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

Recruitment Privacy Statement — Nine Edge Wealth
This privacy statement relates exclusively to personal data collected as part of our online recruitment and application process. It explains how Nine Edge Wealth handles the personal data you provide when you apply to work with us.

Who we are (the controller)
The controller for the purposes of UK data protection law is:

Nine Edge Wealth Limited (please confirm the exact registered name)[Registered office address]Telephone: [phone number]Registered in England and Wales, company number 16823112.
Data Protection contact: [name / job title and contact email] (see note below)

What personal data we collect
Personal data means any information relating to an identified or identifiable individual — for example your name, address, telephone number and date of birth, as well as information about your career history by which you can be identified. Information that cannot be linked, directly or indirectly, to your real identity is not personal data.

If you apply to us electronically — by email or via our online application form — we collect and process your personal data for the purpose of running the recruitment process and, where relevant, preparing an employment contract.

By submitting an application through our recruitment site, you express your interest in working with us and provide personal data that we use and store only for the purpose of your application. In particular, we collect:
  • your name (first and last name);
  • your email address;
  • your telephone number;
  • your LinkedIn profile (optional); and
  • how you heard about us.
You may also choose to upload supporting documents such as a cover letter, CV and references. These may contain further personal data such as your date of birth and address.

Only authorised HR staff and colleagues involved in the relevant recruitment process have access to your data. As a rule, your personal data is stored solely for the purpose of filling the role you have applied for.

Legal basis for processing
We process your application data on the following bases under the UK GDPR:
  • to take steps at your request prior to entering into a contract of employment (Article 6(1)(b));
  • for our legitimate interests in assessing your suitability for the role and managing our recruitment process (Article 6(1)(f)); and
  • where you have given it, your consent — for example, to retain your data in our talent pool (Article 6(1)(a)).
As an FCA-regulated firm, we may also process and retain certain information where necessary to meet our legal and regulatory obligations.

How long we keep your data
If your application is unsuccessful, we will store your data for a period of [number] months after the recruitment process has concluded. We do this to meet legal requirements and to be able to respond to any claims that may arise. After this period, we will delete or anonymise your data. Where data is anonymised, it is retained only as metadata with no direct personal reference, for statistical analysis (for example, the number of applications received in a given period).

We may also retain your data for a further [number] months after the process has concluded so that we can add it to our talent pool and contact you about other vacancies that may interest you. By accepting this privacy statement, you consent to this further storage and to the inclusion of your data in our talent pool. You can withdraw this consent at any time (see "Your rights" below).

If you are offered and accept a position with us, we will retain the personal data collected during the recruitment process for at least the duration of your employment, in line with our employee privacy notice.

Disclosure of data to third parties
Data submitted as part of your application is transferred using TLS encryption and stored in a database operated by Personio SE & Co. KG, which provides our HR and applicant management software (https://www.personio.com/legal-notice/). Personio acts as our processor under Article 28 of the UK GDPR, and the processing is governed by a data processing agreement between us as controller and Personio as processor.

Your rights
If we process your personal data, you have certain rights under the UK GDPR, depending on the legal basis and purpose of the processing. In particular, you have the right of access (Article 15) and the rights to rectification (Article 16), erasure (Article 17), restriction of processing (Article 18) and data portability (Article 20), as well as the right to object (Article 21). Where we process your data on the basis of your consent, you have the right to withdraw that consent at any time under Article 7(3); withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights in relation to data processed during the recruitment process, please contact us using the details above.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority, if you believe we have not handled your personal data in accordance with the law. You can contact the ICO at https://ico.org.uk or by calling 0303 123 1113.

Changes to this statement
We may update this privacy statement from time to time to keep it in line with current legal requirements or to reflect changes to our recruitment or other processes. The updated version will apply to any later visit to our recruitment site or any later application.

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.