Privacy policy for job applicants

In this privacy notice, you can read about how Lunar Way A/S ("Lunar", "we", "our", "us") and our group companies process your personal data during the recruitment process.

Lunar processes personal data during recruitment in various situations:

• When you apply for an available position directly at Lunar.

• When you apply for a position at one of our group companies.

• When you register in our job bank (Connect).

Data controllers
Lunar is providing centralized recruitment services to all group companies and will be acting as the initial data controller for the processing of your personal data performed as part of the recruitment process.

The information you share with us, via the recruitment platform, will be shared with the relevant group companies, who will act as individual data controllers for the processing of your personal data performed in pursuit of the group companies' own purposes, including in connection with the assessment of your skills etc. Only employees involved with the current recruitment process in the individual group companies will have access to the information you share with us. This privacy notice will also apply to our group companies' processing of your personal data. See how to contact each of these companies under "Contact details" below.

Purpose of processing your personal data

Receipt of applications etc.

When we receive your application and other documents, we will send you confirmation that we have received it. When we have read the applications, we will select the persons who we will call for an interview. The selection is based on your qualifications in relation to the position(s). You will be called for the interview by email or telephone.

As part of the recruitment process, we will receive and process the data that you have stated in your application, CV and any other documents you may share with us. We may also ask you to send us additional information. The information obtained in this connection will include information about your previous employment, including information relating to work assignments, skills and performance, and information about your personal appearance and interpersonal skills. We will also obtain other information about you if we consider such information to be necessary for the assessment of your application.

Social media

If relevant, we will obtain available information published by you on social media, such as LinkedIn and Facebook.

Recruitment partners

In some cases we use external recruitment agencies to help us with finding the right candidates for the available positions. The recruitment agency will act as an individual data controller, collecting and transferring the candidate personal data to Lunar, based on their own legal basis. This notice also applies to candidate personal data that we receive from external recruitment agencies.

References

If we wish to obtain information about you from your current or former employer using your references, we will first ask for your consent. Unless you are otherwise specifically notified by us, the information we obtain in that connection will include the following categories: Information about your previous employments, including information relating to work assignments, skills and performance, your personal appearance and interpersonal skills, and the reason for not being or no longer wanting to be employed by the employer in question.

Use of personality and competency tests

During the recruitment process relating to some positions, we will use a personality test and/or a competency test. Typically, the tests are taken after our first interview with you. The purpose of the tests is to identify your personal preferences and skills, forming a basis for a dialogue with you about your personal resources and conduct. The tests will never stand alone but will be part of the overall basis for selecting the right candidate for the position.

Criminal record

During the recruitment process, we often use criminal record certificates. Whether a criminal record certificate is required depends on the position, including the responsibilities and powers involved. If we consider it to be relevant to the position for which you have applied, we will ask you to request a personal criminal record certificate.

Conduct of interviews

If you progress in the recruitment process, we will conduct interviews where we will focus on your professional and personal skills as well as the challenges etc. of the job. We will write down some of the information disclosed during the interview(s). We only use the relevant information in the assessment of whether you should be offered a position.

Access registration

If you are invited to an interview in one of our locations, we will, due to security reasons, log your presence at our locations. We will register your navn, basic contact information, the time of your presence and similar basic information.

Drafting of employment agreement

If we offer you a position, we will process the personal data necessary for staff administration purposes. In that case, you will receive further information on this.

Registration in connect function (job bank)

If you register through our connect function (job bank), we will process your registration information (i.e. your name, email address, telephone number, interest in types of positions, office preferences, age, education, experience, and, if relevant, link to previously produced work) and any other information uploaded by you (including your picture).

Legal basis for processing of your personal data

In the sections below, you can see the legal bases for our processing of your personal data. The legal bases for each of the activities explained above are stated below.

Receipt of applications etc. and conduction of interviews

The legal basis for processing the said personal data is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.

Further, our processing of data that you make available to us on your own initiative is deemed to be performed with your consent. Which statutory provision on consent is the relevant one depends on whether the personal data are general personal data (point (a) of article 6(1) of the General Data Protection Regulation); sensitive personal data (point (a) of article 9(2) of the General Data Protection Regulation); or civil registration number (section 11(2)(ii) of the Danish Data Protection Act), and for our Swedish group companies, section 10 of chapter 3 of the Swedish Data Protection Act (Sw. Dataskyddslagen) (the importance of an accurate identification.)).

Social media
The legal basis for processing the personal data published by you is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person in relation to the contents of the position.

References
The legal basis is the consent you give for the purpose of using your references; see point (a) of article 6(1) of the General Data Protection Regulation.

Personality and competencies tests

The legal basis for processing the said personal data is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.

Drafting of employment agreement

The legal basis for processing the general personal data stated in the application documents may also be point (b) of article 6(1) of the General Data Protection Regulation as it may be necessary to process the personal data in question for the purpose of drafting an employment agreement, if relevant.

Registration in connect function (job bank)

If you choose to connect with Lunar either as part of the application process for a specific job or just to stay in touch, we will keep you in mind for other positions within the Lunar group of companies that become available and may be of interest to you.

The legal basis for the processing of your personal data when you register in our connect function is the consent you give when you register; see point (a) of article 6(1) of the General Data Protection Regulation.

The information will be stored in your connect profile for as long as it remains active. The profile is active for 6 months from registration unless you deactivate your profile (i.e. closes your connect profile) at an earlier date. Your personal data will be deleted immediately after your profile has been deactivated.

You have the right to withdraw your consent at any time. You may do so by deleting your connect profile or by contacting Lunar A/S using the contact details stated below under the title "Contact details".

If you decide to withdraw your consent, it will not affect the lawfulness of our processing of your personal data on the basis of the consent previously given by you and up to the time of withdrawal.

Recipients of your personal data

If it is relevant for Lunar to involve other group companies in the recruitment process (e.g. if you have applied for a position in another group company or a person in a group company needs to be involved in the assessment of your skills), the personal data that Lunar have collected about you during the recruitment process will be disclosed to another group company. The internal transfer of personal data to group companies is based on our legitimate interest, see point (f) of article 6(1) of the GDPR.

Further, your personal data will be made available to our processors, for example the processors hosting our IT systems and offering personality tests. In certain cases, we may also disclose your personal data to our recruitment partner if it is relevant to involve them in the assessment of your skills.We have entered into data processing agreements with all our processors.

Transfer to third countries

We transfer your personal data to recipients outside the EU and EEA. Such transfer will be made if we use processors and/or subprocessors located outside the EU and EEA. This may also be the case if one or more of our relevant business partners are located outside the EU and EEA. You can see a list of our third country transfers here. The list also contains an account of the relevant basis for the transfers (i.e. the statutory authority for our transfer of your personal data to third countries).

If you want additional information about our transfer of personal data outside the EU and EEA, including a copy of the relevant security measures etc., you may make a request to that effect by exercising your rights as stated below under the title "Your rights etc.".

Storage of your personal data

Rejection for a specific position

If you unfortunately don’t end up becoming a part of Lunar, we will keep your information for documentation purposes and in order to defend ourselves against potential claims that may follow the recruitment process for 12 months, after the date when you were informed of the rejection. We will not use the information you have submitted to us during the recruitment process for any other purposes than to document the process and to defend Lunar against potential claims, unless you have chosen to connect with us and become a part of our job bank.

During employment

When you land the job after completing a successful recruitment process, the data that we have processed during the recruitment process will, if relevant, be stored in your personnel file in accordance with the applicable guidelines. In that case, you will be further notified of the processing of your personal data.

Your rights etc.

Under the GDPR, you have several rights in relation to our processing of data about you. Please contact us if you wish to exercise your rights. Your data protection rights comprise:

Right to access data (right of access)

You have the right to access the data which we process about you and several other data.

Right to rectification (correction)

You have the right to have inaccurate data about you rectified.

Right to erasure

In certain circumstances, you have the right to have data about you erased before we are generally required to erase such data.

Right to restriction of processing

You have the right to restrict the processing of your personal data in certain circumstances. If you have the right to restrict the processing, we can, in future, only process the data – except for storage – with your consent or for the establishment, exercise or defence of legal claims or for the protection of a person or important public interests.

Right to object

In certain circumstances, you have the right to object to our otherwise lawful processing of your personal data.

Right to transmit data (data portability)

In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have such data transferred from one controller to another without hindrance.

You can read more about your rights in the Danish Data Protection Agency's guidance on the data subjects' rights, which is available on www.datatilsynet.dk.

Mandatory processing of personal data

Under the data protection rules, you are e.g. entitled to be informed of whether the provision of personal data is a statutory requirement, or a requirement necessary to enter into a contract, and of whether you are obligated to provide the personal data and of the possible consequences of failure to provide such data.

It should be noted in that respect that, under the Danish Health Information Act (helbredsoplysningsloven), an employee must state of its own motion or at the employer's request to that effect whether the employee knows that (s)he suffers from an illness or shows symptoms of an illness which will significantly affect the employee's ability to carry out the work in question.

Further, as a potential future employee, you are subject to the general duty of transfer which means that you must not knowingly withhold information that may be relevant to your opportunity for being employed.

Moreover, it should be noted that, if you are offered a position, Lunar or another group company employing you will use certain personal data about you to draft your employment agreement, including your name and address; see the provisions of the Danish Employment Contracts Act.

If you do not wish to provide the information that you are required to provide under the provisions of the Danish Health Information Act and/or according to your duty of transfer or the information necessary for drafting an employment agreement, we will be unable to offer you a position.

Complaint to the Danish Data Protection Agency

Even though we hope you will direct any questions or comments directly towards us via the contact details found below, you have the right to file a complaint with the local Data Protection Agency if you are not satisfied with our processing of your personal data. You will find the Danish Data Protection Agency's contact details on www.datatilsynet.dk and the Swedish Data Protection Agency’s contact details on www.imy.se.

Contact details of the group data protection officer

If you have any questions about how we process your data or you want to exercise any of your rights as described above, you are welcome to contact our group data protection officer (DPO) at any time. You may contact our DPO in the following ways:

• By email to: dpo@lunar.app

• By letter to: Hack Kampmanns Plads 10, DK-8000 Aarhus C, att. "DPO"

Initial data controller contact details:

Lunar Way A/S

Hack Kampmanns Plads 10, DK-8000 Aarhus C

CVR no.: 36982837

Tel.: +45 70 60 54 54

Email: hello@lunar.app

Lunar Group companies

The following is a list of group companies that may receive your personal data in connection with the recruitment process:

Lunar Bank A/S

Hack Kampmanns Plads 10, DK-8000 Aarhus C

CVR no.: 39697696

Tel.: +45 70 60 54 54

Email: hello@lunar.app

Lunar Block A/S

Hack Kampmanns Plads 10, DK-8000 Aarhus C

CVR no.: 38808117

Tel.: +45 70 60 54 54

Email: hello@lunar.app

Lunar Payments ApS

CVR no: 36693279

Hack Kampmanns Plads 10

Tel.: +44 1403 540 174

Email: hello@paylike.io

Lendify AB

Box 7527

Hovslagargatan 5, 111 48 Stockholm, Sverige

Registration number: 556968-1744

Tel.: +46 020 20 30 40

Email: hello@lendify.se