Privacy policy & Terms of Use

Version: 16.07.2026

Information on the collection of personal data of applicants and temporary workers within Trenkwalder Personaldienste GmbH

This Privacy Policy describes how we collect, use and process your personal data and how we comply with our legal obligations towards you. Your privacy is important to us, and we are committed to protecting and safeguarding your rights.

1. Controller and Data Protection Officer

The controller within the meaning of the GDPR is:

Trenkwalder Personaldienste GmbH, Werner-Eckert-Strasse 6, 81829 Munich

Email: DatenschutzDE@trenkwalder.com

Telephone: 089 991999-0

Data protection officer:

Ms. Helene Yagolnitser

Address: Werner-Eckert-Strasse 6, 81829 Munich

Email: DatenschutzDE@trenkwalder.com

2. Scope

This information applies to applicants for positions advertised by us (internally and with customers) and to temporary workers employed by us. It explains how we process personal data in the application and temporary employment relationship, including in particular AI-supported evaluation of applicant data.

3. Categories of Personal Data

Depending on the phase, we process in particular:

• Master data and contact details: name, address, contact details, date of birth, nationality, work permit.

• Application and qualification data: CV, certificates, qualifications, professional experience, language skills, information on salary expectations and availability.

• Data from the selection process: our interview notes, assessments, internal communication regarding the application process.

• Data from the temporary employment relationship: contract data, assignment company, working hours, remuneration data, holiday and absence times, performance evaluations.

• Special categories (only insofar as provided by you or legally required): e.g. health data (severe disability, fitness for work), religious affiliation for tax purposes.

• IT/usage data: e.g. IP address when visiting our website or using the application portal, log data.

We generally receive this data directly from you (application, communication). In addition, data may come from public sources (e.g. professional networks, job portals) or from third parties (e.g. references, recruitment agencies), insofar as this is permissible for the application process.

4. Purposes and Legal Bases of Processing

4.1 Application and Recruitment Process

We process your data in order to decide, prior to entering into a contract, whether to establish an employment or assignment relationship, in particular for:

• reviewing and evaluation of your application,

• communication with you,

• planning and conducting interviews,

• documenting the decision.

Legal bases: Art. 6(1)(b) GDPR (General Data Protection Regulation) in conjunction with Section 26(1) BDSG (Federal Data Protection Act), (initiation of an employment relationship); insofar as special categories of personal data are concerned, Art. 9(2)(b) GDPR in conjunction with Section 26(3) BDSG.

4.2 Temporary Employment Relationship

In the existing employment relationship, we process your data, among other things, for:

• performance and administration of the employment contract (payroll accounting, assignment planning, working time documentation),

• fulfilment of legal obligations (e.g. tax and social security reporting obligations),

• personnel development, qualification, internal administration.

Legal bases: Art. 6(1)(b) GDPR, Section 26 BDSG (employment relationship), Art. 6(1)(c) GDPR (legal obligations), where applicable Art. 6(1)(f) GDPR (legitimate interest, e.g. IT security, enforcement of legal claims).

4.3 Processing of Applicant Data Supported by Artificial Intelligence (AI)

We use internal company AI software to support the evaluation of application documents. The AI may in particular:

• search and pre-sort documents according to certain criteria (e.g. qualification, professional experience, availability),

• record information from CVs in a structured form,

• generate suggestions for matching with open positions.

We expressly point out that the AI does not make independent decisions on acceptances or rejections. The decision on your application is always made by our employees*. The AI is used only to support and accelerate the selection process.

The AI software is operated exclusively on the IT infrastructure of Trenkwalder Personaldienste GmbH or of an instruction-bound processor within the European Union. Applicant data is processed through the use of external AI models. Applicant data is transmitted to Google or other external AI providers. However, no data is passed on for the training of external AI models.

Legal bases:

for the use of AI as part of the pre-contractual selection process:

• Art. 6(1)(b) GDPR, Section 26(1) BDSG (necessary for the application process)

4.4 Talent Pool / Longer Storage

If you consent, we will include your data in our applicant pool after completion of the specific process in order to contact you later about suitable positions.

Legal basis: Art. 6(1)(a) GDPR, Section 26(2) BDSG (consent).

4.5 Advertising / Newsletters / Surveys (optional)

Only with your express consent will we use your contact details to send you information about job offers, promotions or surveys.

Legal basis: Art. 6(1)(a) GDPR.

5. Recipients of the Data

Depending on the process, we transmit data to:

• customer companies at which you are to be/will be assigned,

• internal specialist departments (recruiting, HR, payroll accounting, IT),

• processors (e.g. data centre/hosting service providers, software providers for applicant management, AI software, payroll service providers),

• public bodies and authorities, insofar as legally required (e.g. tax office, social security agencies),

• advisory service providers (e.g. tax advisers, lawyers), insofar as necessary.

We conclude contracts with processors in accordance with Art. 28 GDPR.

6. Transfer to Third Countries

As a rule, we process your data in states of the European Union or the European Economic Area.

Applicant data is processed through the use of external AI models. Applicant data is transmitted to Google or other external AI providers. However, no data is passed on for the training of external AI models.

In the event of transfer to a third country (e.g. IT service providers), this is done only in compliance with Art. 44 et seq. GDPR (e.g. adequacy decision or EU standard contractual clauses). Reference is made in this respect to point 11.3, which constitutes a special rule for interviews.

7. Storage Period

With your consent to inclusion in the applicant pool, we store your data. The processing purpose of the storage, namely to process applicant data on an ongoing basis for future job offers, is not changed.

We store data from the employment relationship in accordance with the statutory retention periods (in particular commercial, tax and social security law, generally 6-10 years).

8. Obligation to Provide Data

You must provide the personal data that is required for the decision on establishing an employment relationship or for the performance of the employment contract, or that we are legally obliged to collect. Without this data, we cannot process your application.

Consent to AI processing, the talent pool, advertising or WhatsApp communication is voluntary.

9. Automated Decision-Making

No exclusively automated decision-making, including profiling within the meaning of Art. 22 GDPR, takes place that produces legal effects or similarly significantly affects you. The AI is used exclusively to support human decision-makers. The final decision always rests with a human being.

10. Rights of Data Subjects

Subject to the statutory requirements, you have the following rights:

• access (Art. 15 GDPR),

• rectification (Art. 16 GDPR),

• erasure (Art. 17 GDPR),

• restriction of processing (Art. 18 GDPR),

• data portability (Art. 20 GDPR),

• objection (Art. 21 GDPR),

• withdrawal of consents granted with effect for the future (Art. 7(3) GDPR),

• right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

Please direct your enquiries to the contact details listed above.

11. Online Applications / Video Interviews (optional)

11.1. General Information/Voluntary Nature

In addition to personal interviews at the branches, we offer our applicants the option of conducting an interview online. For this purpose, we use the Microsoft solutions Teams, Zoom or WhatsApp.

Participation in online interviews is voluntary. You have the option at any time to discontinue an interview, refuse further interviews and withdraw your consent to participation in the online interview without suffering any disadvantages as a result. The online interviews are not recorded or stored.

It is expressly pointed out that Trenkwalder Personaldienste GmbH offers you the option of conducting the interview also in the form of an in-person meeting on site or by telephone. If you decide on an in-person meeting on site or a telephone call, this will have no adverse effect on your application.

As part of our application process, we sometimes use an automated initial telephone interview with a computer-generated voice (AI). Your answers are recorded electronically and forwarded exclusively to our recruiting team for further processing. No automated decision-making takes place.

The interview is conducted only by employees who are responsible for filling vacancies within Trenkwalder Personaldienste GmbH. Within the scope of the intended purpose, these employees ensure that the confidentiality of your personal data is maintained. It is important to the company to ensure the highest possible protection of your personal data. All personal data collected and processed by us as part of an application is protected against unauthorised access and manipulation by technical and organisational measures.

11.2. Processed Data/Legal Basis/Withdrawal

The categories of personal data processed as part of the Teams interview include: name, transmission of the image (and therefore transmission of your person), transmission of your voice. The online interview is not recorded and/or stored.

In addition, the following personal data is collected by the system when Microsoft Teams is used: IP addresses, email addresses, names, log files, protocol data, metadata (e.g. IP address, time of participation, etc.), profile data (e.g. your user name if you provide it voluntarily).

Data processing as part of the Teams interview is based on the consent you have given, which can be withdrawn at any time with effect for the future, Art. 6(1) sentence 1 lit. f GDPR.

No recordings are made as part of video interviews. Image and sound are transmitted live only during the conversation and are not subsequently stored or further processed.

You have the option at any time to discontinue an interview, refuse further interviews and withdraw your consent to participation in the Teams or Zoom interview without suffering any disadvantages as a result. You may submit the withdrawal by email.

You have the option at any time to discontinue an interview, refuse further interviews and withdraw your consent to participation in the Teams or Zoom interview without suffering any disadvantages as a result. You may submit the withdrawal by email.

11.3. Data Transfer

We use Teams to conduct online interviews. Microsoft Teams is part of Microsoft Office 365. Microsoft Teams is a productivity, collaboration and exchange platform for individual users, teams, communities and networks that is used across corporate groups. This includes, among other things, a video conference function.

Microsoft Office 365 is software of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P52, Ireland.

Microsoft Teams is part of the Office 365 cloud application, for which a user account must be created.

Data processing with Office 365 takes place on servers in data centres in the European Union in Ireland and the Netherlands. We have concluded a processing agreement with Microsoft in accordance with Art. 28 GDPR for this purpose. Accordingly, we have agreed extensive technical and organisational measures with Microsoft for Office 365 that correspond to the current state of the art in IT security, for example with regard to access authorisation and end-to-end encryption concepts for data lines, databases and servers.

In the event of access by Microsoft from outside the European Union in an individual case approved by us, EU standard contracts (standard data protection clauses) are provided with Microsoft. In order to guarantee an adequate level of data protection when transferring personal data to a third country such as the USA in this specific case, we have implemented supplementary measures, as described above, in the form of state-of-the-art technical and organisational measures, such as access authorisation and encryption concepts for data lines, databases and servers.

Microsoft reserves the right to process customer data for its own legitimate business purposes. We have no influence over this data processing by Microsoft. To the extent that Microsoft Teams processes personal data in connection with its legitimate business purposes, Microsoft is an independent controller for these data processing activities and, as such, is responsible for compliance with all applicable data protection provisions. If you require information about processing by Microsoft, please consult the relevant Microsoft statement.

For the technical implementation of the automated initial telephone interview, we use a specialised processor:

FutureChamps GmbH,

Schenkenstrasse 4, 6th floor, Vienna 1010, Austria.

A processing agreement pursuant to Art. 28 GDPR has been concluded with FutureChamps GmbH.

Data processing takes place exclusively on our behalf and under strict observance of confidentiality. The processor is contractually obliged to process the data exclusively for the purpose for which it was transmitted to it and not to use it for its own purposes. The data is not transmitted to unauthorised third parties.

11.4. Application via WhatsApp (PitchYou)

If you use our application-via-WhatsApp function, the legal basis for the communication is your consent, which can be withdrawn at any time (Art. 6(1)(a) GDPR). The application-via-WhatsApp function is provided to us by the IT service provider PitchYou of SBB Software und Beratung GmbH in Germany, Bahnhofstrasse 7, 95119 Naila, Germany, which may access your data for this purpose as a processor. A processing agreement pursuant to Art. 28 GDPR has been concluded with PitchYou.

PitchYou provides for a multi-stage deletion concept in order to safeguard the rights of the data subject. Nevertheless, we point out that we have no influence over data processing by WhatsApp. The data protection provisions of WhatsApp, to which you must agree in advance, apply to the processing. We point out that the information you provide is stored and processed in the USA. We also point out that data processing by WhatsApp is associated with security risks. The USA is currently regarded as a country with an inadequate level of data protection by EU standards. In particular, there is a risk that your data may be processed by US authorities for control and monitoring purposes without you being informed about this data processing and without you having the possibility of a legal remedy against this data processing by the US authorities.

The legal basis of the processing is the voluntary consent granted within the meaning of Art. 6(1) sentence 1 lit. a GDPR in conjunction with Section 26 BDSG for the purpose of carrying out the application process.

You may withdraw the consent expressly granted above at any time with effect for the future by notifying us via WhatsApp. The lawfulness of processing carried out on the basis of the consent until withdrawal is not affected by the withdrawal.

Information on data protection at WhatsApp: https://www.whatsapp.com/legal?eea=0#privacy-policy

Further information on data protection at PitchYou can be found at: https://www.pitchyou.de/datenschutz and
https://www.pitchyou.de/pitchyou-dsgvo

Information on consenting to the use of WhatsApp can be found at: https://www.pitchyou.de/datenschutz-whatsapp

11.5. Sinch AB

To communicate with you via a messenger service (WhatsApp), we use a tool from Sinch AB. Communication takes place only if the person applying to us sends a corresponding initial message and is voluntary. By sending an initial message, you declare your agreement with the applicability of our data protection provisions. In particular, you consent to your personal data (first name and last name, telephone number, messenger ID, IP address, profile picture and the message history) being stored, processed and used in connection with the use of the respective messenger service (WhatsApp) in order to transmit messages to you.

We use Sinch AB, Lindhagensgatan 74, 11218 Stockholm, Sweden, as a technical service provider and processor to provide this communication service. Further information is contained in the respective privacy policies of the messenger service (WhatsApp, https://www.whatsapp.com/legal/privacy-policy-eea) and of Sinch AB (https://www.sinch.com/privacy-notice/).

The legal basis of the processing is the voluntary consent granted within the meaning of Art. 6(1) sentence 1 lit. a GDPR in conjunction with Section 26 BDSG for the purpose of carrying out the application process.

Communication and document exchange via WhatsApp is always voluntary and represents only one possible option. There is always also the possibility of communicating via other communication channels (e.g. email). Consent may be withdrawn at any time with effect for the future directly via the respective WhatsApp chat.

Information on data protection when using Sinch AB and WhatsApp can be found at https://www.whatsapp.com/legal/privacy-policy-eea and https://www.sinch.com/de-de/products/apis/messaging/whatsapp/

12. Right to Lodge a Complaint with the Supervisory Authority

You also have the right, pursuant to Art. 77 GDPR, to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates data protection provisions.

The authority responsible for our company is:

Bavarian State Office for Data Protection Supervision

Promenade 18

91522 Ansbach

Telephone: +49 (0) 981 180093-0

Email: poststelle@lda.bayern.de

However, you may also contact the supervisory authority of your usual place of residence or workplace.