Confidentiality policy

Protection of personal data

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SKILLINK (“We”) builds strong and lasting relationships with candidates (“You”), based on mutual trust. We collect and process your personal data in order to provide you with a service, advise you on your career path and to make your job search as easy and secure as possible. Thus, we are committed to a continuous approach to the protection of candidate data, in accordance with the Data Protection Act of January 6, 1978 as amended and the General Data Protection Regulation (EU) of April 27, 2016. This Policy informs you of the means implemented to protect your Personal Data and informs you of your rights relating to the respect of privacy. It is important that you review this Policy so that you are fully aware of how and why we use your Personal Data.

PREAMBLE

It seems important to us to recall here the strong elements of our professional practices and our ethics when we enter into a relationship with you and when we support you in your professional development.

In order to maintain a high level of quality in the recruitment processes we manage, we are committed to developing a professional relationship with our candidates based on respect, empathy, free from any form of discrimination and which is part of a real approach of personalized support and transparency. Based on our mutual commitments to our clients, who entrust us with their exclusive recruitment missions, we only approach you within the framework of real professional opportunities that have been the subject of in-depth interviews with them and have always resulted in the drafting and signing of a precise recruitment agreement. We do not practice large-scale recruitment or mass processing. Our firm's Consultants do not manage more than ten missions in parallel in order to guarantee you a high level of follow-up and information throughout the entire duration of the processes and after. We consider that our intermediary role has an invaluable added value. In this context, we never use algorithms for pre-selecting our candidates, nor methods of making contact or automatically evaluating your skills. We never use automatic processing to collect your data. Our interventions in the context of the recruitment processes are exclusively human and carried out from start to finish by the Consultants of our firm with whom you are in direct contact. For each of our missions, we define a dedicated and rigorous approach in order to guarantee the relevance and precision of our approach and the processing of your data.

DATA COLLECTION & ORIGIN

All your personal data as candidates is collected directly from you and/or from other sources through various channels:

- our website, when you apply for our job advertisements or when you send us a spontaneous application;

- third party job websites such as Monster, APEC, CadremEmploi, etc. when you post your resume or respond to a job advertisement;

- social media websites or professional social networks on which you are registered such as LinkedIn, Facebook, Twitter, Github, Viadeo, etc.;

- written correspondence (including emails), telephone conversations or meetings with our consultants.

PURPOSE OF THE DATA COLLECTED

The personal data we collect is mainly processed:

- to provide you with our services in the context of your job search;

- to maintain our professional relationship with you;

- to offer you the professional opportunities that our customers entrust to us;

- to allow you to present your CV for applications to our customers;

- to establish matches between your information and the positions given to us by our customers in order to help you find the job that best suits your expectations;

- to keep your information and to inform you of future employment opportunities other than the specific position for which we have contacted;

- to communicate to you, through emails or telephone exchanges, information on the vacancies that we manage on behalf of our customers, which may correspond to your criteria and preferences for research/job development and potentially interesting for you;

- to respond to your requests for information;

- to meet contractual obligations towards our customers;

- to provide personal information to regulatory or law enforcement agencies, if requested or authorized to do so.

CHANGE OF OBJECTIVE

We will use your Personal Data only for the purposes for which it was collected (for example: to provide job search services if you are an applicant or to review your application for a job if you have applied), unless we reasonably decide that we need to use it for another reason and that reason is compatible with the original purpose. In the event that we need to use your Personal Data for unrelated purposes, we will inform you and explain the legal basis that allows us to do so.

TYPES OF DATA PROCESSED

As a recruitment agency, SKILLINK is likely to collect, in order to best support you in your professional development and/or in your job search, all or part of the following data (including and among others):

- identity (name, first names);

-contact details (postal address, telephone number as well as your email address);

- relevant information indicated in your curriculum vitae (“CV”);

- criteria, preferences and expectations related to your job search, mobility, availability, desired remuneration;

- qualifications, skills, experience and training; - current remuneration and other benefits; in order to fulfill our contractual obligations to our customers, we may in particular ask you for a copy of your last payslip on which we would ask you to kindly cross out the elements of personal information that we do not process (for example your social security number); - educational training; in order to fulfill our contractual obligations towards our customers, we could be in particular, asked you to send us a copy of your diploma (s);

- previous jobs;

- details on employment and/or educational training;

- references; in the event that you provide us with information on third parties for reference purposes, we will assume that the third party concerned has given you authorization to do so and therefore authorized SKILLINK to collect, process and transfer its Personal Data in the same way as yours;

- other information that you choose to provide to us.

Whenever SKILLINK processes Personal Data, SKILLINK takes all reasonable measures to ensure the accuracy and relevance of the Personal Data in relation to the purposes for which SKILLINK processes it. We implement a principle of minimizing the personal data processed. We only collect the minimum required taking into account the purpose observed. It is specified that SKILLINK does not use treatments whose purpose or effect is automated decision-making, large-scale processing of your personal data or automated cross-referencing of a set of data (profiling).

DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

Your Personal Data will not be transmitted to commercial or advertising actors. Insofar as necessary or appropriate, SKILLINK may disclose your Personal Data to external third parties such as our clients as part of our recruitment agency activity. Within the limits of their respective responsibilities and for the purposes mentioned above, the main persons likely to have access to your personal data are our recruitment consultants. However, SKILLINK may disclose your Personal Data without seeking your authorization to third parties who perform services for us: data storage facilities, hosting our servers, legal, accounting and other professional services, third parties to whom we choose to sell, transfer, or merge shares in our business or assets, computer consultants who carry out testing and development work on our computer systems, suppliers of services that we may designate for data processing. Your Personal Data may be disclosed to subsidiaries of SKILLINK or members of the same group of companies, in absolute compliance with the principles set out above and exclusively in order to achieve the purposes of this policy. Where necessary, we will impose contractual, security, appropriate confidentiality, and other obligations on third party service providers that we have appointed based on the nature of the services they provide to us. We will only allow them to process your Personal Data if this is in accordance with the law and our instructions. We will not allow them to use your Personal Data for their own purposes and when our relationship ends, we will ensure that your Personal Data is safely retransmitted to us or destroyed.

SHELF LIFE

SKILLINK will keep your Personal Data for as long as necessary to meet the purposes for which it was collected. This means that we will keep your Personal Data for the duration of your relationship with the firm and while we provide you with job search services. It should be noted that we are required by law to keep certain information relating to the execution of our contracts with our customers for a period of up to 10 years after the end of our relationship, in compliance with regulations and for tax purposes. In any event, your Personal Data will be stored in accordance with the law and the limitation periods which require us to keep this data for a longer period of time, for example to defend ourselves in the event of legal actions. Where no retention period is required by law, we determine the appropriate retention period for your Personal Data by considering the quantity, nature, and confidentiality of the Personal Data, the potential risk of harm from the unauthorized use or disclosure of the data, the purposes for which we process it, and whether we can meet these purposes by other means as well as applicable legal obligations.

SAFETY

SKILLINK implements appropriate technical and organizational measures to ensure the security of personal data processing and the confidentiality of Personal Data. As such, SKILLINK takes all useful precautions, with regard to the nature of the data and the risks presented by the processing, in order to preserve the security of the data and in particular, to prevent them from being deformed, damaged or that unauthorized third parties have access to it (physical protection of the premises, authentication processes with personal and secure access via confidential identifiers and passwords and logging of connections).

CONTACTS

If you have any questions about how we use your Personal Data, you can contact us at the following email address: contact@skillink.com. You can also contact us at the following postal address: SKILLINK — 8 rue Blanche 75009 PARIS.

YOUR RIGHTS

In accordance with current European regulations, you have the following rights:

- right to access (article 15 RGPD) and to rectify (article 16 RGPD), to update, to complete your Personal Data;

- right to lock or delete your personal data (article 17 of the RGPD), when they are inaccurate, incomplete, equivocal, outdated or whose collection, use, communication or storage is prohibited;

- right to withdraw consent at any time (article 13-2c RGPD);

- right to limit the processing of personal data (article 18 GDPR);

- right to object to the processing of personal data (article 21 GDPR);

- right to the portability of personal data (article 20 RGPD).

You therefore have the option of requesting the deletion of all personal information that we hold about you including your name, first name, e-mail and telephone numbers.

To delete your data, we invite you to send us an email to the email address contact@skillink.com or to the postal address SKILLINK — 8 rue Blanche 75009 PARIS.

Finally, SKILLINK candidates can file a complaint with the supervisory authorities and in particular with the CNIL (https://www.cnil.fr/fr/plaintes).

ADDITIONAL INFORMATION

We may need additional information from you in order to help us confirm your identity and ensure your right to access your Personal Data (or in order to exercise your other rights or if you make an informal request). This is a security measure to ensure that your Personal Data is not disclosed to anyone other than who is entitled to receive it. We may also contact you to request additional information about your request in order to help us identify your data and expedite our response. We try to respond to any legitimate request within one month. You will not have to pay fees to exercise your rights. However, we may charge you a reasonable fee if your request is unfounded, repetitive, or excessive. In the latter cases, we may also refuse to comply with your request.