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The purpose of this privacy policy (hereinafter the “Policy“) is to provide you with a transparent presentation of the way in which we process the Personal Data we collect through various channels (including but not limited to recruitment platforms, our correspondence, conversations or interviews with our employees) in connection with the consideration of your application for positions offered by Sociabble (hereinafter “Sociabble” or “We“). The Policy complies with European regulations on the protection of personal data and in particular Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter “GDPR“). Who is concerned by this Policy ? This Policy applies to individuals who apply for one or more job vacancies offered by the Sociabble group by any useful and appropriate means in terms of searching for candidates. What do we mean by …? “Collect“ means the collection of Personal Data. “Data Controller“ means the natural or legal person who determines the purposes and means of the Processing. For the purposes of this Policy, the Data Controller is Sociabble. “Data Processor“ means the natural or legal person who processes Personal Data on behalf of Sociabble. “Legal Basis“ means what legally authorizes Sociabble to proceed with the Collection and Processing of your Personal Data. Six legal bases are provided by the GDPR: · the performance of a contract or pre-contractual measures, · compliance with a legal obligation, · the performance of a mission of general interest, · the fulfillment of a legitimate interest, · safeguarding vital interests, · the consent of the person concerned. “Personal Data“ means any information to which Sociabble has access as part of the recruitment and/or hiring process and which relates to an identified or identifiable natural person. “Processing“ means any operation or set of operations applied to Personal Data regardless of the process used, including but not limited to collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, deletion or destruction). Who is Sociabble? We, Sociabble, whose registered office is located at 12, rue Charlot – 75003 Paris (France), act as the Data Controller for Personal Data collected as part of our internal recruitment activities. What data is collected? How is it processed? For which purposes? During the recruitment process During the recruitment process Purpose(s) of the Processing Managing the recruitment process Purposes, nature and legal basis of the Processing Nature of Processing: accessing, reading, consulting, structuring, collecting, retrieving, using and storing Personal Data. Purposes of the Processing : – Pre-selection of candidates Legal basis: legitimate interest – Evaluation of the suitability of the candidate for the position for which they are applying Legal basis: legitimate interest – Verification of references and pre-employment checks, where applicable Legal basis: legitimate interest – Enriching our CV library and proposing other job offers Legal basis: consent Types of Personal Data Identification data: Last name, first name(s), e-mail address, city of residence, personal telephone number (mandatory information), video recording of interview (consent) Professional information provided in your curriculum vitae and cover letter: training, diplomas, career paths, skills, qualifications (mandatory information) Declarative data: information provided by you or third-party sources during recruitment interviews (mandatory information) Data made public at your initiative (e.g. professional social network profiles, hobbies, interests, previous earnings) (optional information) Duration of Processing Personal Data is processed for the time necessary to manage your application. Retention Period Personal Data is kept for up to three (3) months following the decision to refuse employment, for evidentiary purposes, in order to protect us against possible discrimination claims. If you agree, Personal Data is kept for two (2) years after the end of the recruitment process, i.e. after the last contact with you, in order to contact you again to submit other job offers. Optional information It is possible that you may provide us with additional optional and non-mandatory information. This information may be used to help us better assess your capabilities. Additional sources of information We may collect Personal Data indirectly when we collect it from service providers, as it is the case when we collect Personal Data resulting from your responses when using tools provided by our service providers, such as questionnaires useful for analyzing the relevance of your application, or when we analyze your activity on professional social media such as LinkedIn. During the hiring process During the hiring process Purpose(s) of the Processing Drawing up an employment contract Purposes, nature and legal basis of the Processing Nature of processing: accessing, reading, consulting, structuring, collecting, retrieving, using and storing Personal Data. Purposes of Processing: – Formalizing the employment contract Legal basis: pre-contractual measures – Completion of various administrative formalities relating to and following recruitment Legal basis: legal obligation – Organizing your integration into the Sociabble group Legal basis: legitimate interest Types of Personal Data Types of Personal Data: Birth name, surname (if applicable), first name(s), gender, social security number, date of birth, place of birth, photo, nationality, postal address, bank details, diploma, copy of national identity document, personal e-mail address, personal mobile number, family situation, emergency contact, RQTH[1] and SST[2] recognition if applicable. Duration of Processing For the duration of the employment contract with Sociabble Retention period In accordance with applicable personnel management regulations Who may receive your Personal Data? We may share your Personal Data with the following persons to the extent strictly necessary to carry out the Processing and pursue the purposes set out in this Policy: any Sociabble employee involved in the recruitment process and in personnel management, in particular recruitment officers and managers in charge of the department in which the position is offered; any Subprocessor that Sociabble may use to process your application (e.g. our external recruitment consultants) or to provide services, in particular IT and system administration services, such as hosting, e-mail services and alert management. These Subprocessors are contractually bound to guarantee the confidentiality and security of the Personal Data received and to process your Personal Data only on our instructions; any governmental, administrative, judicial or regulatory authority, on the basis of a law, regulation or binding decision, in particular in order to transmit certain Personal Data to the bodies informed of your employment (in particular unemployment insurance, health insurance, retirement, mutual insurance). You can contact our Data Protection Officer (DPO), whose contact details are given below, to obtain a more complete list of the recipients of your Personal Data. Is your Personal Data communicated or accessible from a country outside the European Union? For the purposes described above, we may transfer your Personal Data to countries outside the European Union. Sociabble ensures that such transfers are made to a country recognized as offering adequate and sufficient protection. Where necessary, legal protection tools are put in place, such as standard contractual clauses with our service providers. What are your rights? The RGPD gives you certain rights with regard to the Processing of your Personal Data, namely: The right to access your Personal Data; The right to rectify your Personal Data if it is inaccurate; The right to object to the processing of your Personal Data; The right to request the deletion of your Personal Data; The right to limit the Processing of your Personal Data; The right to withdraw your consent at any time, where Processing is based on consent; The right to portability of your Personal Data. How can you exercise your rights? In order to exercise your rights and/or obtain any type of information concerning this privacy policy, you may contact Sociabble’s DPO at the following address: Sociabble For the attention of the Data Protection Officer 12, rue Charlot – 75003 Paris privacy@sociabble.com What recourse do you have? For all information concerning your rights you can consult the website of the CNIL (www.cnil.fr), an independent public authority responsible for monitoring the application of the RGPD in order to protect the fundamental rights and freedoms of natural persons with regard to Processing and to facilitate the flow of personal data within the European Union. If you consider that your Data Protection rights have not been respected, and you wish to make a complaint relating to the Processing of your Personal Data, you may also contact the CNIL – 3 place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07. What about changes to this Privacy Policy? This Policy will be regularly reviewed to ensure compliance with applicable laws and regulations and to reflect changes in our Data Processing practices aligned with applicable regulations based on changes in regulations applicable to Personal Data Processing. Any changes will be published on this page. We encourage you to consult our Privacy Policy regularly to stay informed of any updates. [1] Recognition of the status of disabled worker [2] Workplace first-aider