Personal data protection policy - Candidates
A PERSONAL DATA PROTECTION POLICY WITH A PURPOSE
Respecting your privacy and personal data
- We respect your privacy and your choices.
- We ensure that privacy and security issues are at the heart of everything we do.
- We will only send you marketing communications if you have asked us to do so. You can change your mind at any time.
- We will not share or sell your data.
- We are committed to securing and protecting your personal data. This means that we only work with trusted partners.
- We are committed to openness and transparency about how we use your data.
- We will not use your personal data in ways that we have not made known to you.
- We are respectful of your rights and will always strive to accommodate your requests to the extent possible within our own legal and operational responsibilities
In order to further explain our data protection and privacy practices, we set out below the different types of personal data we may obtain directly from you or as a result of your interaction with us, how we may use it, with whom we may share it, how we protect it and ensure its security, and the rights you have in relation to your personal data. Of course, not all of these situations may apply to you. This privacy policy is intended to give you an overview of the range of situations in which we may interact with each other.
The more you communicate with us and provide us with information about yourself, the better we are able to provide you with personalised services.
When you provide us with personal data or when we collect personal data from you, we will use it in accordance with this Policy. Please read this information carefully, as well as our Frequently Asked Questions (FAQ) page. If you have any questions or concerns about your personal data, please contact us at [email protected].
WHO ARE WE?
QUI SOMMES-NOUS ?
CTRP, Centre Thermal de la Roche Posay is responsible for the personal data you provide to us. The terms "CTRP", "we", "us" or "our" used herein refer to the CTRP company. In accordance with the applicable regulations on the protection of personal data, CTRP is the "data controller".
CTRP, a simplified joint stock company with a capital of 5,647,105.00 euros, whose registered office is located at 4 Cours Pasteur - 86270 La Roche Posay, registered in the Poitiers Trade and Companies Register under the number 533 334 660 RCS, intra-community VAT number FR50 533334660.
Representative : Mr. Julien PRINCE
CTRP is part of the L'Oréal Group.
Who is concerned?
WHAT IS A PERSONAL DATA?
"Personal data" means any information that can identify you directly (e.g. your name) or indirectly (e.g. through pseudonymised data such as a unique identifier). This means that personal data includes information such as postal/email addresses, mobile phone numbers, usernames, profile pictures, personal preferences and shopping habits, user-generated content, financial data and information relating to your beauty/wellbeing. Personal data may also include unique numerical identifiers such as the IP address of your computer or the MAC address of your mobile device, and cookies.
WHAT DATA DO WE COLLECT FROM YOU AND HOW DO WE USE IT?
How do we collect and recieve your personal data?
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Provide you with the service you have opted for
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To assess your candidacy for a position to be filled;
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For the use of certain tools in the context of recruitment.
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For compliance with legal obligations.
Summary table of purposes, data processed, basis of processing
In what context can your personal data be collected?
Browse online
Information collected via cookies or similar technologies, when you browse our sites (or from third parties acting on our behalf).
What personal data are we likely to hold about you?
Browsing information:
Pages visited
Viewed videos
Content you clicked on
Jobs you searched for
Duration of your navigation
Jobs selected
Information about your device:
IP address
Your Location, depending on your browser settings
What can we use your data for?
Allow the proper functioning of our sites:
Adapt our sites to your profile, your language, your personal settings, etc.
Improve our sites, for example by testing new ideas on them.
Ensuring the security of our sites
Protect you from fraud or misuse of our sites and services, for example through incident detection.
Establish statistics: Avoid visitors to be registered twice.
Study the reaction of users to advertising campaigns.
To provide you with selected services:
Provide you with job recommendations based on your browsing history,
Provide you with content tailored to your profile and interests;
Allow, where appropriate, the sharing of content on social networks
On what legal basis is the processing of your personal data based with regard to the purpose of processing?
Legitimate interest
Consent
Data retention period
6 months
Access with your Linkedin Profile
What personal data are we likely to hold about you?
Fields of your "basic profile" from your Linkedin Connect Profile, such as: last name, first name, function, location, professional field, etc.
What can we use your data for?
-Personalize your browsing and offer you content and job recommendations
On what legal basis is the processing of your personal data based with regard to the purpose of processing?
Consent
Data retention period
3 months max
Apply for a job offer
On our site
What personal data are we likely to hold about you?
Name, email, address, telephone number
Languages, photo, age
Professional experience, CV
School and university career
Professional preferences
Social media profile, if shared
What can we use your data for?
Skills assessment from a recruitment perspective
Management of your application in connection with your request
Establish statistics, improve our tools and our service offer
On what legal basis is the processing of your personal data based with regard to the purpose of processing?
Consent
Legitimate interest
Data retention period
2 years max
Follow the recruitment process for interviews and assessments
What personal data are we likely to hold about you?
Identification data (name, address, tel, email, photo, etc.)
Professional data (CV, career and experience, diplomas, voluntary activities, etc.)
Letter of application
Possible video
Recommendations
What can we use your data for?
Organizing the recruitment process and interviews
Assessing skills with a view to recruitment
Reimburse recruitment-related expenses
On what legal basis is the processing of your personal data based with regard to the purpose of processing?
Consent
Data retention period
2 years max
WHO CAN ACCESS YOUR DATA?
We can communicate your data within the company CTRP, in a limited way
Your Data may be viewed by:
The people who need to know them as part of their functions within the company CTRP, access rights have been defined internally for this purpose. Your personal data is thus sent to the Human Resources department as well as to the department concerned by the offer.
We may communicate your data for commercial prospecting purposes only with your consent.
- We do not communicate your Data to third parties for commercial prospecting purposes.
- In this context, your Data is processed by the third party or entity in question, which acts as data controller, and is subject to its general conditions and its Data protection policy, separate from the present ones. We recommend that you carefully check these documents before consenting to the communication of your Data to this third party.
Your data may be processed on our behalf by trusted service providers
We may share your Data with some of our service providers who need to have access to some of your Data to perform the mission entrusted to them, including some who are outside your country. In this case, CTRP imposes strong obligations on these co-contractors in terms of processing, confidentiality and security of the Data to which these service providers have access. Thus, we only provide them with the Data they need to perform the service and require them not to use your Data for other purposes.
In this context, your Data may in particular be transmitted to:
third parties who assist us and help us to provide and make available to you digital tools and services (e.g.: a platform for centralizing job offers within CTRP for France, etc.),
third parties who provide us with solutions and tools for interviewing candidates using new technologies (such as online interview, video presentation, chatbot)
third parties who assist us and help us provide IT services, such as platform providers, hosting services, maintenance services and technical support for our databases as well as for our software and applications which may contain data about you (these services may sometimes require access to your Data in order to perform the tasks requested);
third parties who assist us in securing and monitoring our premises.
We may communicate your data to third parties in certain specific cases
- If we proceed or plan to proceed with the transfer of an activity or assets (by any means whatsoever, including by transfer of the company carrying out this activity or owning these assets), we may communicate your Data to the acquirer of this activity or these assets and to potential acquirers in the context of an audit, including their advice.
- If CTRP or any part of its assets are acquired by a third party, the Data held concerning the candidates and linked to these assets will be one of the transferred assets. If applicable, in the latter case, your Data will be processed by the acquirer who will act as the new data controller and its Data protection policy will then govern the processing of your Data.
- If we are forced to disclose or share your Data to comply with a legal obligation, or to enforce or apply our contract of collaboration with you or any other circumstances that you have accepted; or to protect the rights, property, or safety of CTRP, its customers, or its employees;
- If we have your consent to do so; Or
- If the law allows us to.
We do not give or sell your Data.
HOW LONG DO WE KEEP YOUR DATA?
Some of our websites and applications allow users to upload their own content. We remind you that any content transmitted to one of the social networks that we use may be accessible to the public. Thus, we invite you to exercise caution with regard to the communication of certain personal data such as financial data or an address. We are not responsible for any actions taken by third parties in the event that you post personal data on one of our social networks, and we recommend that you do not communicate this information.
Where do we store your personal data?
Localisation of your data
- Your Data may be transferred, accessed and stored in a country outside the European Economic Area (the “EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers.
- The company CTRP proceeds to the transfer of Data outside the EEA only in a secure manner and in compliance with the legislation in force. As some countries may not have any law governing the use and transfer of Data, we undertake to take all necessary measures to ensure that the third parties concerned comply with the conditions provided for in this Policy. These measures may include a control of the standards applied by these third parties in terms of Data protection and security and/or the signing of appropriate contracts (e.g. the standard contractual clauses adopted by the Commission of the European Union)
Security process
- We take all useful and reasonable precautions with regard to the nature of the Data and the risks presented by their processing, to preserve the security of the data and, in particular, to prevent them from being distorted, damaged, or that unauthorized third parties have access.
- In addition, we require third-party service providers who have access to your Data on our behalf to do the same, by contractual means.
- However, since the transmission of Data via the Internet is not completely secure, we cannot guarantee the security of your Data which is transmitted via the Internet.
Social media and user-generated content
We decline all responsibility for any action by third parties relating to the content you post on our social media.
Your rights and choices
The right to be informed
You have the right to receive clear, transparent, understandable and easily accessible information about how we use your personal and your rights. That is why we provide you with information in this Policy.
The right of access
You have the right to access the personal data we hold about you (subject to certain restrictions). We may require payment of a reasonable fee taking into account the administrative costs incurred in providing the information.
Requests that are manifestly unfounded, excessive or repeated requests may not be answered. To exercise your right of access, please contact us using the details below.
The right of rectification
You have the right to request that your personal data be rectified if it is inaccurate or outdated and/or be completed if it is incomplete. To exercise your right to rectification, please contact us using the details below. If you have an account, it may be easier to change your own data via the "My Account" function.
The right to erasure / the right to be forgotten
In certain cases, you have the right to obtain erasure or deletion of your personal data. This is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate. If you would like us to delete your data, please contact us using the details below.
The right to object to marketing including profiling
You can unsubscribe or object to receipt of our commercial prospecting messages at any time. Simply click on the unsubscribe" link in any email or communication we send you. You can also contact us using the contact details below. If you wish to object to any profiling, please contact us using the details below.
The right to withdraw consent at any time for data processing based on consent. You can withdraw your consent to the processing of your data if that processing is based on consent. Withdrawal of consent does not undermine the lawfulness of the processing based on consent prior to the withdrawal of consent. We invite you to consult the table inserted in the section "What personal data do we collect from you and how do we use it? and in particular the column "What is the legal basis for the processing of your personal data by us?, to find out whether our processing is based on consent.
If you wish to withdraw your consent, please contact us using the details below.
The right to object to the processing of data based on legitimate interest
You may at any time object to the processing of your data where the processing is
based on legitimate interest. We invite you to consult the table inserted in the section "What personal data we collect from you and how do we use it?, to find out whether our processing is based on legitimate interest. If you wish to exercise your right to object, please contact us using the contact details below.
The right to lodge a complaint to a supervisory authority
You have the right to have recourse to and lodge a complaint to the data protection authority (the CNIL) to challenge CTRP's data protection practices, with regard to the protection of personal data and respect for privacy. We invite you to contact us at the address below prior to making any complaint to the the relevant data protection authority.
The right to data portability
You have the right to move, copy or transmit data about you from our database to another. This only applies to data that you have provided, where the processing is based on your consent or on a contract, and is carried out using automated processes. Please refer to the table in the section "What personal data do we collect from you and how do we use it?, and in particular the column "What is the the legal basis for the processing of your personal data by us", to find out whether our processing is based on contract or consent. For further information, please contact us, see the details below.
The right to restrict processing
You have the right to request a restriction on the processing we carry out on your data
about you. This right means that the processing of your data by us is limited so that we can keep the data, but not use or process it.
This right applies in special circumstances as set out in the circumstances set out in the General Data Protection Regulation, namely:
- The accuracy of the personal data is challenged by the data subject (i.e. you), for a period of time the data controller needs to verify the accuracy of the personal data;
- The processing is unlawful and the data subject (i.e. you) objects to their erasure and instead requires the restriction of use of the data;
- The controller (i.e. CTRP) no longer needs the personal data for the purposes of the processing but it is still necessary for the for the establishment,
- the exercise or defence of legal claims; the data subject (i.e. you) has objected to the processing on the basis of the legitimate interests pursued by the controller during the verification of whether the legitimate grounds pursued by the controller override those of the data subject.
If you wish to obtain the restriction of the processing, please contact us using the contact details below.
The right to deactivate cookies
You have the right to deactivate cookies. The settings of Internet browsers are set to accept cookies by default, but you can easily change cookies. You can easily transform this by changing your browser settings.
Many cookies are used to improve the usability and operation of websites/applications, therefore, disabling cookies may prevent you from using certain parts of this website, as explained in the relevant cookie table. If you wish to restrict or block all cookies that are set by our websites/applications (which may prevent you from using certain parts of the site), or by other applications, you can do so by going to your browser settings. The Help function of your browser will tell you how to do this. For more information, you can consult the following link: http://www.aboutcookies.org/
In order to respond to your request, we may require proof of identity.
Nous contacter si vous avez des questions ou souhaitez exercer vos droits
If you have any questions or comments about the way we process and use your personal data, or if you wish to exercise any of your rights mentioned above, please contact us at the following e-mail address: [email protected] or write to us at the following address Centre Thermal de La Roche-Posay, 4 cours Pasteur - 86270 La Roche Posay
You can also contact our DPO at the following address: [email protected]
SPECIAL PROVISIONS FOR FRANCE
We remind you that in accordance with the provisions of article 85 of the modified law 78-17 of 6 January 1978, you have the right to formulate general directives (with a trusted digital third party certified by the CNIL) or particular directives (with the data controller) relating to the conservation, deletion and communication of your personal data after your death.