Introduction

aperlead is a responsible and conscious recruitment firm, which places considerable importance on respecting privacy and personal data of people who contact us via this website or by any other means.

Therefore, aperlead and the website administrators (host, IT service providers) comply with the principles laid down in domestic and Community legislation on personal data protection, the French Data Protection Act of 6 January 1978, as amended and, in particular, the European General Data Protection Regulation 2016/679 of 27 April 2016 (referred to as “GDPR”), applicable with effect from 25 May 2018.

This policy sets out aperlead’s commitments in its capacity as Data Controller towards you and describes how we collect and use your personal data, the data we collect when you visit our website and the means available to you to control this use and exercise your related rights.

Therefore, in full transparency, it informs you about

how we collect and process your personal data
the commitments made to ensure the security of your personal data
the rights available to you over your personal data processed in accordance with our obligations respecting your rights, with the aim of ensuring the utmost protection of your data.

aperlead adopts the principles of data minimisation, data protection by design and data protection by default. As a result, we collect relevant and adequate data, which is limited to what we need to know in view of the purposes for which such data is processed.

1. Identity and contact details of the Data Controller

We process your personal data in the capacity as Data Controller, which means that we control how this personal data is processed and we decide the purpose of the data processing.

You can send us any questions, information requests or complaints by referring to Article 6.

2. What personal data do we collect?

In the scope of our operations, we collect personal data from:

Candidates
Clients/Companies
Service Providers
Employees

You can visit our website without disclosing any personal data. However, some services that you use may require the collection and storage of automatically recognised data: date and time, IP address, domain name, browser and operating system used (if the browser provides this information), address of the visited page (if the browser provides this information), object requested and status of the execution request.

This data collection uses cookies intended to generate website visitor statistics.

When you visit our website for the first time, a banner will show on your screen explaining how cookies are used. From then on, by continuing to browse our website, you will be deemed to be informed about and have consented to use of cookies. This consent will be valid for thirteen (13) months. You can disable cookies in your browser settings.

For more information, please go to the French Data Protection Authority’s website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

We collect necessary and relevant data on candidates for recruitment:

Last name and first name;
Contact details (personal or professional such as: telephone number, email address, postal address);
Training;
Language skills;
Professional experience;
Information on your current salary and career development goals;
Geographical mobility preferences;
Information on your expectations and needs with regard to your future job, data collected and inferred, for example from the jobs you have consulted or articles you have read on our website;
Additional information you wish to provide us.

Important: this data is entered into our database and may be present in full or in part.

No information that does not directly relate to the recruitment process will be requested.

Declarative personal data is either digital data, such as data which you provide via forms on websites, or hard copy data or in response to questions put to you by the firm’s employees during telephone or in-person meetings.

Personal data collection relating to our clients, service providers and employees complies with the principles of minimisation, lawfulness, fairness, transparency and purpose limitation.

3. How do we collect your personal data?

If you are a candidate, we collect your personal data directly from you or via data you have shared or posted online (CV libraries, social media), in higher education or professional directories, via your contacts in order to help you develop your career path, or also to obtain references.

If you are a client, we collect your personal data directly from you or via company files in which you have consented to feature.

4. Why do we collect and use your personal data?

If you are a candidate, we store and use this data to:

Help you find a job that most closely matches your profile and expectations.
Put forward job offers to you and keep you informed about the progress of your job applications.
Put forward the best profile to our clients.

If you are a client, we store and use this data to:

Provide the services for which we have been commissioned
Pass on reports on the state of progress of our assignment

We process your personal data on the basis of one of these foundations:

your freely given, specific, informed and unambiguous consent to processing of your personal data
aperlead’s legitimate interest to respond to your requests via our website, by sending emails to the address you provided to us and, where applicable, by keeping you up-to-date about our news.
performance of a contract or implementation of pre-contractual measures (for example: job application, starting a mandate, etc.);
a legal obligation applicable to aperlead, such as anti-fraud, checking qualifications, etc.

5. What security measures do we apply to your personal data?

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to such data by third parties.

We also monitor how our service providers process your personal data to ensure that they provide sufficient guarantees in terms of implementing appropriate data security measures.

6. How long do we store your data?

Personal data collected is kept for the period required to achieve the purposes described in Article 3. “Why do we collect and use your personal data?”, increased by the period required by law.

The main storage periods are as follows:

Client data: duration of the contractual relations, increased by five (5) years for business development and promotional purposes.
Data on prospective clients: three (3) years with effect from the last contact with the firm
Candidate data: period required to process the job application and, in the event of a negative outcome, with your consent for five (5) years after the last renewable contact with your consent.
Accounting documents and records: ten (10) years as accounting proof

7. What are your rights?

You have the following rights with regard to your personal data:

Right of information and access, you may request access to data we hold concerning you
Right to rectification, you may correct any incomplete or inaccurate data we hold concerning you
Right to withdraw consent and right to erasure (or “right to be forgotten”), you may ask for your personal data to be erased or deleted
Right to personal data portability, The candidate, client or employee must have the right to receive personal data concerning him or her, held by the company in a legible format

You may exercise your rights at any time by sending an email to dpo@aperlead.com. If we do not process your request, you may submit a complaint to the competent supervisory authority (in France, the Commission Nationale de l’Informatique et des Libertés, or « CNIL ») https://www.cnil.fr/

8. To whom can we transfer your data?

We can transfer your personal data we collect to:

authorised aperlead employees
technical service providers who supply services that contribute to achieving the purposes described in Article 4. “Why do we collect and use your personal data?”, and in particular service providers in charge: sending direct marketing emails, sign-up invitations and any other information email to you
our clients in the scope of a business introduction and in relation to a job opportunity

If you do not want your data to be transferred, it is possible for you to exercise your rights set out in Article 7. “What are your rights?”. You accept that we may also be obliged to disclose your personal data in order to comply with Applicable Laws and Regulations.

9. Is your personal data transferred outside the European Union?

Your personal data will not be transferred to recipients (service providers, partners) located outside the European Economic Area and, in particular, the United States.

10. Amendments

This Personal Data Protection Policy may be amended. The previous Personal Data Protection Policy will accordingly be automatically replaced by the new version which will be immediately binding on you.

11. Liability

You undertake to strictly comply with the terms and conditions of this Personal Data Protection Policy. aperlead will not be held liable in the event where:

Personal Data is incorrect or is not updated by you
non-compliance with your obligations with regard to Applicable Laws and Regulations, this Personal Data Protection Policy and/or other contractual documents applicable to you.

Personal data protection charter