Privacy Policy

This document is intended to inform you of ARCHINOV Partners’ policy on the protection of personal data and of your rights relating to the protection of personal data.

2.1 Definitions

“Entity”: refers to the entity ARCHINOV PARTNERS.

“Assignment”: refers to a service agreed between a client and the entity ARCHINOV PARTNERS to provide assistance to the client under the agreed terms.

“Candidate”: refers to a person who wishes to join the entity ARCHINOV PARTNERS.

“Employee”: refers to a person who has joined the entity ARCHINOV PARTNERS and is still part of the entity.

“Former employee”: refers to a person who joined the entity ARCHINOV PARTNERS (or one of the entities of the RAINBOW PARTNERS Group, of which ARCHINOV PARTNERS is a part), but who is no longer on the payroll following termination of the contract at the initiative of the employee or the entity.

“User”: refers to a person with no connection to any of the entities (neither a candidate nor an employee) who uses the website and leaves their contact details in order to be contacted.

“Client”: refers to a person with a direct business relationship with the entity ARCHINOV PARTNERS (or one of the entities of the RAINBOW PARTNERS Group, of which ARCHINOV PARTNERS is a part).

“Prospect”: refers to a person in business contact with the entity ARCHINOV PARTNERS (or one of the entities of the RAINBOW PARTNERS Group, of which ARCHINOV PARTNERS is a part).

“Partners”: refers to a person who has established commercial, editorial or technological partnerships with the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part).

“Processor”: refers to any company that may process Personal Data on behalf of the entity ARCHINOV PARTNERS, in accordance with the instructions given by it.

2.2 Scope

This Data Protection Policy applies to:

• Employees of the entity ARCHINOV PARTNERS
• Employees and former employees of the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Candidates applying for a position within the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Persons working as subcontractors of the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Clients of the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Prospects of the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Partners of the entity ARCHINOV PARTNERS (or one of the entities of the Group of which ARCHINOV PARTNERS is a part)
• Users of the websites of the entity ARCHINOV PARTNERS

By giving your explicit consent to this Data Protection Policy, you agree that your personal data will be made available to the entity ARCHINOV PARTNERS and to the entities of the Group of which ARCHINOV PARTNERS is a part, under the terms set out in this policy.

 

The Data Protection Officer of the entity ARCHINOV PARTNERS can be contacted at dpo@archinov-partners.fr

Unsolicited collection

At the initiative of a website user who submits their CV in order to be contacted, or at the initiative of the persons responsible for searching for candidates to meet a business need. The search is carried out using public social networks. At this stage, the persons identified cannot be considered candidates, and the public information gathered is not recorded in the company’s information system.

Collection during a preliminary interview

During a job interview, personal data may be collected and recorded in the information system in order to manage the recruitment follow-up process. The collection will first be approved by the candidate, who will have been informed of their rights and remedies relating to data protection and of the means of exercising them.

Collection upon hiring

When the contract to join the entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs) is signed, the personal information required for the administrative or business management of the employee will be collected and recorded in the information system. The employee will have been informed of their rights and remedies relating to data protection and of the means of exercising them.

Collection at the employee’s initiative

An active employee of the entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs) may complete or modify their personal data. The editable data concern the person’s identity, place of residence, qualifications, languages spoken, skills and CV.

Secure access (login / password) is required to access this editable personal data. The employee is informed of their rights and remedies relating to data protection and of the means of exercising them.

For employees active as of May 25, 2018, whose personal data is recorded in the information system, specific information is provided setting out their rights and remedies relating to data protection and the means of exercising them.

Collection at the initiative of the client or prospect

Through one of the website’s contact forms, in order to contact the entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs) or to access premium content that requires the user to identify themselves.

Collection at the partner’s initiative

Through one of the website’s contact forms, in order to contact the entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs).

Personal Data collected directly from you

Among the Personal Data collected directly from you during an interview, we may collect the following:

• Last name, first name, maiden name, gender, postal address, nationality, legal information relating to residence in France (residence permit number, date of issue), level of education and qualifications, email address, IBAN, number of children, marital status, date and place of birth, social security number, telephone number.

Personal Data collected indirectly

We may also collect Personal Data indirectly from websites on which you have made your information available (LinkedIn, Viadeo, etc.). In this case, the data collected is limited to the data made available.

The Personal Data we collect directly from you, in particular upon hiring or during annual reviews, may be processed for the following purposes:

Processing No. 1: Recruitment of new employees
Searching for profiles on social networks, interviews to assess technical and functional skills, assessment of interpersonal skills and motivation.

Processing No. 2: Searching for assignments
Searching for client assignments.

Processing No. 3: Departure of an employee
Resignation of an employee, end-of-contract procedure.

Processing No. 4: Payroll processing
Calculation of salaries and delivery of payslips.

Processing No. 5: Employee career development
Monthly committee reviewing career development requests.

Processing No. 6: Management of employee training needs
Monthly committee reviewing employees’ training requests or needs.

Processing No. 7: Disciplinary interview
Interview held following a breach by an employee.

Processing No. 8: Management of the entity
Production of operational monitoring data for the entities’ management dashboards.

Processing No. 9: Compliance with legal obligations
Transmission of required information to the relevant supervisory bodies.

For Clients and Prospects

B2B business development by telephone or email campaigns, satisfaction surveys, management of internal and external events, sharing of prospect contacts between the Group’s entities and with partners.

For Partners

Partner management, sharing of partner contacts with our clients and prospects, management of internal and external events.

7.1 Depending on your profile and the type of Personal Data

The retention periods are listed below:

Employees and former employees

• Personal data: 1 year from the end of the contract
• Payslips: 5 years from the end of the contract
• Periodic assessment documents (project sheets, annual reviews): until the employee’s resignation
• Disciplinary records, training: until the employee’s resignation
• Badge access data (for the employees concerned): 3 months
• Telephone data (for the employees concerned): 3 months
• Video surveillance data (for the employees concerned): 3 months
• Documents relating to employment contracts (including amendments): 5 years from the end of the contract
• Dismissal notification letter: 5 years from the end of the contract
• Final settlement receipt: 5 years from the end of the contract

Candidates

• CV: two years after the last contact, with explicit consent
• Cover letter: two years after the last contact, with explicit consent
• Interview reports, assessments, tests: two years after the last contact, with explicit consent
• Personal data: two years after the last contact, with explicit consent

Clients / prospects

• 3 years from collection or from the last exchange with our client / prospect

Partners

• 3 years from collection or from the last exchange with the partner

The following may have access to your Personal Data:

• Only certain duly authorized employees based at the Group’s headquarters and assigned to HR, Marketing / Communication, Administration or Sales functions have access to your Personal Data, only when necessary, and they are bound by a strict duty of confidentiality.
• Processors or service providers we use for technical services, analytics solutions, etc.
• Our partners, as part of joint Marketing / Communication / Sales initiatives.

Please note that your personal data, limited to “professional experience”, may be transferred to one of the entities of the Group to which ARCHINOV PARTNERS belongs as part of the search for assignments.

This transfer will only take place with the consent of the person concerned.

The entity receiving the personal data is subject to the same Data Protection Policy.

You have the right of access, rectification, erasure, restriction and objection, the right to set instructions regarding the handling of your data after your death, and the right to data portability.

10.1 Contact

You may exercise your rights:

• By email: dpo@archin-partners.fr

or

• By post:
  ARCHINOV PARTNERS, for the attention of the Data Protection Officer, 8 place du marché, 92200 Neuilly-sur-Seine, France

10.2 Supporting documents

In accordance with Decree No. 2007-451 of March 25, 2007 amending Decree No. 2005-1309 of October 20, 2005 implementing French Law No. 78-17 of January 6, 1978 on information technology, data files and civil liberties, your request to exercise any of your rights must be accompanied by a photocopy of a signed identity document. Your request must also specify the address to which the reply should be sent.

We will then have one (1) month from receipt of the request to respond. This period may be extended by two (2) months, depending on the complexity and number of requests.

These rights are not absolute: you may exercise them within the applicable legal framework and within the limits of these rights. In certain cases, we may be unable to grant your request (legal obligation, fulfilment of our commitments to you, etc.). If so, we will inform you of the reason(s) for the refusal.

10.3 Right of access, rectification or erasure

As an employee, you may access the Personal Data we have collected directly from you in order to rectify, complete or erase any inaccurate information by:

• Logging in directly to the intranet with your User Account, “Employee” section: edit the inaccurate/incomplete information, then save your changes;
• Contacting us directly at the email and/or postal address(es) given above.

You have the right to have your Personal Data erased when:

• It is no longer necessary for the purposes for which it was collected or processed;

or

• You have objected to the processing and there are no overriding legitimate grounds for the processing;

or

• The Personal Data must be erased to comply with a legal obligation under European Union or Member State law.

As a candidate or user (see the Definitions section), you may withdraw your consent to the use of your personal data held by any of the entities of the RAINBOW PARTNERS Group without restriction.

10.4 Right to restriction of processing

You have the right to obtain restriction of processing where one of the following applies:

• You contest the accuracy of the Personal Data;

or

• The processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of its use instead;

or

• The entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs) no longer needs the Personal Data for the purposes of the processing, but you require it for the establishment, exercise or defense of your rights;

or

• You have objected to the processing, pending verification of whether the legitimate grounds of the entity ARCHINOV PARTNERS (or one of the entities of the Group to which ARCHINOV PARTNERS belongs) override yours.

10.5 Right to data portability

You have the right to data portability, meaning the right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format, and to transmit it to another data controller.

To exercise your right to data portability, please contact us using one of the means set out in section 10.1 Contact of this policy.

10.6 Right to lodge a complaint with the competent supervisory authority

If you encounter any difficulties, you have the right to lodge a complaint with the CNIL (French Data Protection Authority): https://www.cnil.fr/fr/plaintes

10.7 Instructions regarding your Personal Data after your death

You have the right to set instructions regarding the handling of your Personal Data after your death.

To exercise this right, please send an email to dpo@archinov-partners.fr:

• With the subject line “Instructions regarding my Personal Data after my death”;
• Indicating the person(s) who may act on your behalf with us in the event of your death, as well as the instructions you wish us to follow.

If an employee dies without having left instructions regarding their Personal Data, their heirs may request the erasure of the deceased’s data, once all necessary formalities have been completed, by contacting us by email at dpo@archinov-partners.fr.

The entity ARCHINOV PARTNERS and the entities of the Group to which ARCHINOV PARTNERS belongs ensure that your data is processed securely and confidentially, including when certain operations are carried out by processors or partners. To this end, appropriate technical and organizational measures are in place to prevent the loss, misuse, alteration and deletion of your personal data. These measures are adapted to the sensitivity of the data processed and to the level of risk presented by the processing or its implementation.

This Personal Data Protection Policy will be reviewed annually and may be amended in the event of a significant change in the regulatory framework or of new measures implemented within the entity ARCHINOV PARTNERS and the entities of the Group to which ARCHINOV PARTNERS belongs.

The information collected through this form is used by ARCHINOV PARTNERS to process your request for information. It is recorded and forwarded to the relevant department so that your request can be handled. You may access, modify, exercise your right to portability, have any data concerning you deleted, request the restriction of the processing of your data, withdraw your consent and object to the processing of your data by writing to the following postal address: Archinov Partners – Communication Department – 8 place du marché, 92200 Neuilly-sur-Seine, France, or by email to: dpo@archinov-partners.fr. For more information on how your data is managed and on your rights, please see our Personal Data Protection Policy.

Last updated: September 30, 2024