This Policy applies to all applicants for a position within Playengo (whether permanent or temporary), regardless of the type of contract at stake.
By “Personal Data”, we mean any directly or indirectly individually identifiable information about you, collected or otherwise received by Playengo, as defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and described in this Policy.
1. What Personal Data do we collect and how?
2. Why does Playengo collect your Personal Data?
3. With whom does Playengo share your Personal Data?
4. Is your Personal Data transferred to other countries and why?
5. For how long does Playengo retain your Personal Data?
6. What are your rights on your Personal Data?
7. Contact and complaints
8. Changes to this Policy
During the course of your application and the recruitment process, and to the extent this is reasonably necessary for the processing of your application, Playengo recruitment process and for compliance and legal requirements, or for our legitimate business purposes as listed in section 2 below, Playengo collects Personal Data about you.
Playengo may collect your Personal Data directly from you, notably on the basis of collection forms, official documents, CVs, general HR applications and more generally throughout the Playengo recruitment process, or indirectly from other entities within the Playengo group if you have previously worked in another entity of the group, through government and other regulatory bodies, and through professional recruitment advisors (head hunters). The categories of Personal Data Playengo may collect indirectly in this context include, without limitation, the following:
In most cases, the information Playengo collects is required by law or is necessary in order to take steps prior to entering into an employment agreement with Playengo or for Playengo legitimate purposes. Failure or refusal to provide the information marked with an asterisk on the collection forms available on our online recruitment platform may result in our inability to communicate with you, process your application or manage your recruitment.
In the event you did not provide all or part of the information necessary in order for Playengo to process your application, Playengo may contact you using the information provided, at its sole discretion, in order to collect the missing information.
Playengo generally collects and processes your Personal Data for the purposes of processing your application, managing your recruitment and communicating with you, and for other purposes as described in the table below, in the course of its activity. However, no Personal Data will be processed without a legal ground (or “lawful basis”), which we describe in the below table.
|**Purposes of applicants Personal Data processing**||**Legal Ground**|
|Administrative management of human resources, including management of applicant files||Preliminary steps prior to entering into a contract, compliance with Playengo’s legal and regulatory obligations as per applicable law and Playengo legitimate interest to recruit personnel|
|Determination of applicant abilities as regards the position for which he/she applied or for another position within Playengo in case a similar position would open||Playengo legitimate interest to recruit personnel with skills and know-how in adequacy with its needs|
|Communication with the applicant regarding the follow-up of the recruitment process||Playengo legitimate interest to recruit personnel with skills and know-how in adequacy with its needs|
|In the event the application is accepted, proceed with the recruitment process and employment contract||Preliminary steps prior to entering into a contract, compliance with Playengo’s legal and regulatory obligations as per applicable law and Playengo legitimate interest to recruit personnel|
|Compilation of statistics regarding Playengo employment opportunities||Playengo legitimate interest of having relevant information about its recruitment process and policies|
|Meeting legal or regulatory requirements applicable as well as Playengo group internal policies||Compliance with Playengo’s legal and regulatory obligations as per applicable law and Playengo legitimate interest to ensure that its internal policies are complied with|
|Investigations and management of litigations, offences and court cases||Compliance with Playengo’s legal and regulatory obligations as per applicable law, or Playengo legitimate interest to ensure the efficiency of its defence|
|Storage of applicant Personal Data||Compliance with Playengo legal and regulatory obligations, as per applicable law, to keep applicant Personal Data to comply with the applicable statute of limitations and respond to applicant requests or claims|
Playengo shares your Personal Data with the following categories of recipients, as necessary for the purposes described in section 2 above:
With respect to the disclosures of Personal Data described above, Playengo:
In the event of a change of control or ownership of Playengo or in the event all or part of Playengo business is otherwise transferred to a third party, you are informed that your Personal Data as collected and maintained by Playengo may be transferred to that third party, subject to applicable local law requirements.
Playengo may also disclose information about applicants in instances where we are required to do so by law, including pursuant to a court order or in circumstances where we believe that such action is necessary to prevent fraud or cybercrime or to protect the rights, property, or safety of Playengo or Playengo group or any person, in each case as required or permitted by applicable law.
For the purposes listed in section 2 above, your Personal Data will be transferred to other entities of the Playengo group and third party service providers or partners located outside of the European Economic Area (“EEA”), in countries not offering a level of protection of personal data equivalent to that offered within the EEA, such as the USA.
When transferring Personal Data to such recipients, Playengo implements appropriate contractual measures to establish and/or confirm that, prior to receiving any Personal Data, they will provide an adequate level of protection and that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
Absent any adequacy decision of the European Commission, the transfer of your Personal Data will be made pursuant to contractual measures based on the European Commission model clauses (controller to controller or controller to processor) to secure such transfer.
When Personal Data need to be transferred to Playengo affiliates for the purposes described in section 2 above, Playengo has entered, into contractual measures based on the European Commission model clauses as appropriate (controller to controller or controller to processor) to ensure that all Personal Data disclosed to Playengo affiliates is protected.
You can obtain details on the transfer mechanism used to protect the Personal Data transferred outside of the EEA by contacting Playengo using the contact details in section 7 of this Policy, although some details may be redacted for confidentiality reasons.
Our general approach is to retain your Personal Data only for as long as required to fulfil the purposes for which it was collected, as described in this Policy.
In the event of a negative outcome to your application, we will notify you about our intent to retain your Personal Data, for further recruitment management purposes in order to re-evaluate your application, for a maximum period of two years after the last contact between you and Playengo, unless you ask Playengo to delete it prior to the expiry of that period.
We may retain your Personal Data for a longer period but only with your consent.
In the event of a positive outcome to your application, we will retain your Personal Data for the duration of the recruitment process and, further to that time, for the term of your employment agreement with Playengo. You will receive additional information in this respect during the recruitment process and once you become an Employee.
However, we may retain your Personal Data for a reasonable period of time after expiration of the abovementioned retention period for archival purposes, when we are required to do so to comply with our legal, tax, social and regulatory obligations, or where such data is necessary to establish the existence of a right or a contract. In that case, your Personal Data will be archived and retained for the duration imposed by applicable law, or for the duration of the applicable statute of limitations.
After this period, your Personal Data will be anonymized or deleted from Playengo information system and from that of Playengo’s relevant subcontractors.
You have a number of rights in relation to your Personal Data. More information about each of these rights is provided below:
You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your Personal Data infringes applicable law. In France, the supervisory authority for the protection of Personal Data is the Commission Nationale de l’Informatique et des Libertés (“CNIL”) - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 - www.cnil.fr.
Please help us to keep your data accurate by informing us immediately of any change regarding your situation, including change of name, address or any other relevant change that may be relevant regarding the management of your application or recruitment process.
To exercise any of your rights or if you have any question, concern or complaint regarding this Policy or the processing or your Personal Data, please contact us at the following email address: email@example.com.
This Notice is posted on the Playengo’s website. You are invited to consult it regularly as it may be updated periodically to take account of changes in the law, regulations, or Playengo practices.
**Last Update: **30 July 2019