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

1. Responsible Data Controller

  • The responsible data controller for the “magicplan” App, Cloud, and Website, is Technologies magicplan Inc., 1275 Avenue des Canadiens-de-Montréal, 5th Floor, Montreal, QC H3B 0G4, Canada („magicplan“).
  • enapt GmbH, Goethestr. 25A, 80336 Munich, Germany („enapt“) is the German parent company of Technologies magicplan, Inc.
  • magicplan and its affiliated parent company enapt are jointly responsible data processors. In this respect, the companies have defined in an agreement which of them fulfills which data protection obligation. The essential content of this agreement is available to you from magicplan or enapt on request.

  • magicplan is committed to protecting your personal data in accordance with applicable data protection and privacy regulations, including the EU General Data Protection Regulation (GDPR). In this context, magicplan’s internal Compliance Team acts as the company’s Data Protection Officer (DPO).

    You can contact our compliance team regarding any data protection or privacy-related matters at: security@magicplan.app.

    Our compliance team is responsible for:

    • Monitoring ongoing compliance with data protection laws and internal policies

    • Responding to data subject rights requests (access, rectification, erasure, etc.)

    • Cooperating with supervisory authorities

    • Advising the organization on its obligations under applicable data protection laws

2. Privacy Policy & GDPR 

3. Technical & Organizational Measures

The measures outlined in this section reflect our adherence to internationally recognized security standards, including SOC 2 and ISO/IEC 27001, and are designed to meet the data protection principles and requirements set forth by the General Data Protection Regulation (GDPR).

3.1 Access Control

  • All entrances to the building are secured with locks. Employees get access with a registered key.
  • Service providers and freelancers also get access to the building with a registered key.
  • Keys are issued only to authorized persons. It is documented which persons have access to the building. If an employee or other authorized person leaves, the key is returned and documented.
  • Visitors have to ring the bell and are picked up by an employee at the door. Strangers do not stay in the office unaccompanied.
  • All windows in the office are lockable from the inside.
  • Servers are not owned by Enapt GmbH or Technologies magicplan Inc., magicplan is hosted by Amazon Web Services. The technical and organizational measures of the contractors apply. For more information see section 3.10.

3.2 Information Security

  • HR documents are housed in a lockable cabinet. Only staff responsible for human resources management have access to it.
  • Only authorized persons have access to digital documents.
  • Hardware is locked away when not in use for a long time
  • Paper files are locked away when not in use for a long time.
  • The stock of hardware is documented and recorded digitally. The issue and return of hardware to employees are digitally documented.
  • Different levels of access are regulated so that each employee only receives the privileges in the IT system, which they also need for their activities.
  • An authorization concept applies.
  • Each employee has an individual user account with their own password.
  • There is a password policy. Depending on the application, the complexity and length of the password is technically forced.
  • Depending on the application, changing the password is technically enforced and user access is blocked after multiple incorrect entries.
  • Multi-factor authentication (MFA) or single sign-on (SSO) is enforced wherever supported for user access.
  • There is a time-controlled automatic screen lock of the PCs/laptops.
  • Employees are instructed to lock their screens when leaving the workplace.
  • The WLAN is encrypted with WPA 2.
  • The number of system administrators is limited to the bare minimum.
  • There is a clean desk policy.

3.3 Entry Control

  • Logging of the activities of the IT system itself for all security-related aspects at the operating system level.
  • Logging of the activities of IT administrator activities at the level of individual computers.
  • Installation of new software only from the Apple App Store or certified developers. Software can only be ordered via a central office and is purchased and purchased through secure providers.
  • Exclusive use of mobile data carriers left by the company and purchase centrally by the IT department. Purely internal use.

3.4 Job Control

  • Order processing contracts are concluded according to Art. 28 GDPR.
  • Clear design of the order processing contracts.
  • Control of technical and organizational measures of contractors.
  • Return or deletion of data after completion of the contract ensured by contractual arrangements.

3.5 Separation Control

  • Separation of data concerning different customers/clients by multi-client capable system at the application level.
  • Separation of data that is processed for different purposes, through multi-client-enabled system at the application level or through the use of different applications with different data storage.
  • There is a deletion concept.

3.6 Relay Control

  • WLAN backup according to the WPA2 standard.
  • Private Wi-Fi available.
  • SSL data encryption when transferring data electronically.
  • The e-mail communication is provided with a transport encryption. Sensitive data is transmitted in encrypted ZIP folders.
  • Disposal of unneeded paper files with a shredder.
  • Disposal of data CDs / DVDs with a shredder.

3.7 Availability and Resilience (Article 32 (1) (b) GDPR)

  • Relevant data is available as cloud backup and is redundantly mirrored by authorized persons.
  • Fire extinguishers, surge protection, smoke detectors on-site.
  • There is an emergency plan for the failure of the IT infrastructure.
  • There is an emergency plan for data breaches.
  • There are clear reporting channels for emergencies (both IT emergencies and data breaches).
  • Notification of IT administrators in case of disruptions of the IT system.

3.8 Organizational Control

  • All employees are obliged to confidentiality.
  • All employees have completed training on data protection.
  • There is a privacy policy and a data management policy.
  • A procedure for risk assessment and risk management has been established and documented.
  • There is a guideline for working in the home office.  
  • There is a guideline for the use of company internet access and the company e-mail account.

3.9 Effectiveness Checks

  • Regular checks on the effectiveness of the technical and organizational measures.
  • Regular monitoring whether and to what extent existing measures still comply with requirements and corporate development. In addition, authorizations, used hardware, etc. are checked and adjusted on a case-by-case basis (eg staff change).
  • After reports by partners/service providers, event-related analyses of the present protocols are carried out.
  • The maintenance of the internal systems is the responsibility of a trained IT specialist (internal employee) for system integration.
  • Unusual events and alerts are reported to management and appropriate action is taken.
  • Audit by external service providers, every two years.
  • Penetration tests are carried out based on the application.

3.10 Hosting, Data Center Location and Infrastructure

3.11 Application Security and Assurance

  • Access to live databases is handed to developers on a need-to-know basis, depending on CEO approval
  • A list of employees authorized to access customer data is available and regularly updated.
  • Data between apps and systems is exclusively transmitted using industry-standard encryption technology
  • Employees have been educated for GDPR compliance and explicitly self-committed.
  • Access credentials are stored and organized using industry-standard encryption technology and clear access privilege rules are established.

3.12. Third-Party Back Office Applications

  • HubSpot
  • ClickUp
  • Aircall
  • AWS
  • GitHub
  • Google G Suite
  • MailJet
  • Slack
  • Sentry
  • Stripe
  • Typeform
  • Google Firebase
  • Microsoft Office 365
  • OpenAI
  • Antrhopic

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.