PERSONAL DATA PROCESSING POLICY

This data processing policy sets out the way in which we manage the processing of personal data collected on our Website.

 Our data protection policy may be amended at any time. Please ensure that you check it regularly.

 Any individual connecting to or using our Website hereby acknowledges that he/she has read this data processing policy in full at the time of connection.

 Data controller

 SNETOR, a French simplified joint stock company (société par actions simplifiée) with share capital of €15,000,194.85, registered in the Nanterre Trade and Companies Register under number 300 960 622, having its registered office at 11 Avenue Dubonnet, 92400 Courbevoie, France – Tel.: 33 (0) 1 49 04 88 88, is the data controller of the personal data collected.

SNETOR ensures the security of your personal data via an enhanced data protection mechanism through the use of appropriate physical, technical or organisational security methods, designed to prevent the data from being modified, damaged, destroyed or disclosed to unauthorised third parties, including protection against the unauthorised or unlawful processing of such data and against loss, destruction or accidental damage.

SNETOR hereby undertakes to protect your privacy as well as the confidentiality of the data disclosed, pursuant to the EU General Data Protection Regulation no. 2016/679 (the “GDPR”) and the French Data Protection Act no. 78-17 dated 6 January 1978, as amended.

The Data Protection Officer (DPO) appointed at SNETOR is Mr Laurent Jubault.

Collection and purpose of the personal data processing

 1/ Our Website lets you apply for jobs listed on the site and send an unsolicited application via an online form, in which you are asked to enter your personal data, such as your full name, address and email address, and to submit your CV and cover letter.

Data collected from a response to a job offer or an unsolicited application is sent to the SNETOR Human Resources Department, which is in charge of applications and hiring.

2/ Data collected via contact forms you may fill out, such as your full name, company name, position, country, email address, or phone number, are required in order to be able to respond to your requests, and is disclosed to authorised staff at SNETOR for administrative and commercial management purposes, with a view to processing the request and managing the business relationship as efficiently as possible.

This data enables SNETOR to contact you, as a representative of SNETOR’s current or prospective client, and not as a private individual, by phone or email, regarding our sales offerings, products and services, pursuant to the provisions set out below.

In both situations mentioned above, the data we collect via our Website is obtained from the voluntary disclosure of your professional and/or personal data. By providing your data on our Website, you thereby grant your express consent to SNETOR collecting your data.

The data thus collected will always be obtained and processed fairly and in accordance with applicable legislation. It will be recorded for specific and legitimate purposes and will be used in accordance with such purposes.

The data collected in this way shall be appropriate, relevant and not excessive in relation to these purposes.

No personal data collected on our Website is disclosed or sold to third parties for commercial or other purposes.

You may withdraw your consent at any time, specifically by stating that you no longer wish to receive emails, by clicking on the link provided for this purpose, or by contacting us directly at the postal address provided herein (see section “Your rights” below).

Retention period

 The personal data provided and any information relating to your browsing history on our Website will be retained for a period not exceeding that which is necessary for the purposes for which they are processed, and within the limits of the applicable limitation periods.

Regarding hiring data, the maximum retention period is two years following the most recent interaction with the applicant.

With regard to data collected via online contact forms, the retention period is that which is necessary for the processing of the request and/or business relations.

Browsing data will be retained for a maximum period of six months, pursuant to CNIL recommendations.

You may request additional information should you have a specific question about these retention periods.

Your rights

In accordance with applicable regulations, you have rights over your data, namely:

  • A right to object at any time, in the event of an objection to the legitimacy of the grounds for the processing by the data controller (pursuant to Art. 21 of the GDPR);
  • A right to access your data held by the data controller for inspection and verification purposes (pursuant to Art. 15 of the GDPR);
  • A right to the rectification of incorrect data (pursuant to Art. 16 of the GDPR);
  • A “right to be forgotten” (pursuant to Art. 17 of the GDPR);
  • A right to the restriction of processing (pursuant to Art. 18 of the GDPR) ;
  • A right to data portability from another data controller (pursuant to Art. 20 of the GDPR);
  • The right to give instructions regarding your data after your death (pursuant to Article 40-1 of the “Lemaire” Act relating to a digital economy, dated 7 October 2016).

Finally, you also have the right to information in the following circumstances:

  • The right to be informed within one month of action taken on a request (pursuant to Art. 12 of the GDPR);
  • The right to be informed of any corrections, deletions or restrictions (pursuant to Art. 19 of the GDPR);
  • The right to be informed as soon as possible in the event of a breach of data likely to result in a high risk to their rights or freedoms (pursuant to Art. 34 of the GDPR).

 You can exercise your rights at any time by sending a letter to the following address:

SNETOR
HR Department
11 avenue Dubonnet
92407 COURBEVOIE CEDEX – France

In accordance with applicable regulations, you request, when it is sent by letter, must be signed and submitted together with a photocopy of an identification document including your signature, and must state the address to which the response must be sent.

However, applicants are hereby informed that exercising their right to withdraw their consent or their right to erase their personal data – which would be vital for the hiring process, i.e. their full name, address and email address – will result in the automatic closure of their Account, and they shall be considered to have retracted their application.

Finally, you are entitled to submit a complaint to the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés or CNIL) if you believe the processing of your data constitutes a breach of applicable legislation.

Cookies

 A cookie is a block of data that serves to record information relating to a user’s browsing on a website, but which does not make it possible to identify said user.

Traffic data and cookie files that SNETOR stores on your computer are intended to recognise a user during their next visit to the site, and to enable SNETOR to conduct internal visitor and statistical analyses via Google Analytics, within the limits of the cookie’s validity or storage periods.

The purpose of SNETOR’s statistical analyses is to improve site ergonomics, thereby enhancing the user experience.

User browsing data is not linked to identified users; this refers to aggregated data.

None of this data enables Google to identify the user, in accordance with its rules of confidentiality.

If the user does not delete their cookies (via Tools/Internet Options on their browser), this data is stored permanently on their computer.

Pursuant to recommendations issued by CNIL, when you first connect to our Website, you will be asked to expressly accept the Website’s cookies.

This consent is granted for a maximum validity period of 13 months.

SNETOR hereby informs you that you may object to the storage of cookies at any time by simply configuring your browser.

More information about cookies can be found on the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser