Privacy Policy for the Voyage Privé

Date of publication: 13-10-2024

We at Voyage Privé manage our employer branding and recruitment process through our career site (the “Career Site”), and by using a related applicant tracking system.

In this privacy policy, we explain how we process your personal data if:

1. You visit our Career Site (you being a “Visitor”)

2. You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)

3. You apply for a position with us, via our Career Site or a third party service (you being an ”Applying Candidate”)

4. We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)

5. We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)

6. We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).

This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.

When we use the term “Candidate” in this privacy policy, we are referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it’s stated otherwise.

1. About processing of personal data

Personal data is all information that can be directly or indirectly linked to a living, physical person. Examples of personal data are: name, e-mail address, telephone number and IP address. Processing of personal data is any operations which is performed on personal data - such as collecting, creating, analyzing, sharing, and deleting personal data.

There are laws and regulations on how companies may process personal data, so-called data protection laws. Different data protection laws apply to different types of use of personal data, and in different parts of the world. An example of a data protection law that is relevant for our use of your personal data, as described in this privacy policy, is the EU Data Protection Regulation (2016/679, “GDPR”).

2. Who is the data controller ?

Most obligations under the GDPR apply to the so-called data controller. A data controller is the entity that decides for which purposes personal data will be processed, and how the processing will be executed. The data controller can use a data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller, and may not use the personal data for its own purposes.

With regard to the Career Site, the data controller is VPG, a simplified joint-stock company with a share capital of €910,301,59 whose registered office is located at 330 rue Pascal Duverger, 13090 Aix-en-Provence, France, and which is registered with the Aix-en-Provence Trade and Companies Register under number 479 345 043.

We are the data controller when we process your personal data as described in this Privacy policy.

3. Where do we receive your personal data from?

All individuals

• From the Career Site. If you visit our Career Site, we collect technical and statistical information about how you use the Career Site, and information from your device.

• Directly from you. Most of the information we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application or provide you the information you request to get from us.

References

• From the person for whom you are a reference. If a Candidate lists you as their reference, we will collect your contact details from the candidate to be able to contact you.

Candidates

• From public sources. We may collect personal data about you from public sources, such as LinkedIn or the website of your current employer.

• From our references. We may receive information about you from our employees or partners (such as recruitment service providers), when they believe your profile is of interest for our current or future vacancies.

• From your references. If you provide us with references, we may collect information about you from them.

• Data we create ourselves or in cooperation with you. Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may for example include notes from interviews with you, assessments and tests made.

4. For what purposes, on what basis and what types of personal data do we process ?

Voyage Privé, as the data controller, collects and uses your personal data for the following purposes:

Purpose of the processing: Review profiles and applications sent to us. This also includes communicating with you about your application and profile.

Legal basis: Execution of the contract (Pre-contractual measures)

Persons concerned by the processing: Connecting Candidates; Applying Candidates.

Types of personal data: Any information disclosed in the CV: First name - Last name - E-mail address - Physical address - Phone number - Experiences - Knowledge - Education - Photo - Hobbies - References - Geographic mobility - Social media profile - Work samples - Salary requirements - Motivation letter - Any information in your public profile - Records or transcripts of your interview, Assessments and test made.
(*) Sensitive data where you have voluntarily provided such information.

Purpose of the processing: Collect and evaluate your professional profile on our own initiative. This also includes communicating with you regarding your profile.

Legal basis: Legitimate interest

Persons concerned by the processing: Sourced Candidates; Referred Candidates.

Types of personal data: Any information disclosed in the CV: First name - Last name - E-mail address - Physical address - Phone number - Experiences - Knowledge - Education - Photo - Hobbies - References - Geographic mobility - Social media profile - Work samples - Salary requirements - Motivation letter - Any information in your public profile - Records or transcripts of your interview.
(*) Sensitive data where you have voluntarily provided such information.

Purpose of the processing: Include your profile in the Voyage Privé talent community and contact you directly to ask whether you would be interested in specific future job opportunities that may match your profile.

Legal basis: Your consent

Persons concerned by the processing: Connecting Candidates Applying Candidates

Types of personal data: Any information disclosed in the CV: First name - Last name - E-mail address - Physical address - Phone number - Experiences - Knowledge - Education - Photo - Hobbies - References - Geographic mobility - Social media profile - Work samples - Salary requirements - Motivation letter - Any information in your public profile - Records or transcripts of your interview. Assessments and test made.
(*) Sensitive data where you have voluntarily provided such information.

Purpose of the processing: Contact you to ask for your participation in surveys

Legal basis: Your consent

Persons concerned by the processing: Candidates

Types of personal data: First name - Last name - E-mail address - Information provided in the survey

Purpose of the processing: Contact you to ask you to provide information about a Candidate and evaluate the information you provide.

Legal basis: Legitimate interest

Persons concerned by the processing: References

Types of personal data: E-mail address and/or phone number and any information disclosed during the communication

Purpose of the processing: Analyze how the Career Site and its content is being used and is performing, as described in our Cookie Policy.

Legal basis: Your consent

Persons concerned by the processing: Visitors

Types of personal data: Device information: IP address, browser type and version, session behavior, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage ; Technical and statistical data: URLs you visit, and your activity on the site

Purpose of the processing: Collect information about your use of the Career Site, using cookies and other tracking technologies, as described in our Cookie Policy.

Legal basis: Your consent

Persons concerned by the processing: Visitors

Types of personal data: Device information: IP address, browser type and version, session behavior, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.

Purpose of the processing: Maintain, develop, test, and otherwise ensure the security of the Career Site.

Legal basis: Legitimate interest

Persons concerned by the processing: Visitors

Types of personal data: Device information: IP address, browser type and version, session behavior, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage ; Technical and statistical data: URLs you visit, and your activity on the site

Purpose of the processing: Maintain, develop, test, and otherwise ensure the security of the Career Site.

Legal basis: Legitimate interest

Persons concerned by the processing: Visitors

Types of personal data: Device information: IP address, browser type and version, session behavior, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage ; Technical and statistical data: URLs you visit, and your activity on the site

Purpose of the processing: Use of innovative tools and technologies to assess a candidate’s suitability for a position and measure their professional skills: technical tests and video interviews

Legal basis: Candidates

Persons concerned by the processing: Visitors

Types of personal data: All information disclosed during a job interview

Purpose of the processing: Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.

Legal basis: Legitimate interest

Persons concerned by the processing: The individuals affected by the legal issue : Visitor, Connecting Candidates, Applying Candidates, Sourced Candidates, Referred Candidates, References.

Types of personal data: All the categories of personal data listed above can be used for this purpose.

(*) During the recruitment process, Voyage Privé may process sensitive data[1] concerning you where you have voluntarily indicated that you benefit from a recognized disability status or require workplace accommodations. The provision of such information is entirely optional. It will only be accessed by authorized persons who need it to arrange the requested accommodation and will be deleted when it is no longer necessary.

Purpose of the processing: Purpose of processing personal data using an artificial intelligence system without automated decision-making for the transcription of the audio interview to assist recruiters in completing an assessment form.

Legal basis: Legitimate interest

Persons concerned by the processing: The individuals affected by the legal issue : Visitor, Connecting Candidates, Applying Candidates, Sourced Candidates, Referred Candidates, References.

Types of personal data: Types of personal data

Purpose of the processing: The AI-enabled tool is used solely to assist with the transcription of your interview in completing an assessment form and does not make or influence any recruitment decisions. All decisions made throughout the recruitment process are taken exclusively by a Voyage Privé recruiter and managers.

To ensure full transparency, you may choose whether to allow Voyage Privé’s recruitment team to use this AI-enabled transcription tool. Your decision will have no impact on your application or your prospects in the recruitment process.

Legal basis: Your consent

Persons concerned by the processing: Candidate

Types of personal data: Records or transcripts of your interview. All information disclosed during the interview.

5. What AI systems does Voyage Privé use for the processing of your personal data ?

In more details, here is the AI technology used, subject to your consent:

· Transcription & Summarization: Performed via AssemblyAI to generate meeting notes, chapters and speech analytics, with the candidate’s prior consent. Each transcription & Summarization is review systematically by Voyage Privé recruiters.

· AI-assisted evaluation suggestion: Generated using GPT-4 via OpenAI Enterprise, based on the interview and the selection criteria for the position. The suggestion is advisory only and does not constitute an automated decision. Recruiters remain responsible for the assessment and may disregard or amend the suggestion based on their discussions with the candidate and other relevant information.

6. Who are the recipients of your personal data ?

· Voyage Privé

The recruitment officers, human resources managers and managers of Voyage Privé supervising future hire as well as the people in charge of managing the Career Site may access data concerning you.

The legal department, in connection with any request to exercise your rights in accordance with Section 9 of this Privacy Policy.

· Our group companies

We share your personal data with our group companies, when they provide us services and functionality to our employer branding- and recruitment process, such as access to particular systems and software.

· Voyage Privé external suppliers and service providers

We share your personal data with our suppliers who provide services and functionality in our employer branding- and recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.

· Public, governmental and/or judicial authorities

Voyage Privé may be required to disclose your personal data to Courts, public authorities, regulators or other external recipients where disclosure is necessary to comply with a legal or regulatory obligation or a judicial decision, or to safeguard and defend our rights. In such cases, Voyage Privé ensures that only the personal data strictly necessary for the relevant purpose is disclosed.

· Companies providing cookies on the Career Site.

If you consent to it, cookies are set by other companies than us, who will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in our Cookie Policy.

7. When do we transfer your personal data outside of the EU/EEA, and how do we protect it ?

Your data are stored within the EU/EEA area. We always strive to process your personal data within the EU/EEA area.

However, some of our service providers may process your personal data outside of the EU/EEA. We also may use suppliers whose parent company, or whose subcontractor’s parent company, is based outside the EU/EEA. In these cases, we have taken into account the risk that the personal data may be disclosed to countries outside the EU/EEA, for example because of an authority request.

In cases where another recipient of your personal data is based outside the EU/EEA, this will also mean that your personal data is transferred outside the EU/EEA.

When we, or one of our suppliers, transfer your personal data outside the EU/EEA, in a country that has not been recognized by the European Commission as providing an adequate level of data protection, the transfer is governed by the Standard Contractual Clauses adopted by the European Commission (“SCCs”) or by any other appropriate safeguard provided for under applicable data protection laws.

When your personal data is transferred outside the EU/EEA, we also implement appropriate technical and organizational safeguards, to protect the personal data in case of a disclosure. Exactly which protective measures we implement depends on what is technically feasible, and sufficiently effective, for the particular transfer.

8. When do we transfer your personal data outside of the EU/EEA, and how do we protect it ?

Recruitement: We may retain the personal data of unsuccessful candidates for up to three months following the end of the recruitment process, in order to respond to any requests for information regarding the reasons for our decision.

If you have given your consent for Voyage Privé to contact you directly about specific future job opportunities, your profile will be included in the Voyage Privé talent community for this purpose. We may retain your personal data for up to two years from our last contact with you. During this period, Voyage Privé may contact you from time to time to ask whether you would be interested in specific future job opportunities that may match your profile. You may withdraw your consent at any time. If you withdraw your consent, or if the two-year period expires without renewal, your profile will be removed from the talent community and your personal data will no longer be used for these purposes, unless we are required to retain it by law.

Candidate account: Personal data used to create and manage your candidate account is retained for as long as you use the candidate area. If you do not use your account for two years, your personal data will be deleted.

Cybersecurity: Personal data processed for the cybersecurity of the website and candidate area is retained fifteen days and then deleted.

Cookies: The retention periods for cookies are set out in our Cookie Policy.

9. When do we transfer your personal data outside of the EU/EEA, and how do we protect it ?

You have the right to request access to your personal data. You can also request the rectification of inaccurate personal data or the completion of incomplete personal data. You have the right to ask for the erasure of your data. You also have the possibility to withdraw our consent or object to the processing of your personal data and request the limitation of said processing (including the right to request cessation of the collection, processing, or use of your personal data), if applicable. Finally, you can request the communication of your personal data in a structured and standard format.

To exercise any of these rights or raise a question concerning the processing of your personal data, please contact talents@voyageprive.com

You also have the right to lodge a complaint with the competent data protection supervisory authority. In France, the competent authority is the Commission Nationale de l’Informatique et des Libertés (CNIL).