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Data Processing Policy for Applicants

  1. About this Privacy Policy

• At Cuculus, we take privacy seriously and comply with all applicable laws and regulations when handling personal information.
• This privacy policy informs you about how Cuculus processes your personal data when you apply for a job we have advertised or send us an unsolicited application.
• It also describes your data protection rights, including the right to object to any part of the processing that Cuculus carries out. For more information about your rights and how you can exercise them, please see the section “Your rights”.

  1. Responsibilty

The responsible party for the processing of personal data within the meaning of Art. 4 (7) GDPR is Cuculus GmbH.

How to contact the data protection officer:

By mail:

Cuculus Ltd.
Data Protection Officer
Anger 63
99084 Erfurt

By emai:

  1. Data Collection

As part of the HR selection process, we collect and process the following categories of personal data, if available:

• Contact details in your candidate profile (e.g. first and last name, address, email, phone number).
• Information from a possible application form (this includes e.g. salary requirements, your motivation, information about a disability (only if relevant for the advertised position).

• Application materials (including, for example, resume, photograph, cover letter, career development data, qualifications, volunteer activities, and language skills),
• Results of possible online selection procedures (e.g., personality tests, cognitive performance tests), video/telephone interviews, and on-site interviews,
• If applicable, references that you provide to us,
• Other personal data that you provide to us as part of the application process.

Should you take a cognitive performance test, we will evaluate the results using relevant reference groups, taking into account your profession and level of experience.

We may also obtain the above data about you from other sources, including external business partners, such as recruitment agencies. We may also receive data that you have made public on job-related social networks, such as LinkedIn and XING, or that you provide to us via third-party websites, such as “Monster Jobbörse”, or from other publicly available sources (only if the data has relevance to your professional life).

  1. Nature and Purposes of the processing of Personal Data

Your personal data will be processed exclusively for the following purposes:
• Initiation and, if successful, establishment of an employment relationship.
• To contact you, should you be considered for an alternative position.
• If you have given us your consent to ask you about your satisfaction with the application process.
• To contact you based on your unsolicited application.
• To send you personalized information about job openings at Cuculus in accordance with the consent you have given.
• Verification of the accuracy of your information from the application documents.
• To contact you via business networks such as LinkedIn and XING.

  1. Legal Basis

We collect and process your personal data in order to offer advertised positions and to carry out the selection process. For certain positions, this may include your participation in an online cognitive performance test or personality test. The legal basis for the cognitive performance test is Section 26 Para. 1 in conjunction with Para. Abs. 8 S. 2 Bundesdatenschutzgesetz (BDSG) and § 22 Abs. 1 b) BDSG. The “BDSG” is German legislation (Federal Data Protection Act ) and applicable to Cuculus, being a German company.

The provision of your personal data as part of the application process is voluntary. However, the provision of personal data is necessary for the processing of your application or the conclusion of an employment contract with us. The legal basis for the personality test is your consent in accordance with § 26 (2) BDSG. Participation in possible personality tests is voluntary.

If we obtain information from your public profile on professional social networks, we base the processing on our legitimate interest in forming a decision-making basis for establishing an employment relationship with you. The legal basis is Art. 6 (1) f) GDPR in conjunction with Art. 9 (2) e) GDPR.

If we invite you to participate in a survey about your satisfaction with the application process at Cuculus, the relevant legal basis is your consent pursuant to Section 26 BDSG in conjunction with Article 7 GDPR. Your potential registration for the Cuculus Job Newsletter, in which you receive personalized information about current job openings at Cuculus, is also based on this legal basis.

Furthermore, we may process personal data about you insofar as this is necessary for the defense of asserted legal claims against us arising from the application process. The legal basis for this is Art. 6 (1) b) and f) GDPR. The legitimate interest is, for example, a duty to provide evidence in proceedings under the German General Equal Treatment Act (“Antidiskriminierungsgesetz” – AGG).

  1. Recipient of the Data

We may transfer your personal data to companies affiliated with us, insofar as this is permissible within the framework of the purposes and legal basis set out above.

Furthermore, personal data may be processed on our behalf on the basis of contracts pursuant to Art. 28 GDPR, this in particular by providers of systems for applicant management and applicant selection procedures. There is no transfer of personal data to third parties if there is no reference to the applicant management and applicant selection process or in addition to the purposes described in the section “Nature and purposes of the processing of personal data”.

The transfers may involve the transfer of personal data to recipients outside the European Union / European Economic Area. Standard contractual clauses have been concluded with these external service providers, unless they are based in countries with an adequacy decision pursuant to Art. 45 of the GDPR.

We reserve the right, in the event of a legal obligation, to disclose information about you if the disclosure is required of us by lawful authorities or law enforcement bodies. The legal basis is Art. 6 (1) c) GDPR.

  1. Your Rights

Right to information
• You have the right to information about the personal data stored about you in our company (Art. 15 GDPR).

Right of rectification or erasure
• If your personal data is not correct, you can have it corrected or completed by us (Art. 16 GDPR).
• You can also request the deletion of your data under certain conditions (Art. 17 GDPR).

Right to restriction of processing
• Under certain circumstances (Art. 18 GDPR), you may request the restriction of the processing of your data, e.g. if the accuracy of your data is disputed and should be verified by us.

Right to data portability
• Under certain conditions (Art. 20 GDPR), your data will be provided to you upon request in a structured, common and machine-readable format.

Right to object to processing
• You can object to the processing of your data on the basis of our legitimate interests (Art 21 GDPR).

To exercise these rights, please contact the data protection officer.

In addition, you have the right to complain to the supervisory authority at any time.

  1. Retention Period

We store your personal data for a period of 6 months after the end of the application process for the position for which you have applied. If you have not applied for an advertised position, this is a speculative application. In this case, we will store your data for 6 months, calculated from the date your application documents are received by the HR department. This is necessary for the burden of proof in proceedings under the German General Equal Treatment Act (“Antidiskriminierungsgesetz” – AGG). Furthermore, we will store your data for this period in the event of the existence of an alternative job advertisement for which you might be suitable. You can request the withdrawal of your application at any time by contacting us at