Privacy policy

1. Preamble
Partner Talents (hereinafter referred to as "We") is committed to respecting the privacy of its users (hereinafter referred to as "You") and is committed to providing the highest level of protection for the personal data entrusted to it.
This commitment is made in strict compliance with the applicable regulations, particularly the General Data Protection Regulation (GDPR) and the French Data Protection Act of January 6, 1978, as amended (LIL).
For better understanding of this document, the following useful definitions are provided:

Personal Data is any information relating to an identified or identifiable natural person, directly or indirectly, particularly by reference to an identifier, such as a name, identification number, location data, online identifier, or one or more specific elements related to their physical, physiological, genetic, mental, economic, cultural, or social identity.
Processing is any operation or set of operations performed or not by automated means and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination, or any other form of provision, combination or interconnection, limitation, erasure, or destruction.
Data Controller is the entity that determines the purposes and means of processing alone or jointly with others.
Processor is the entity that processes personal data on behalf of the data controller.
DPO - Data Protection Officer: refers to the person responsible for advising and overseeing the Data Controller regarding the protection of personal data.
"User": refers to any person using or browsing our website(s).

2. Purpose
This policy demonstrates our transparency regarding the processing of personal data we carry out on our site.
Furthermore, it aims to inform users of the site about:

How we collect and process their personal data on our site.
The rights they have regarding this data;
The person responsible for the processing of personal data collected and processed on the site;
The recipients of this personal data;
The site's cookie policy.

3. Scope
This policy applies to any processing of personal data carried out by and for Partner Talents on this site:
It complements the legal notices and the Terms and Conditions of Use.
The processing of personal data for which Partner Talents acts as a processor is specified in a Data Protection Agreement (DPA).
This policy is intended for users located in the European Union (EU) and the European Economic Area (EEA).
Users located in other countries will be subject to different notices in accordance with their national legislation.

4. Identity of the Data Controller
Personal data is collected and processed by Partner Talents.
They have a Data Protection Officer (hereinafter referred to as "DPO").
The data controller and the DPO can be contacted as follows:

By email: [email protected]

5. What personal data do we collect?
In accordance with the principle of data minimization, we ensure that we only collect relevant and necessary data on our site for predefined purposes.
Data is collected directly from you due to your activity on the site or may be collected indirectly through our partners.
Thus, in the context of data processing activities on our site, we may collect and process the following information about you, depending on your use of our site:

Source of collection	Processed data
When you browse the site	Browsing data: IP address, log data…
When you browse the site and have accepted cookies	Browsing data: historical IP address, browsing path…
When you create an account on our site	Identity: name, surname (you and your partner), partner company, country of residence, expatriation country, profile photo Professional experience: CV, years of experience, areas of expertise, languages spoken Contact data: email address, phone number Login data: login, password
When you use our contact form:	Identity: name, surname Contact data: email, phone, company Free comment area
When you leave a review or comment on our site	Identity: name, surname, pseudonym

Some data is necessary for the use of certain services that we would not be able to provide if processing is refused. You will be informed at the time of collection about the mandatory or optional nature of the data collected.

6. Why do we collect your data?
We collect your personal data for several legitimate purposes defined below:

Monitoring and usage statistics of our Site
Responding to any requests you may have on our site
Commercial prospecting
Creating your account on the site
Managing your account
Sharing your application with partner companies
Managing your complaints
Technical assistance and user support

7. What allows us to process your data?
Each data processing implemented on our site is based on at least one legal basis according to its purposes.
The table below specifies the applicable legal basis for each processing purpose:

Applicable legal basis	Processing purpose
Legitimate interest for …	Monitoring and usage statistics of our Site
	Responding to any requests you may have on our site
	Commercial prospecting targeting professionals related to their activity or for ancillary products.
	Managing your complaints
	Technical assistance and user support
Contractual execution or pre-contractual measures for…	Creating and managing your account on the site
Consent for …	Sharing your profile with partner companies

8. How long do we use your data?
The personal data we process is securely stored for as long as necessary to achieve the purposes for which it was collected.
Other durations may apply due to legal or regulatory constraints, recommendations from supervisory authorities, sectoral guidelines, or otherwise based on our needs regarding the purpose of processing.
The table below specifies the applicable retention periods for the data we process based on processing purposes:

Category of data	Applicable retention period
Profile data	For the entire contractual relationship
Application data	6 months renewed with each availability notification
Prospect data	3 years from the last contact with one of our services
Cookies	13 months

Furthermore, we inform our users that we may retain data beyond the announced periods for statistical purposes on our site. In this case, the data will be anonymized and will not be subject to any re-identification.

9. Who are the recipients of your data?
Depending on processing operations, your personal data may be intended for:

Our internal services
Internal services have access to data only within the limits of their activities and need to know.
Our processors:
Processors process personal data on behalf of and for Partner Talents.
When we use subcontracting, we only engage processors who provide sufficient guarantees and ensure strict contractual relationships in accordance with Article 28 of the GDPR.
For more details on who our processors are, we maintain an up-to-date list available to you.
Our partners:
We may share your data with our business partners when you have consented to this sharing. They process the data for their own account.
Authorities:
We may need to disclose your data to authorities to comply with any legal or judicial requests or when we need to defend our rights in court.

10. Are your data transferred outside the EU?
In the event of a potential transfer of your personal data to third countries outside the European Union, Partner Talents commits to respecting the conditions required by the GDPR, notably by using providers located in countries offering an adequate level of data protection, utilizing the various legal tools defined by the GDPR and national and European legislation.

11. How is your data secured?
We are committed to ensuring the highest level of protection for the personal data entrusted to us, which is why we implement numerous technical and organizational measures to limit access to your Data and ensure their availability and integrity.
This includes the physical security of our premises, the security of our IT systems, as well as internal governance measures to limit access to the data.

12. Your rights regarding your data
In accordance with the GDPR, you have the following rights regarding your data, which you can exercise at any time and free of charge, upon proving your identity, subject to the limits attached to certain rights.

Right of access
You have the right to request access to your data or to obtain a copy.
Right to rectification
You have the right to rectify information you believe to be inaccurate or outdated, or to complete information you think is incomplete.
Right to erasure
You have the right to request the deletion of your personal data in certain circumstances, when they are inaccurate, incomplete, ambiguous, outdated, or when their collection, use, communication, or retention is unlawful.
Right to restrict processing
You have the right to request that we restrict the processing of your data in certain circumstances.
When processing has been restricted, this data may only be processed with your consent, for the establishment, exercise, or defense of legal claims, for the protection of another individual or entity's rights, or for reasons of public interest.
Right to object
You have the right to object at any time for reasons related to your particular situation, to the processing of personal data concerning you.
However, the exercise of this right may be denied for justified reasons in the following cases:
Compliance with a legal obligation
Compelling legitimate grounds for continuing to process the said data
For the establishment, exercise, or defense of legal claims.
When processing is based on the legal grounds of consent or contractual execution, unless you withdraw your consent or terminate your contract.
Right to data portability
You have the right to request that we transfer your information that you have provided to us to another organization in certain circumstances.
This right only applies if your data is processed automatically (paper files are therefore not concerned) and based on your prior consent or the execution of a contract concluded with you.
Right not to be subject to automated decision-making
You have the right to refuse to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.
Right to define directives regarding your data after your death
You can provide us with directives regarding the retention, deletion, and communication of your personal data to be implemented after your death.

13. How to exercise your rights regarding your data?
To exercise your rights, please send your request as follows:
By email to: [email protected]
Partner Talents commits to responding to requests for exercising rights within one (1) month from the receipt of the request. This period may be extended to two (2) months if the request is complex; in this case, the concerned individual will be informed.

14. Possibility to contact the supervisory authority
If you believe, after contacting us, that your rights regarding your data are not being respected, you may file a complaint with the CNIL.
CNIL – Complaint Service
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07

15. Updating the policy
We may update this policy according to legal developments or changes in our activities.
We will inform you of any updates made and invite you to consult it regularly to be aware of the changes made.