DATA PROTECTION NOTICE

1. General provisions

This data protection notice refers exclusively to the data collected as part of the online job application process and includes information on the processing of the candidate's personal data collected during that process.

2. Data Controller

The data controller for data protection purposes is:
Tangelo Games Spain, S.L.U.
NIF: B65596744
Address: Calle Amigo, 11, 08021, Barcelona
Data Protection Officer: dpd@tangelogames.com

3. Processing of personal data in the job application process

Personal data is information about the personal or material circumstances of an identified or identifiable natural person, such as name, address, telephone number and date of birth, but also information about their education, etc., which can be attributed to a specific person with reasonable effort. Any information that cannot be used to determine a person's identity, directly or indirectly, does not constitute personal data.

4. Principles and purposes of the processing of personal data in connection with the receipt of applications and the job application process

When submitting an application electronically, i.e. by email or through our online form, the candidate's personal data is collected and processed for the purpose of managing and handling the selection process and applying the relevant pre-contractual measures (art. 6(1)(b) GDPR).

By submitting an application through our recruitment page, the candidate explicitly indicates their interest in working with us. The personal data you provide in this context will be used and retained solely for the purposes of the job search and application.

Where the data does not come directly from the candidate -for example, through a referral by an employee under our referral programme, or through recruitment agencies or headhunters- we will inform them of the source of their data at the first contact we have with them and, in any case, within a maximum period of one month from obtaining it, in accordance with Article 14 GDPR. In these cases, the legal basis for the processing is our legitimate interest in evaluating the referred or submitted profile (art. 6(1)(f) GDPR). You may object to this processing at any time, on the grounds and with the effects provided for in Article 21(1) GDPR.

In particular, we will collect the following data:

• Full name
• Email address
• Phone number
• LinkedIn profile (optional)

Data marked as mandatory on the form is necessary to manage the application; failure to provide it prevents the process from continuing. The remaining data is optional and its absence does not affect the application.
In the course of the selection process, the candidate may also attach relevant documents, such as a cover letter, their CV and qualifications, which may also contain personal data such as date of birth, address, etc.

We ask that you do not include in your CV or in any attached document any data relating to your health, disability, trade union membership, religion or sexual orientation, unless strictly necessary to request reasonable accommodations or to demonstrate your inclusion in the reserved quota for persons with disabilities (art. 42 of Royal Legislative Decree 1/2013), in which case the processing will be based on art. 9(2)(b) GDPR.
Only authorised employees of the HR department or employees involved in the selection process will have access to your data.

We do not adopt automated decisions or carry out automated screening or scoring of applications within the meaning of Article 22 GDPR: evaluation is always carried out by individuals. Certain tools may automatically extract the information contained in the CV to facilitate its reading and its incorporation into the application file, without this in itself determining any decision regarding your application.
Personal data is stored exclusively for the purpose of filling the vacancy for which the application was submitted.

Once the selection process has concluded, your data will cease to be used and will remain blocked for a period of three (3) years, available exclusively to judges and courts, the Public Prosecutor's Office or the competent Public Administrations, for the purpose of addressing any liabilities arising from the selection process and during the limitation period thereof, in accordance with Article 32 of Organic Law 3/2018, of 5 December, and Article 4(1) of Royal Legislative Decree 5/2000, of 4 August. The legal basis for this retention is compliance with legal obligations and our legitimate interest in defending against potential claims (articles 6(1)(c) and 6(1)(f) GDPR). Once this period has elapsed, your data will be irreversibly deleted or anonymised, so that only aggregated information without personal reference will be retained for statistical purposes (for example, the number of applications received per period or the gender distribution of candidates).

If you give your express consent, we will keep your data in our talent pool for twelve (12) months after the selection process has concluded, in order to identify any other position that may be of interest to you. This also applies, for example, to applications for training or internship positions. This consent is independent and does not condition your current application, and you may withdraw it at any time. The legal basis for this processing is your consent (article 6(1)(a) GDPR).
If, in the course of the selection process, the candidate receives and accepts a job offer, the personal data collected during the selection process will be kept, at a minimum, for as long as the employment relationship lasts.

5. Disclosure of data to third parties

The data provided as part of the application is transmitted using TLS encryption and stored in a database. This database is operated by Personio SE & Co. KG, which provides candidate and human resources management software (https://www.personio.es/legal-notice/). In this context, Personio acts as our data processor under the contract entered into in accordance with Article 28 GDPR.
Personio uses sub-processors for the provision of certain ancillary services (cloud hosting, authentication and communications, among others), all of them subject to the safeguards of Article 28 GDPR. You may request the updated details of these sub-processors by contacting dpd@tangelogames.com.
International transfers: Personio SE & Co. KG may transfer personal data to its subsidiary in the United States, Personio, although all customer data resides in the European Union. This transfer is based on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework (Commission Implementing Decision (EU) 2023/1795), as Personio is certified under that Framework, in accordance with Article 45(1) GDPR.
Except as indicated above, we will not disclose your data to third parties unless legally required to do so.

6. Data subject rights

To the extent that we, as the controller, process personal data, the candidate has certain rights as a data subject under Chapter III GDPR, depending on the legal basis and purposes of the processing concerned, namely: the right of access (Article 15 GDPR), the right to rectification (Article 16 GDPR), the right to erasure (Article 17 GDPR), the right to restriction of processing (Article 18 GDPR), the right to data portability (Article 20 GDPR) and the right to object (Article 21 GDPR). Where the processing of personal data is based on your consent, under Article 7(3) GDPR, the candidate has the right to withdraw that consent at any time.
To exercise the rights available to you as a data subject in connection with the processing of data during the online job application process, please contact our Data Protection Officer (see point 2).
You also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you believe that the processing of your data does not comply with applicable regulations.

7. Final provisions

We reserve the right to modify this data protection notice at any time in order to comply with applicable legal requirements or to reflect changes made to the job application procedure or other similar processes.
Substantial changes will be communicated to you expressly before they take effect and, where they affect processing based on your consent (such as inclusion in the talent pool), we will collect your consent again before applying them.

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.