Privacy policy and cookies

(updated on 07 January 2023)

Easyliks SAS with a capital of 1000 € whose head office is located at 38 rue de la fraise - 24380 Eglise Neuve de Vergt, France, registered in the Perigueux Trade and Companies Register under the number 880 490 370 (hereinafter the "Company") which operates the Easyliks.com site (hereinafter the "Site") is committed to preserving the relationship of trust which links it to its users.

As such, we attach the greatest importance to the respect of your private life, the confidentiality, security and integrity of your personal data.

This is why we undertake to ensure that the collection and processing of personal information is carried out in accordance with EU Regulation No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as the "GDPR", as well as all of the provisions of the French regulations applicable in this area.

Cookies, other tracers or similar technologies (hereinafter "Cookies") may be deposited and/or read in your browser when you visit the Site.

1. WHO ARE THE DATA CONTROLLERS?

The Company that determines the purposes and means of the processing of personal data, i.e. the objective and the way in which it is carried out, is considered the data controller.

2. WHAT ARE THE LEGAL BASES FOR THE PROCESSING?

We process your personal data in accordance with the applicable regulations (Articles 6 and 9 of the GDPR). The processing of your personal data is based on the following legal grounds.

2.1 Your consent

(Article 6(1)(a), Article 7 and Article 9(2)(a) of the GDPR). The Company may process your personal data on the basis of the consent you have expressly given (by filling in a form on the Site, or by ticking a dedicated box for example). You may withdraw your consent at any time.

2.2 The execution of a contract

(Article 6(1)(b) of the GDPR). The Company will process your personal data for the purpose of establishing and performing a contract between you and the Company.

2.3 The fulfilment of a legal obligation

(Article 6, paragraph 1, point c) of the GDPR). The Company is subject to a number of legal obligations under the applicable regulations. The Company must therefore process some of your personal data to comply with these obligations.

2.4 Our legitimate interest

(Article 6(1)(f) of the GDPR). The Company may process your personal data for the purposes of legitimate interests pursued by the Company or by a third party, without prejudice to your rights and interests.

3. WHAT DATA IS COLLECTED?

In general, the Company undertakes to collect only personal data that is strictly necessary for the purposes described below (see What are the purposes of processing?).

The Company may collect and process information about you or individuals within your company in connection with the services provided by the Company.

3.1 your identification data

Company data for Recruiter/DSC/Bizbox account types: company name, company type, company number, country, VAT number, postal address, logo and company description.

User data for Recruiter/DSC/Bizbox account types: e-mail, title, surname, first name, language of use, job title, telephone, manager.

User data for the Candidate account type: e-mail, title, first name, surname, language of use, country, postal address, telephone, level of education, languages, profile, level of experience, type of contract, mobility, salary/daily rate, working hours, skills, training, work experience, photo, nationality, driving licence, Linkedin link and leisure activities.

3.2 Other data

your login and encrypted password used to identify you on the Site.

your commercial data (e.g. your order history).

your billing data (e.g. payment methods and history, transaction data, invoices).

your statistical and usage data relating to our communications (email, SMS, notifications).

your connection and usage data for our services (e.g. IP address, type of terminal, type and version of the browser you are using, operating system and the date and time of your access, etc.).

When your personal data is collected through a form, you are informed of the compulsory nature of the information by an asterisk (*) next to the relevant fields. The absence of an asterisk means that the information is not mandatory.

4. IN WHAT CONTEXTS ARE DATA COLLECTED?

In general, data is collected directly from you on the occasion of:

the creation and management of an online account (User Account).
subscribing to a subscription.
posting of Advertisements.
the creation of CVs.
your connection to our Site.
your navigation on the Site.
your use of our Services.
your sharing and interaction of our content with social networks.
your requests for information via the contact form.
the exercise of your rights relating to your personal data.

5. WHAT ARE THE PURPOSES OF THE PROCESSING OPERATIONS?

Why do we collect and process personal data and on what legal basis?

To respond to your request to provide services	Legal basis for processing
Create and manage your User Account	Performance of your contract with us
Access to our Service	Performance of your contract with us
Taking into account your cookie setting preferences	Your consent
Taking into account your subscription contract and its execution	Performance of your contract with us
Accepting your order for products or services and fulfilling that order	Performance of your contract with us
Billing	Performance of your contract with us
Collecting payments	Performance of your contract with us
Manage any unpaid bills and disputes	Performance of your contract with us
Manage your subscription to our email alerts	Votre consentement
Publish your Ads	Performance of your contract with us
Ensure customer relations: provision of a customer service accessible by mail, contact form, e-mail for any question or complaint	Performance of your contract with us or your consent or our legitimate interest
Check the quality of our services: collection of customer opinions, satisfaction surveys	Our legitimate interest
Update your information in a dedicated database, bring your address up to postal standards	Our legitimate interest
Send you information about changes or developments in our services	Our legitimate interest
To ensure the continuous improvement of our products and services, including through the use of advanced data analysis technologies	Our legitimate interest
To carry out studies and statistics on our existing products and services or in the context of the development of new products and services	Our legitimate interest

6. HOW LONG YOUR PERSONAL DATA WILL BE KEPT?

Your personal data is kept for a period of time that is in accordance with legal requirements or proportionate to the purposes for which it was collected. However, your personal data is kept for a longer period of time when required by legal and regulatory obligations.

Retention periods vary depending on the nature of our relationship:

we have an ongoing contractual relationship with you (you are an active customer).
we have had a past contractual relationship with you (you are an inactive customer).
we do not have a contractual relationship with you (you are a prospect or a User).

6.1 Data relating to a prospect

Data categories	Purposes	Retention periods
Data set	Creation and management of a file of prospects	3 years from the collection of the data or the last contact (1) from the prospect

6.2 Data relating to an active customer

Data categories	Purposes	Retention periods
Login data	Access to the service	For the duration of the contractual relationship
Data set	Management of the User Account, taking into account your subscription, your order, information alerts, customer relations, products and services, etc.	For the duration of the contractual relationship
Identification data collected in the contact form	Taking into account the submission of comments, contributions and opinions	3 years from the end of the contract
Payment data	Fee for service	Immediate deletion of data

6.3 Data relating to an inactive customer

Data categories	Purposes	Retention periods
Data relating to the execution of the contract, including name, first name, postal address	Management of the User Account, orders, invoicing, payments, accounting documents	10 years after the end of the contract or the last contact (1) from the inactive User
	Sending information on the evolution of our offers	3 years after the end of the contract or the last contact (1) from the inactive User
Identification and contact data	Sending information on the evolution of our offers	3 years after the end of the contract or the last contact (1) from the inactive User

6.4 Data relating to the Users of our services

Data categories	Purposes	Retention periods
Data set - User account	User Account Management	Not retained beyond the User's unsubscription or beyond 3 years from the last contact (1) from the User
Identification and contact data collected during a request for information	Information request	3 years from the date of collection of the data or the last contact (1) from the User
Data related to your navigation on our online services	To carry out studies and statistics on our services	6 months from the time the cookies are deposited on your device subject to your prior consent

6.5 Data relating to the exercise of your rights

Data categories	Purposes	Retention periods
Personal identification data provided in connection with a request to exercise a right (excluding identification)	Response to the data subject's request for a right	6 years from the request to exercise a right
Identification provided in connection with a request to exercise a right	Check the identity of the applicant	Not retained beyond the processing of the claim

6.6 Data relating to our cookies

Data categories

Purposes

Retention periods

Data related to your navigation on our online services

Operation and optimisation of services.

Measures of frequentation.

Consultation and usage statistics.

Sharing cookies (social networks)

13 months maximum from the time the cookies are deposited on your device

Retention of consent expressed on the Site

Collection of consent

6 months in case of acceptance.

2 months in case of refusal.

(1) Last contact: positive action on the part of the User / Customer / Prospect. For example, response to a survey, modification of his/her online account, click in an email, request for information, etc.

7. WHO HAS ACCESS TO YOUR PERSONAL DATA?

The following recipients may process the data according to their respective needs:

7.1 The Company's staff

Your data is communicated to employees of the Company's internal departments. In accordance with the regulations, access to your data is based on individual, limited and supervised access authorisations.

7.2 Our subcontractors

Your data is communicated to authorised subcontractors who provide services on our behalf, in particular:

the management of your subscription.
the management of e-commerce solutions (online sales).
online payment, invoicing, securing this payment and combating fraud.
electronic signatures for the SEPA mandate.
the management of the Advertisements.
the personalisation of the Site's content.
online studies and surveys.
digital reading solutions including video.
digital communications management (email, SMS, notifications).
the provision of analytical solutions or audience measurement statistics.
hosting, technical maintenance and development operations.

7.3 Social networks

The use of social networks to interact with our Site (in particular the "share" buttons on Facebook, Twitter, Linkedin, Youtube) or to connect via your social network account, is likely to result in the collection of your personal data by these social networks. We invite you to consult the personal data management policies of the various social networks to find out about the collection and processing of your data by them.

8. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

We store your personal data in the European Union. However, we may transfer your personal data to our subcontractors or partners located outside the European Union. In such cases, we ensure that the processing of personal data is carried out in a country considered to be a country with adequate protection or that the processing is legally regulated in order to guarantee a sufficient level of protection of the privacy and fundamental rights of individuals

Due to their presence on the Internet, our publications may be accessible outside the European Union.

9. HOW TO EXERCISE YOUR RIGHTS?

In accordance with legal and regulatory provisions, you have the following rights:

9.1 Right of access to your data (GDPR - art. 15)

You may request access to your personal data collected by us at any time. This information includes, in particular, the categories of data processed, the purposes of the processing, the origin of the data when we have not collected it directly from you, the intended period of retention of the personal data or, where this is not possible, the criteria used to determine this period and the recipients to whom we transmit your data, if applicable. You will be provided with a free copy of your data upon justified request.

9.2 Right of rectification (RGPD - art. 16)

You may request the Company to correct your personal data. We take all reasonable steps to keep the data we hold about you up to date, and we process it regularly, accurately and completely, according to the latest information available to us.

9.3 Right to erasure ("right to be forgotten") (GDPR - Art. 17)

You can request the deletion of your data if the following conditions are met:

the data is no longer necessary for the purposes for which it was collected or processed not in accordance with the information originally received.
you withdraw your consent, where consent is the sole and exclusive legal basis for processing the data.
you object to the processing of your data and there is no legitimate reason for the processing, or you object to the processing of your data for canvassing purposes.
the data has been processed unlawfully.

If you were a minor (under 15 years of age) at the time your data was collected, you benefit from an accelerated procedure for exercising your right to erasure. In this respect, the data controller has a maximum of one month to respond to you. Your request for the right to erasure may also concern the deletion of your online account.

By way of exception, your request for deletion will not be accepted where processing is necessary:

in order to comply with our legal obligations regarding retention periods.
to establish, exercise or defend legal claims.

9.4 Right to restrict processing (GDPR - Art. 18)

You can request the restriction of the processing of your data.

9.5 Right to data portability (RGPD - art. 20)

You have the right to receive the personal data you have provided to us in a commonly used and readable format, and the right to transfer that data to another controller.

9.6 Right to object to marketing profiling (GDPR - Art. 22)

Subject to your prior consent, cookies and other tracking devices allow us to infer your preferences, interests and use of our products and services from your browsing of our Site. Marketing profiling also results in the display of personalised advertising and content by us and some of our partners.

You can object to this processing at any time from our cookie consent platform accessible on our Site at the bottom of the page in the "Cookie settings" section by clicking on "Change your consent".

9.7 Right to object (GDPR - art. 21)

You may object to the processing of your personal data at any time, unless there is a legitimate reason for doing so that overrides your interests or we need your data for the establishment, exercise or defence of legal claims.

9.8 Deceased person having left instructions on the processing of his/her personal data (art. 85 of the amended Data Protection Act)

You can define directives concerning the conservation, deletion and communication of your personal data in the event of your death. In this case, these directives will be implemented at the request of the person responsible for their execution.

10. WHO TO SEND YOUR REQUESTS TO?

You can exercise your rights with the Data Protection Office by sending a letter to the following postal address: Délégué à la Protection des Données Personnelles Easyliks, 38 rue de la fraise 24380 Eglise Neuve de Vergt, France.

By sending an e-mail to the following address: rgpd@easyliks.com: rgpd@easyliks.com

In the interests of confidentiality and the protection of your personal data, we may ask you for proof of identity and additional information to enable us to process your request.

Response times: We will do our best to respond to your request within 30 days. However, this period may be extended for reasons related to the complexity of your request and the number of requests.

Recourse to the competent authorities: In the event of an unsatisfactory response, you may lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL): https://www.cnil.fr/fr/plaintes.

Before filing a complaint with the CNIL, we encourage you to contact us to resolve your request together.

11. HOW YOUR PERSONAL DATA IS PROTECTED?

As data controller, we take all necessary measures to preserve the security and confidentiality of the data and in particular to prevent it from being damaged or accessed by unauthorised third parties, including:

the appointment of a data protection officer.
a department dedicated to the security of information systems.
awareness of the confidentiality requirements of our employees who have access to your personal data.
securing access to our premises and IT platforms.
securing access to personal data, its sharing and transfer to our subcontractors.
the high level of data protection requirements when selecting our subcontractors and partners.

12. UPDATE OF THE PERSONAL DATA PROTECTION POLICY

This privacy policy may be changed or adjusted at any time. When necessary or required, we will inform you. We invite you to consult it regularly.