Privacy Policy

PRIVACY POLICY
1. GENERAL PROVISIONS
This Privacy Policy is part of the Legal Notice of the website and shall apply to any user of www.complexcoup.fr. This Privacy Policy describes the processing related to personal data which may be collected by ComplexCoup when the user has access and uses the Website.

2. DEFINITIONS AND PERSONAL DATA COLLECTION
By using the website and providing personal information, the user consents to the collection and use of their personal data according to this personal data Privacy Policy.

ComplexCoup determines the purposes and means of the personal data processing and therefore acts as controller in accordance with the regulations applicable to personal data and in particular the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation “GDPR”).

“Personal data” is defined as any information relating to a directly or indirectly identified or identifiable person, in particular by reference to an identifier such as a name, first name, email address, IP address, etc.

“Personal data processing” is defined as any operation or collection of operations carried out with or without the use of automated procedures and applied to data or collections of data of a personal nature, such as collection, recording, organizing, storing, modification, consultation, use, distribution, deletion, destruction, etc.

A “purpose” is defined as the aim pursued by the implementation of processing, the reason for which the data are collected.

Applying a transparent approach, personal data are collected and processed in a fair and lawful manner. The collected data are suitable, relevant and not excessive in relation to the purpose for which they are collected.

These purposes are mainly the creation of a contact, an applicant profile, or a search agent on the recruitment pages.

Data collected in this way by ComplexCoup are retained for a limited duration determined by the purpose of the processing, regulatory requirements, the recommendations of the supervisory authority.

3. REQUIRED OR OPTIONAL
Information identified as required, particularly in the contact form or on the recruitment pages, is essential for processing your request or application. Its status as required or optional is shown during collection. If the information is incomplete, ComplexCoup will not be able to respond to your request.

4. APPOINTING A DATA PROTECTION OFFICER
ComplexCoup has chosen freely to appoint a Data Protection Officer (DPO) as guarantor of ComplexCoup’ compliance with personal data protection regulations.

5. USER RIGHTS
The user has a right of access, to rectification, to erasure, to object, to restriction of processing, to data portability.

Right of access to data: the user may make a direct request to ComplexCoup for information about data and processing affecting them;
Right to rectification: if ComplexCoup is holding obsolete or incorrect data, the user may request the rectification of incorrect, incomplete, ambiguous or expired data;
Right to erasure (right to be forgotten): the user may ask ComplexCoup to delete their personal data if they are not necessary or for any other reason stipulated in law;
Right to object to use: the user may object, at any time and no cost, to processing of their data, pursuant to legal provisions and particularly when their data are processed for direct marketing purposes;
Right to restriction: the user also has the right to limit the processing of their data, pursuant to legal provisions;
Right to data portability: the user has the right to receive their personal data in a structured, commonly used and machine-readable format (this right applies only to cases where the personal data is provided by the user and processed with their consent or for the execution of a contract).
Finally, the user has a right of decision over the disposal of their data post-mortem.

These rights can be exercised, provided that the person justifies their identity, on simple written request sent by e-mail to the following address DPO@ComplexCoupgroup.com or by post to the Data Protection Officer at the following address: ComplexCoup, 3 Rue Drouot, 75009 Paris.

The user has the right to lodge a complaint with the supervisory authority of their country.

In France, the supervisory authority is the “Commission Nationale Informatique et Libertés (CNIL)” reachable online on www.cnil.fr/fr/plaintes or by mail at the following address: 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.

The contact information of the European supervisory authorities of the countries in which ComplexCoup operates is available on the “Data Privacy” page of this website.

6. RECIPIENTS OF PERSONAL DATA
The user is informed, prior to the collection of their data, that their data can be transmitted to partners acting as Processor (as defined in GDPR) in the execution of the data processing of the personal data concerned by this collection.

The data collected is only intended for the use of the internal services of ComplexCoup companies. The personal data collected is not subject to any communication to external third parties. ComplexCoup does not sell personal data to third parties.

ComplexCoup reserves the right to report to the authorities any activity on the website of a user that may be illegal and to disclose any information about users of the site to meet legal requirements.

7. COOKIES
When the user visits the ComplexCoup website, cookies may be installed on their device (computer, tablet or smartphone), for a maximum period of 13 months from their installation.

Different cookie types used on our website:

– Traffic counter cookies

These are Google Analytics cookies which track the user’s visit, to establish traffic statistics and monitor the performance of the website and each of its pages. These data enable ComplexCoup to enhance and improve flow in the user’s experience of the website. These cookies require your consent. On your first visit to one of our websites, a banner appears on the arrival page and a clickable link can be used to refuse installation of traffic counter cookies. Continuing to navigate to another page on the website or selecting an item on the website (picture, link, search button, etc.) constitutes your acceptance of the installation of these cookies on your device. If you refuse the installation of these cookies, they will not be installed on your device.

– Cookies promoting job offers on the dedicated recruitment pages

These cookies, with a maximum life of 12 months, promote job offers to candidates who visit the dedicated recruitment pages of the ComplexCoup website.

The user may oppose the installation of all cookie types using their browser settings (if their browser has this functionality). Refusal to authorise certain cookies may impair the proper functioning of the website.

8. LINKS TO OTHER WEBSITES
ComplexCoup Website contains links to other websites owned by any third party for whom ComplexCoup has no control on the content and where ComplexCoup cannot be held liable.

ComplexCoup cannot be held responsible for the processing of personal data, the content and the use of any websites owned by any third party or any link contained in a linked website, or any changes or updates to such websites and to which access by the user shall be at his own risk and peril.

The user is requested by ComplexCoup to study the processing of personal data, applied to the website owned by any external third parties and also check the terms of the processing of personal data when the user clicks or interacts with a link leading to a website owned by any external third party.

9. MODIFICATION
ComplexCoup shall have the right to update and amend the provisions of this Privacy Policy when ComplexCoup deems necessary and without prior notice. The user is invited to read on time to time basis the terms of this Privacy Policy.

Note that in case of disagreement between the French version and the English version, the French version prevails

PERSONAL DATA

This Privacy Policy applies to all European companies of the ComplexCoup group.

1. General Provisions

ComplexCoup attaches the utmost importance to the protection of personal data as well as compliance with legal and regulatory obligations in this area.

The purpose of this Privacy Policy is to provide third parties with clear and transparent information about how their data is processed by ComplexCoup.

ComplexCoup determines the purposes and means of all the processing of personal data and therefore acts as controller in accordance with the regulations applicable to personal data and in particular the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation “GDPR”).

2. Definitions and personal data collection

A “purpose” is defined as the aim pursued by the implementation of processing, the reason for which the data are collected.

3. Purposes of processing and legal bases

To realize its business, ComplexCoup collects data from customer contacts for the purposes of customer management and business relationship monitoring, ComplexCoup collects data from prospect contacts for commercial prospecting purposes, ComplexCoup collects data supplier contacts for the purpose of managing the business relationship.

On its online recruitment platform, ComplexCoup collects candidate data for recruitment management purposes.

The processing of data carried out by ComplexCoup is based on the legal basis of the performance of a contract, pre-contractual measures or the legitimate interest of ComplexCoup. As part of the commercial prospecting activities, ComplexCoup ensures compliance with the consent of customers and prospects.

Personal data collected by ComplexCoup are not used for purposes other than those described above.

4. Categories of data processed

The third-party contact data collected by ComplexCoup is mainly identification data (first name, first name, professional email address, professional telephone numbers, business address) necessary to monitor the commercial relationship between ComplexCoup and its partners.

As part of the management of applications and recruitment, the following categories of data are collected by ComplexCoup: identification data (name, surname, email address, telephone number) data relating to working life (CV and cover letter).

5. Duration of storage

The data thus collected by ComplexCoup are kept for a limited period of time depending on the purpose of the processing, the regulatory obligations or the recommendations of the supervisory authorities.

The data relating to the management of the commercial relationship are kept for a maximum of 5 years after the end of the commercial relationship for the customers and 3 years after the last contact for the prospects.

Data on the management of applications are deleted after 2 years for applications that have not resulted in recruitment.

6. Recipients of personal data

The data collected is intended for the internal services of ComplexCoup as controller in charge of the data processing.

The collected data may be transmitted to partners or subcontractors as processors involved in the data processing.

The personal data collected is not subject to any communication to third parties for the purposes of commercial prospecting without the consent of the person concerned. ComplexCoup does not sell personal data to third parties.

7. Data transfers

The collected data may be transferred to a country outside the European Economic Area (EEA). In this case, ComplexCoup ensures that the transfer is framed by appropriate legal safeguards.

8. Data Protection Officer

The ComplexCoup Group has freely chosen to appoint a Data Protection Officer (DPO) to ensure compliance with the regulations on the protection of personal data by the Group companies concerned.

9. Data security

ComplexCoup places great importance on the confidentiality and security of data and puts in place technical and organizational measures to protect the personal data it collects and / or processes against any loss, destruction, alteration, access or unauthorized disclosure.

10. Rights of the data subject

Any data subject has a right of access, to rectification, to erasure, to object, to restriction of processing, to data portability.

Right of access to data: the data subject may request directly to ComplexCoup information about data and processing affecting them;
Right to rectification: if ComplexCoup is holding obsolete or incorrect data, the data subject may request the rectification of incorrect, incomplete, ambiguous or expired data;
Right to erasure (right to be forgotten): the data subject may ask ComplexCoup to delete their personal data if they are not necessary or for any other reason stipulated in law;
Right to object to use: the data subject may object, at any time and no cost, to processing of their data, pursuant to legal provisions and particularly when their data are processed for direct marketing purposes.
Right to restriction: the data subject also has the right to limit the processing of their data pursuant to legal provisions.
Right to data portability: the data subject has the right to receive their personal data in a structured, commonly used and machine-readable format (this right applies only to cases where the personal data is provided by the user and processed with their consent or for the execution of a contract).
Finally, the user has a right of decision over the disposal of their data post-mortem.

The data subject has the right to lodge a complaint with the supervisory authority of his country.