Klara GmbH – Applicant Privacy Notice (GDPR)

Last revised: 5 October 2023
Table of contents

Klara GmbH (“Klara”) has prepared this Applicant Privacy Notice (the “Notice”) to provide notice to prospective employees, temporary staff, interns, contractors and consultants located in the EU or who are applying for prospective employment by Klara GmbH (“Applicants”).

This Notice may be modified periodically, and the date of last revision will be included above. 

Key Definitions

  • data controller: the party that, alone or jointly with others, determines the purposes and means of the processing;
  • data protection authority: the Berlin data protection authority (Berliner Beauftragte für Datenschutz und Informationsfreiheit);
  • data protection law: the General Data Protection Regulation, the Privacy and Electronic Communications Regulations and all relevant laws supplementing or implementing them into domestic, local or EU member state laws, as applicable to the relevant processing activity;
  • personal data: any information that can be used to identify an individual. This is a broad concept, and includes: name, email address, phone number, interests, and unique identifiers and cookie information such as device ID and IP address;
  • processing: any operation or set of operations performed upon personal data, whether or not by automated means, such as creating, collecting, recording, accessing, organizing, storing, altering, retrieving, analyzing, disclosing, sharing, destroying or any other use of personal data.


This Notice applies to all Applicants whose personal data falls within the scope of data protection laws (“you” or “your”, as applicable). This Notice describes how we process your data when undertaken by or on behalf of:

  1. Klara GmbH;
  2. Modernizing Medicine, Inc. (excluding Klara GmbH), in the context of monitoring the behavior of individuals in the EU;

in each case regardless of the location where it is received, developed, stored and accessed. This includes information that is physical, electronic, processed and stored by Klara-managed processing facilities as well as vendor and cloud-based service providers.

Categories of Personal Data

Klara collects, processes, and uses the following categories of personal data about you in the context of your employment relationship with Klara:

  • Identifiers including information such as your name and photographic image (if you provide an image).
  • Contact Information including your postal address, email address, and phone number(s).
  • Professional or employment related information such as your primary language, salary, past job history (including whether you have entered into any agreements with your former employer that might restrict your ability to work for Klara), whether you have any immediate family members or close personal relations currently employed with Klara (or its parent company, Modernizing Medicine, Inc.), and other professional qualifications or information that you provide to use as part of your application, including any personal data contained in your CV, cover letter or resume.
  • Right to work information such as sponsorship requirements and any other information to establish your right to work in the relevant country or EU Member State of employment.
  • Background check information such as your credit score or consumer background and criminal background information.

Certain categories of personal data may be considered to be sensitive data or protected data under data protection law (“Sensitive Data”). The categories of Sensitive Data that Klara processes include your nationality and gender identity (if you provide it). 

Please ensure that all personal data provided does not violate the privacy rights, publicity rights, copyrights, contract rights, intellectual property rights, or any other rights of any person, and that you are duly authorized to disclose the personal data of such other persons, if requested to do so.

Where applicable, we indicate whether and why you must provide us with personal data, as well as the consequences of failing to do so. If you do not provide personal data when requested, we may not be able to process your application and comply with our reporting obligations and applicable laws.

Sources of Personal Data

We typically receive personal data directly from you, for example when you provide personal data as part of your application, or as contained in your cover letter, resume and/or CV. In addition, where required or authorized under applicable law, Klara  may obtain personal data from third parties, such as former employers, educational institutions, government agencies and background check providers.

Klara may seek personal data from such third parties in connection with:

  • Application, references, employee screening and background checks;
  • Information submitted by recruiting agencies;
  • Internal investigations; and
  • Other purposes as appropriate or authorized by law.

Purpose and Use of Personal Data

Klara uses your personal data for the following purposes:

Human Resources (HR) Operations:

  • Processing and reviewing your application for employment.
  • Creating reports for workforce planning or for HR analytics, including some reports that may be anonymized or pseudonymized for such purposes.
  • Protecting, enforcing and defending the legal rights, privacy, safety, or property of Klara and its employees, agents and contractors (e.g., enforcement of relevant agreements and terms of use).
  • Protecting against fraud and managing risk. 

Legal and Compliance:

  • Problem resolution (e.g., internal reviews, grievances), internal investigations, auditing, compliance, risk management and security.
  • Conflict of interest reporting and nepotism review.
  • Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations, including garnishments, withholdings or similar requests or proceedings.
  • Supporting any claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel.
  • To comply with applicable law requiring employers to maintain certain records.


  • As necessary or appropriate to protect the rights, property, or safety of us, our clients or others, including conducting appropriate security and related reviews of our systems. 
  • Other legitimate business purposes of Klara, which may include the day-to-day conduct of the business or the sale or transfer of all or part of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Klara only processes your personal data for the above purposes when we have a legal basis, including when:

  • we have obtained your prior consent;  
  • necessary to take pre-contractual steps to process an employment agreement between Klara and you;
  • necessary to protect your vital interests;
  • the collection and use is required by applicable law (e.g., for compliance with tax or social security laws, or court orders); 
  • necessary for the performance of a task carried out in the public interest; or
  • we, or a third party, have a legitimate interest in using your personal data (e.g., careful and reliable HR management, protection against claims, investigations and litigation, fraud and security).

In addition, Klara only processes your Sensitive Data when we have a legal basis, including when:

  • necessary for the purposes of carrying out Klara’s obligations and to exercise Klara’s rights as the controller in the field of employment and social security and social protection law;
  • necessary to protect your vital interests of the relevant individual or another person if the individual is incapable of providing consent; 
  • processing is required or permitted by applicable law;
  • the data have manifestly been made public by the Applicant; 
  • necessary for the establishment, exercise or defense of legal claims; 
  • necessary for reasons of substantial public interest on the basis of applicable EU or member state law; or
  • Klara has obtained the explicit consent of the Applicant for the processing of such data where the obtaining of such consent is either appropriate or required by applicable law.

Klara processes personal data of Applicants only for the purposes described in this section, unless Klara is required or permitted by law to process the personal data for another purpose.

Klara does not engage in what is known as “automated decision making,” which involves making decisions with legal or similarly significant effects solely based on automated processing of personal data.

Disclosure of Personal Data

Klara only discloses personal data for the purposes described in this Notice to the recipients described in this section.

We share personal data with: 

  • Klara and its affiliates globally
  • Members of Klara management and of our People Operations, Legal, and Compliance departments to allow them to access and process personal data in connection with their job responsibilities. In addition, managers have access to certain personal data as reasonably necessary to undertake certain job functions. Klara staff accessing personal data is required to maintain its confidentiality and to process such data in accordance with applicable law.

We also share personal data with service providers who perform services on our behalf and in relation to the purposes described in this Notice:

  • IT support providers; 
  • Third-party service providers which provide assistance in assessing and recruiting Applicants, such as Greenhouse;
  • Government agencies, in response to lawful requests, such as from law enforcement or government statistics offices; 
  • Security companies; and
  • Auditors, accountants, forensic investigators or law firms, for group, statutory or other periodic audits, or as part of an investigation of suspected illegal activity.

These third parties are contractually (i) required to protect the personal data they receive from us with adequate safeguards and security measures and (ii) prohibited from processing personal data for any purpose other than to perform the services as instructed by Klara. 

In addition, Klara may disclose personal data to other recipients to fulfill a legitimate business purpose and:

  • In the context of a sale or transfer involving all or a portion of Klara’s business or assets (including in the event of a reorganization, dissolution or liquidation);
  • If required to do so by law, regulation or legal process (such as a court order or subpoena); or
  • When we believe disclosure is necessary or appropriate to protect the rights and properties of Klara, to prevent physical harm or financial loss, or another overriding interest.

International Data Transfers

Klara may transfer personal data to recipients outside of the EU and Switzerland, including to our affiliates and our vendors and service providers located in countries around the world. In accordance with EU data protection laws, we have implemented relevant safeguards to protect personal data, such as the EU Commission’s standard contractual clauses for the transfer of personal data to third countries when transferring personal data to the United States. Further information on the relevant safeguards can be obtained by contacting Klara per the “Contact Us” section below.  

Your Rights and Choices

If you are in the EU, then unless otherwise indicated, Klara is the entity responsible, or “data controller”, for the processing of personal data in this Notice. In the EU, you have the following rights, subject to applicable law:  

Right of access: You have the right to access your personal data and request a copy of it. Klara may choose to limit the right to access where: the disclosure would violate the rights of other Applicants; it relates to an ongoing investigation of wrongdoing and disclosure could compromise the investigation; or Klara is otherwise authorized or required to limit or deny such access by applicable law.

Right to rectification: You have the right to obtain rectification of your personal data that is inaccurate or incomplete.

Right to object: You may object to certain types of processing of your personal data. We will reasonably accommodate such objections, as appropriate, and if granted, Klara will no longer process your personal data unless we have compelling legitimate and lawful grounds to do so. We will not subject Applicants to any disciplinary action for objecting to the processing of personal data.

Right to deletion:  You may ask us to delete your personal data in specific cases such as if: we no longer need that information; you withdraw your consent to the processing and we do not have any other legal ground for the processing; your personal data has been processed unlawfully; or deletion is required by law.

Right to restriction: You may request that we limit the way in which we process your personal data  where you contest the accuracy of your personal data; the processing is unlawful and you don’t want your personal data  deleted; we no longer need your personal data  for the processing, but you request that we retain it in anticipation of a potential legal claim; or you objected to the processing and we are reviewing whether we have an overriding interest to keep processing the personal data. 

Right to data portability: You may also have the right to data portability, which means the ability to easily transfer your personal data to another company, when you provided your personal data directly to us, and where the processing is based on your consent or is necessary for the performance of a contract.

Right to lodge a complaint: You have the right to lodge a complaint with the data protection authority.

If you would like to exercise these rights or lodge a complaint, please contact us as specified in the “Contact Us” section below. In your request, please make clear what personal data you would like to have changed, whether you would like to have the personal data that you have provided to us suppressed from our database, or what other limitations you would like to put on our use of the personal data that you have provided to us. To protect your privacy, we may need to verify your identity before implementing a request.

Please note that these rights may be limited in some circumstances by local law. Also, we may need to retain certain information for recordkeeping or legal compliance purposes or to continue to perform our obligations under the employment relationship.

Retention Periods

Unless otherwise provided by applicable law, your personal data is retained for the periods set out below:

  • Identifiers: 5 years from end of employment/application date
  • Contact Information: 5 years from end of employment/application date
  • Professional or employment related information:
    • Successful applicants: for the duration of employment
    • Unsuccessful applications: 6 months unless you give consent to allow us to retain the personal data for longer
  • Sensitive Data: 5 years from end of employment/application date

Note that we generally retain employment-related personal data for as long as necessary to carry out the processing purposes in the Notice or in order to comply with our legal requirements. 


Klara maintains appropriate administrative, technical and physical safeguards to protect personal data against the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Contact Us

Klara is the entity responsible or “data controller” for the processing of personal data described in this Notice.

For any questions regarding our privacy practices or for more information about this Notice, please contact us via email at Privacy@Klara.com (Attn: Privacy Officer), via phone at 1-833-396-2630 (to be directed to the Privacy Officer) or in writing to:

Klara GmbH
4850 T-Rex Avenue, Suite 200
Boca Raton, Florida 33431
Attention: Privacy Officer

For applicants based in Germany, please contact us at:
Klara GbmH
Brunnenstraße 166
10119 Berlin
Attention: Privacy Officer