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

This data privacy statement, which refers exclusively to data collected as part of the online application process, is to inform you about how your personal data that is collected as part of the online application process is handled at our end.

The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Personio on behalf of Avidly ("Controller" “we” “us” etc.). It is important that the persons using the Service ("Users”) feel safe with, and are informed about, how we handle User's personal data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of personal data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy").

The controller

The controller under data protection law is: 
Avidly Oy
Konepajankuja 1
00510 Helsinki
Finland

Phone: +358 10 231 9000

Email: info@avidlyagency.com 

Commercial register entry number: 2018481-2

Registration Court: Finnish Patent and Registration Court

Data Protection Officer: gdpr@avidlyagency.com 

1. General

We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.

2. Collection of personal data

We are responsible for the processing of the personal data that the Users contributes to the Service, or for the personal data that we in other ways collect with regards to the Service.

When and how we collect personal data
We collect personal data about Users from Users when Users;

  • make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and

  • use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and

  • provide identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure.

We collect data from third parties, such as Facebook, LinkedIn and through other public sources. This is referred to as “Sourcing” and can be manually performed by our employees or automatically in the Service.

In some cases, existing employees can make recommendations about potential applicants. Such employees will add personal data about such potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Policy and will be informed about the processing.

The types of personal data collected and processed
The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed. Examples of data we collect are:

  • first and last names

  • address

  • e-mail address

  • phone number 

  • LinkedIn profile

Purpose and lawfulness of processing
The purpose of the collecting and processing of personal data is to manage recruiting. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment and for the purpose of executing the application process and preparing contracts.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.

The consent of the data subject
The User consents to the processing of its personal data with the purpose of the Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;

  • make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and

  • when they use the Service to connect to the Controller's recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

The User also consents to the Controller collecting publicly available information about the User and compiles them for use in recruitment purposes.

The User consents to the personal data being collected in accordance with the above a) and b) will be processed according to the below sections: Storage and transfer and How long the personal data will be processed.

The User has the right to withdraw his or her consent at any time, by contacting the Controller using the contact details listed under 10. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

Storage and transfers

The personal data collected through the Service is stored and processed inside the EU/EEA, or such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully complies with the lawfulness of third country transfers or to other suppliers where adequate safeguards are in place to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such adequate safeguards, contact us using the Contact details listed in 10.

How long the personal data will be processed

If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. Furthermore, we reserve the right to store your data for 365 days after the application process has been concluded for the purpose of adding it to our Talent Pool in order to identify any other vacancies that may be of interest to you. This includes, for example, applications for apprenticeships or internships. By accepting the data privacy statement, you consent to any further storage of your data as well as its inclusion in our Talent Pool.

Should you be offered and accept a position with us during the application process, we will store the personal data collected as part of the application process for at least the duration of your employment. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in 10.

Use of automated decision making

We are using the Personio system to receive your applications and streamline our recruitment process. The system allows us to see suggestions and recommendations for the best candidates suitable for the position, however, we do not make decisions based solely on such automated processing. We ensure that all recruitment materials are being reviewed by the individual responsible for the hiring process.

3. Users’ rights

If we, as the Controller, process your 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. These rights include:

  • Right of access (article 15 of the GDPR): The right to request information about the personal data that is processed by us. You have the right to one (1) copy of the processed personal data which belongs to you without any charge. For further demanded copies, the Controller has a right to charge a reasonable fee on the basis of the administrative costs for such demand;

  • Right to rectification (article 16 of the GDPR): The right to, if necessary, rectification of inaccurate personal data concerning you, via a written request;

  • Right to erasure (article 17 of the GDPR): The right to demand deletion of your personal data under certain circumstances;

  • Right to restriction of processing (article 18 of the GDPR): The right to demand restriction of processing under certain circumstances;

  • Right to data portability (article 20 of the GDPR): Under certain circumstances, the right to get the personal data and transfer these to another Controller as long as this does not negatively affect the rights and freedoms of others;

  • Right to object (article 21 of the GDPR): The right to object to processing based on legitimate interest under certain circumstances;

  • Right to withdraw consent (article 7 III of the GDPR): If the personal data is processed with your consent, you have the right to withdraw this consent at any time. Using this right may, however, mean that you cannot apply for a specific job or otherwise use the Service.

To assert your rights as a data subject in relation to the data processed during this online application process, please contact our Data Protection Officer (see 10).

You also have the right to lodge a complaint to the supervisory authority regarding the processing of personal data relating to you, if you consider that the processing of personal data infringes the legal framework of privacy law.

4. Security

We prioritise personal integrity and therefore work actively so that the personal data of the Users are processed with utmost care. We take the measures that can be reasonably expected to make sure that the personal data of Users and others are processed safely and in accordance with this Privacy Policy and the GDPR-regulation.

However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret.

5. Transfer of personal data to third party

We do not sell your personal data to third parties. However, we use Personio GmbH to operate our recruitment database. Personio acts as our data processor, handling your data on our behalf and under our instructions, in compliance with GDPR.

Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. This database is operated by Personio GmbH, which offers a human resource and applicant management software solution (https://www.personio.com/legal-notice/). In this context, Personio is our processor under article 28 of the GDPR. In this case, the processing is based on an agreement for the processing of orders between us as the Controller and Personio.

6. Aggregated data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.

7. Cookies

When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling cookies can affect the experience of the Service, for example disabling some functions in the Service.

8. Changes

We have the right to, at any time, make changes or additions to the Privacy Policy. The policy is reviewed and updated regularly. The latest version of the Privacy Policy will always be available through the Service. A new version is considered communicated to the Users when the User has either received an email informing the User of the new version (using the e-mail stated by the User in connection to the use of the Service) or when the User is otherwise informed of the new Privacy Policy.

This Policy had been reviewed and updated in April 2025.

9. Concluding provisions

We reserve 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 application process or other processes. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application. 

In addition to this data privacy statement, please view our general data privacy statement at https://www.avidlyagency.com/privacy-statement 

10. Contact

For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details.

Avidly’s HR Director: benjamin.veltman@avidlyagency.com or

Avidly’s Data Protection Officer: gdpr@avidlyagency.com

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.