore, we must be able to refer to the previous correspondence. In our experience, there are usually no further questions about our answers after this period. You can withdraw your consent to us retaining your personal data at any time.

3. Online Application System

The Kaufland Group is constantly looking for qualified and motivated employees. Please note that applications you send us via e-mail will be sent to us unencrypted. Therefore, we ask you to use our online application system exclusively to enable us to comply with this policy.

Our online application system provides two options of submitting your application. You may log in and create your own profile with a personal password. With that, you can view the status of your application, submit further documents, change your data later or withdraw the application. If you submit an application without logging in, you only submit the data required for the application to us without having direct access to your application. Also, in this case, you may view, edit and manage your profile upon request. This can be done at any time by requesting a password (register/login: “Forgot password” and enter your e-mail address). For both options of submitting your application, the same data will be collected and sent to us.

Purpose of Data Processing, Legal Basis/Mode of Operation: In our online application system you can create a profile with a personal password or you can submit the information to us without logging in. All information and attachments saved and submitted with your application are processed by us exclusively for the purpose of processing the application submitted by you. In Australia the processing of applicants’ information is covered by the Privacy Act 1988 (Cth) and the Kaufland Group treats this information in accordance with the privacy standards set out in the Apps. Subclause 3.2 APP stipulates that personal information may be collected if it is reasonably necessary for, or directly related to, one or more of the entity’s functions or activities. Kaufland aims to hire new employees, and it is reasonably necessary to collected personal information in order to do so. The information obtained relates to the information needed to determine if an applicant is qualified and could fulfill the requirements of the position.

If you check the box in your online profile confirming you consent to your profile being visible (see Recipients/Categories of Recipients below), your application data and attachments may also be used by the Kaufland Group to assess your suitability for other roles in the Kaufland Group. If you also consent to this secondary processing of your data, Subclause 6.1 lit. a APP is the legal basis for further processing of your application. We use an encryption method for the online transmission of your applicant data in this system, so that your data is protected against unauthorized access.

Recipients/Categories of Recipients: Without consent or the submission of a specific application the data in your profile can only be viewed by you.

The recruiters responsible for an open position will not have access to your application data until you create and submit a specific application via your profile. Your profile will only be considered for other job openings in the Kaufland Group, which are relevant to your qualifications or interests, if you give specific consent via the system (in the form of checking a box indicating for whom your profile should be visible). In addition, we will never forward your application to third parties outside the Kaufland Group.

Your data may also be transferred to an overseas recipient if you apply for international job openings with Kaufland or you have expressly given your consent to have your profile included in the application pool, so that recruiters from all Kaufland countries may check your data for matching vacancies. In these cases, the legal basis for the data transfer is your consent to us using your data for a secondary purpose in accordance with Subclause 6.1 lit. a APP.

Retention Period/Criteria for Defining the Retention Period: After completion of the application process, the data of a specific application will be made anonymous in accordance with applicable national law. The applicant data is made anonymous in Australia after 2 years.

Your profile in our online application system and the data stored in it remains stored in the system regardless of a concrete active application. This gives you the opportunity to apply online for further jobs within the Kaufland Group. If there are no active applications and your profile has been inactive for a period of 12 months, your profile will be deleted automatically.

However, you can delete your profile and your personal applicant data at any time. If you are processing an application at that time, your application will be withdrawn.

4. Job Agent

Once you have entered a job title and/or location, corresponding to your interests, into the search field, you may request that our Job Agent send you corresponding job offers via e-mail. You may specify how often or seldom the emails should be sent. The purpose of data processing, when ordering a Kaufland Job Agent as an information service, is to inform subscribers about job vacancies in the Kaufland Group in order to prepare/facilitate possible applications. The legal basis for data processing within the scope of sending the Job Information Newsletter is your consent pursuant to Subclause 6.1 lit. a APP.

If you register for the free Kaufland Job Agent, you agree to the processing of your e-mail address and the job criteria you provided (e.g. location, position or working hours) in order to inform you via email regarding job offers that match your requirements. Your email address and job criteria will not be shared. You can revoke your consent at any time by logging in with your profile and deleting the job agent.

5. Data Processing When Using the “Share” Function

For reasons of data protection, we have deliberately decided against integrating the "share" function of the various social networks as a social plugin in our online application system. Therefore, the "share" functions included on this page are only implemented as links. The links only open the pages of the social networks in a new browser window. By simply calling up this page, no data is transmitted to providers of the different social media networks. Profiling by third parties is thus excluded. However, we do not wish to deny the opportunity to those visitors who would like to "share" our job posting with their social network. Therefore, only if you press the respective "share" button, does a transfer of data to the provider of the social network you selected take place

Purpose of Data Processing/Legal Basis: Subclause 3.2 APP stipulates that personal information may be collected if it is reasonably necessary for, or directly related to, one or more of the entity’s functions or activities. By providing applicants the opportunity to voluntarily share the job posting on social media, Kaufland Group is reaching a greater number of people who may be interested in an available position, which helps the Kaufland Group to reach a wider audience and recruit quality employees.

Recipients/Categories of Recipients: The "sharing" of website content means that certain data can be transferred to the provider of the social media website, for example:

- The address of our website

- Date and time of accessing the website or pressing the “share” button

- Information about the browser and operating system used

- Your current IP address

- Content you share

The shared content (job postings) can then also be viewed by other users of the same social media network, depending on the data protection setting you have on your account. If you are already logged into the associated social media network when you press the “share” button, its provider is also able to determine your user name and, if necessary, your real name from the above data. This data can potentially be processed by the provider internationally. We have no influence on the extent, type and purpose of data processing by the provider. Please note that providers of social media networks with the above data are quite capable of creating pseudonymized and even individualized user profiles. Please be aware that we are not responsible for the privacy policies or practices of third party websites or social network platforms and your interactions with any social media features are governed by the privacy policies and practices of the hosting entities.

Storage Duration/Storage Duration Criteria: The length of time your shared content is displayed depends on your account's social media network privacy settings and their privacy policies. The Kaufland Group has no control over this.

6. Cookie Usage

So-called "cookies" are used in our online application system. Cookies are small text files that are sent, when you visit our website, from our web server to your device (PC, notebook, smartphone or tablet) and are stored there in the internet browser. The cookies used can fulfil various functions. The following subsections inform you about the individual purposes of the various cookies that may be used.

You can also set your browser to inform you when cookies are placed. This procedure helps make the use of cookies transparent. You can also adjust your browser settings so that it does not accept cookies in general or rejects cookies from individual providers. However, we would like to point out that this may impair the functionality of our online application system.

Purpose of Data Processing/Legal Basis: The following information is collected when using our online application system:

- Encrypted e-mail address and user ID

- Autofill of the e-mail address.

This information is required by session cookies for job search functionality. The data collected is not used to personally identify the visitor of the website. The usage data stored in the cookies is also not combined with personal data concerning the bearer of the pseudonym.

The legal basis of this data processing, storage and use of cookies is Subclause 3.2 APP. Kaufland Australia uses cookies to provide a more enjoyable website experience. Having a user friendly online application system helps to make the application process easier for eligible candidates.

Storage Duration/Storage Duration Criteria for Cookies: Session cookies are deleted at the end of your Internet session (when you close the browser).

7. Encryption and security of personal information

We take technical and organizational security measures to protect your data as comprehensively as possible against unwanted access. In addition to securing the operating environment, we also use encryption methods. The information you provide is transmitted in encrypted form using an SSL protocol (Secure Socket Layer) and authenticated to prevent misuse of the data by third parties. You can verify that your data is encrypted by the lock symbol in the status bar of your browser and the address line starting with "https".

While we endeavor to provide a secure online environment, there are inherent risks associated with the transmission of information via the internet and no data transmission over the internet can be guaranteed to be completely secure. We therefore cannot warrant the security of any information you provide to us over the internet and you do so at your own risk. We encourage you to maintain the confidentiality of your passwords and account details used on our website. We will not be liable for any damages, loss or expense suffered due to your failure to maintain the confidentiality of your password and account details.

8. Data Transfers to the EU

Currently, Kaufland Group hosts its data center in Weinsberg, Germany, where all data collected by Kaufland Group, including data from Australia, is stored. In Germany (and the EU) the collection, use and storage of personal data is governed by the General Data Protection Act (GDPR). This regulation protects personal data in a way that is at least substantially similar to the APP and the individuals may access the protection of the law, as required in Subclause 8.2 para. a lit. i and ii APP.

9. Your Rights as a Data Subject

According to the APP you have certain rights as an individual whose data is collected, held or used. The previous sections of this policy have explained the data which is collected through the online application system and how Kaufland Group will use the data. Section 10 contains information regarding who you may contact in the case of questions, a data breach or to request access to your data. If for any reason you are not satisfied with the response you receive from Kaufland Group regarding your data protection you may contact the Office of Australian Information Commissioner.

As stated in Section 8 your data is transferred to Kaufland Group’s server, located within the European Union, this means that you have certain additional rights regarding your data according to the General Data Protection Regulation (GDPR). According to:

Art. 15 para. 1 GDPR - you have the right to receive information, at any time and free of charge, regarding your personal data, stored by the Kaufland Group entity to which you are applying,

Art. 16 GDPR - you have the right to demand the correction of incorrect data stored about you.

Art. 17 GDPR - you have the right to request the deletion of data if we are no longer allowed to store the data (e.g. because the data is no longer required for the hiring decision or because you revoke consent).

Art. 18 GDPR - you have the right to request the restriction of the processing of personal data.

Art. 20 GDPR - If you have provided the processed data yourself, you have the right to data transmission.

Art. 21 GDPR - If the data processing is based on legitimate interest according to Art. 6 para. 1 e) or f) GDPR, you have a right of object. If you object to data processing, this will not take place in the future. This does not apply if the data subject can prove compelling reasons worthy of protection for further processing which outweigh the interest of the data subject in the opposition.

If data processing is based on a consent pursuant to Art. 6 para. 1 a) or Art. 9 para. 2 a) DSGVO, you can revoke your consent at any time with effect for the future. The legality of the previous processing remains unaffected by this. Please note that revoking your consent will result in your profile being immediately deleted from our online application system and all applications will be withdrawn and made anonymous accordingly.

In the cases mentioned above, in case of open questions or in case of complaints, please contact the data protection officer in writing or by e-mail. Any individual whose data is being processed has the right of appeal to a supervisory authority in the EU, without prejudice to any other administrative or judicial remedy, if the data subject considers that the processing of personal data concerning him or her is contrary to the GDPR (Article 77 GDPR). The data subject may exercise this right before a supervisory authority in the Member State of the EU where he/she resides, works or is suspected of having committed an infringement.

10. Contact Details of the Data Protection Officer

If you have an issue regarding data protection or you would like access to the data processed by Kaufland Group you may contact the data protection officers of the individual Kaufland companies using the following contact details:

- Australia

E-Mail: recruiting@kaufland.com.au

Address:

Kaufland Australia Pty Ltd.

Level 2, 327 Ferntree Gully Road

Mount Waverley VIC 3149

-  Bulgaria

E-Mail: dataprotection@kaufland.bg

Anschrift:

1A Skopje Str

1233, Sofia

-  Croatia

E-mail: gdpr@kaufland.hr

Adresa:

Kaufland Hrvatska k.d.

Službenik za zaštitu podataka

Donje Svetice 14

10 000 Zagreb

-  Czech Republic

e-mail: oou@kaufland.cz

Poštovní adresa:

Kaufland Česká republika v.o.s.

Bělohorská 2428/203169 00 Praha 6

-  Germany

datenschutz@kaufland.de

Postanschrift:

Kaufland Dienstleistung GmbH & Co. KG

Datenschutzbeauftragter Kaufland Dienstleistung

Rötelstraße 35

74172 Neckarsulm

-  Poland

Kaufland Polska Markety sp. z o.o. sp. k.

e-mail: daneosobowe@kaufland.pl

adres:

al. Armii Krajowej 47

50-541 Wrocław

-  Romania

E-mail: protectiadatelor@kaufland.ro

Adresa poștală:

Kaufland România, Bd. Barbu Văcărescu 120-144, sectorul 2 , București

În atenția departamentului Protecția Datelor

-  Slovakai

Kaufland Slovenská republika v.o.s.

Recht und Compliance

Adresse: Trnavská cesta 41/A, 831 04 Bratislava

E-mail: dataprotection@kaufland.sk

 

 

II EU Member States

1. Responsible entity within the meaning of Art. 4 No. 7 General Data Protection Regulation (DSGVO/GDPR)

For Germany

Kaufland Dienstleistung GmbH & Co. KG

Rötelstraße 35

74172 Neckarsulm

Phone: +49 7132 9400

Email: karriere@kaufland.de

For the Czech Republic

Kaufland Česká republika v.o.s.

Bělohorská 2428/203169 00 Praha 6

Phone: +420 251 05 1111

Email: personal@kaufland.cz

For Slovakia

Kaufland Slovenská republika v.o.s.

Head Office: Trnavská cesta 41/A, 831 04 Bratislava

(hereinafter referred to as “Kaufland”)

Phone: +421 2 49 59 02 00

Email: service@kaufland.sk

For Croatia

Kaufland Hrvatska k.d.

Donje Svetice 14

10 000 Zagreb

Phone: +385 1 2353 555

Email: karijera@kaufland.hr

For Poland

Kaufland Polska Markety sp. z o.o. sp. k. (dalej: Kaufland)

al. Armii Krajowej 47

50-541 Wrocław

Phone: +48 71 37 70 100

Email: service@kaufland.pl

For Romania

Kaufland România SCS

B-dul Barbu Văcărescu 120-144, Sector 2

București, CP 020284

Phone: +40 372 090 000

Email: recrutare@kaufland.ro

For Bulgaria

Кауфланд България ЕООД & КОКД

ул.“Скопие“ 1А

1233 София

Phone: +359 28125000

Email: recruitment@kaufland.bg

2. Contact form/Email contact/Telephone contact

Purpose of the data processing/Legal basis:

Any personal information provided by you when filling in the contact forms, over the phone or by email will of course be treated confidentially by us. We use your data only for the intended purpose and to respond to your enquiry. The legal basis for this type of data processing is Art. 6 para. 1 lit. f) DSGVO/GDPR. The legitimate interest on the part of the Kaufland Group results from the endeavour to respond to enquiries of website users to maintain and ensure their satisfaction.

Recipients/Recipient categories:

The transfer of data to third parties outside the Kaufland Group is principally excluded. By way of exception, data will be processed by contractors on our behalf. All contractors are carefully selected and audited by us and contractually obliged in accordance with Art. 28 DSGVO/GDPR.

Furthermore, it may be necessary for us to disclose excerpts from your enquiry to other Kaufland companies (e. g., the Kaufland company to which your request relates) in order to process your enquiry. As far as possible, however, your request will be anonymised prior to being disclosed so that third parties cannot associate the enquiry with you. However, in individual cases it may be necessary to share your personal information in order to process your enquiry.

Storage period/Criteria for the determination of the storage period:

Any personal information that you provide to us when sending an enquiry through this website or via email will be deleted or safely anonymised by us no later than 90 days after our final response to you. This is due to the fact that our website visitors often contact us again for the same matter after having received a response. In this case, we must be able to refer to the earlier correspondence. For this reason, we keep your documents on file for 90 days. In our experience, there are usually no further questions regarding our responses after this period. In case of assertion of your data subject rights, your personal data will be stored for 3 years after the final response to prove that we have provided you with comprehensive information and that the legal requirements are met.

3. Online application system

The Kaufland Group is constantly looking for qualified and motivated employees. Please note that applications sent to us by email are transmitted to us without encryption. We therefore recommend that you exclusively use our online application system.

Our online application system provides two options for submitting your application. You may create an account and set up your own profile with a personal password. This way, you can view the status of your application, submit documents, change your data at a later stage or withdraw the application. If you submit your application without creating an account, you simply transmit the data required for the application but there is no direct access to your application. You may still view, edit and manage your profile subsequently on request. This is possible at any time by requesting a password (create account/login: click on “forgot password” and enter your email address). For both application options, the same kind of data will be collected and sent to us.

Purpose of the data processing, legal basis/Technical functionality: With our online application system, you can create a profile with a personal password or transmit the data to us without creating an account. All the information and attachments saved and submitted with your application are processed by us only for the purpose of processing the application submitted by you. The legal basis for this is

- For Germany

§ 26 para. 1 sentence 1 Federal Data Protection Act (BDSG) new in conjunction with Art. 88 DSGVO/GDPR.

- For the Czech Republic

Art. 88 GDPR.

- For Slovakia

Art. 11 of Law No. 311/2001 - Labour Code in conjunction with Art. 88 DSGVO/GDPR.

- For Croatia

Article 6, para. 1 (f) of the General Data Protection Regulation.

- For Poland

Art. 22 Labour Code and Art. 6 para. 1 (b) DSGVO/GDPR

- For Romania

§ 6 para. 1 f) DSGVO/GDPR.

- For Bulgaria

Art. 88 DSGVO/GDPR.

If, in addition, you grant separate consent, Art. 6 para. 1 a) DSGVO/GDPR forms the legal basis for disclosure of your application. We use an encryption method for the online transmission of your applicant details within this system, so that your information is protected from unauthorised access.

Recipients/Recipient categories: Without separate consent or submission of a concrete application, your profile information remains visible to you only.

The recruiters responsible for the vacant position will only get the authority to view your application data if you create a concrete application via your profile and submit it to us. Only if you give us your respective permission via the system (in the form ticking a box as to who is permitted to view your application), your profile will also be considered for other job vacancies at the Kaufland Group in accordance with your relevant qualifications or interests. Other than that, we will not disclose your application to third parties outside the Kaufland Group.

In principle, your data will not be transferred to any countries outside the EU unless you apply for jobs at Kaufland outside the EU, or you have expressly consented to the inclusion of your profile in the application pool, so that recruiters of all Kaufland countries are able to match your data to vacant positions. In these cases, the legal basis for the transmission of data then is your consent according to Art. 6 para. 1 a) DSGVO/GDPR.

Storage period/Criteria for the determination of the storage period: The data of a concrete application will be anonymised after completion of the application process according to the applicable state law. The anonymisation of the applicant data occurs

- For Germany, Poland, Croatia, the Czech Republic and Slovakia

after 90 days.

- For Romania

90 days after completion of the recruitment and selection process and deletion within one year after this date.

- For Bulgaria

after 180 days.

Your profile in our online application system and the respective data will continue to be stored on the system irrespective of whether or not there is a concrete active application. This gives you the opportunity to apply for other positions at the Kaufland Group online. If your profile has been inactive for a certain period and no application is in progress, your profile will be deleted automatically.

The deletion will occur

- For Germany

after 90 days.

- For Bulgaria

after 180 days.

- For Poland, the Czech Republic, Croatia, Romania and Slovakia

after 12 months.

You may also delete the profile yourself at any time. If there are current applications in progress at that time, these will be withdrawn as your profile is deleted. Thereby, the deletion of the profile occurs instantly while the anonymisation of the personal applicant data is carried out in accordance with the above statutory deletion period.

4. Job agent

After having entered the job title and/or the place of work into the search field according to your interests, you may choose to receive emails with the corresponding vacancies at your chosen frequency through our job agent. The purpose of the data processing as part of the assignment of the Kaufland job agent as an information service is to provide information on job vacancies at the Kaufland Group in order to prepare/facilitate possible applications. The legal basis for the processing of data within the context of the delivery of the job information newsletter is your consent according to Art. 6 para. 1 a) DSGVO/GDPR.

By signing up for the free Kaufland job agent, you consent to us processing your email address and voluntary information regarding your desired job criteria (e. g. area of activity, job type or working hours) in order to inform you of suitable job vacancies via email. Your email address and job criteria will not be disclosed. You can revoke your consent at any time by logging in to your profile and deleting the job agent.

5. Data processing in case of use of the share functions

For data protection reasons, we deliberately decided not to integrate the “share” function of various social networks directly into our online application system as a social plug-in. Therefore, the “share” functions on this page are provided in the form of links only. The link opens a new browser window that links with the respective social network. Consequently, no data is transmitted to social media service providers by simply opening this page. The building of profiles by third parties is thus excluded. However, we do not want to deny website users the opportunity to “share” the job advertisements of our website with their social network. Only by clicking the respective “share” button and logging on to the social media service, a transfer of data to the provider of the selected social network will occur.

Purpose of the data processing/Legal basis: The legal basis for the data processing when using the “share” function is Art. 6 para. 1 lit. f) DSGVO/GDPR. The legitimate interest of the Kaufland Group results from the endeavour to be able to offer this function to the website user as a voluntary option.

Recipients/Recipient categories: The “sharing” of contents of this website results in the fact that certain data can be transmitted to social media service providers, for example:

- Our website address

- Date and time of access to the website or clicking the share button

- Information about the browser and operating system used

- Your current IP address

- The content you shared.

The shared content (job advertisements) may then be viewed by other users of the same social network depending on the privacy settings of your own account. If you are already logged in to the respective social media service at the time of clicking the share button, the respective provider will also be able to determine your user name and maybe even your real name based on the above data. This data may also be processed by the provider in countries outside the EU. We have no control over the scope, nature and purpose of the data processing by the provider. Please note that providers of social media services are quite capable of creating pseudonymised and even individualised user profiles using the above data.

Storage period/Criteria for the determination of the storage period: The period of display of the contents shared by you depends on the privacy settings of your account with the relevant social network as well as their privacy policy. The Kaufland Group has no influence on this.

6. Use of cookies

Our online application system uses so-called “cookies”. Cookies are small text files that are sent from our web server to your device (PC, laptop, smartphone or tablet) when you visit this website and stored by the internet browser used by you. The cookies used may perform various operations. The following subsections provide you with information about individual purposes of various cookies that may be used.

You can set up your browser to notify you before a cookie is saved. This procedure makes the use of cookies transparent to you. Moreover, you can change the settings of your browser so that it principally does not accept cookies, or rejects cookies from certain providers. However, we would like to advise you that this may affect the functionality of our online application system.

6.1 Use of Indeed Conversion Tracking

This website also uses a web analytics tool by Indeed (Indeed Ireland Operations, Ltd., 124 St. Stephen's Green, Dublin 2, Ireland). To analyse the use of the website and Indeed.com (if applicable) certain usage data submitted by your browser will be collected and evaluated by Indeed. Usage data includes the user's click behaviour from accessing a job advertisement to completing the application process by submitting an application. In order to collect usage data, Indeed may use one or several cookies. In addition, the IP address assigned to your device at that time and a browser-specific identifier will be transmitted. The IP address is needed solely for session identification purposes and for the geo-localisation (at city level).

Purpose of the data processing/Legal basis:

The following data is generated when using our online application system:

• Encrypted email address and user ID

• Auto-population of the email address.

This information is required by session cookies in relation with the job search function. The data collected is not used to personally identify the website user. The user data stored by the cookie will also not be linked to any personal data relating to the owner of the pseudonym.

The legal basis of this kind of data processing, data storage and use of cookies is

- For Germany

Art. 6 para. 1 f) DSGVO/GDPR.

- For the Czech Republic

Law No. 127/2005 Slg. on electronic communication.

- For Slovakia

§ 55 no. 5 Law No. 351/2011 on electronic communication

- For Croatia

Art. 6. para. 1 f) DSGVO/GDPR.

- For Poland

Art. 6 par. 1 lit. f) RODO.

- For Romania

Art. 8 of Law 506/2004.

- For Bulgaria

Art. 6 para. 1 f) DSGVO/GDPR.

Storage period/Criteria for the determination of the storage period for cookies: Session cookies are deleted at the end of your internet session (closing the browser).

7. Encryption

We adopt technical and organisational measures to protect your data as comprehensively as possible from undesired access. In addition to securing the operating environment, we use encryption methods. The information provided by you will be transmitted in encrypted form using an SSL protocol (Secure Socket Layer) and authenticated to prevent misuse of the information by third parties. You can recognise this by the fact that the lock symbol in the status bar of your browser is closed and the address line starts with “https”.

8. Your data subject rights

According to Art. 15 para. 1 EU DSGVO/GDPR, you have the right to obtain information about any personal data stored about you by the Kaufland company where you have applied at any time free of charge.

In addition, you have the right to demand the correction of incorrect data stored about you according to Art. 16 DSGVO/GDPR.

Finally, you have the right to request the deletion of data according to Art. 17 DSGVO/GDPR if we are no longer permitted to store the data (e. g. because the data is no longer needed for the recruitment decision or because you revoke a given consent).

Furthermore, you have the right to request a restriction of the processing of personal data pursuant to Art. 18 DSGVO/GDPR.

If the data processing is based on Art. 6 para. 1 e) or f) DSGVO/GDPR, you have the right to object pursuant to Art. 21 DSGVO/GDPR. If you object, the data processing will not take place from that point in time. This does not apply if the person responsible can prove compelling, protection-worthy reasons for the further processing that outweigh the interest in the objection of the data subject.

If you have provided the processed data yourself, you have a right of data transfer according to Art. 20 DSGVO/GDPR.

If the data processing is based on a permission granted pursuant to Art. 6 para. 1 a) or Art. 9 para. 2 a) DSGVO/GDPR, you may withdraw your permission at any time with effect for the future. This does not affect the legality of any previous processing. Please note that a revocation of the consent results in your profile being immediately deleted from our online application system and accordingly, all applications in progress are withdrawn and anonymised.

Please contact the data protection officer in writing or by email in any of the above cases, or if there are open questions or complaints.

Any data subject has the right of appeal to a supervisory authority, without prejudice to any other administrative or judicial remedy, if the data subject considers that the processing of personal data concerning him or her is in contravention of DSGVO/GDPR (Article 77 DSGVO/GDPR). The data subject may exercise this right before a supervisory authority in the member state in which he or she resides or works or in which the suspected breach took place.

9. Contact details of the data protection officer

You can contact the data protection officers of the respective Kaufland companies using the following contact details:

- For Germany

datenschutz@kaufland.de

Postal address:

Kaufland Dienstleistung GmbH & Co. KG

Data Protection Officer Kaufland Service

Rötelstraße 35

74172 Neckarsulm

- For the Czech Republic

email: oou@kaufland.cz

Poštovní adresa:

Kaufland Česká republika v.o.s.

Bělohorská 2428/203169 00 Praha 6

- For Slovakia

Kaufland Slovenská republika v.o.s.

Law and Compliance

Address: Trnavská cesta 41/A, 831 04 Bratislava

Email: dataprotection@kaufland.sk

- For Croatia

Email: gdpr@kaufland.hr

Adresa:

Kaufland Hrvatska k.d.

Službenik za zaštitu podataka

Donje Svetice 14

10 000 Zagreb

- For Poland

Kaufland Polska Markety sp. z o.o. sp. k.

Email: daneosobowe@kaufland.pl

adres:

al. Armii Krajowej 47

50-541 Wrocław

- For Romania

Email: protectiadatelor@kaufland.ro

Adresa poștală:

Kaufland România, Bd. Barbu Văcărescu 120-144, sectorul 2 , București

În atenția departamentului Protecția Datelor

- For Bulgaria

Email: dataprotection@kaufland.bg

Address:

1A Skopje Str

1233, Sofia

 

 

III Moldavia

THE COMPANY WITH LIMITED LIABILITY “KAUFLAND”

SECURITY OF PERSONAL DATA

DIRECTIVE

- Chişinău, 2019 -

SECURITY OF PERSONAL DATA

DIRECTIVE

1. Purpose of the directive

This directive describes the conditions and the way in which personal data of employees and potential employees is processed, as well as the security measures and protective functions determined to ensure data security.

2. Scope

2.1.The directive governs the way in which personal data is collected and processed and the conditions for the use of such information within “KAUFLAND” SRL, a legal entity registered in the Republic of Moldova, located at Chişinău, 29 Sfatul Ţării Street, IDNO 1016600004811 (hereinafter referred to as “Kaufland”, “the data controller” or “the company”).

2.2. This directive applies to the personal data of the company’s employees or potential employees (data collected in paper and/or electronic form) that is processed and stored by the data controller.

2.3. This directive includes the following terms and definitions:

Personal data - any information about an identified or identifiable natural person; an identifiable person is a person that can be identified, directly or indirectly, in particular by reference to a specific identification number or to one or more factors specific to their physical, physiological, psychological, economic, cultural or social identity;

Processing of personal data - any operation or series of operations that are carried out in relation with personal data, automated or not automated, such as collecting, registering, organising, storing, retaining, restoring, adjusting or modifying, extracting, advising, using, disclosing to third parties by transmission, dissemination or otherwise, joining or combining, blocking, deleting or destroying;

Storage - storage of personal data on any type of carrier;

Personal data archiving system - any structured set of personal data that can be accessed using specific criteria, whether that structure is centralised, decentralised or distributed according to functional or geographical criteria;

User - any person acting under the supervision of the data controller or his/her permanent representative with a recognised right of access to the databases containing personal data.

3. Reference documents

3.1.Convention on the protection of individuals regarding the automatic processing of personal data, concluded in Strasbourg on 28 January 1981 and ratified by the Republic of Moldova by Parliament's decision no. 483 of 2 July 1999;

3.2. Constitution of the Republic of Moldova;

3.3. Law no. 133 of 8 July 2011 on the protection of personal data;

3.4. Law no. 71 of 22 March 2007 on registers;

3.5. Law no. 982 of 11 May 2000 on access to information;

3.6. Government resolution of 14 December 2010 regarding the approval of requirements to ensure the security of personal data as part of the processing by personal data information systems

http://lex.justice.md/index.php?action=view&view=doc&lang=1&id=337094

4. Responsibilities

The company is primarily responsible for the development, implementation and monitoring of the application of the provisions of this directive.

5. Description of processing and safety procedures

5.1. Minimum security requirements for personal data

This Kaufland directive on the security of the processing of personal data governs the technical and organisational measures required to safeguard the confidentiality and integrity of personal data collected by Kaufland.

Within the company, the security of the processing of personal data is ensured in strict compliance with the following provisions:

5.1.1. Authorisation of physical access

Access to the premises/offices or facilities where the personal information systems and/or registers are located is restricted and granted only to persons with the necessary authority and only during working hours in accordance with the schedule and corresponding identification documents to prevent unauthorised persons from gaining access.

5.1.2. Administration and supervision of physical access

The data controller ensures the administration and supervision of the physical access at all access points to the information systems and/or registers containing personal data and also responds to any violation of access.

Access of visitors (third parties) is granted according to the provisions of the applicable legislation for the protection of personal data.

5.1.3. Ensuring the protection of personal data

Employees dealing with personal data as part of their professional activities are required to maintain confidentiality and to strictly comply with the provisions of law no. 133/2011 on the protection of personal data.

The provisions of this article shall apply equally to any information collected by the data controller through third parties and made known to employees in the course of their activity.

5.1.4. Processing of personal data

It is not permitted to process personal data without the consent of the data subject except in cases where the processing is required:

• to fulfil a contract to which the data subject is a party or to act upon their request prior to the conclusion of the contract;

• to fulfil the legal obligations of a data controller;

• to protect the life, physical integrity or health of the data subject;

• to fulfil tasks of public interest;

• to comply with a legitimate interest of the data controllers or the third party to whom the personal data is transmitted, provided that such interest does not affect the interests or fundamental rights and the freedom of the data subject;

• for statistical purposes, provided that the personal data remains anonymous throughout the processing; for any purpose other than a legal purpose required to perform the respective task.

If the data subject has not consented to another storage location, further storage or processing after completion of the processing of the personal data, such data will be:

• destroyed; or

• transferred to another data controller, provided that the company guarantees that the subsequent processing pursues similar purposes to the initial processing; or

• converted into anonymous data and stored for statistical or other statutory purposes only.

5.1.5. Amendment of personal data

The personal data of employees or potential employees is collected in order to fulfil the obligations of the data controller under the applicable law, but also to ensure the protection of employees or potential employees and the efficient personnel management, thereby ensuring high-quality services.

All personal data of employees or potential employees are treated strictly confidential. This obligation applies to all employees of the data controller who have a direct or indirect involvement with this data.

5.1.6. User identification and authentication

To gain access to a database containing personal data of the company, users must identify themselves. The identification is accomplished by entering a user account (or “user name”) and the password associated with the user account.

Any user who is given access to the Kaufland databases containing personal data must have their own username and password, which are unique within the company.

Kaufland manages the user accounts (and implicitly the associated passwords) in accordance with this directive.

Manual access of users to databases containing personal data is given in accordance with a schedule approved by the competent person at Kaufland.

The access rights of users to personal data is reviewed on a regular basis (at least every 6 months) as well as after each change of user status to ensure that no unauthorised access has been granted.

Access to the security features of information systems for personal data and to the data stored therein is granted only to the responsible person of the data controller who has been appointed in accordance with the provisions of this directive.

5.1.7. Type of access

Users may only access personal data as required to perform their tasks.

The technical support department is permitted to access personal data in order to resolve exceptional issues with the express prior consent of the responsible person of the data controller, provided that the data subject (whose data is accessed) is informed and the relevant documents are created for each instance of access.

The data controller applies strict procedures for the destruction of personal data.

5.1.8. Collection of personal data

The data controller collects information directly from employees and potential employees (natural persons, data subjects) by way of informing you of the data categories and the purpose of the data processing. Taking into account the specific tasks of the data controller and the scope of his activity, as well as the provisions of the legislation applicable to the area concerned, the data controller processes special personal data, in particular regarding the health status of his employees and potential employees. This requirement is necessary due to the specific activity. Under the legislation regarding public health monitoring, the data controller is required to review the appropriate health status of his or her employees and potential employees on a regular basis once a year, both at the time of recruitment and thereafter. For these reasons, the processing of these data categories is directly related to the scope of activity of Kaufland, as well as the safety of employees and potential employees and their physical integrity.

In accordance with the statutory provisions on the protection of personal data, the data subject is informed of his or her rights regarding the processing of their personal data, in particular:

• the right of access to personal data;

• the right of correction of personal data;

• the right of the data subject to object to the data processing;

• the right not to be the subject of an individual decision;

• access to justice;

• miscellaneous.

The data controller processes the personal data solely for the purpose of complying with the provisions of the applicable law (including, but not limited to, compliance with regulatory requirements, professional standards and internal regulations).

Kaufland appoints authorised users to collect and record personal information in an information system, and any changes to the personal information may only be recorded by the authorised users appointed by the company.

The personal data of employees is subject to the following processing methods: Collection, recording, organisation, storage, retention, restoration, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or otherwise, joining or combining, blocking, erasure or destruction, transmission to competent authorities in accordance with the applicable law, transmission to other companies affiliated with the data controller and other subcontractors and their respective access, including cross-border transmission.

The personal data may be transferred to data subjects in accordance with the applicable law, to the central/local authorities, to social or health services, to legal representatives of data subjects, to other companies associated with the data controller, to contracting partners of the data controller and to other companies which provide sufficient guarantees regarding the protection of personal data.

As the legislation of the Republic of Moldova contains no special provisions on the period of the processing of personal data, the data controller complies with the principles of correct data processing. The data subject is informed about the period of data storage. The data controller stores and processes the employee's personal data for a period of 75 years from the date of data collection.

In accordance with the statutory provisions, the data controller stores the personal data as paper and electronic copies.

In the event that a third party has a business requirement to collect information about the employees of the data controller, the data controller informs the employees or potential employees of the security restrictions and conditions imposed on the third party regarding the processing of their personal data. Kaufland will only disclose information about employees to third parties under the conditions permitted by law and using the legally permissible means.

5.1.9. Preparation of backup copies

At Kaufland, backups of personal data are made on a monthly basis and programs are used for automated processing.

5.1.10. Computers and terminals for access

Computers and other terminals for access are installed in lockable rooms with restricted access.

In addition, the work session closes automatically when the personal data screens don’t show anything for a period of up to 15 (fifteen) minutes.

The terminals used in public areas to access the personal data are positioned so that they are not visible to the public. In addition, if they are not used for a period of up to 5 (five) minutes, the data displayed will automatically fade out.

5.1.11. Access to files

Any access to the database containing personal data is recorded, either in a file for access (for automated processing in a “protocol”) or in a register for manual processing of personal data.

In case of automated processing, all this information is to be stored in a file for general access. Any unauthorised access attempt must also be recorded.

Kaufland keeps the access files for at least 2 (two) years.

5.1.12. Telecommunication systems

Kaufland regularly reviews the authentication and access types to detect malfunctions in the use of telecommunication systems (every 6 months).

The telecommunication system of Kaufland is designed so that no personal data can be intercepted or transmitted by anyone. As an alternative security measure, the user is obliged to transmit the personal data using the encryption method used at the time of transmission.

In addition, the telecommunication system can transmit personal data only when absolutely necessary.

5.1.13. Staff training

As part of the training, Kaufland advises employees of:

(i) the provisions of law no. 133/2011 on the protection of personal data;

(ii) the minimum security requirements for the processing of personal data set out in this directive; such as

(iii) the risks associated with the processing of personal data depending on the type of the activity of the user.

Users who have access to personal data are instructed about their confidentiality obligation by the company and receive warning messages on their screens during their work.

Users are required to end their work session when leaving their workplace.

The staff responsible for the operation of the information systems and/or the personal data registers attend a training course at least once a year on the responsibilities and obligations relating to the management and response to security breaches in relation with the protection of personal data.

5.1.14. Use of computers

In order to ensure the security of the processing of personal data (in particular against computer viruses), Kaufland has taken the following measures:

a) users may not use software originating from external or suspicious sources;

b) users are constantly informed about the danger of computer viruses;

c) the company has implemented a central automated anti-virus and security system for its IT systems and technical measures to detect cyber-attacks, including means of identifying attempts of unauthorised use of information systems or the unauthorised transfer of personal data (phishing);

d) the “print screen” button displayed on the screen has been deliberately deactivated on all workstations (in particular) containing personal data to prevent the intentional or accidental printing of data.

5.1.15. Data printing

The printing of personal data is only carried out by users who have been specifically authorised by the responsible person of the company in accordance with specific internal procedures of Kaufland for the use and destruction of such materials.

Kaufland reserves the right to take additional security measures that form an integral part of this directive if deemed appropriate and depending on the importance of the personal data processed.

5.1.16. Security incidents

Security incidents relating to the systems containing personal data are consistently and automatically monitored and documented.

The person responsible for implementing this directive conducts monthly reviews to ensure compliance with all personal data security regulations. After the checks have been carried out, a report of any deviations/incidents is prepared.

This directive is reviewed at least once a year and authorised at the highest level. In addition, it is brought to the attention of users and employees of the data controller involved in the processing of personal data as well as displayed in a summarised version on the website of the data controllers.

5.2. Contact form/Email contact/Telephone contact

Purpose of the data processing and legal basis:

The personal data that you provide us with when filling out the contact forms by telephone or email will be treated confidentially by us. We use your data only for the purpose of processing your request. The legal basis for this data processing is Article 5 (5) (e) of Law No. 133/2011 on the protection of personal data. Kaufland's legitimate interest lies in the company's intention to respond to requests from visitors to the website, thereby maintaining and increasing their satisfaction.

Beneficiaries/Categories of beneficiaries:

Disclosure of data to third parties that are not part of the Kaufland Group is generally excluded. By way of exception, there is the possibility that the data is processed by processors who have been assigned by us. These are carefully selected, audited and contractually bound according to Article 30 (3) of Law No. 133/2011 on the protection of personal data.

It may also be necessary for us to send parts of your application to other Kaufland companies (for example, the Kaufland company to which your request relates) in order to process your request. If possible, your request will be anonymised prior to being disclosed so that third parties cannot relate the request to you. In some cases it may be necessary to share your personal information in order to process your request.

Storage time/Criteria for the determination of the storage time:

Any personal information you submit to us as part of your enquiries via this website or by email will be deleted or anonymised for purposes and provisions of the applicable law, but in any case no later than 90 days from the date of submission of the final response to you. This process is based on the fact that, after submitting an answer, many visitors to the website contact us again regarding the same topic. For this purpose, we must be able to refer to the previous correspondence. Therefore, your documents will be kept on file for 90 days. There are usually no further questions about our answers after this period. In the event of a dispute, your personal information may be stored for 3 years or until the end of the dispute or until a final and irrevocable decision is made to prove that we have provided you with complete information and that the legal requirements have been met.

5.3. Online application system

Kaufland is constantly on the lookout for qualified and motivated employees. Please note that applications sent to us by email are transmitted un-encrypted. For applications, please only use our online application system. There are two ways of submitting your application via our online application system. You may register and create your own profile with a personal password. In this case, you can view the status of your application, send documents, change the details later, or withdraw your application at any stage. If you submit the application without registration, you will only send the required data for the application, but you do not have direct access to your application once the details are submitted. Upon your request, you may view, edit and manage your profile. This is possible at any time by requesting a password (by clicking on “I forgot my password” and entering your email address at a later time). For both application methods, the same data and information is collected and sent to us.

Purpose of the data processing/Legal basis/Method:

In our online application system, you can create a profile with a personal password or send us your details for authentication. All data and attachments that you save and transmit with the application will be processed by us solely for the purpose of processing the submitted application. The legal basis for this is:

For the Republic of Moldavia

Article 5 (5) (e) of Law No. 133/2011 on the protection of personal data.

If, in addition, you provide your separate consent, the legal basis for forwarding your application is Article 5 (1) of Law No. 133/2011 on the protection of personal data. For the online transmission of your application data via this system, we use an encryption process to protect your information from unauthorised access.

Storage time/Criteria for determining the storage time:

The data of a specific application will be anonymised after completion of the selection procedure in accordance with the purposes and provisions stipulated in the applicable national legislation. The anonymisation of the application data occurs as follows:

For the Republic of Moldavia

after one year

Your profile in our online application system and the respective data stored are kept on the system irrespective of any specific active application. Accordingly, you can apply online for other jobs within the Kaufland Group. If your profile has been inactive for a certain period and no application is in progress, your profile will be deleted automatically.

The deletion occurs as follows:

For the Republic of Moldavia

after one year

You can delete your profile at any time. If at that time there are current applications in progress, these will be withdrawn as your profile is deleted. In this case, the deletion of the profile is effected instantly and the anonymisation of the personal data occurs after expiry of the above-mentioned statutory deletion period.

6. Use of Indeed Conversion Tracking

This website also uses a web analytics tool by Indeed (Indeed Ireland Operations, Ltd., 124 St. Stephen's Green, Dublin 2, Ireland). For the analysis of the use of the website and Indeed.com (if applicable) certain usage data submitted by your browser will be collected and evaluated by Indeed. Usage data includes the user's click behaviour from accessing a job advertisement to completing the application process by submitting an application. In order to collect usage data, Indeed may use one or several cookies. In addition, the IP address assigned to your device at that time and a browser-specific identifier will be transmitted. The IP address is needed solely for session identification purposes and for the geo-localisation (at city level).