Confidentiality policy

Introduction

1 - Definitions

The following terms will have the following definition, whether they are used in the singular or the plural:

- Access: refers to the process by which Users access the Solution using an identifier - email address - and a password.
- Customer: refers to companies that have subscribed to a user license so that their employees can access the PickYourSkills Solution Services.
- Candidate: refers to natural persons who have submitted an application for a job offer within PickYourSkills.
- Data: refers to all data and information that is collected and processed by PickYourSkills and that concerns Users, Candidates, Customers, Suppliers, and Visitors and may in particular be qualified as personal data within the meaning of the Applicable Regulations on the protection of personal data.
- Supplier: refers to legal persons who provide PickYourSkills with goods and/or services.
- Applicable regulations on the protection of personal data: refers to law No. 78-17 of January 6, 1978, known as the “Informatique et Libertés” law in its latest version in force and Regulation 2016/679 relating to data protection.
- Services: refers to the functionalities of the Solution that are offered to the User as part of the Access granted to him by the Customer.
- Solution: refers to the Saas platform accessible via Access and which is published and maintained by PickYourSkills.
- User: refers to natural persons who have Access to the Solution according to the authorizations defined and configured by the Customer and who can access the Services as part of these personal and individual Access.
- Visitors: refers to any natural or legal person who accesses the site https://www.napta.io/.

2 - What is the nature of the data collected by PickYourSkills?

PickYourSkills may collect different categories of information depending on the nature and purpose of the processing of personal data that it operates and the type of person concerned. In all cases, PickYourSkills undertakes to collect and process only the data strictly necessary for the purposes pursued by said data processing.

2.1 - Regarding the Users of the Solution

As part of the use of the application, PickYourSkills records data about you: data relating to your identity (name, first name, professional email address, position, seniority), information relating to your skills, your experiences and data concerning your availability. PickYourSkills also collects the number of visits as well as the date and time associated with each of them for all Users.

2.2 - Regarding PickYourSkills Customers and Prospects

As part of the management of its Customers and the search for prospects, PickYourSkills records data about you: data relating to your identity (name, first name, professional email address, telephone number, position, seniority), financial data (bank details of the legal entity to be invoiced as far as Customers are concerned), data relating to the monitoring of the commercial relationship (requests for documentation, services subscribed, seniority), financial data (bank details of the legal entity to be invoiced as far as Customers are concerned), data relating to the monitoring of the commercial relationship (requests for documentation, services subscribed, seniority), financial data (bank details of the legal entity to be invoiced as far as Customers are concerned), data relating to the monitoring of the commercial relationship (requests for documentation, services subscribed, seniority), financial data (bank details of the legal entity to be invoiced for Customers) order number, correspondence with the customer and after-sales service, comments from customers and prospects, person (s) in charge of customer relations), data relating to the payment of invoices, data necessary to carry out prospecting, study, and promotion actions.

2.3 - Regarding Candidates for a position within PickYourSkills

As part of the recruitment of its employees, PickYourSkills collects data relating to the identity of Candidates (name, first name, email address), data relating to the career and professional life of Candidates and more generally any other information that Candidates decide to communicate in their Curriculum Vitae and/or cover letter. PickYourSkills does not want you to communicate sensitive data to it and in particular any information relating to your origin, health condition, morals, sexual orientation, political opinions, trade union activities, religious beliefs, religious beliefs, membership or non-belonging to an ethnic group, a nation or a race. Any communication of sensitive information of this type may result in the rejection of your application within PickYourSkills.

2.4 - Regarding Visitors to the Site

The data collected during your visit to the PickYourSkills website is the date and time of your visit.

2.5 - Regarding PickYourSkills Suppliers

PickYourSkills is required to collect data relating to the identity of Suppliers (company name, first name and last name/title of the contact point, address of the head office and billing location, telephone, fax, professional email address, professional email address, SIREN number) as well as data relating to the billing and payment of Supplier invoices.

3 - How is data collected?

We collect your personal data in the following ways:


- through the use of the Services and the PickYourSkills Solution (https://app.pickyourskills.com);
- via third-party services integrated into the PickYourSkills application (software, applications and tools such as your CRM, ERP or SIRH, among others): we offer integration with third-party services directly from our platform. Some of these services store and share your personal data with PickYourSkills;
- via third party recruitment services (Welcome To the Jungle, Jobteaser) with respect to data from Candidates for a position at PickYourSkills; We use aggregated and anonymous information in particular in order to improve the PickYourSkills Services, to test our computer systems, to test our computer systems, to conduct research, to analyze data, and to develop new functionalities.

4 - Do we share your personal data?

PickYourSkills is committed to protecting the data of its Users, Customers, Customers, Suppliers, Candidates and Visitors and to restrict their sharing as much as possible. Each data sharing is either necessary to provide the PickYourSkills Services, or justified to contribute to the improvement of the PickYourSkills Services. PickYourSkills does not sell the personal data of its Users, Customers, Suppliers, and Candidates and Visitors. The actors with whom some data is shared are:


- the employees of your company with regard to User data. Your contact details (name, first name, email,...) are accessible to all employees of your company via their personal space on the Solution. On the other hand, some information is only accessible to certain types of Users of the tool, depending on the rights that your company will have configured with respect to the use of PickYourSkills Services. These privileged accesses give, among other things, access to the levels of expertise of employees, to future commercial opportunities, to reports, to evaluations...;
- Invisible Service Providers. PickYourSkills uses the services of technical providers who can operate the technical infrastructure we need to provide the PickYourSkills Services, in particular the providers who host, store, manage and maintain the PickYourSkills Solution and Site, its content and the data we process. PickYourSkills also uses technical service providers to help us communicate with you;
- the buyers of our company. We will share your personal data if we sell or negotiate to sell our business to a buyer or potential buyer. In this case, PickYourSkills will continue to ensure the confidentiality of your personal data and will inform you in advance of any transfer of your personal data to the purchaser or of any application of new privacy policies.

5 - What is the storage period of your data?

PickYourSkills only keeps Data for a period of time that is necessary and proportional to the purpose of the processing for which they were collected. Thus, the durations are specified for each category of Data below:

5.1 - Customer and Prospective Data

The personal data used in the context of the management of our Customers and prospects will not be kept longer than necessary to manage our commercial relationship with your company.
However, regarding personal data that you may have shared with other Users of the Services (i.e. Employees of your company), this data will remain visible by these Users and therefore stored on the Services until all of these Users have left the Services (plus a period of three (3) years) or deleted this data.
Regarding possible prospecting operations for former Customers, Customer data may be kept for a period of three (3) years from the end of the commercial relationship. At the end of this period of three (3) years, we will be able to contact you again to find out if you want your company to continue to receive commercial solicitations. Information allowing your right to object to be taken into account is kept for a minimum of three (3) years from the exercise of the right of opposition.

5.2 - Solution User Data

As part of the use of the Services, you may be required to modify or delete all or part of your Personal Data. These changes will be effective immediately following your action. If any deletion is taken into account immediately on the Services, we have several backup copies of the data in order to prevent any technical disaster; therefore, any deletion of personal data is only final within our technical platform after a period of one (1) month, allowing the rotation of all backups.
The Personal Data used in connection with the Services will not be kept longer than a period of three (3) years following the deletion of your User account. This period will allow you to find all of your personal data if you decide to join the Services again.
However, regarding personal data that you may have shared with other Users of the Services (i.e. Employees of your company), this data will remain visible by these Users and therefore stored on the Services until all of these Users have left the Services (plus a period of three (3) years) or deleted this data.
In the event that a Customer wishes to terminate its license, PickYourSkills has a period of one (1) month to delete all Personal Data relating to the Customer's employees.

5.3 - Data relating to statistics and audience measurements

The information stored in the Users' terminal or any other element used to identify Users and allowing them to be traced or visited will not be kept for more than 12 months.

5.4 - Data of Candidates for a position at PickYourSkills

If you apply to PickYourSkills and your application is not selected, we will keep your data in our CV library in order to be able to contact you again for a position that you would be more suitable for, for two years, provided that you do not oppose it when we inform you. You can object to the storage of your data for this purpose at any time.

5.5 - Supplier Data

Data relating to PickYourSkills suppliers will be kept for the duration of the contractual relationship and then for a period of three years.
Upon your request, we will delete or anonymize your Personal Data so that you can no longer be identified, unless the law allows or requires us to keep certain Personal Data.
PickYourSkills keeps all of its data within the European Union, and does not transfer personal data outside the European Union. PickYourSkills servers are managed by Amazon Web Services and located in Frankfurt. To manage the authentication of Users on the Solution, PickYourSkills uses the service provider Auth0, which also stores Personal Data in the European Union.

6 - How is your personal data secured?

PickYourSkills is committed to protecting the personal data of its Users. We implement appropriate technical and organizational measures in order to protect the security of your personal data. However, please note that no system is completely secure. We take all organizational and technical measures in accordance with the state of the art in order to protect your personal data against any security breach and in particular against the destruction, loss, alteration, unauthorized, accidental or illicit disclosure of personal data transmitted, stored or otherwise processed.
Your password protects your User account, so we encourage you to use a secure and unique password and to limit access to your computer and browser.

7 - Do we share your data?

We do not disclose your personal information to third parties except through the use of service providers or in exceptional circumstances as described below.

7.1 - Suppliers

Hubspot: CRM tool used to manage our prospects and Customers. Link to their security policy
Welcome to the Jungle: Publication of job offers and receipt of applications in response. Link to their privacy policy
Crisp: Customer relationship management and online help. Link to their privacy policy
AWS: Server hosting. Link to their privacy policy
Auth0: Securing authentication on the Solution: Link to their privacy policy
Postmark: Communication with our Customers. Link to their privacy policy
UserPilot: In-app onboarding. Link to their privacy policy

7.2. Legal obligations

We may disclose your information, including your IP address, in order to comply with any law, regulation, court order, or other legal request to protect people and property, to resolve technical problems, or to protect the rights or property of PickYourSkills.

8 - What are your rights?

In accordance with the provisions of the law known as “Informatique et Libertés” of January 6, 1978 as amended and the General Data Protection Regulation (RGPD), you have the right to access, rectify, delete, limit, oppose and to the portability of personal data concerning you within the limits of our legal obligations and the requirements of your employers.
To exercise your rights, we invite you to contact us at privacy@pickyourskills.com and we will get back to you as soon as possible, and in any event within the period of one month allotted to us.


Your request can also be sent to the following address: PickYourSkills SAS, 112 Avenue de Paris, 94300 Vincennes.
- Right to information: this Policy informs our Users about the nature and use of personal data.
- Right of access: You have a right to access the data concerning you processed by PickYourSkills. It allows you to review the data we have on you and, if you wish, to request a copy of it.
- Right to correction: Under the terms of the applicable regulations on the protection of personal data, you can request from us the correction of inaccurate personal data concerning you. You can also request that incomplete personal data concerning you be completed, including by providing a supporting statement.
- Right to erasure: You have, within the limits of your employer's legal obligations to store data or our legal obligations, the right to obtain the erasure, as soon as possible, of personal data concerning you subject to our legitimate interest or any legal obligation requiring us to keep it.
- Right to portability: You can request the portability of your data at any time from PickYourSkills. We are committed to transmitting to you within a reasonable time and in a machine-readable format the data that you have provided to us, whether declared by yourself or generated by your activity on the platform.
- Right to withdraw consent: You have the right to refuse the processing of your personal data at any time for personal reasons as well as the right to refuse the processing of your personal data for direct marketing purposes.
- Right not to be subject to automated decision-making: we do not use automated decision-making.
- Right to file a complaint with a supervisory authority: PickYourSkills is located in Paris. As such, the supervisory authority competent to deal with any request concerning us, including, where applicable, a user complaint, is the Commission Nationale de l'Informatique et des Libertés (CNIL).


If you wish to contact the CNIL with any request, you will find the contact details below:
CNIL (NATIONAL COMMISSION FOR INFORMATION TECHNOLOGY AND FREEDOMS)
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tel.: 01 53 73 22 22 (Monday to Thursday from 9 am to 6.30 pm/Friday from 9 am to 6 pm)
Fax: 01 53 73 22 00


Careful! The CNIL does not receive the public and does not provide any information on site.


If you wish to file a complaint with the CNIL, you can fill in the online complaint form available at the following address: www.cnil.fr/fr/fr/
If you have a question about your computer rights and freedoms, you can consult the CNIL website: www.cnil.fr.

9 - Will this privacy policy be changed?

We may need to make changes to this Policy.
If this Policy changes, we will notify you by means of appropriate notifications, for example, by displaying a notice in the PickYourSkills application or by sending you an email. We can notify you of these changes in advance.

10 - How to contact us?

Thank you for reading our Privacy Policy.
For any question relating to the protection of your personal data, you can contact us at support@pickyourskills.com and detail your question. We will do our best to answer you in a clear and understandable way and as soon as possible.

The purpose of this privacy policy (hereinafter “Policy”) is to inform you about the methods of collecting and processing personal data collected or processed by PickYourSkills in accordance with the Applicable Regulations on Personal Data. The terms “you”, “your” and “your” refer, as appropriate, to Customers, Users, Candidates, Suppliers and Visitors to the Site (https://pickyourskills.com).

Indeed, to allow its Customers to manage skills and to streamline their staffing processes, PickYourSkills collects and records your personal data as a Customer's collaborator and User of PickYourSkills Services. The confidentiality and security of your personal data are, and will remain, our priorities.

This Policy sets out essential information relating to the use of personal data by PickYourSkills SAS (hereinafter “PickYourSkills”), and applies to all PickYourSkills Services and Related Services.

We sometimes develop and offer new Services or additional offers. If the introduction of these new Services or additional offerings changes the way in which we collect and process personal data, we will provide you with additional information and additional terms or policies. Unless otherwise specified, new Services or additional offerings added will be subject to this Policy.