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Privacy Policy

–  Data processing in the context of our application/ recruitment process –

We take the protection of your personal data seriously and we would like to inform you about the processing of your personal data according to Art. 13, 14 of the General Data Protection Regulation (hereinafter: GDPR).

According to Art. 15 of the GDPR, you have the right to know whether we process personal data about you. If this is the case, you have the right to receive further information about it. With this Privacy Policy, we want to give you  an overview of what personal data is collected, stored, processed and, if necessary, passed on by us. 

This Privacy Policy describes our practices with respect to Personal Data collected in the context of the recruiting activities of UP42 GmbH. This Privacy Policy further provides information on your rights under applicable data protection laws. 

For the purposes of this Privacy Policy, “Personal Data” means any data or information which relates to an individual who may be identified from that data or information, or from a combination of a set of information. Similarly, “Processing” refers to any operation performed on personal data, such as collection, storage, use, disclosure, deletion. 

This Privacy Policy does not apply if you are only a visitor of our corporate website. 

1. Name and contact details of the controller 

Controller of the data processing is:

UP42 GmbH

Ohlauer Str.43, 10999 Berlin

You can contact our data protection team by email to

2. Contact details of the data protection officer

The contact details of the data protection officer are:

ISiCO Datenschutz GmbH

Am Hamburger Bahnhof 4, 10557 Berlin

3. What type of personal data do we process and how do we use it? 

3.1 Information you actively provide to us when you apply for a job (“Application Data”):

We collect and process personal data about you to manage your application and evaluate it against our open positions (Art. 6 (1) (b) GDPR). This includes using your data to communicate with you.

Those Application Data might be your full name, email address, phone number, picture, CV, cover letter, résumé statuses, notes, planning related to your job application, certificates, LinkedIn profile, Indeed profile, email communication, which job you have applied for and further information which you provided with your application.

The Application Data you provide is made available to the recruitment team handling the position you applied for. We may also share your application with other UP42 functional areas that match your candidate profile (Art. 6 (1) (f) GDPR).

If you provide us with sensitive information, we will need your consent to process this information (Art. 9 (2) (a) GDPR). We strongly advise against including sensitive information (e.g. ethnic origin, political opinions, religious or philosophical beliefs) in your application. Providing such data may prevent UP42 from processing your application, as UP42 does not require sensitive personal information for job application processing.

We may also use your personal data for our legitimate business interests (Art. 6 (1) (f) GDPR), such as conducting satisfaction surveys related to the recruitment process to improve or modify our services and operations.

In certain cases, we may be legally required to process your data or use it to help establish or defend against legal claims.

Your application will be automatically deleted 215 days (approx. 7 months) after the date of your  application. We do not delete the documents immediately upon notification of rejection because we have a legitimate interest in keeping the documents due to legal deadlines. The legal basis is Article 6(1) of the GDPR.

You can request us to delete your data at any time by emailing Please note that this will withdraw you from any ongoing application processes and the legal retention period still applies.

3.2 Information collected during technical assessments in the course of the application process (“Assessment Data")

Regarding our recruitment of programmers and technical engineers, please be aware that we may conduct certain online coding skill tests to assess your suitability for employment with UP42 by asking you to solve a programming problem. These assessments might include live-coding sessions. The tests will be conducted through an online assessment platform operated by one of our third-party providers.

To invite you to participate in these online assessments, we will send you a direct link once you have applied for a position with UP42. You will be informed about the identity of our service provider before you begin the assessment.

We will process Assessment Data solely to assist our recruiters in determining your potential success in the role for which you have applied and to evaluate and assess the results of your test. We will not use the assessment results for any automated decision-making.

Our legal basis for processing your Assessment Data is the legal provisions in your jurisdiction that permit data processing for the purpose of performance of a contract or to take steps at your request prior to entering such a contract (e.g., processing your employment application) under Art. 6(1)(b) GDPR.

Your Assessment Data will be automatically deleted 215 days (approx. 7 months) after the date of your  application.  

3.3 Information gathered from third parties (“Third-Party Candidate Data”)

To offer you a position with our company, we may process Personal Data collected from third parties rather than directly from you. 

If this occurs, we will notify you without undue delay after adding your data to our systems, for instance, by email (unless you have already received such a notification from the third party who provided the data to us). 

Your Personal Data may be obtained from publicly available sources (e.g., career networks such as LinkedIn, Glassdoor, Indeed, or others; we do not collect data from social media) or provided to us by someone who referred you for potential employment, such as a UP42 employee, a recruitment agency, or a headhunter.

In some cases, if verification is required, we will initiate a limited verification process for the documentation and references you have provided by cross-checking your information with former employers or educational institutions. If we conduct such checks, we will notify you separately in writing prior to starting the assessment.

Your Personal Data will be processed solely for managing our recruitment-related activities, which include setting up and conducting interviews and tests for candidates, evaluating and assessing the results, and other necessary steps in the recruitment and hiring processes. 

Such processing is legally permissible under Art. 6(1)(f) GDPR and Section 26 (1) BDSG, as it is necessary for the legitimate interests pursued by UP42, which include soliciting, evaluating, and selecting candidates for employment.

Those Data will be integrated into your Candidate profile and will be automatically deleted 215 days (approx. 7 months) after the date of your application. 

3.4 Creation of a Talent Pool

To facilitate future recruitment opportunities, we may process and retain your Personal Data in a talent pool after the initial application process. If you consent to this, we will notify you without undue delay after adding your data to our talent pool, typically via email.

Your inclusion in the talent pool allows us to consider you for positions that may become available in the future. The data retained will be sourced from your application materials, such as your resume, cover letter, and any assessments you completed during the application process.

We will process your Personal Data solely for managing our future recruitment-related activities. This includes identifying potential candidates for open positions, setting up and conducting future interviews and tests, evaluating and assessing the results, and any other necessary steps in the recruitment and hiring processes. Such processing is legally permissible under Art. 6(1)(a) GDPR, based on your consent, and Art. 6(1)(f) GDPR, as it is necessary for the legitimate interests pursued by UP42, which include maintaining a pool of qualified candidates for future employment opportunities.

Your data will be retained in our talent pool for a period not exceeding 360 days, after which it will be deleted unless you renew your consent. You can withdraw your consent at any time by contacting us at, which will result in your data being removed from our talent pool.

4. What happens to your data if you are hired by UP42? 

If an employment relationship arises between you and us, we may, in accordance with Art. 88 GDPR in  conjunction with § 26 BDSG, further processes the personal data already received from you for the purposes of the employment relationship, insofar as this is necessary for the performance or termination of the employment  relationship.

5. Who are the recipients / processors of your Personal data?

As a matter of principle, only the data necessary to fulfill the purpose of the company and the contractual agreements will be passed on. Your personal data will be treated confidentially. 

Internally, employees of UP42 and its affiliates who are involved in human resources management (recruiters, managers, etc.) may access it within the scope of their respective responsibilities.

As part of the recruitment process, you may be asked to take part in interviews via video conference (e.g. Google Meet etc.).

As subprocessors,

  • for our application management, talent pool management, contact management with candidates, interview scheduling, we use the services of Recruitee B.V , Keizersgracht 313, 1016 EE Amsterdam, The Netherlands ( 

For any transfers of your personal data from the EEA to countries that are not considered as providing an adequate level of protection by the European Commission we have put in place adequate measures such as Standard Contractual Clauses adopted by the European Commission to protect your personal data. You may obtain the copy of these measures by contacting us via the contact information provided below.

6. Your rights in the context of data processing 

In particular, you have the following rights on the condition that the requirements are met:

  • Right of access (Art. 15 GDPR); right to obtain from us confirmation as to whether or not personal data concerning you has been processed, and, where that is the case about which data.

  • Right to rectification of your data (Art. 16 GDPR); 

  • Right to erasure (Art. 17 GDPR); 

  • Right to restriction of the processing of your data (Art. 18 GDPR);

  • Right to data portability (Art. 20 GDPR);

In the case of data processing based on Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest), you have the right to object at any time under the conditions of Art. 21 GDPR.

In the case of data processing based on your consent, you can withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You also have the right to lodge a complaint with a supervisory authority. The data protection authority responsible for us is “Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, email:

We take your rights as a data subject seriously. 

Therefore, please do not hesitate to :

  • Use all Recruitee features to assert your rights;

  • Contact us at the following e-mail address Alternatively, you can also assert your rights by post or telephone.

7. Changes to this Policy

We may update this Privacy Policy from time to time to reflect our new processes, new technologies, and legal obligations. We are committed to keeping you informed of any changes to our privacy practices, so we encourage you to review this Privacy Policy to keep updated.

Last modified: July, 2024