Privacy Policy and
Personal Data Protection

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Introduction

The General Data Protection Regulation (GDPR) follows on from the French “Data Protection Act” of 1978, as amended by the Act of 20 June 2018 relating to the protection of personal data, which establishes rules governing the collection and use of data within French territory. It was designed around three main objectives:

  • strengthening individuals’ rights;
  • increasing the accountability of entities processing data;
  • enhancing regulatory credibility through reinforced cooperation between data protection authorities.

This Privacy Policy describes how we collect and process the personal data of users browsing our Digital Platforms, as well as of any individual using or benefiting from our Services. It applies to all processing of personal data carried out through our websites and mobile applications (the “Digital Platforms”) and complements the General Terms of Use or General Terms and Conditions of Sale applicable to our products, as well as the Contribution Policy governing the moderation of online content on the Digital Platforms.

Its purpose is to inform you about the methods used to collect and process your personal data, as well as the options and rights available to you.

This policy may be amended at any time, in particular to comply with regulatory, case law, editorial or technical developments. The version in force is the one published on our website.

For any additional questions, you may contact our Data Protection Officer, Serge Roukine, at the following address:
dpo@groupe-freeteam.com.

In all circumstances, we undertake to comply with the following principles:

  • your personal data are used solely for explicit, legitimate and defined purposes related to the Services provided;
  • only personal data that are relevant and necessary for these purposes are collected and processed.

Identification of the Data Controller

The Digital Platforms are published by Provisia SAS, acting as Data Controller, registered with the Trade and Companies Register under number 839 009 750, with registered offices at 14 avenue de l’Opéra, 75001 Paris, France.

This personal data protection policy informs you about the processing operations implemented by Provisia SAS, hereinafter referred to as the “Publisher” or “We”.

Provisia SAS is the data controller within the meaning of applicable personal data protection regulations, in particular Regulation (EU) 2016/679 (GDPR).

Purpose of Processing

We collect data in the context of your use of our Digital Platforms, our contractual relationships, or services to which you have subscribed or consented.

When using our Digital Platforms or subscribing to one of our Services, certain personal data are required, in particular to enable contractual performance. Failure to provide such data may prevent us from delivering the requested services or responding to your request.

We may also tailor the content of our Digital Platforms to your preferences or usage patterns, based on your interests. This may lead us, over time, to ask you about your preferences.

We also collect data in order to contact you directly or indirectly, including via partners, social networks or our service providers.

The purposes of such processing include: receiving personalised information about umbrella employment by email or phone; receiving a personalised salary simulation; receiving information about suitable training programmes.

The legal basis for this processing is your consent.

Categories of Personal Data Collected

Personal data are information relating to an identified or identifiable natural person.

Your personal data, as a visitor or user of the Digital Platforms, may be collected in the following situations:

  • from the Publisher’s partners, subject to your prior consent and information;
  • during visits to and navigation on the Digital Platforms;
  • when creating a personal account;
  • when placing an order, registering for training or subscribing to one or more Services;
  • during exchanges with the Publisher;
  • when subscribing to a newsletter.

The data collected may include: email address, postal address, date of birth, gender, first and last name, telephone number, IP address, connection dates and times, and browsing data.

We do not request sensitive personal data. You are asked not to provide such data voluntarily.

Where you contribute to recruitment areas, forums, blogs or brand communities on social media, published content will be visible to all users and will not be used for other purposes by the Publisher.

Optional information you provide may, under your responsibility, reveal sensitive data (e.g. ethnic origin, nationality, religion). By providing such information, you assume full responsibility for its disclosure.

Recipients of Personal Data

Your personal data may be processed by:

  • authorised members of the Publisher or Freeland group companies involved in your registration or service delivery;
  • authorised service providers;
  • IT, hosting, maintenance and secure payment solution providers.

Your data will not be shared with third parties without your consent, except where legally required.

Recipients are contractually and legally limited in their use of your data to the purposes identified by the Publisher and are subject to confidentiality and security obligations in compliance with applicable laws, including the GDPR.

Personal data may also be disclosed to comply with legal obligations (e.g. administrative authorities).

Current processors include: Brevo, RiseUp, Salesforce, Typeform.

Transfers Outside the European Union

The Publisher may use services whose servers or systems are located outside the European Union.

Such transfers are governed by appropriate safeguards in accordance with applicable regulations, including standard contractual clauses approved by the European Commission.

Cookie and tracking data may also be transferred outside the EU for hosting and processing related to advertising or audience measurement purposes.

Data Retention Periods

Personal data are retained only for as long as necessary to fulfil the purposes for which they were collected, including compliance with legal and accounting obligations.

Retention periods vary depending on data type and purpose and are regularly reviewed to ensure compliance with applicable law and CNIL recommendations.

In the context of these processing operations, data may be retained for up to three (3) years.

Data are deleted or anonymised once they are no longer required. Requests for deletion are honoured unless retention is required for legitimate interests or legal obligations.

Data Security

We implement appropriate technical and organisational measures to ensure the security, integrity and confidentiality of personal data and to prevent unauthorised access, alteration or disclosure.

Measures are adapted to the sensitivity of the data and the associated risks.

In the event of a personal data breach, affected individuals will be informed in accordance with applicable legal requirements.

However, no system can eliminate all risks. You are responsible for maintaining the confidentiality of your login credentials.

Security measures include (non-exhaustive):

  • password-protected access
  • encrypted connections
  • data processing agreements with processors

Exercising Your Rights

As a data subject, you have rights under the GDPR, including:

  • right of access
  • right to rectification
  • right to erasure
  • right to withdraw consent
  • right to data portability
  • right to object
  • right to restriction of processing
  • right to determine the fate of your data after death (where applicable)

Requests may be sent to:
dpo@groupe-freeteam.com.
Proof of identity may be requested where necessary.
Responses are provided within the timeframe set out in Article 12(3) GDPR.

You also have the right to lodge a complaint with a supervisory authority. In France, this is the CNIL.

Cookies

Cookies are small files or identifiers stored on your device when accessing the Digital Platforms.

They are used to secure navigation, measure audience statistics and improve content.

Cookies used include:

  • strictly necessary cookies
  • preference cookies
  • audience measurement cookies

Cookies may be placed by the Publisher, its service providers, partners or third parties.

Strictly necessary cookies are exempt from consent. Other cookies require prior consent, which may be given via the consent banner and is valid for up to six (6) months.

Refusal of cookies may affect navigation and functionality.

Browser settings can also be used to manage cookies (Chrome, Safari, Firefox, Edge).

The Publisher declines any responsibility for degraded functionality resulting from cookie refusal.

Revisions

Our activities evolve, and this policy may be updated accordingly. We encourage you to consult this page regularly. Substantial changes that would reduce the level of protection of previously collected personal data will not be implemented without the consent of the data subjects.