Privacy Policy

Introduction

1 - Definitions

The following terms shall have the following definition, whether used in the singular or plural:

- Access: means the process by which Users access the Solution using a login - email address - and a password.
- Client: refers to companies that have subscribed to a user license so that their employees can access the PickYourSkills Solution Services.
- Candidate: refers to the natural persons who have submitted an application for a job offer within PickYourSkills.
- Data: refers to all data and information collected and processed by PickYourSkills concerning Users, Candidates, Clients, Suppliers and Visitors and which may be qualified as personal data within the meaning of the applicable regulations on the protection of personal data.
- Supplier: refers to the legal entities that supply PickYourSkills with goods and/or services.
- Applicable regulations regarding the protection of personal data: means the law n°78-17 of 6 January 1978 known as the "Informatique et libertés" law in its latest version in force and the 2016/679 regulation regarding data protection.
- Services: means the functionalities of the Solution that are offered to the User as part of the Access entrusted to him by the Customer.
- Solution: means the Saas platform accessible via the Accesses and which is edited and maintained by PickYourSkills.
- User: means the natural persons who have an Access to the Solution according to the authorizations defined and configured by the Client and who can access the Services within the framework of these personal and individual Accesses.
- Visitors: refers to any natural or legal person who accesses the https://www.napta.io/ website.

2 - What is the nature of the data collected by PickYourSkills?

PickYourSkills may collect different categories of information depending on the nature and purpose of the personal data processing it operates and the type of person concerned. In all cases, PickYourSkills undertakes to collect and process only the data that is strictly necessary for the purposes of the said data processing.

2.1 - Concerning the Users of the Solution

When using the application, PickYourSkills records data about you: identity data (last name, first name, professional e-mail address, position, seniority), information about your skills, your experience and data about your availability. PickYourSkills also collects the number of visits and the date and time associated with each visit for all Users.

2.2 - Concerning PickYourSkills' Clients and prospects

In the course of managing its Clients and searching for prospects, PickYourSkills stores data about you: data relating to identity (surname, first name, professional e-mail address, telephone number, position, seniority), financial data (bank details of the legal entity to be invoiced as regards Customers), data relating to the follow-up of the commercial relationship (requests for documentation, services subscribed to, periodicity, order number, correspondence with the customer and after-sales service, comments from customers and prospects, person(s) in charge of the customer relationship), data relating to the payment of invoices, data necessary for the realization of prospecting, study and promotional actions.

2.3 - Concerning Candidates for a position within PickYourSkills

In the context of the recruitment of its employees, PickYourSkills collects data relating to the identity of the Candidates (surname, first name, e-mail address), data relating to the career paths and professional life of the Candidates and more generally any other information that the Candidates decide to communicate in their Curriculum Vitae and/or cover letter. PickYourSkills does not want you to communicate sensitive data to us, in particular any information relating to your origin, state of health, morals, sexual orientation, political opinions, trade union activities, religious beliefs, membership or non-membership of an ethnic group, nation or race. Any communication of such sensitive information may result in your application being rejected by PickYourSkills.

2.4 - Concerning the Visitors of the Site

The data collected during your visit to the PickYourSkills website is the date and time of your visit.

2.5 - Concerning PickYourSkills Suppliers

PickYourSkills collects data relating to the identity of Suppliers (company name, first name and surname/title of the point of contact, address of the registered office and place of invoicing, telephone, fax, professional e-mail address, SIREN number) as well as data relating to the invoicing and payment of Suppliers' invoices

3 - How is the data collected?

We collect your personal data in the following ways:


- via the use of the PickYourSkills Services and Solution (https://app.pickyourskills.com);
- via third-party services integrated with the PickYourSkills application (software, applications and tools such as your CRM, ERP or HRIS, among others): we offer integration with third-party services directly from our platform. Some of these services store and share your personal data with PickYourSkills;
- via third party recruitment services (Welcome To the Jungle, Jobteaser) with respect to data of Candidates for a position with PickYourSkills; We use aggregated and anonymous information for purposes such as improving the PickYourSkills Services, testing our IT systems, conducting research, analyzing data, and developing new features.

4 - Do we share your personal data?

PickYourSkills is committed to protecting the data of its Users, Customers, Suppliers, Applicants and Visitors and to restricting the sharing of such data to the greatest extent possible. Each sharing of data is either necessary to provide the PickYourSkills Services or justified to help improve the PickYourSkills Services. PickYourSkills does not sell the personal data of its Users, Customers, Suppliers, and Candidates and Visitors. The actors with whom some data is shared are:


- your company's employees with regard to User data. Your contact information (last name, first name, email, etc.) is accessible to all your company's employees via their personal space on the Solution. On the other hand, some information is only accessible to certain types of Users of the tool, depending on the rights that your company has configured to use the PickYourSkills Services. These privileged accesses give, among other things, access to employees' expertise levels, future business opportunities, reports, assessments...;
- the invisible Service Providers. PickYourSkills uses the services of technical providers who may operate the technical infrastructure we need to provide the PickYourSkills Services, including providers who host, store, manage and maintain the PickYourSkills Solution and Site, its content and the data we process. PickYourSkills also uses technical service providers to help us communicate with you;
- the buyers of our business. We will share your personal data if we sell or negotiate to sell our business to a buyer or potential buyer. In this case, PickYourSkills will continue to maintain the confidentiality of your personal data and will notify you in advance of any transfer of your personal data to the buyer or of any implementation of new privacy policies.

5 - How long will your data be kept?

PickYourSkills only keeps the Data for a period of time that is necessary and proportional to the purpose for which it was collected. Thus the duration is specified for each category of Data below:

5.1 - Customer and prospective customer data

Personal data used in the management of our Customers and prospects will not be kept beyond the time necessary to manage our commercial relationship with your company.
However, concerning the personal data that you could have shared with other Users of the Services (i.e. Employees of your company), these data will remain visible by these Users and thus preserved on the Services until all these Users have left the Services (plus a three (3) years delay) or deleted these data.
Regarding any prospecting operations aimed at former Customers, Customer data may be kept for a period of three (3) years from the end of the commercial relationship. At the end of this three (3) year period, we may contact you again to find out if you wish to continue receiving commercial solicitations. The information that allows us to take into account your right to object will be kept for a minimum of three (3) years from the time you exercise your right to object.

5.2 - Data of the Users of the Solution

In the course of using the Services, you may be required to modify or delete all or part of your Personal Information. These changes will be effective immediately upon your action. If any deletion is taken into account immediately on the Services, we have as a security measure several backup copies of the data in order to prevent any technical disaster; consequently, any deletion of personal data is final within our technical platform only after a period of one (1) month, allowing the rotation of all backups.
The Personal Data used in the context of the Services will not be kept beyond a period of three (3) years following the deletion of your User account. This period will allow you to retrieve all of your Personal Data should you decide to join the Services again.
However, with respect to personal data that you may have shared with other Users of the Services (i.e., your company's employees), such data will remain visible to such Users and therefore retained on the Services until all such Users have left the Services (plus a period of three (3) years) or deleted such data.
In the event that a Customer wishes to terminate its license, PickYourSkills has one (1) month to delete all Personal Data relating to the Customer's employees.

5.3 - Data relating to statistics and audience measurements

The information stored in the terminal of the Users or any other element used to identify the Users and allowing their traceability or frequentation will not be kept beyond 12 months.

5.4 - Candidate data for a position at PickYourSkills

If you apply to PickYourSkills and your application is not successful, we will keep your data in our CV database so that we can contact you again for a position to which you are more suitable, for a period of two years, provided you do not object when we inform you of this. You may object at any time to the retention of your data for this purpose.

5.5 - Supplier data

Data relating to PickYourSkills Suppliers will be retained for the duration of the contractual relationship and for a period of three years thereafter.
Upon your request, we will delete or anonymize your Personal Data so that you can no longer be identified, unless we are permitted or required by law to retain certain Personal Data.
PickYourSkills keeps all of its data within the European Union, and does not transfer personal data outside the European Union. PickYourSkills servers are managed by Amazon Web Services and located in Frankfurt. To manage the authentication of the Users on the Solution, PickYourSkills uses the service provider Auth0 which also stores the Personal Data in the European Union.

6 - How are your personal data secured?

PickYourSkills is committed to protecting the personal data of its Users. We implement appropriate technical and organizational measures to protect the security of your personal data. However, please note that no system is completely secure. We take all state-of-the-art organizational and technical measures to protect your personal data against security breaches, including the destruction, loss, alteration, unauthorized disclosure, accidental or unlawful transmission, storage or other processing of personal data.
Your password protects your User account, so we encourage you to use a secure and unique password and to limit access to your computer and browser.

7 - Do we share your data?

We do not disclose your personal information to third parties, except through the use of service providers or in exceptional circumstances described below.

7.1 - Suppliers

Hubspot: CRM tool used to manage our prospects and customers. Link to their security policy
Welcome to the Jungle: Publication of job offers and receipt of applications in response. Link to their privacy policy
Crisp: Customer relationship management and online help. Link to their privacy policy
AWS: Server hosting. Link to their privacy policy
Auth0: Securing authentication on the Solution: Link to their privacy policy
Postmark: Communication with our Customers. Link to their privacypolicy
UserPilot : Onboarding in-app. Link to their privacy policy

7.2. Legal obligations

We may disclose your information, including your IP address, to comply with any law, regulation, court order or other legal request to protect persons and property, to troubleshoot technical problems or to protect PickYourSkills' rights or property.

8 - What are your rights?

In accordance with the provisions of the law known as "informatique et libertés" of January 6, 1978, as amended, and the General Data Protection Regulation (GDPR), you have the right to access, rectify, delete, limit, oppose and port personal data concerning you within the limits of our legal obligations and the requirements of your employers.
To exercise your rights, please contact us at privacy@pickyourskills.com and we will reply as soon as possible, and in any case within the one month period allowed to us.


Your request can also be sent to the following address PickYourSkills SAS, 112 Avenue de Paris, 94300 Vincennes.
- Right of information: this Policy informs our Users about the nature and use of personal data.
- Right of access: You have a right of access to the data concerning you processed by PickYourSkills. It allows you to see the data we have about you and, if you wish, to request a copy.
- Right to rectification: Under the terms of the applicable regulations on the protection of personal data, you may request that we rectify any personal data concerning you that is inaccurate. You may also request that incomplete personal data concerning you be completed, including by providing a supplementary statement in support of your request.
- Right to erasure: You have, within the limits of your employer's legal data retention obligations or our legal obligations, the right to obtain the erasure, as soon as possible, of personal data about you subject to our legitimate interest or any legal obligation requiring us to retain it.
- Right to portability: You may at any time request the portability of your data to PickYourSkills. We undertake to transmit to you within a reasonable period of time and in a machine-readable format the data you have provided to us, whether declared by yourself or generated by your activity on the platform.
- Right to Withdraw Consent: You have the right to refuse the processing of your personal data for personal reasons at any time as well as the right to refuse the processing of your personal data for direct marketing purposes.
- Right not to be subject to automated decision making: we do not use automated decision making.
- Right to lodge a complaint with a supervisory authority: PickYourSkills is located in Paris. As such, the competent supervisory authority to deal with any request concerning us, including, if applicable, a user's complaint, is the Commission Nationale de l'Informatique et des Libertés (CNIL).


If you wish to contact the CNIL with any request, you will find below the contact details:
CNIL (COMMISSION NATIONALE DE L'INFORMATIQUE ET DES LIBERTÉS)
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tel: 01 53 73 22 22 (Monday to Thursday from 9am to 6:30pm / Friday from 9am to 6pm)
Fax: 01 53 73 22 00


Attention! The CNIL does not receive the public and does not provide any information on site.


If you wish to file a complaint with the CNIL, you can fill in the online complaint form available at the following address: www.cnil.fr/fr/plaintes
. If you have a question about your rights regarding data processing and liberties, you can consult the CNIL website: www.cnil.fr.

9 - Will this privacy policy change?

We may make changes to this Policy from time to time.
If we make changes to this Policy, we will notify you through appropriate notices, such as by posting a notice in the PickYourSkills application or sending you an email. We may notify you of such changes in advance.

10 - How to contact us ?

Thank you for reading our Privacy Policy.
If you have any questions about the protection of your personal data, you can contact us at support@pickyourskills.com and detail your concern. We will do our best to answer you in a clear and understandable way and as soon as possible.

The purpose of this privacy policy (hereinafter "Policy") is to inform you of the methods of collection and processing of personal data collected or processed by PickYourSkills in accordance with the applicable Regulations on personal data. The terms "you", "your" and "yours" refer, as the case may be, to Customers, Users, Candidates, Suppliers and Visitors to the Site (https://pickyourskills.com).

Indeed, in order to allow its Clients to manage their skills and to make their processes more fluid assignment, PickYourSkills collects and records your personal data as a collaborator of a Client and as a User of PickYourSkills Services. The confidentiality and security of your personal data are, and will remain, our priorities.

This Policy sets forth essential information regarding the use of personal data by PickYourSkills SAS ("PickYourSkills"), and applies to all PickYourSkills Services and related Services.

We sometimes develop and offer new Services or additional offerings. If the introduction of these new Services or additional offerings results in a change in the way we collect and process personal data, we will provide you with further information and additional terms or policies. Unless otherwise specified, any new Services or additional offerings added will be subject to this Policy.