Data Privacy Notice

Data Privacy Notice

Version March 2024

The security and privacy of your personal data is important to us. This Data Privacy Notice explains primarily from the point of view of the European General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – “GDPR”) how we process your personal data as part of the application process. Please see the appendix for more information under U.S. regulations as well as for China, if relevant for you.

Who is responsible for the TTTech career platform?

This career platform is managed by TTTech Computertechnik AG, headquartered in Vienna and with its business address Schönbrunner Straße 7, 1040 Vienna, Austria.

You can contact our Data Privacy team at any time at the email address datenschutz(at)tttech.com.

Which TTTech company is granted access to your personal data?

The TTTech career portal is provided and operated by TTTech Computertechnik AG ("TTTech"). You have several choices that affect how we share your information within our group of companies:

Either you indicate that your data should only be shared with the company for whose open position you would like to apply (a), or you decide that your application documents may be shared with other companies within the group, so that you may also be contacted by HR contacts from other units (b).

In the case of (a), your data will only be disclosed to the TTTech Group company that advertised the position in question and, of course, to the respective managers and recruiters (technical and HR) who are responsible for the hiring decision. In the case of (b) we will make your personal data available to all TTTech group companies worldwide that may offer jobs that match your profile.

However, in the case of alternative (b), you can also assert your rights as a data subject centrally with TTTech.

What personal data categories do we process?

TTTech processes the following categories of personal data:

• Information that you actively provide to us when you apply through our career portal, including your full name, contact details, CV and additional documents you provide to us, your work experience, qualifications and skills ("Profile Data");
• Information that you provide to us via the link to XING and LinkedIn when you use your social media profile to complete your information in our career portal ("Professional Social Media Data");
• Communication via XING or LinkedIn, provided that our HR specialists write to you directly via these social media portals ("Social Media Communication");
• Information contained in your uploaded CV to be matched with open positions using tool-based automation ("Matching Data")
• Information that you provide to us further along the application process for a particular vacancy, including audio and video recordings that you have provided to us during the application process ("Application Data").
• Information about your interactions with our career portal, including your device and user identification, information about your operating system, pages visited during your visit, and the date and time of each visitor request (“Usage Data”).

We expressly request that you do not provide us with any information as part of your application data that qualifies as special categories of personal data (i.e. information about race or ethnic origin, political opinions, religious or philosophical views, trade union membership, health or sexual orientation), unless this is legally required in individual cases. If you provide us with special categories of personal data, you hereby expressly consent to the processing of such data as described herein.

For which purposes do we process your personal data?

TTTech processes your Profile Data (including data from professional social networks) and Application Data for the following purposes:

• To process your application,
• to assess qualifications and personal suitability,
• to show you other suitable positions in your personal user interface on the career portal, if possible,
• and to send you information, documents and invitations in connection with your profile.

TTTech also processes your data for the following purposes:

• To provide services and features of the career portal, which include: to create and manage your online account, to support the smooth technical operation, to provide support, and to improve and develop our career portal.
• If necessary to establish or defend a legal claim or defense and to prevent fraud or other unlawful acts, including attacks on our information technology systems.
• To fulfill legal obligations, in particular in the area of export control (checking of restricted lists / embargo lists or other essential regulatory requirements to which TTTech is subject).

TTTech processes your Matching Data to enable the career portal to make automated suggestions for suitable positions and to help you find the open position(s) that best match your skills and talents.

What is the legal basis for the processing of your Personal Data?

TTTech processes your personal data based on the following legal bases:

If you provide us with special categories of personal data without this being required by local law, this constitutes consent pursuant to Art 6 (1) (a) GDPR.

Otherwise, the legal basis is the execution and fulfillment of a contract with you (Art 6 (1) (b) GDPR) or the fulfillment of legal obligations to which we are subject (Art 6 (1) (c) GDPR).

In other cases, we rely on the protection of our legitimate interest pursuant to Art 6 (1) (f) GDPR, our legitimate interest lies in the processing of your personal data for the purpose of (1) the use of our career portal by you and (2) the processing of your application to TTTech. When we rely on our legitimate interest for a specific purpose, we consider that your interests, fundamental rights and freedoms are sufficiently taken into account as (i) we regularly review the processing activities and underlying processes described in this Privacy Notice, (ii) we consider the protection of your personal data in our processes, (iii) we ensure the transparency of our processing activities and (iv) you are entitled to the aforementioned rights regarding our processing activities. If you would like to receive further information on the balancing of interests described above, please contact our Data Privacy team at datenschutz(at)tttech.com.

How long do we store your personal data?

If you have given preference to option (a) (i.e. your application may only be processed by the responsible Group company), your Profile Data (including Professional Social Media Data) will be deleted for a maximum period of seven months after the end of the last application process active in your account or seven months after your last log-in (whichever is longer).

In the event that you wish your application to be considered within the TTTech Group (option b), we will store your Profile Data (including Professional Social Network Data) for a period of 3 years after your last login. Of course, you can also change or update your data in your account or delete your profile completely.

If you are subject to a mandatory export control check as part of the application process, your personal data required for this will be stored for one month after the check has been carried out.

Should you wish your data to be deleted, we would like to point out at this point that we take every deletion request seriously and process it promptly, and that even if an employment relationship is ultimately unfortunately not established, your personal data can only be deleted after the seven-month period has expired. This is due to the anti-discrimination regulations currently in force in Austria and our legitimate interest in being able to protect ourselves against any legal claims.

An exception to the above retention period applies to Profile Data (including Professional Social Network Data) and Application Data used to apply for jobs at TTTech Group companies in the United States. Here we are required by local law to retain the personal data for a period of three years after completion of your application process.

Matching Data is only stored for the duration of your browser session, your Usage Data is stored for six months.

Who are the recipients of your data?

As we describe above, you have the option of deciding whether we may pass on your personal data within our Group. These are the following Group companies that are currently connected to our platform:

• TTTech Auto AG, Operngasse 17-21, 1040 Vienna, AUSTRIA
• TTTech Industrial Automation AG, Schönbrunner Strasse 7, 1040 Vienna, AUSTRIA
• TTTech Digital Solutions GmbH, Schönbrunner Strasse 7, 1040 Vienna, AUSTRIA 
• TTControl GmbH, Schönbrunner Strasse 7, 1040 Vienna, AUSTRIA
• TTControl S.r.l., Julius-Durst-Strasse 66, I-39042 Brixen / Bressanone, ITALY
• TTTech Computertechnik AG, o.s., Šumavská 519/35 C, PSC 602 00 Brno, CZECH REPUBLIC
• TTTech Auto Germany GmbH, Despag-Straße 4, 85055 Ingolstadt, GERMANY
• TTTech Deutschland GmbH, Emmy-Noether-Ring 16, Business Campus München, 85716 Unterschleißheim, GERMANY
• TTTech Development Romania S.r.l., 7 Oitelor Str., 5th and 6th floor, Ap. 14, District 4, 040278, Bucharest, ROMANIA
• TTTech Flexibilis Oy, Tullikatu 6, 33100 Tampere, FINLAND
• TTTech North America, Inc., 300 Brickstone Square Suite 1003, Andover, MA 01810, UNITED STATES
• TTTech Auto China Company Limited, RM226, 1000 Chen Hui Road, Zhangjiang High- tech Park, 201203 Shanghai, CHINA
• TTTech Auto China Company Limited, RM1603, No. 9 Courtyard, Huilongguan West Street, Changping District, Beijing, CHINA
• TTTech Auto Korea, Suite# 402-A Pangyo InnoValley B, 253 Pangyo-ro, Bundang-gu, Seongnam, Gyeonggi-do, REPUBLIC OF KOREA
• TTTech Japan Corporation, Nagoya Technical Center, Sumitomo Seimei , Nagoya Building 15F, 2-chome 14-19, Meieki Minami, Nakamura-ku, Nagoya, Aichi 450-0003, JAPAN

In addition, we may commission service providers (so-called data processors) to support us in the processing and use of your personal data. Specifically, for hosting the platform, it is a German company based in Hamburg that operates this career platform on our behalf. The data is only processed for the purposes described and stored within the EU.

TTTech may also use other service providers where deemed necessary. The recipients of your data may be located in countries other than your home country (a so-called "third country"), where the applicable laws do not offer the same level of data protection as in your home country. In such cases, and where required by applicable data protection law, TTTech will take steps to ensure appropriate and adequate safeguards to protect the personal data elsewhere.

We only pass on your data to TTTech group companies in third countries if they have concluded EU standard contractual clauses with TTTech.

We only transfer your data to external recipients in third countries if there is either a corresponding adequacy decision by the European Commission for this country or if we have concluded EU standard contractual clauses with the recipient.

The application process for some vacancies may require your voluntary participation in assessment, selection or similar procedures by third parties. In this case TTTech or the TTTech company offering the relevant position will inform you during the application process and prior to the transfer of your data to third parties about the relevant procedures and recipients.

Data upload via XING or LinkedIn / communication via Social Media

If you have set a corresponding setting in your Social Media profile, you can automatically share your complete Social Media profile with us when you click on "Apply". This function is not a "must" in order to successfully complete the application process, it is merely an option that you can use voluntarily to make the process more efficient for you. A corresponding data transfer from the Social Media channel to us is based on your voluntarily given consent, so please take into account the Data Privacy information of the respective Social Media channel in this context.

The same applies if you communicate with our HR experts via Social Media; here, too, you decide which data should be automatically forwarded to us, apart from the communication with us.

What are your rights as data subject?

Under the GDPR, you have specific rights in relation to your personal data. In particular, and subject to the statutory requirements, you may be entitled to:

• obtain confirmation as to whether TTTech processes personal data about you and, where that is the case, obtain access to your personal data processed by TTTech as well as other information,
• obtain the rectification of your inaccurate personal data processed by TTTech,
• obtain from TTTech the erasure of your personal data processed by TTTech,
• obtain from TTTech restriction of processing of your personal data,
• obtain a copy of your personal information that you have provided to TTTech or request that your personal information be transmitted to another recipient,
• object on grounds relating to your particular situation to the processing of your personal data by TTTech insofar as the processing of your personal data is based on legitimate interests.

If you have given TTTech your consent to process your personal data, you have the right to withdraw your consent at any time with effect for the future, i.e., your withdrawal does not affect the lawfulness of the processing based on consent before its withdrawal.

To receive more information regarding these rights or to exercise any of your rights, please contact the TTTech Data Privacy Organization (datenschutz(at)ttech.com).

Who can I contact if I have questions or would like to exercise my rights as a data subject?

If you have any questions or comments about our handling of your personal data, or if you would like to exercise any of your Data Privacy related rights, you can contact the TTTech Data Privacy Office at datenschutz(at)ttech.com. Alternatively you may send us a letter to the following address:

TTTech Computertechnik AG
c/o Data Privacy Office
Schönbrunner Straße 7
1040 Vienna
Austria

The TTTech Data Privacy Office will always use best efforts to address and settle any requests or complaints brought to its attention.

In addition, you may also contact a supervisory authority with requests or complaints. The lead supervisory authority for TTTech is:

Österreichische Datenschutzbehörde / Austrian Data Protection Authority 
Barichgasse 40-42
1030 Vienna
Austria

Updates

We keep our Privacy Notice under regular review to make sure it is up to date and accurate. The date of the last update can be found at the beginning of this Privacy Notice. We recommend that you visit this page regularly to check for any updates that may have been made.

Additional Information for US citizens

The following additional information applies to US citizens:

Do Not Track

Our online offers do not recognize so-called "Do Not Track" settings of your web browser. For more information on the "Do Not Track" functionality, please visit the help pages of your web browser.

Use by children

Our online services are not intended for children under the age of thirteen. Where required by law, we do not knowingly collect personal data from children under the age of thirteen without the consent of a parent or guardian. We collect and transfer personal data from children only to the extent permitted by law, to obtain parental consent or to protect the child.

Your rights in certain US states

Under the laws of some US states, residents of these states have additional rights with regard to their personal data. Further information can be found here:

For California Residents Only

The purpose of this Notice is to provide additional information to California residents and to notify them of their rights under California law. This section is not applicable to, and may not be relied upon by, anyone except California residents.

California’s “Shine The Light” law:

California’s “Shine The Light” law permits those of our customers who are California residents to annually request a list of their personal information (if any) that we have disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. At this time, we currently do not share any personal information with third parties for their direct marketing purposes.

Rights:

California residents have the right to request that we delete the personal information that we have collected about that resident. Please note that there are circumstances under which such a right of deletion does not apply, such as where it is reasonable for us to maintain the personal information to:

• Complete the transaction for which the personal information was collected, provide a good or service requested or reasonably anticipated, or otherwise perform a contract with the resident.
• Detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another resident to exercise his or her right of free speech, or exercise another right provided for by law, or Comply with a legal obligation.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical or statistical research in the public interest (when deletion of the information is likely to render impossible or seriously impair the achievement of such research) if the resident has provided informed consent.
• To enable solely internal uses that are reasonably aligned with the resident's expectations based on the relationship with us.
• To otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which the resident provided the information.

California residents have the right to request that we disclose, with respect to that resident,

• The categories of personal information we have collected.
• The categories of sources from which we collected the personal information.
• The purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information.
• The specific pieces of personal information we have collected.

California residents have the right to request correction of inaccurate personal information.

California residents have the right to not be discriminated against by us for any exercise of these rights.

To exercise the rights that may be available to you as described above, please contact us by writing us an email at datenschutz(at)tttech.com

Additional Information / Processing in accordance with the Law of People’s Republic of China on the Protection of Personal Data

This section applies to the processing of data by one of our companies within the borders of the People's Republic of China ("PRC") or the processing of personal data within the borders of the PRC and provides you with further information.

Processing of sensitive personal data

According to the PIPL, sensitive personal data is personal data that, if it or used unlawfully, could easily violate the dignity of natural persons and compromise and can seriously compromise personal or material security, including information on biometric characteristics, religious beliefs, a particular status, health status, financial accounts, tracking of individual location, etc., as well as personal location, etc., as well as the personal data of minors under the age of fourteen.

In principle, we do not ask you to provide us with sensitive personal data as part of your application data, unless this is required by law in individual cases. If your sensitive personal data is processed, we will inform you about the necessity of the processing and the effects on the rights and interests of the individual and, if necessary, obtain your express consent.

Transfer and disclosure of personal data

In accordance with the requirements set out in Article 23 of the PIPL and in addition to the recipients mentioned in this Privacy Notice, we will generally not disclose your personal data to third parties unless we (1) receive your express consent, if applicable, or (2) to comply with legal obligations under local laws and regulations.

International Transfer

You acknowledge that your data will be transferred and processed outside the PRC as described in this Privacy Notice. We will comply with applicable laws and decisions of the relevant authority and ensure that your data is protected in a manner consistent with the PRC Personal Data Protection Law.

The legal basis for processing

The PIPL obliges us to inform you about the legal basis for processing your personal data. The legal basis for our processing is:

• PIPL Article 13(2) (Contract performance)
• PIPL Article 13(3) (Legal obligations and responsibilities)
• PIPL Article 13(6) (Processing of publicly available data)
• PIPL Article 13(1) (Consent)

Use by Children

This online offer is not intended for children under the age of fourteen. We will not knowingly collect personal data from children under the age of fourteen without prior parental consent, if required by applicable law. We will only use or disclose personal information about a child to the extent permitted by law to obtain parental consent, in accordance with local laws and regulations, or for the protection of a child.