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

1. General information
This notice explains how YCO SAM and the Y.CO Group handle your personal data when you apply through our online recruitment platform (Personio). YCO SAM acts as lead data controller for all group recruitment. The Y.CO Group comprises YCO SAM (Monaco), YCO 3 LLP (United Kingdom), YCO Inc. (United States), and YCO NZ Ltd (New Zealand), all ultimately controlled by YCO 2 SAM.

Our recruitment process involves multiple rounds with HR (YCO SAM), line managers and the Managing Director (who may be employed by any group entity), and the co-founders (YCO SAM). Your data is therefore shared within the group on a need-to-know basis as described in Section 3.

2. The Data Controller
The controller under data protection law is:
YCO SAM (Société Anonyme Monégasque)
17 Avenue Albert II, L'Albu, 98000 Monaco
Phone: +377 93 50 12 12
Data Protection Officer: DPO@Y.CO

3. Group-Wide Recruitment — How Your Data Is Shared

Round	Who is involved	Y.CO entity
Round 1 — HR interview	HR team	YCO SAM (Monaco)
Round 2 — Line manager	Line manager	YCO SAM / YCO 3 LLP / YCO Inc. / YCO NZ Ltd (depends on role)
Round 3 — Managing Director	MD	YCO SAM or local entity
Round 4 — Co-founders	Co-founders	YCO SAM (Monaco)

Your data is shared within the Y.CO Group only on a need-to-know basis with the relevant interviewers at each stage. It is not shared outside the group during the recruitment process. All group entities handling your data are bound by the Y.CO Group Intra-Group Data Sharing Agreement.

4. Personal Data Collected

4.1 Application form data

Name, email address, telephone number
LinkedIn profile URL (optional)
How you found the vacancy
Location / position applied for

4.2 Documents you upload

Cover letter, CV, certificates, references — may contain date of birth, address, qualifications, employment history.

4.3 Data generated during the process

Interview notes, assessment records, and internal communications created by Y.CO staff involved in your application.

4.4 Special category data

We do not request special category data as part of the application process. If any is included in your documents, it will be treated with enhanced protection and accessed only by authorised HR staff.

5. Why We Process Your Data

Purpose	Legal basis
Assessing your application and conducting interviews	Pre-contractual steps — Law 1.565 Art. 5 / GDPR Art. 6(1)(b) / UK GDPR Art. 6(1)(b) / NZ Privacy Act Principle 1
Communicating with you about your application	Pre-contractual steps / Legitimate interest
Sharing your data within the Y.CO Group with relevant interviewers	Legitimate interest in conducting group recruitment — Law 1.565 Art. 5 / GDPR Art. 6(1)(f)
Legal compliance (right-to-work checks etc.)	Legal obligation — Law 1.565 Art. 5 / GDPR Art. 6(1)(c)
Talent pool — future vacancies (consent only)	Consent — Law 1.565 Art. 5 / GDPR Art. 6(1)(a) — see Section 7
Successful application: transition to employee HR file	Contract performance / Legal obligation

6. Our Recruitment Platform and Data Storage

We use Personio SE & Co. KG (Munich, Germany) as our recruitment platform. All application data is stored on Personio's EU-based servers (Frankfurt) using TLS encryption. Data remains within the EU at all times.

Personio acts as our data processor under Article 26 of Law No. 1.565 / Article 28 GDPR. A Data Processing Addendum governs how Personio handles your data on our behalf.

Intra-group data access during recruitment

Your data is stored in Personio's EU servers regardless of which country the position is based in.

During recruitment, your data may be accessed by Y.CO staff in Monaco, UK, USA and New Zealand as part of the multi-round process.

Access by YCO Inc. (USA) staff is governed by the Y.CO Group Intra-Group Data Sharing Agreement as the contractual transfer safeguard.

No data is shared outside the Y.CO Group during recruitment.

7. Retention Periods

7.1 Unsuccessful applications

Personal data is retained for 24 months from the end of the recruitment process, then permanently deleted or anonymised. Anonymised data may be retained for statistical analysis only.

7.2 Successful applications

Your application data is transferred to your employee HR file and retained for the duration of employment and applicable statutory retention periods. A separate Employee Privacy Notice will be provided at onboarding.

8. Your Data Protection Rights

Right	What it means	Applicable framework
Information	To be informed — this notice serves that purpose	All
Access	Copy of your personal data	All
Rectification	Correction of inaccurate data	All
Erasure	Deletion where no longer necessary or consent withdrawn	Law 1.565 / GDPR / UK GDPR
Restriction	Limit processing in certain circumstances	Law 1.565 / GDPR / UK GDPR
Portability	Data in portable format (consent/contract processing)	Law 1.565 / GDPR / UK GDPR
Object	Object to legitimate interest processing	Law 1.565 / GDPR / UK GDPR
Withdraw consent	At any time without affecting prior processing	All

To exercise any right: contact the DPO at DPO@Y.CO. Response within one month.

9. Supervisory Authorities

Position applied for / your residence	Supervisory authority	Contact
Monaco positions / Monaco residents	APDP (Autorité de Protection des Données Personnelles)	apdp.mc
UK positions / UK residents	ICO (Information Commissioner's Office)	ico.org.uk
New Zealand positions / NZ residents	OPC (Office of the Privacy Commissioner)	privacy.org.nz
US positions / US residents	Relevant state AG (e.g. California AG for CA residents under CPRA)	Varies by state
EU/EEA residents	Local EU supervisory authority	ec.europa.eu/justice/data-protection/bodies/authorities

10. Updates to This Notice

YCO SAM may update this notice to reflect changes in law, the recruitment process, or the group structure. The current version is always available on our recruitment platform. Material changes will be communicated to active applicants by email

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.