Privacy Notice Draft

PRIVACY NOTICE
HOW WE USE PERSONAL DATA

Privacy Notice

This Privacy Policy explains how FINOLOGEE (“FINOLOGEE”, “we”, “us” or “our”) collects, uses, shares and otherwise processes your Personal Data in accordance with applicable data privacy laws and regulations, which include the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.

Your privacy is important to us. The purpose of this Privacy Notice is to inform you about the information FINOLOGEE may gather about you, how FINOLOGEE may use that information, whether FINOLOGEE discloses it to anyone, and the choices you have regarding our use of the information FINOLOGEE collects.

1. Personal data we collect about you

When using the term “Personal Data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold, as defined by the GDPR.

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

  • If you have consented to us doing so, or
  • If we need it to perform the contract we have entered into with you; or
  • If we need it to comply with a legal obligation; or
  • If we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms.

Finologee collects and processes your personal data when you submit information in our contact forms for job applications, such as name, contact details, curriculum vitae (CV) and other information that you may provide by such forms. Finologee also collects information by use of social media, public searches, and own- or third-party cookies and other follow-up tools data you fill out in your job application include: name, surname, title, personal photo, position, hyperlinks to social networks, address, e-mail address, Skype username, phone number, educational background, work experience, CV…

2. Your rights in relation to your Personal Data

Under the GDPR you have various rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

  • Request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • Request rectification of your Personal Data;
  • Request the erasure of your Personal Data;
  • Request the restriction of processing of your Personal Data;
  • Object to the processing of your Personal Data

If you want to exercise one of these rights please contact us

by email jobs@finologee.com

or by post

Finologee SA
Att Data Protection Officer
7, rue Jean Fischbach
L-3372 Leudelange

3. Security of your Personal Data

We are committed to take appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, disclosure, destruction or damage.
Your Personal Data is stored in the European Union or in territories (such as the USA) which may not offer an equivalent level of protection to privacy as that applicable within the European Union. In this case, we will take all the necessary steps to verify that your Personal Data receives an adequate level of protection. This, either by entering into data transfer agreements or by ensuring that supplier used are certified under appropriate data protection schemes (for example, EU-US Privacy Shield).

Finologee may use some third party suppliers in human resources domain.These third parties may have access to or merely host your Personal Data, but will always do so under our instructions and subject to a contractual relationship. This, either by entering into data transfer agreements or by ensuring that third parties are certified under appropriate data protection schemes.

4. Retention period

We will only retain your Personal Data for as long as we need it in order to fulfil the purposes for which it was collected and processed.

Your data will be store for a period maximum of 5 years or until revocation of your consent. Data will be automatically removed at the end of this period.

5. ’Cookies’

What is a cookie?

A cookie is a small piece of data or message that is sent from an organisation’s web server to your web browser and is then stored on your hard drive. Cookies can’t read data off your hard drive or cookie files created by other sites, and do not damage your system.

How do FINOLOGEE Site and services use cookies?

We only use cookies to monitor the performance of our website and to improve user experience. We use Google Analytics for this purpose. Analysis is performed on a purely anonymous basis. In our configuration, Google Analytics remarketing features are neither used nor enabled, and therefore we do not share any data with third parties. Google Analytics uses “cookies”, to help the website analyse how users use the websites, applications or services:

Google Universal Analytics

Cookie type

Google Universal Analytics

Purpose

This helps us count how many people visit our website by tracking if you have visited before

gat_

Cookie type

Google Universal Analytics

Purpose

Used to manage the rate at which page view requests are made

utma_

Cookie type

Google Analytics

Purpose

Used to determine new and returning visitors

utmb_

Cookie type

Google Analytics

Purpose

Used to determine the average time spent on the website

utmz_

Cookie type

Google Analytics

Purpose

Used to determine the traffic source, medium which delivered the user to our website

utmv_

Cookie type

Google Analytics

Purpose

Used to store visitor-level custom variable data

utmt_

Cookie type

Google Analytics

Purpose

Use to throttle request rate

The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the websites, applications or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our website, applications or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout

6. Change to this privacy notice & contact information

We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, we will post the revised Privacy Policy on the Site. All such changes shall be binding on you 30 days after they are initially posted on the Site unless you are a new user, in which case they are binding on you immediately.

If you have questions or concerns regarding this Privacy Notice or you wish to exercise your rights in relation to your Personal Data, please do not hesitate to contact us at info@finologee.com or send your request to the following address:

FINOLOGEE S.A.
7, rue J. Fischbach,
L-3372 Leudelange,
Luxembourg

Email-disclaimer Information Policy

This message is intended for use by its addressee only.

The addressee (i) is aware that this message is confidential and may also be legally privileged, (ii) understands that it remains solely liable for any form of reproduction, copying, disclosure, modification and/or publication of this message, its content and any attachment and (ii) acknowledges that Finologee shall not be held liable for any further use, disclosure or processing of this message.

If you received this in error, please contact us at info@finologee.com and delete the material from every electronic device which may have processed this message. No liability whatsoever will be incurred by Finologee. This message and its content do not constitute a formal commitment by Finologee.

The addressee of this message agrees to comply with the applicable laws and regulations in the jurisdictions where it uses the information contained herein.

Any use, review, retransmission, distribution, reproduction or any action taken in reliance upon this message is strictly prohibited.

Please note that the processing of this message may incur the processing by Finologee of “personal data”. If you wish to obtain more information in relation thereto, please refer to this Privacy Notice You may also contact us at info@finologee.com if you wish to exercise any the rights described in this Privacy Notice.