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

Data Privacy Statement — Online Application Process

ALEMI-zurich.com · info@alemi-zurich.com

Version: June 2026

1. General Information

This data privacy statement applies exclusively to personal data collected as part of the online application process via ALEMI's recruitment website (powered by Personio). It informs you how your data is handled, by whom, and for how long.

2. Joint Controllers

ALEMI operates one recruitment system jointly for two legal entities. Both act as joint controllers within the meaning of Art. 26 GDPR and the Swiss revDSG (nDSG). The entity responsible for your application depends on the position you are applying for:

DE — AMELI Zurich Eurotrade GmbH Eythweg 12, 89542 Herbrechtingen, Germany Amtsgericht Ulm, HRB 743998 · USt-IdNr. DE351654441→ Applies to positions based in Germany or other countries outside Switzerland/Liechtenstein

CH — AMELI Zurich GmbH Apollostrasse 9, 8032 Zurich, Switzerland Handelsregister Zürich CH-020.4.070.898-2 · UID CHE-430.998.760→ Applies to positions based in Switzerland or Liechtenstein

Both entities have entered into a joint controller agreement pursuant to Art. 26 GDPR regulating their respective responsibilities. For any data subject requests, you may contact either entity; we will coordinate internally to respond.

Data Protection Officer (both entities):Carl Christian Stahl, Benjamin Stahl privacy@alemi-zurich.com

3. Personal Data Collected

Personal data means any information relating to an identified or identifiable individual. During the application process, we collect and process the following data:

First and last name
E-mail address
Phone number (optional)
Channel through which you found us
Application documents you choose to upload (cover letter, CV, certificates, reference letters — these may contain additional data such as date of birth, address, etc.)

Only authorised HR staff and staff directly involved in the selection process have access to your application data.

4. Legal Basis and Purpose

We process your personal data on the basis of:

Art. 6(1)(b) GDPR / Art. 31(2)(a) revDSG — processing necessary for pre-contractual measures at your request (executing the application process and preparing a potential employment contract)
Art. 6(1)(f) GDPR / Art. 31(1) revDSG — our legitimate interest in defending against claims under anti-discrimination law (AGG / applicable cantonal or federal law) during the statutory limitation period
Art. 6(1)(a) GDPR / Art. 31(1) revDSG — your consent, where you opt into the Talent Pool (see Section 6)

5. Data Retention

Unsuccessful applicants: Your data is stored for 6 months after the conclusion of the application process. This period is necessary to fulfil legal requirements and to enable us to defend against any claims arising from applicable anti-discrimination law (in particular the German AGG). After this period, your data will be deleted or anonymised.

Anonymised statistical metadata (e.g., number of applications per period, share of applicants by category) may be retained indefinitely for internal reporting purposes, without any personal reference.

Hired applicants: If you accept a position with us, your application data is retained for the duration of your employment and subsequently for the periods required by applicable statutory retention obligations.

6. Talent Pool (Optional — Requires Separate Consent)

We would like the opportunity to consider you for future vacancies that may match your profile. For this purpose, we store your application data for up to 12 months after the conclusion of the application process.

Participation in the Talent Pool is entirely voluntary and requires a separate, explicit opt-in. You will be asked for this consent via a dedicated checkbox in the application form — it is independent of and not a condition for submitting your application.

You may withdraw your Talent Pool consent at any time with effect for the future by contacting us at privacy@alemi-zurich.com. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

7. Disclosure of Data to Third Parties

Application data is transmitted via TLS encryption and stored in a database operated by Personio GmbH, which provides HR and applicant management software (https://www.personio.com/legal-notice/). Personio acts as our data processor pursuant to Art. 28 GDPR, and we have concluded a data processing agreement with Personio accordingly.

No application data is sold to third parties or shared for marketing purposes.

8. Applicable Law and Supervisory Authorities

DE Company (AMELI Zurich Eurotrade GmbH): Processing is governed by the EU General Data Protection Regulation (GDPR). The competent supervisory authority is the Landesbeauftragte für den Datenschutz Baden-Württemberg.

CH Company (AMELI Zurich GmbH): Processing is additionally governed by the Swiss Federal Act on Data Protection (revDSG / nDSG). The competent supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC).

9. Your Rights as a Data Subject

Depending on the applicable law and the legal basis of processing, you have the following rights:

Right of access (Art. 15 GDPR / Art. 25 revDSG)
Right to rectification (Art. 16 GDPR / Art. 32 revDSG)
Right to erasure (Art. 17 GDPR / Art. 32 revDSG)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to object (Art. 21 GDPR)
Right to withdraw consent (Art. 7(3) GDPR / Art. 31 revDSG) — where processing is based on consent

To exercise any of these rights, please contact our Data Protection Officer at privacy@alemi-zurich.com.

10. General Privacy Policy

This statement covers the application process only. For information on how we handle personal data across our other services, please refer to our general privacy policy at https://alemi-zurich.com/en/policies/privacy-policy.

11. Changes to This Statement

We reserve the right to update this statement at any time to reflect changes in legal requirements or our application processes. The version applicable to your application is the one published at the time you submit your application.

Version: June 2026 · AMELI Zurich Eurotrade GmbH, Eythweg 12, 89542 Herbrechtingen · AMELI Zurich GmbH, Apollostrasse 9, 8032 Zurich

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.