Privacy Principles

Last updated: October 2018

Allianz Global Investors – Recruiting Privacy Notice

As part of its recruitment activities, Allianz Global Investors GmbH and its affiliates (“AllianzGI”, “we”, “us” or “our”) collects and processes your personal information (i.e. data which can be linked/attributed to an individual person, “Personal Data”).

The privacy and protection of your Personal Data is of utmost importance to us. Therefore we are committed to being transparent about how we collect and process your Personal Data in accordance with the high standards of applicable data protection laws and regulations.

The purpose of this Recruiting Privacy Notice is to inform you as a candidate about why and how we process your Personal Data during and after your job application. This includes information regarding with whom we will share your Personal Data, how long we will retain it and which rights you have in relation to its processing.

1. Who is responsible for the processing of your Personal Data?

If you apply for a position within Allianz Global Investors GmbH or any affiliates in Europe, Allianz Global Investors GmbH is the data controller, which means it is the entity deciding why and how to collect and process your Personal Data.

In addition, other companies of the AllianzGI may become responsible for the processing of your Personal Data (for example in cases where you apply directly to a specific AllianzGI entity that is not Allianz Global Investors GmbH).

A list with the contact details of the AllianzGI entities can be found here here.

In the event that two or more AllianzGI entities process your Personal Data in a joint manner, we kindly ask you to address any queries you may have directly to the contact details as set out in Section 10. The respective Privacy Contact Person will then forward your query to the AllianzGI entities who is primarily responsible, if necessary. Typically, this will be the AllianzGI entity you applied to directly.

2. What Personal Data do we collect?

We collect the following types of your Personal Data:

• Personal information (such as your surname, first name, address, date of birth, gender, telephone number, email address etc.)
• Education-related information (such as your educational history, relevant skills and degrees etc.)
• Job-related information (such as your employment history, relevant experience etc.)
• Financial information (such as your current level of remuneration, benefit entitlements etc.)
• Information in relation to legal issues (such as your work or residence permit, etc.)
• Other information (such as relevant previous convictions, etc.)

As a matter of practice, we will not collect any sensitive Personal Data about you (for example data concerning health, racial or ethnic origin or political opinions). If there is a need for us to process such sensitive Personal Data for purposes of the recruitment process with you (for example where we would need to know about any disabilities to provide a suitable workplace environment, or about relevant previous convictions), we will only process such sensitive Personal Data in strict compliance with applicable data protection laws and regulations.

Generally, we will collect the abovementioned Personal Data directly from you (for example, when you provided this information as part of your application letter, your CV or during an interview). You are under no statutory or contractual obligation to provide your Personal Data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

In certain scenarios like for pre-employment screening etc., we will also obtain your Personal Data from other sources such as through background check providers etc., in strict compliance with applicable data protection laws and regulations.

3. For which purposes do we collect process your Personal Data?

We collect and process your Personal Data for the following purposes:

• To create and maintain your personal recruiting file, and to manage and assess your application (for example, to evaluate and confirm your suitability for the position you have applied for);
• To document, analyse and improve our recruitment process (for example, by keeping recruitment statistics);
• To present to you future employment opportunities in case your application was unsuccessful for now;
• To comply with any legal obligations (for example, financial and administrative obligations or checking your eligibility to work);
• Internal or external investigations where it is necessary to assess, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or our assets;
• To establish, enforce or defend against legal claims;
• To comply with law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities.

4. On which legal bases do we process your Personal Data?

We use the following legal bases for the processing of your Personal Data:

• Your consent, where required under applicable data protection laws and regulations; in such a case, we will separately ask for your consent;
• Where the processing is necessary for us to decide about whether to establish an employment relationship with you;
• Compliance with legal obligations to which we are subject (for example, where we are legally obliged to check your work and residence permit);
• For some roles, we are obliged to seek information about criminal convictions and offences. Where this is the case, we will only do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.
• Where the processing is necessary for our legitimate interests (such as to protect AllianzGI from harm by preventing or detecting illegal activities, fraud or similar threats; to establish, exercise or defend against legal claims; or to analyse and improve our recruitment processes, unless we determine in a case-by-case assessment that our interests are overridden by your interests or fundamental rights and freedoms).

5. Who has access to your Personal Data?

To manage your recruiting process, we will share your Personal Data internally with members of the HR department, interviewers involved in the recruitment process and managers in departments with a vacancy, and in each case only if access to your Personal Data is necessary for the performance of their roles.

In addition, and only when necessary to fulfil the purposes mentioned above, we will disclose your Personal Data to the following recipients or categories of recipients, as the case may be:

• Other AllianzGI Companies and authorized persons working for or on behalf of AllianzGI;
• Third party agents, service providers and advisers (for example in connection with IT services, visa application, compliance vetting, background checks, medical examinations, payments, legal advice or postal services);
• Law enforcement, government authorities or courts where necessary to comply with applicable laws;
• Other parties in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

We will not disclose your Personal Data to any parties who are not authorized to process them.

6. Where will my Personal Data be processed?

Your Personal Data will be processed both inside the European Union (“EU”) and the European Economic Area (“EEA”) and outside the EU and EEA on a global level by the parties specified in Section 5 above.

Please note that EU / EEA Member States and other countries all have different laws regarding the protection of Personal Data. If we transfer your Personal Data from your own country to another country, the laws and rules that protect your Personal Data in the country to which your information is transferred to can be different (or less protective) from those in the country in which you live.

If we transfer any of your Personal Data outside the EU or EEA, we will ensure that the recipient of the Personal Data provides for an adequate level of data protection, in particular, by implementing safeguards such as standard contractual clauses approved by the European Commission.

Whenever we transfer your personal data for processing outside of the EEA to another Allianz Group company, we will do so on the basis of the binding corporate rules (“BCRs”) of Allianz Group known as the Allianz Privacy Standard (“APS”) which establish adequate protection for Personal Data and are legally binding on Allianz Group companies. The BCRs and the list of Allianz Group companies that comply with them can be accessed here.

7. How do we protect your Personal Data?

AllianzGI maintains appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. All our employees and contractual partners are bound by confidentiality and may only process your Personal Data based on the "need-to-know" principle.

8. How long do we keep your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes the data was collected for or to fulfil our legal obligations. Afterwards, we will delete your Personal Data.

Your job application submitted on our career page or on an unsolicited basis will be deleted 6 months after their submission unless there are deviating local retention periods. For specific information please contact our Data Protection Officer via e-mail to dataprivacy@allianzgi.com.

9. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period;
• Request the update or correction of your Personal Data so that it is always accurate;
• Request the deletion of your Personal Data if it is no longer needed for the purposes indicated above;
• Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy;
• Withdraw your consent at any time where your Personal Data is processed with your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
• In the event and to the extent that we process your Personal Data based on our legitimate interests as mentioned above, you have the right to object to the processing on specific grounds relating to your particular situation

You may exercise these rights by sending a request to the contact details set out in Section 10 below.

Such rights may be denied based on applicable laws.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you may lodge a complaint with a competent data protection authority if applicable.

10. How can you contact us?

If you have any queries about this Recruiting Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer via e-mail dataprivacy@allianzgi.com.

11. How often do we update this Recruiting Privacy Notice?

We regularly review this Recruiting Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you via a notification on our recruiting website, via e-mail or similar means. This Recruiting Privacy Notice was last updated on September 2018.