RECRUITMENT PRIVACY POLICY

This Privacy Policy was updated in October 2023.

INTRODUCTION

SYNACKTIV, "Société par actions simplifiées à associé unique" and share capital of €20,000, registered with the Paris "Registre du Commerce et des Sociétés" under SIREN number 750 913 634, with its registered office located at 5 Boulevard Montmartre, Paris (75002) (hereinafter the “Company”), attaches great importance to respecting the privacy of job applicants (hereinafter the “Applicant(s)”) and takes all necessary measures to ensure the confidentiality and security of Applicants' personal data, via the privacy policy presented for information below (the “Privacy Policy”).

PROTECTION OF PERSONAL DATA

Description of the processing of Candidates' personal data

In accordance with applicable laws and regulations, the Company, acting as data controller, collects personal data relating to Candidates. The categories of personal data collected, the purpose of processing this personal data, and the retention period are specified in the table below.

Purposes	Personal data collected	Legal basis for processing	Retention period
Management of applications, contacting the Candidate	First and last name, telephone number, email address, professional background, educational background, current and/or desired salary	Processing is based on the performance of pre-contractual measures	Destruction of the file if the Candidate is not selected, and up to two years from the last contact with the Candidate if they have given their consent to the retention of their file for this period
Assessment of skills during recruitment interviews, checking professional and educational background	Educational background, professional background, diplomas, certificates and attestations, foreign languages spoken	Processing is based on the legitimate interests of the Company	Destruction of the file if the Candidate is not selected, and up to two years from the last contact with the Candidate if they have given their consent to keep their file for this period
Response to any questions/complaints from the Candidate	Candidate's surname, first name, telephone number, email address	Processing is necessary for the purposes of the legitimate interests pursued by the Company	Up to one year from the date of the question/complaint submitted by the Candidate
Management of requests for access, erasure, portability of personal data, restriction of processing, rectification, and objection	Candidate's last name, first name, and email address	Processing is necessary in order to respond to Candidates' requests for their rights	Up to one year after the Candidate has exercised their right; up to three years after the Candidate exercises their right to object

The Company may collect personal data from Candidates through other sources, such as verification of the Candidate's educational background, previous professional experience, individuals recommending the Candidate and/or listed as references, and third-party websites such as LinkedIn.

The Candidate is informed that if they do not wish to consent to the provision of the requested personal data, the Company will not be able to consider their application for the job and/or internship.

Retention of Candidates' personal data

Candidates' personal data is retained only for the time necessary to fulfill the purpose for which the Company holds such personal data, in order to meet the needs of Candidates or to fulfill its legal obligations.

However, the Company may retain certain personal data in order to fulfill its legal or regulatory obligations, for archiving purposes, to enable it to exercise its rights and defend itself in the event of a dispute, and/or for statistical or historical purposes.

At the end of the periods mentioned above, personal data will be deleted or the Company will anonymize it.

Recipients and hosting of Candidates' personal data

The Company may be required to transmit Candidates' personal data to various technical and IT service providers acting as subcontractors.

Candidates' personal data may be transmitted by the Company to social security organizations and administrative and judicial authorities in accordance with applicable laws and regulations.

Candidates are informed that, as part of the recruitment process, the Company uses MobiSkill, which hosts data on servers in France.

Candidates' personal data is therefore not transferred outside the European Economic Area.

Security measures

The Company ensures the security of Candidates' personal data by implementing appropriate technical and organizational measures to guarantee a level of security appropriate to the risk, such as pseudonymization and encryption of Candidates' personal data, any means of ensuring confidentiality, the integrity, availability, and resilience of processing systems and services at all times, any means of restoring the availability and access to Candidates' personal data, and a procedure for regularly testing, analyzing, and evaluating the effectiveness of the technical and organizational measures in place.

Candidates' rights over their personal data

Candidates have the following rights:

Right of access and rectification	Candidates may request access to their personal data. They may also request the rectification of any inaccurate personal data or the completion of any incomplete personal data. Candidates also have the right to know the origin of their personal data.
Right to erasure	Candidates may request the erasure of their personal data when:     1. The personal data is no longer necessary for the purposes for which it was collected and processed;     2. Candidates have chosen to withdraw their consent (in cases where consent was collected as the legal basis for processing), this withdrawal not affecting the lawfulness of the processing prior to its implementation;     3. Candidates have objected to the processing;     4. The personal data has been processed unlawfully; the personal data must be erased to comply with a legal obligation; or     5. Its deletion is required to ensure compliance with applicable legislation, in particular with regard to the retention periods applicable to the personal data processed.
Right to object	Candidates may object to the processing of their personal data in accordance with the legal obligations imposed on the Company.
Right to restrict processing	Candidates may also request the restriction of the processing of their personal data if:     1. Candidates contest the accuracy of such personal data;     2. The Company no longer needs such personal data for the purposes of processing; and     3. The Candidate has objected to the processing of personal data.
Right not to be subjected to a decision based exclusively on automated processing of personal data	Candidates have the right not to be subject to a decision based exclusively on automated processing that produces legal effects concerning them or significantly affects them.
Right to data portability	Candidates may ask the Company to provide them with their personal data in a structured, commonly used, machine-readable format, or request that it be “ported” directly to another data controller, provided that:     1. The processing is based on their consent; and     2. It is carried out by automated means.
Right to issue advance directives on the processing of their personal data after their death	Pursuant to Article 85, I of the French Data Protection Act of January 6, 1978, as amended, Candidates may define guidelines on the exercise of their rights under this section after their death (in particular on the retention period of their personal data, its deletion and/or communication), and may designate a person responsible for exercising these rights. In the absence of such guidelines, the Company will comply with the requests of the Candidates' heirs as set out in Article 85, II of the French "Informatique et Libertés" Act.
Right to withdraw consent	Candidates may withdraw their consent to the processing of their personal data at any time. The withdrawal of the Candidate's consent is only valid for the future and does not call into question the lawfulness of any processing carried out by the Company on the basis of the Candidate's consent prior to its withdrawal or the lawfulness of any processing based on another legal basis, such as the legitimate interests of the Company.
Right to lodge a complaint with a supervisory authority	If Candidates have concerns or complaints regarding the protection of their personal data, they have the right to lodge a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés) via the following link: CNIL : Online complaints. The CNIL can also be contacted at the following address: 3 Place de Fontenoy, 75007 Paris and phone number 01 53 73 22 22. Candidates are invited to inform the Company's Data Protection Officer in advance so that he or she can process the request and attempt to find an amicable solution.

Contact details for the Company's Data Protection Officer

For any questions regarding the processing of their personal data and in order to exercise their aforementioned rights, Candidates may contact the Company's Data Protection Officer at the following email address: dpo@synacktiv.com or by mail at the following postal address: Synacktiv, 5 Boulevard Montmartre, 75002, Paris.

In the event of “reasonable doubts” about their identity, the Company may ask the Candidate to provide a copy of a valid identity document.

This will be deleted by the Company once the Candidate's request has been granted.

The Company may retain a copy of the Candidate's identity document for the sole purpose of establishing evidence in the event of a dispute with the Candidate.