APPLICANT PRIVACY POLICY
INTRODUCTION
This Applicant Privacy Policy explains how personal data is collected, used, and processed in connection with applications submitted through the New Vision Brands Limited application portal.
It applies to all applicants, including individuals based on US military bases in the EU, and other EU citizens.
DATA CONTROLLER
The data controller responsible for processing personal data is:
New Vision Brands Limited
Theodor Stern Kai 1
60596 Frankfurt am Main
Email: axel@nvcoffee.com
For any questions, complaints, or to exercise your rights, please use the contact details above.
CATEGORIES OF PERSONAL DATA, PROCESSING PURPOSES AND LEGAL BASES
We collect and process personal data only where necessary and on appropriate legal grounds.
Website Usage Data
When you access the website or application portal, we process:
• IP address
• Date and time of access
• Time zone difference to GMT
• Requested content (pages visited)
• Access status / HTTP status code
• Data volume transmitted
• Referring website
• Browser type, version and language
• Device type and operating system
This processing is necessary to ensure the functionality, security and optimisation of the website.
Legal basis: Legitimate interest (Art. 6 (1) (f) GDPR).
Cookies and Similar Technologies
Cookies are small text files stored on your device to support website functionality and performance.
We use:
• Session cookies (e.g. session ID tracking)
• Authentication cookies
• Security cookies (fraud detection)
• Multimedia cookies (video/audio playback)
• Persistent cookies (up to 14 months)
These cookies help deliver and improve the web service.
Where applicable, third-party services (e.g. Microsoft technologies) may also use cookies.
Legal basis:
• Necessary cookies: Legitimate interest (Art. 6 (1) (f) GDPR)
• Non-essential cookies: Consent (Art. 6 (1) (a) GDPR)
Online Application Data
We process the following applicant data:
• Contact details (name, address, phone, email)
• Professional and educational background
• Skills, experience, evaluations and references
• Language skills
• Photo (if voluntarily provided)
It is not expected that special categories of personal data (“Sensitive Applicant Data”) will be processed. However, if voluntarily provided (e.g. health data), this will also be processed.
Purpose:
To assess suitability for roles and manage the recruitment process.
Legal bases:
• Pre-contractual measures (Art. 6 (1) (b) GDPR / Section 26 BDSG)
• Legitimate interest (applicant management) (Art. 6 (1) (f) GDPR)
• Consent where applicable (Art. 6 (1) (a) GDPR)
• Legal obligations (Art. 6 (1) (c) GDPR)
Providing data is voluntary, but failure to do so may prevent consideration of your application.
CATEGORIES OF RECIPIENTS
Your data may be shared with:
• Internal departments involved in recruitment
• Group companies where relevant to the role
• Service providers acting as data processors
• Authorities, courts, or advisors where legally required
Access is restricted to those who need it to perform their duties.
INTERNATIONAL DATA TRANSFERS
Some recipients may be located outside the EU/EEA, including the United States.
Where this occurs, appropriate safeguards are implemented, including:
• EU Standard Contractual Clauses
• Transfers to countries with recognised adequate protection
A copy of safeguards is available upon request.
DATA RETENTION
We retain data only as long as necessary:
• Website usage data: duration of session
• Unsuccessful applications: 6 months
• Legal obligations: up to 10 years where required
• Applicant pool (with consent): up to 1 year
Data is deleted once retention periods expire unless required for legal reasons.
AUTOMATED DECISION MAKING
No automated decision-making or profiling is used in the recruitment process.
YOUR RIGHTS
Under applicable data protection laws, you may have the right to:
• Access your data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Data portability
• Object to processing
You may withdraw consent at any time.
You also have the right to lodge a complaint with a supervisory authority.
RIGHT TO OBJECT
You may object to processing based on legitimate interests at any time.
Where data is used for direct marketing, you may object at any time and processing will cease.
CHANGES TO THIS POLICY
This Privacy Policy may be updated to reflect legal, technical or operational changes.
Updates will be published on the website or communicated where appropriate.
This privacy policy was created April 2026