SPRYKER APPLICANT PRIVACY NOTICE
(last update: January 2025)1. Scope of Application
The protection of Personal Data1 is very important to Spryker. This Notice describes how Spryker is handling Personal Data of Applicants as Data Subjects2. “Applicants” refers to everyone applying for a job at Spryker.
2. Data Controller
Personal Data is being processed by Spryker as the Controller1, which can be reached via email at legal@spryker.com. Spryker can refer to either of the following companies, depending on which entity the Applicant is talking to regarding potential employment:
- Spryker Systems GmbH, Heidestraße 9-10, 10557 Berlin, Germany
- Spryker Systems Ltd., 63/66 Hatton Garden, Fifth Floor, Suite 23, London EC1N 8LE, UNITED KINGDOM
- Spryker Systems America Inc., 80 Pine Street, Floor 24, New York, NY 10005, USA
- Spryker Systems Australia Pty. Ltd. Level 6, 8 Spring Street, SYDNEY, NSW, 2000, Australia
3. Data Protection Officer
Spryker has appointed MARAIT Rechtsanwaltsgesellschaft mbH as its external DPO, with postal address at Neuer Wall 75, 20354 Hamburg, Germany. The DPO can be reached at mail@marait.de.
Please contact Spryker’s internal Privacy Team at any time with any questions or suggestions regarding data protection at dataprotection@spryker.com.
4. Processing Activities, Purpose and Legal Basis
Spryker carries out the following processing activities based on Art. 6 (1) (b) GDPR1 or the respective specific local provision, e.g. in Germany § 26 BDSG2 (i.e. as necessary in order to take steps at the request of the Applicant prior to entering into a contract)
By submitting an application via Spryker’s recruitment website, via third-party recruitment pages, or via headhunters or agencies, the Applicant expresses interest in working with Spryker. In this context, the Applicant may transmit the Personal Data listed in the right column of this row, which Spryker will use and store exclusively for the purpose of the application process, to assess the application and to communicate with the Applicant within the application process. Spryker may ask the Applicant to provide additional Personal Data where necessary for the hiring process.
- Full name
- Address
- Phone/mobile number
- Email address
- Possible start day
- Desired salary
- Application photo
- Date of birth
- Birthplace
- Nationality and/or citizenship and/or immigration information (e.g. passport details, driver’s license information, government identification number, citizenship or immigration status)
- Gender
- Information about schooling, studies, vocational training, and further education
- Language skills
- IT knowledge
- Other qualifications and motivations
- Information about the Applicant’s career
- Application documents, such as cover letters, references, and CV
- LinkedIn profile etc.
- Other information contained in interview notes, as provided by the Applicant
Spryker processes an Applicant’s Personal Data to assess potential employment, e.g. by way of email communication with the Applicant, online or offline job interviews. The interviewers will fill in scorecards to enable the best decision on the right candidate. For that purpose, Spryker processes the Personal Data listed in the right column of this row.
- Content of email communication
- Content and findings from online or offline job interviews
- Image of the Applicant (e.g. in online interview)
- Scorecard findings
- Impression of Applicant
To the extent necessary and permitted under local law, Spryker may carry out background checks. For that purpose, Spryker processes the Personal Data listed in the right column of this row.
- Photographs and/or biometric data (the latter only where required for security purposes).
Spryker drafts and negotiates employment contracts with Applicants. If Spryker intends to make an offer to an Applicant, Spryker asks the Applicant to provide certain information and processes the Personal Data listed in the right column of this row for the purpose of creating employment contracts.
- Full name
- Nationality
- Personal email address
- Address
- Phone number
- Planned time off during probation period
- Passport and, if applicable, Visa information
- Information on work permit, if required
- Copy of passport and work visa, if required
- Job title
- Salary
- Bonus entitlement, as applicable
- Start date
- Bank account details
In case of consent to use an AI notetaker in job interviews, Spryker uses such notes taken by the AI notetaker instead of taking manual notes. For that purpose, Spryker processes the Personal Data listed in the right column of this row.
- Full name
- Personal email address
- Transcript of online interview
Spryker can also obtain information from professional social networks, such as LinkedIn, job boards, and from other publicly accessible sources (only information relevant to the Applicant’s professional life) for the purposes of actively approaching someone with job offers or for the purpose of confirming the accuracy of the information presented within the course of an application.
- Full name
- Work history
- Current employment
5. Special Categories of Personal Data
To the extent that special categories of Personal Data are processed in accordance with Art. 9(1) GDPR, this serves to exercise rights or to fulfill rights or legal obligations arising from labor law, social security law and social protection (e.g. disclosure of health data to the health insurance company, recording of a serious disability for determining the severe disability levy). This is based on Art. 9(b) GDPR and Section 26 (3) BDSG.
In addition, the processing of health data may be necessary for the assessment of an Applicant’s ability to work in accordance with Art. 9(2) GDPR and Section 22(b) BDSG or other comparable national regulations. In addition, the processing of special categories of Personal Data may be based on consent under Article 9(2)(a) GDPR and Section 26(2) BDSG (e.g., occupational health management).
Furthermore, Spryker may process Personal Data about an Applicant where this is necessary to defend Spryker against legal claims arising from the application process against Spryker. The legal basis for this is Art. 6(1)(b) and (f) GDPR; the legitimate interest is, for example, a burden of proof in proceedings under the German General Equal Treatment Act (“AGG”).
An Applicant is under no obligation to provide Spryker with information that, under the AGG”. Such data (like race, ethnic origin, gender, religion or beliefs, disability, age, or sexual identity) in general cannot be used. The same applies to application photos, illnesses, pregnancy, ethnic origin, political beliefs, philosophical or religious beliefs, union membership, physical or mental health, or sex life.
7. Data Retention
Spryker deletes Personal Data as soon as it is no longer necessary for the above-mentioned purposes and there are no legal documentation or record keeping requirements or retention periods to be met. If Spryker cannot offer the Applicant an employment for the discussed job vacancy, Spryker will keep such Applicant’s Personal Data for 180 days for the purpose of being able to answer questions related to the application and/or rejection.
Furthermore, in case of Applicant’s consent, Spryker will store the Applicant’s Personal Data for 180 further days thereafter (with the option of extending that period upon further consent) for the purpose of adding it to the Spryker Talent Pool in order to identify any other vacancies that may be of interest to an Applicant.
8. Recipients
Spryker may use data processors for the described purposes and share the Applicants’ Personal Data with them (e.g. in connection with the use of an AI notetaker in job interviews, Application management, or interview scheduling). Such sharing of Personal Data always is covered by a data processing agreement between Spryker and the data processor.
Spryker may also share the Personal Data with its other entities to the extent to administer the application for employment. Such transfer is covered by intra-group data protection agreements.
Spryker may also share the Personal Data with third parties where necessary, e.g. where required to seek legal advice externally or they act as data processors on Spryker’s behalf. E.g. Personal Data will be shared with Greenhouse Software, Inc., a cloud services provider located in the United States of America to help manage the recruitment and hiring process on Spryker’s behalf. Accordingly, if an Applicant is located outside of the United States, the Personal Data will be transferred to the United States once submitted through this site. Applicant’s Personal Data is stored on European servers.
To the extent Spryker forwards Personal Data to countries outside the European Economic Area, Spryker will take the necessary steps to ensure that an appropriate level of data protection is maintained according to Article 44 et seq. GDPR.
9. Data Subjects’ Rights
An Applicant has the right
- to obtain information about the Personal Data processed by Spryker at any time ( Art. 15 GDPR)
- to rectification of incorrect or completion of incomplete Personal Data ( Art. 16 GDPR)
- to deletion of Personal Data ( Art. 17 GDPR)
- to restriction of the processing of Personal Data ( Art. 18 GDPR)
- to data portability ( Art. 20 GDPR)
- to withdraw consent (Art. 7 GDPR)
- to lodge a complaint with a supervisory authority (as set out in Art. 77 GDPR).
The Data Subjects also have the right to object to the processing of their Personal Data, which is based on Art. 6 lit.1 para. e or f GDPR (including profiling based on those provisions), at any time, on grounds relating to their particular situation.
About Spryker
Spryker is the leading global composable commerce platform for enterprises with sophisticated business models to enable growth, innovation, and differentiation. Designed specifically for sophisticated transactional businesses, Spryker’s easy-to-use, headless, API-first model offers a best-of-breed approach that provides businesses the flexibility to adapt, scale, and quickly go to market while facilitating faster time-to-value throughout their digital transformation journey. As a global platform leader for B2B and B2C Enterprise Marketplaces, IoT Commerce, and Unified Commerce, Spryker has empowered 150+ global enterprise customers worldwide and is trusted by brands such as ALDI, Siemens, ZF Friedrichshafen, and Ricoh. Spryker is a privately held technology company headquartered in Berlin and New York backed by world class investors such as TCV, One Peak, Project A, Cherry Ventures, and Maverick Capital. Learn more at spryker.com.