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

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