A. Definitions

“Data controller“: refers to any natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes (the “why”) and means (the “how”) of the processing operation.“Data subject“: refers to any natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.“Personal data“: refers to any information relating to an identified or identifiable natural person. This person is called the “data subject”.“Processing of personal data“: refers to any operation or set of operations which may or may not be performed using automated processes and applied to Personal data or sets of Personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction.“Processor“: refers to any natural or legal person, public authority, department or other body which processes Personal data on behalf of the Data controller.IMPORTANT: NOTE TO USERSBROWSING THE SITE AFTER PUBLICATION OF THIS PRIVACY POLICY IMPLIES UNRESERVED ACCEPTANCE OF IT.If the User wishes to withdraw his consent to the processing of his data, he simply need to send a request directly by email to the following address: gdpr@kakoo-software.comIn addition, where required by law and/or in certain circumstances, the User’s consent will be obtained or an opportunity to refuse will be provided before any data is transmitted.

B. Who is responsible for processing the personal data collected ?

Kakoo-Software is Data controller for processing Personal data.

C. What data do we collect and how do we use it ?

All data processed by Kakoo-Software complies with regulatory requirements in terms of compliance with purposes, retention periods, recipients and data security. Kakoo-Software specifically informs you of the processing carried out on your data prior to its implementation, for example via legal clauses inserted into our tools and websites. However, you will find below some general information on our data processing.

 Candidates

Would you like to join our team? Then you’re right!When you send us your application or when we contact you, we essentially process these categories of data about you:

• Identification data (such as surname, first name, postal address, email address, telephone number, etc.);
• Professional details (such as CV, covering letter, etc.);
• Data relating to interviews and any tests;
• Connection data (such as IP address, web pages visited on the site and browsing data such as cookies).

The recipient of the Personal data collected on the Site is first and foremost Kakoo-Software and in particular our HR team, our Management.Personal data will not be disclosed to third parties, except for any processors we may use to provide services to the Site – subject to supervision where applicable – (for example, if we use a third party to perform impartial technical tests on you).Candidates’ Personal data is kept for up to two (2) years from the last contact from you, unless you have given us your consent to keep it for longer (e.g. to remain in our CV database).

Clients

Have you put your trust in us and become one of our happy clients? Then you’re right!When you work with us and our tools, we essentially process these categories of data about you:

• Identification data (such as surname, first name, email address, telephone number, etc.);
• Job-related data (such as job title, Kakoo-Software authorisation levels, etc.);
• Billing data;
• Exchanges and data relating to customer service;
• Connection data (such as IP address, web pages visited on the site and browsing data such as cookies).

The primary recipient of the data is Kakoo-Software and in particular our technical and sales teams.Personal data will not be disclosed to third parties, except for any Processors we may use – subject to supervision where applicable – (for example when we provide you with assistance via our ticketing tool).As a Client, your data is kept for the duration of our contractual relationship, plus five (5) years for the purposes of commercial canvassing and proof (statutory limitation period). For further information, please refer to the “Data protection / GDPR” appendices to our General Terms and Conditions of Sale.

Prospects

Have you expressed an interest in our products and services? We look forward to welcoming you as one of our Clients !When we exchange information with a view to future collaboration, we essentially process these categories of data about you:

• Identification data (such as surname, first name, postal address, email address, telephone number, etc.);
• Data relating to the company, professional situation and business needs;
• Data relating to commercial actions and exchanges (such as the monitoring of commercial exchanges and proposals, management of demonstrations, etc.);
• Connection data (such as IP address, web pages visited on the site and browsing data such as cookies).

The recipient of the Personal data collected on the Site is first and foremost Kakoo-Software and in particular our sales teams.Personal data will not be disclosed to third parties, except for any processors we may use to provide services to the Site – subject to supervision where applicable – (for example, if we organize a remote demonstration using a videoconferencing tool).Prospects’ personal data is kept for up to five (5) years from the last contact from you, unless you object in advance to our commercial canvassing activities.

Visitors

As we have not yet had the pleasure of getting to know you, we do not process any data about you, except for browsing data, in particular cookies.

D. What is the purpose and legal basis for collecting personal data ?

1) Purpose of the personal data collected

Personal data collected on the Site is used solely for and during the performance of services for the following purposes:

• recruitment management for candidate data;
• commercial relationship management for client data;
• management of pre-contractual relations for prospect data;
• collection of information by means of cookies and other tracers;
• proper operation and continuous improvement of the Site and its functionalities: general administration, performance monitoring and general management of Site security.

Kakoo-Software may also use the data to meet its legal and/or regulatory obligations, where applicable.

2) Legal basis for processing activities

Processing activities and the collection of Personal data are authorized on the following legal basis:

• performance of contractual or pre-contractual obligations for the management of recruitment, the management of commercial relations and the management of pre-contractual relations;
• Kakoo-Software’s legitimate interest in guaranteeing the highest level of operation and quality of the Site for the proper functioning and continuous improvement of the Site;
• User’s consent to the deposit of cookies and other tracers.

 

3) Aggregation with non-personal data

Kakoo-Software reserves the right to publish, disclose and use aggregated information (information about Users or specific groups or categories of Users combined in such a way that an individual User can no longer be identified or referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.

E. What are our canvassing practices ?

Under no circumstances do we use Candidate data for commercial canvassing purposes. As far as our Clients and Prospects are concerned, we comply strictly with the regulations in force, whatever the channel (post, email, SMS/MMS, automatic call machines, etc.). Furthermore, when you have given us your trust and consent to the transmission of relevant information about our products and services, in line with your needs, you retain the ability to reverse your decision at any time. Otherwise, your data will be kept for up to three (3) years from the last contact from you.

F. When is the data collected ? 

The data collected by Kakoo-Software is freely communicated by Users when registering for an account for candidates, clients and prospects.It may also be collected automatically during use of the Site, in particular when the User browses the Site’s pages.This automatically collected data does not reveal the identity of the User but concerns the use of the services. This collection is necessary for the maintenance and operation of Kakoo-Software services and for its internal analyses and reports.This information includes:

• information on how the services are used (frequency, traffic data, how the User reached the Site);
• information about the device used to access the services (device name, country, location, IP address, browser and device characteristics, operating system, language preferences, reference URL).

In any event, the Personal data collected :

• will be obtained and processed fairly and lawfully;
• will be recorded for specific and legitimate purposes;
• will be used in accordance with these purposes;
• will be adequate, relevant and not excessive in relation to these purposes; and
• will be subject precautions to ensure the security and confidentiality of the data in order to prevent it from being damaged, modified, destroyed or communicated to unauthorized third parties.

 

G. Do we use cookies and other tracers ?

A cookie is a text file that may be stored in a dedicated space on the hard disk of the User’s computer when he visits an online service using his browser software.In practice, cookies are small text files that are placed on the User’s computer by the websites that the User visits. They are used to operate the websites and improve the ease of use of these sites.The cookie is sent by a website’s server to the User’s browser. Each cookie is assigned an anonymous identifier. A cookie cannot be traced back to a physical person.When consulting the Platform, Users are informed that cookies or other means of recording browsing data are used by the Platform or by third parties providing services for the Platform and deposited on the User’s terminal (computer, mobile or tablet).Kakoo-Software or its partners may install, subject to the User’s acceptance, various cookies and in particular:

• session cookies, which disappear as soon as the User leaves the Platform;
• permanent cookies, which remain on the User’s terminal until their lifetime expires or until the User deletes them using their browser’s functions; and
• statistical cookies (used to measure the Platform’s audience).

Only the issuer of a cookie can read or modify the information contained in it.In accordance with the recommendations of the CNIL, when connecting to the Platform for the first time, Users will be expressly asked to accept cookies from the Platform.To see exactly which cookies we use in real time, we invite you to download “Ghostery”, a free browser extension.

Purpose of cookies

The cookies used by Kakoo-Software or its partners make it possible to identify Users, to recognize their browser when they connect to the Platform, to record their access frequencies (traffic measurement) and the display preferences of the Users’ terminal, to adapt and/or personalize the presentation of the Platform to improve the experience of Users and to optimize the Platform with the sole aim of providing the services requested by the User.The different types of cookies that may be used on our websites are as follows:

Mandatory cookies

These cookies are necessary for the Platform to function properly and cannot be deactivated. They are useful to us for providing you with a secure connection and ensuring the minimum availability of our website.

Functionality cookies

These cookies enable us to analyze the use of the Platform so that we can measure and improve its performance. For example, they enable us to store your connection information and display the various modules of our site more consistently. They also enable us to activate certain features of the Platform, such as chat support.

Social and advertising targeting cookies

These cookies are used by advertising agencies (Google Analytics, Google Adwords, Google dynamic Remarketing, DoubleClic and Piwik) and by social networks (via AddToAny) and authorize the sharing of pages on social networks, the publication of comments and the distribution (on our site or not) of advertising tailored to your areas of interest.

Cookie retention period

In accordance with CNIL recommendations, cookies are kept for a maximum of thirteen (13) months after they are first placed on the User’s terminal, as is the period of validity of the User’s consent to the use of these cookies. The lifespan of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.

The User’s right to refuse cookies

When browsing the Platform for the first time, a banner explaining the use of cookies appears. It allows the User to activate or deactivate some cookies. This banner will only disappear once the User has accepted, or not, the use of cookies in order to continue browsing.The saving of a cookie is subject to the Users’ wishes. In accordance with legal and regulatory provisions, Kakoo-Software obtains prior consent for the deposit of cookies.Regarding advertising cookies placed by third parties, you can also connect to the Youronlinechoices platform, offered by digital advertising professionals belonging to the European Digital Advertising Alliance (EDAA). You can then refuse or accept the cookies used by the member advertising professionals.It is also possible to object to certain third-party cookies directly with the publishers:

• For analytical and performance cookies: the deactivation method Realitycs and Google Analytics.
• For targeting or advertising cookies: the deactivation method is Mediarithmics

Users also have the option of configuring their browser software in such a way as to oppose, in whole or in part (depending in particular on the issuer), the recording of cookies. The configuration also offers the possibility of accepting or refusing cookies on a one-off basis, before they are stored on the User’s terminal.Users who wish to prevent cookies from being saved can follow the procedure specific to each browser and described in the browser’s help menu.

• Chrome
• Internet Explorer
• Edge 
• Safari
• Firefox
• Opera

However, if Users object to the saving of cookies or uninstall a cookie, they are informed that certain services may no longer function correctly.Click here to change your cookie preferences

H. Where do we host your personal data ?

As far as possible, Kakoo-Software only processes your data within the European Union and does not transfer this data outside this area.However, in the case of international transfers outside the European Union, a distinction must be made between :

• countries that have been the subject of an adequacy decision by the European Commission: in this case, the data is transferred to a country that provides a level of protection deemed sufficient and adequate to the provisions of European data protection regulations; and
• countries whose level of data protection has not been recognised as adequate: in this case, to guarantee a transfer in compliance with European regulations, and in particular to ensure data security, Kakoo-Software will base its transfer on protection mechanisms adapted to each service provider and processor, such as the conclusion of standard contractual clauses approved by the European Commission, the application of binding company rules or under an approved certification mechanism.

 

I. How do we protect your personal data ?

Protecting your Personal data and privacy is of great importance to Kakoo-Software.Kakoo-Software undertakes to implement appropriate and reasonably necessary measures about the regulations applicable to the protection of Personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, in order to guarantee a level of security appropriate to the risks incurred for the rights and freedoms of natural persons in connection with the processing referred to in this privacy policy.Kakoo-Software takes care to protect and secure your data in order to ensure its confidentiality and prevent it from being distorted, damaged, destroyed or disclosed to unauthorized third parties. Kakoo-Software takes the necessary precautions, in the light of the state of knowledge, the nature of your data, the needs, the risks, the costs of implementation and the nature, scope, context and purposes of the processing, to preserve the security of the data and implements the following measures:

• Organizational: authorizations, data processing procedures to ensure that only the people who need your data in the course of their duties have access to it (these people being subject to an obligation of confidentiality), etc. ;
• Physical/hardware: protection of our premises, encryption of our work tools, choice of reliable hosting providers whose security is widely recognized;
• Logic: implementing security tools (antivirus, firewall, anti-intrusion systems, etc.), securing computer workstations and network peripherals, etc. We also have regular security audits carried out by specialist third parties, and we undertake to correct any vulnerabilities detected as quickly as possible.

Where Personal data is transferred to third parties for processing, Kakoo-Software ensures that such third parties implement all appropriate technical and organizational measures to ensure the protection of Personal data in accordance with applicable laws.Finally, in the event of a violation of rights concerning Personal data likely to give rise to a high risk for the rights and freedoms of the User, Kakoo-Software undertakes to assist the Client in guaranteeing compliance with its obligations, in order to inform the User of this violation within a maximum period of seventy-two (72) hours.

J. How can you exercise your rights with regard to your data ?

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the “GDPR“, on the protection of individuals with regard to the processing of Personal data and on the free movement of such data, and with Law No. 78-17 of 6 January 1978, known as the “Informatique et Libertés” law, as amended by Law 2004-801 of 6 August 2004 on information technology, files and freedoms, the User has:

• the right of access to their Personal data;
• the right to rectify Personal data;
• the right to delete and erase their Personal data;
• the right to object to the processing of Personal data;
• the right to limit the processing of his data;
• the right to data portability, where the data is processed automatically on the basis of consent or a contract;
• the right to withdraw consent at any time; and
• the right to define what happens to their data after their death.

Users wishing to assert one of their rights may send their request by email or by post to the following addresses:

• Postal address : Kakoo-Software – 95 B RUE DE MORIFOSSE 95100 ARGENTEUIL – FRANCE
• Email address: gdpr@Kakoo-Software.com

In the event of exercising one of these rights, the User must provide Kakoo-Software with the information required to identify him: surname, first name, email address and, if applicable, postal address.In addition, in accordance with the regulations in force, the User’s request must be clear and specify in detail the right he wishes to exercise as well as the address to which he wishes to receive a reply if one of the rights listed above is exercised. Users may be asked to provide a photocopy of an identity document bearing their signature in order to verify their identity.Kakoo-Software undertakes to respond within a maximum of one (1) month following receipt of the User’s complete request.Due to the complexity of the request and/or the number of requests, this period may be extended by two (2) months on condition that the User is informed of the reasons for the postponement within one (1) month of receipt of the request.Users also have the right to lodge a complaint with the Commission for Data protection and Liberties (hereinafter the “CNIL“) in one of the ways indicated below:

• Via the CNIL website: www.cnil.fr/fr/plaintes or www.cnil.fr
• By postal address : Commission Nationale de l’Informatique et des Libertés – CNIL

3 Place de Fontenoy TSA 80715 – 75334 PARIS CEDEX 07

K. Changes to the data protection policy

This data protection and confidentiality policy may change at any time as a result of legal, regulatory, case law and doctrinal developments (particularly CNIL doctrine). We will publish any changes on this page and, in the case of significant changes, on other pages of this website via dedicated inserts or information banners. Any changes that must be expressly brought to the attention of data subjects will be communicated, for example, by email.The version that prevails is that which is accessible online on the day the Site is consulted.Any consultation of the Site after publication of the amended confidentiality policy implies unreserved acceptance of the new confidentiality policy.