Privacy Policy

1. GENERAL

VALUMEN GROUPE SAS (« VALUMEN GROUPE », “we,” and “our”), whose corporate headquarters are located at 41 rue Camille Desmoulins, 92130 ISSY LES MOULINEAUX, France, in its capacity as a data controller, places great stock in protecting and respecting your privacy. This policy seeks to inform you about our practices regarding the collection, use, and sharing of information that you may provide to us through our website www.valumen.com or our mobile application.

This policy (as well as our Terms and Conditions of Use and any document referred to in our Cookie Policy) explains how we process the personal data that we collect and that you provide to us. Please read this document carefully to learn more about and gain an understanding of the practices that we use for processing your personal data.

2. TYPES OF INFORMATION WE COLLECT

We may collect and process the following data:

2.1. INFORMATION THAT YOU SEND TO US DIRECTLY

By using our Site and/or our Application, you will send us information, some of which can be used to identify you (“Personal Data”). This particularly occurs when you fill in forms (such as, for example, the registration form), when you contact us—by phone, email, or any other means of communication—or when you inform us of any issues.

In particular, this information contains the following data:

2.1.1. Data necessary for registering you for the service that we provide on our meeting sites or for access to any other service that we provide. This data includes your first and last names, email address, date and place of birth, gender, phone number, banking information (routing and account numbers), and password. The same applies to information gathered in relation to your academic and professional background (diplomas and/or certifications from employers), your acquired skills (hard skills, soft skills, and mad skills), as well as certain hobbies or association memberships that you may decide to share (Curriculum Vitae). Any photos of the Applicant (optional) This information is required for setting up your applicant profile, with the exception of information beyond the professional sphere (hobbies, association memberships, mad skills), even if the latter are reviewed along with your profile for the purposes of given assignments. Without this, VALUMEN GROUPE will be unable to provide the services offered by our Site and/or Application, and you will not be permitted to create an account on our Site and/or Application. As a reminder, “hard skills” correspond to analyzable technical skills acquired as part of a set skills base for the position sought; “soft skills” allow us to analyze your adaptive abilities (management, ease with public speaking, empathy, ability to unite people, etc.) in a specific professional environment; “mad skills” are atypical skills that characterize an applicant’s personality particularly outside the professional scope;

2.1.2. A photo on your profile;

2.1.3. Your town/city and country of residence;

2.1.4. A copy of all correspondence between you and VALUMEN GROUPE;

2.1.5. Details of your visits to our Site and the content that you accessed;

2.1.6. Where applicable, your responses to our questionnaires, which may be used in particular during our searches and user activity analyses;

2.1.7. Data that we may request that you provide when you alert us to an issue with our Site or our services, such as the purpose of your request for assistance;

2.1.8. Data related to your location, once you have accepted that we collect and process this data;

2.1.9. A copy of your passport, your driver’s license, your ID card, or any other similar document that you have agreed to provide to us as needed in order to prove your identity in the event of litigation on one of our sites or involving the company VALUMEN GROUPE.

2.2. DATA COLLECTED AUTOMATICALLY

2.2.1. During each of your visits, in accordance with applicable legislation and with your consent, we may collect information about the devices on which you use our services or the networks from which you access our services where applicable, such as your IP addresses, connection data, internet browser types and versions used, browser plugin types and versions, systems and sites used, data regarding your browsing path on our Site and/or Application, particularly your path on the various URL pages of our Site and/or Application, the content that you access or view, search terms used, download errors, the amount of time spent viewing specific pages, your device’s advertising ID, interactions with the page, and any phone number used to contact us. Among other technology types used to collect this information, we use cookies (to learn more about this, please refer to our Cookie Policy).

2.2.3. We also collect information on your use of our Site and/or Application (frequency, interactions, introductions, requests for information).

2.3. HOW LONG WE RETAIN YOUR DATA

2.3.1. With the exception of the categories of Personal Data referred to in Articles 2.3.2. and 2.3.3. below, your Personal Data is archived at the end of the following periods:

  • Three years after your last use of our Sites, if you did not close your account;
  • One year after the closure of your account, unless you’ve received a negative decision or a notification, in which case your data is retained for two years following the most recent negative decision or notification received, whichever is longest.

2.3.2. The following categories of Personal Data may be retained for varying lengths of time:

  • Financial data (for example, payments, reimbursements, etc.) are retained for the duration required by applicable legislation on taxation and accounting;
  • Content created by you on our Sites (such as comments, opinions, and ratings) are anonymized after the periods mentioned in 2.3.1 but remain visible on our Sites.

2.3.3. Should your account be suspended or blocked, we retain your data for a period of between one and three years following the suspension in order to prevent you from circumventing the rules in effect on our Site.

3. HOW WE USE THE DATA WE COLLECT

We use the data that we collect to:

3.1. optimize the management of your applicant area, in order to better label the search and the assignments offered based on the needs expressed by our prospective and current corporate customers;

3.2. execute contracts between you and us, and provide you with the requested information and services, particularly with regard to introductions to our corporate customers and ensuring the administrative management of our relationships (orders, contracts, invoices);

3.3. send you information about our services via e-mail, text message, or any other means of communication;

3.4. allow you to personalize your profile on our Site;

3.5. allow you to communicate and discuss with other users who may be applicants or hold a position, particularly regarding our services;

3.6. give you access to and allow you to communicate with our “Users” support service;

3.7. ensure that (i) applicable legislation, (ii) our terms and conditions of use, (iii) our privacy policy, and (iv) our code of user conduct are all being obeyed. Any failure to comply on your part may result in suspension of your account on our Sites;

3.8. send you, in accordance with the applicable legal provisions and with your consent where required by legislation, offers, news, and information about the use of our services, or offer suggestions and advice on services that may interest you;

3.9. inform you about changes made to our services;

3.10. verify the information contained in your passport, driver’s license, ID card, or any other proof of identification that we may have collected during your registration or your use of our Site and/or Application if needed (litigation, complaints, administrative and/or legal requests);

3.11. manage our Site and/or Application and perform technical operations when resolving problems, analyzing data, conducting tests, research, analyses, studies, and surveys;

3.12. improve and optimize our Site and/or Application, particularly in order to ensure that the way our content is displayed is suitable for your device;

3.13. improve your experience as a customer and as an applicant;

3.14. help us maintain a healthy and secure environment on our Site and/or Application.

4. WHO RECEIVES THE INFORMATION WE COLLECT AND OUR REASONS FOR SHARING IT

4.1. When using our applicant/customer introductory platform, some of your information is transmitted to other users through your profile: this involves professional information entered by you and helpful for optimizing an application as part of a proposed job offer. No other information is shared among users. You remain the sole party liable for the other personal data that you may send directly and deliberately to another user; VALUMEN GROUPE cannot be held liable to this effect.

4.2. We may also share information regarding you, particularly Personal Data, with other entities in the VALUMEN GROUPE within the framework prescribed by this policy.

4.3. We also work in close collaboration with third-party companies, which may have access to your Personal Data, particularly with:

  • social media sites that may offer you functions that allow you to add information from their site to your VALUMEN GROUPE profile;
  • subcontractors which we may employ for technical, payment, or identity verification services, or suppliers of analytical solutions and collection and credit agencies.

4.4. We only share your data with the third parties mentioned in 4.3 above in the following cases:

4.4.1. When we call on a service provider during the execution of any contract between you and us or in order to provide or improve our services

4.4.2. When we call on providers of search engines and analytical solutions to improve and optimize our Site and/or Application;

4.4.3. When you expressly request it;

4.4.4. When we are legally obligated to do so or if we believe in good faith that it is necessary (i) for responding to any complaint regarding VALUMEN GROUPE, (ii) for complying with any judicial requests, (iii) for ensuring the execution of any contract entered into with our Users, such as the Terms & Conditions of Use and this Privacy Policy, (iv) in the event of an emergency putting public health or a person’s physical integrity at risk, (v) as part of inquiries or investigations, or (vi) in order to secure the rights, property, and security of VALUMEN GROUPE, its members and, in a more general sense, any third party;

4.4.5. Should we come to sell or purchase a company or assets, in which case we reserve the possibility of sharing your Personal Data with the potential seller or purchaser of said company or said assets;

4.4.6. If VALUMEN GROUPE or any part of its assets are purchased by a third party, the data in our possession will be transferred to the new owner where applicable;

4.4.7. In accordance with applicable legislation, and with your consent where required, we may aggregate data concerning you that we receive or send to our business partners, in particular, all or part of your Personal Data and the information collected through the use of cookies. This aggregated information will only be used for the purposes described above.

5. USE AND MODERATION OF MESSAGES

We may review the messages that you exchange with other Users via our Site and/or Application, particularly for the purposes of preventing fraud and poor conduct, and/or risks to the physical or moral integrity of our members, improving our services, assisting users, and verifying that our members are complying with our Terms & Conditions of Use.

6. NEWSLETTERS, E-MAILS, AND TEXT MESSAGES

In accordance with applicable legislation, and with your consent where required, we may use the data that you provide to us on our Sites for the purposes of business development (for example, (i) to send you our newsletters, and (ii) to send you invitations to our events), or any other communication that may interest you.

With regard to promotional emails: You can withdraw your consent at any time by (i) unchecking the appropriate box in your account, (ii) clicking on the “unsubscribe” link provided in each of our messages, or (iii) contacting us using the methods described in Article 14 below.

7. DATA RETENTION AND TRANSFER

We keep your Personal Data in the European Union. However, it is possible that the data that we collect when you use our Site and/or Application or within the scope of our services will be transferred to other countries, some of which may have less stringent data protection legislation than that in effect in your country of residence.

This is particularly true with respect to data transferred to our subcontractors located outside the European Union, particularly in the United States. We may make use of their services to respond to your requests, to provide marketing services, or to provide emailing or text message services.

This is also the case with respect to companies affiliated with VALUMEN GROUPE located outside the European Union, to whom we may transfer some of your data within the framework of providing our services in these countries.

Should this type of transfer occur, we ensure that the processing is performed in accordance with this policy, and that it is framed by the standard contractual clauses of the European Commission that allow for the guarantee of a sufficient level of protection of individuals’ private life and fundamental rights.

Upon simple request, we can provide you with the list of countries where we store your data and those where it is occasionally sent.

8. WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL DATA?

8.1. Where provided for by applicable legislation, you have the right to obtain a copy of your personal data that we hold. Before responding to your request, we may (i) verify your identity and (ii) ask you to provide us with more information in order for us to respond to your request.

8.2. We will make every effort to follow up with your request within a reasonable time period and, in any event, within the time limits defined by law. If you wish to exercise this right, please contact us using the methods provided in Article 14 below.

As a user of our Site and/or Application, you also have the ability to access the Personal Data that we hold through your account, in order to correct, modify, or delete any incorrect information. You undertake to provide us with information that is complete, accurate, valid, and up to date. You may also close your online account at any time.

You may also modify this information by contacting us directly (see Article 14 below).

Please note that we may retain certain information about you where required by law, or where we have legitimate grounds for doing so. This is the case, for example, if we believe that you have committed fraud or violated our Terms & Conditions of Use and we wish to prevent you from violating the rules that apply to our community.

8.3. You also have the right to create directives regarding what happens to your Personal Data after your death.

9. COOKIES AND SIMILAR TECHNOLOGIES

To learn more, please see our Cookie Policy.

10. KEEPING YOUR PASSWORD PRIVATE

You are responsible for the privacy of the password that you’ve chosen to use for accessing your account on our Sites.

You undertake to keep this password secret and not to share it with anyone.

11. LINKS TO OTHER WEBSITES AND SOCIAL MEDIA

Our Site and/or Application may sometimes contain links to the websites of our partners or of third parties. Please note that these websites have their own privacy policies and that we deny any responsibility regarding the way these sites use the information collected when you click these links. We invite you to read the privacy policies of these sites before sending them your Personal Data.

12. GENERAL DATA PROTECTION REGULATION

We guarantee that the data collected on our servers is kept confidential in accordance with the recommendations of the General Data Protection Regulation (GDPR) – (Regulation EU 2016/879 of April 27, 2016).

We guarantee the right to erasure and the right to the portability of the Personal Data of any person registered in one of our files, upon their first request.

We undertake to inform the national protection authority immediately in the event of a data leak or violation, so that the persons concerned can take every possible measure to protect their data.

We undertake to ensure that any subcontractors we work with can comply with these measures.

Some information gathered and held as part of the T&Cs may give rise to the exercise of the right of access and rectification under the conditions provided by French Law No. 78-17 of January 6, 1978 as amended on computing, files, and liberties.

Our CNIL [French data protection agency] contact and data protection delegate is Mr. Nicolas Doucerain, who can be contacted by email at the following address: contact@valument.com or at the following mailing address: VALUMEN GROUPE – Données Personnelles – 41 rue Camille Desmoulins 92130 Issy-les-Moulineaux, France.

13. CHANGES TO OUR PRIVACY POLICY

We may make occasional changes to this privacy policy. When that is necessary, we will inform you and/or request your consent. We advise that you regularly visit this page to review any changes or updates made to our privacy policy.

14. CONTACT INFORMATION

For any questions regarding this privacy policy, or for any requests pertaining to your personal data, you may contact us via email at contact@valumen.com or by sending a letter to the address mentioned at the top of this document.

November 14, 2020 version