V1.2021

Employee Privacy Notice

 

1. Introduction

At Contentsquare we have a privacy-first philosophy. It means that we inform you about everything we do with your Personal Data, but also that we are committed to protecting your privacy. “Personal Data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you.

This Employee Privacy Notice (the “Notice”) describes how Contentsquare SAS and its affiliated companies (“Contentsquare”, “we”, “our” or “us”) treats the Personal Data of our employees, subcontractors and trainees ("you").

Specifically, it describes the Personal Data we typically receive or collect, how and for which purposes we may use such data, where we store it and for how long we retain it, with whom we may share it, our use of communications regarding updates and amendments, our security practices, your choices and rights regarding such data, and how to contact our privacy team if you have any questions or concerns regarding your privacy or this Notice.

Contentsquare is a global company with headquarters in US and France and additional offices in Israel, EU, Singapore and the United Kingdom. While this Notice is intended to describe the broadest range of our data practices globally, those practices may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal data we can collect or the manner in which we process that data. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

Please read this Notice and make sure that you fully understand and agree to it.

For Employees based in France, please read the specific Notice here (available in French only).

2. Categories of Personal Data collected

We collect and receive the following categories of data:

2.1. Personal Data received from you during your job application process

Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, such as:

  • your identifying data (first name and last name);
  • contact details (home address, email address, phone number);
  • work history, technical skills, educational background, professional certifications and registrations;
  • language capabilities;
  • training records;
  • public information in professional social media; and
  • salary history and expectations

We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process or from other sources, such as your references, placement agencies or our Service Providers (defined below).

2.2. Personal Data received from you during your employment

Once you join Contentsquare as an employee, and during your employment with us, you may provide us with additional personal data about you, such as:

  • identifying and contact data about you (your profile picture (optional), ID information and document , passport details, gender, date of birth and place of birth, nationality, marital status)
  • identifying and contact data concerning your immediate family members (as necessary under applicable tax and benefits forms) and emergency contacts you have provided;
  • data concerning your work situation (residency and work permit status, military status, );
  • data concerning your bank account number (only for depositing your salary);
  • social security number (only for wage reporting purposes in US and for payroll management and the handling of related administrative formalities in France);
  • data concerning health and benefits providers (e.g., selected pension or insurance providers, mobile carrier, health providers);
  • data concerning any personal expressed preferences or requests;
  • meal orders and dietary preferences; and
  • any other Personal Data you may provide us with during and relating to your employment at Contentsquare.

You may also provide us Personal Data qualified as “Sensitive Personal Data” (under applicable law), such as:

  • data concerning your health and accessibility (so we could best attend any special requirements or preferences you might have, or for sick day permits and work-related accident);
  • data concerning your religious or philosophical beliefs (to the extent necessary for us to respect your religious holidays and dietary requirements under applicable law);
  • data concerning your trade union membership (e.g. for staff representative elections).

We will only use your Sensitive Personal Data in accordance with applicable law and in line with this Notice.

2.3. Personal Data generated by Contentsquare, its employees or Service Providers

We, other Contentsquare employees or our Service Providers may create additional data about you, such as:

  • data concerning your employment (job offer letters, employee ID number, workplace, type of contract, start date of the contract, job title, date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment (e.g., references))
  • data concerning your career and mobility (professional evolution goals, professional and performance assessment, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies),
  • data concerning your training (diplomas and professional certifications, follow-up of training requests and training periods carried out, knowledge assessment);
  • your salary, pension, benefits, and stock options;
  • your records of work absences, vacation/paid time off;
  • your entitlement and requests;
  • your work travel plans;
  • your calendar events, participation in work events, and other data concerning your activities as a Contentsquare employee;
  • data for the organization chart (your name, profile picture, job title) and your tasks;
  • your username and hashed password for your accounts at Contentsquare; and
  • your voicemails, emails, correspondence, chat, documents, calendar and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment.

2.4. Data automatically collected or generated

When you use any of Contentsquare's systems or devices, including when you connect to or use your Contentsquare email inbox, we and our Service Providers (such as Google) may collect or generate technical data about you.

Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding your device, operating system, browser version location and language settings used, the cookies and pixels installed on the device, and the activity (clicks and other interactions) on any such systems.

We mostly use this data to have a better understanding of how our employees typically use and engage with such systems and devices or in order to investigate any suspected illegal activity, abuse or wrongdoing.

CCTV footage data and other data obtained through electronic means such as swipecard records may also collect Personal Data about you.

3. Personal Data Uses

We will use your Personal Data for the following purposes:

  • To set up and manage your employee files and contract in accordance with applicable labor law and collective agreement;
  • To finalize, and submit all necessary social security, tax and governmental forms, and process your salaries and benefits;
  • To manage your leave of absence and work-related accident;
  • To assess your skills, qualifications, and overall fitness to work at Contentsquare;
  • To manage your career and mobility, including to verify, consider, and process your application and candidacy for any of our positions, and to contact you regarding such processes;
  • To authenticate the identity of our employees, and allow them access to our facilities and systems;
  • To ensure an appropriate and compatible work environment for our employees;
  • To respect our employees' personal preferences and requirements, such as their religious holidays (under applicable law) ;
  • To conduct performance reviews, managing performance and determining performance requirements, and manage your day-to-day activities at Contentsquare;
  • To manage your training requests and training periods completed;
  • To contact you with information about Contentsquare or documents concerning your employment with us (such as your salary slips, employee forms or any other information or documents sent to all or some of our employees);
  • To enhance our security and anti-fraud measures and mitigate risks, and to create aggregated statistical or inferred data regarding our candidates and employees for the further development and improvement of our recruitment and HR processes;
  • To further develop, customize, and improve our HR operations based on our employees' common or personal preferences, experiences, and difficulties or other anonymized/aggregated information;
  • To contact you concerning work-related matters or your family members/contact person in case of emergencies; and
  • To manage accounting and auditing;
  • To act as permitted by, and to comply with, any legal or regulatory requirements (such as applicable labor laws), and to conduct any additional activities that may require the use of your Personal Data, for which we will request your specific approval in advance.

4. Legal basis

Where we collect and process your Personal Data as part of your employment, we may rely on certain legal basis, depending on the applicable law. These may include, without limitation:

  • as necessary for the performance of our agreement with you;
  • for complying with applicable law, such as applicable labor laws or regulations concerning data privacy and security;
  • on our legitimate interests in managing the day-to-day operations of Contentsquare's human resources, enabling us to better understand and support our candidates and employees, and ensuring that our employees, customers, and assets are protected, along with securing and enhancing Contentsquare's reputation and values;
  • in limited circumstances, with your consent (e.g. to publish your profile picture on our organizational chart).

Sensitive Personal Data requires higher levels of protection. Under the GDPR, where applicable, we need to have further justification for collecting, storing and using this type of Personal Data. We may process special categories of personal information in the following circumstances:

  • for carrying out our obligations and rights in the field of employment and social security and social protection law in so far as it is authorised by law or a collective agreement (e.g. processing of your health data for workplace injury management purposes) ;
  • for the establishment, exercise or defence of legal claims;
  • in limited circumstances, with your explicit written consent (e.g. processing of your health data, any disability to ensure your health and safety in the workplace and to provide appropriate workplace adjustments).

5. Data Storage

Contentsquare is a global company with headquarters in US and France and additional offices in Israel, EU, Singapore and the United Kingdom. Your Personal Data may be maintained, processed, accessed, and stored by Contentsquare, any of its affiliated companies, our Service Providers and business partners in France, Israel, Singapore, the US, and other jurisdictions, including the UK and the European Union (“EU”), as necessary for the proper performance of our company or as may be required by law.

While privacy laws may vary between jurisdictions, Contentsquare has taken reasonable steps to ensure that your Personal Data is treated by its Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.

6. Data Retention

Contentsquare may retain your employee Personal Data for the duration of your employment with us, and then for an additional period, as reasonably necessary to comply with our legal obligations, resolve disputes or legal claims, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.

However, if your Personal Data is only useful for a short period (for example, CCTV footage data) we will delete it.

Following such a period of time, we may retain limited copies of your data so as to allow us to maintain a registry of everyone who has ever worked at Contentsquare. However, such a registry shall only contain such limited data as is necessary for this purpose.

Note that, except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time.

7. Data Sharing

We may share your Personal Data with certain third parties, including regulatory, tax, law enforcement agencies, our Service Providers and our affiliates, our auditors and our legal, accounting and other professional advisors, but only in accordance with this Notice.

7.1. Compliance with Laws, Legal Orders, and Authorities

We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, a search warrant or court order (or similar requirement) or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we believe, in good faith, that we are legally compelled to do so or that disclosure is appropriate in connection with efforts to investigate, prevent or take action regarding actual or suspected illegal activity, fraud or other wrongdoing.

7.2. Service Providers and Business Partners

We may engage selected third-party companies and individuals to perform services complementary to our own (e.g., hosting services, human resources software and service providers, data analytics services, data and cyber security services, fraud detection and prevention services, payroll and payment processing services, email distribution and monitoring services, and our business, legal, financial, and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our services, and may only use it for such purposes and in accordance with our instructions

7.3. Contentsquare Customers

We may disclose certain Personal Data to our customers, such as your name, position, and contact details, and in some cases (if it is required for you to provide support or professional services on Contentsquare's behalf) additional data, such as your ID and existence of a background check (if any), to those customers requiring such data for security and regulatory reasons.

7.4. Other Contentsquare Employees

Your fellow employees may have access to certain Personal Data, such as your identity and contact details, as may be available to them in the internal employee directory, as well as additional data, depending on their specific roles and responsibilities and need for such data (e.g., payroll data may be disclosed to HR, Finance, and Management personnel).

7.5. Protecting Rights and Safety

We may share your personal data with others if we believe, in good faith, that this will help protect the rights, property or personal safety of Contentsquare, any of our customers or any members of the general public.

7.6. Contentsquare Group

We may share personal data internally within our group of companies, for the purposes described in this Notice. In addition, should Contentsquare undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via email and/or prominent notice on our services.

For the avoidance of doubt, Contentsquare may share your personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.

7.7 Data Location and International Transfer of Personal Data.

Your Personal Data may be processed by and transferred to the entities described above located in all countries that Contentsquare do business in, including without limitation the following countries and regions: EU (including France, Germany, Netherlands, Belgium and Spain), United Kingdom, Israel, US, Canada, Singapore and Australia. Such list may be updated from time to time by a written notice by Contentsquare.

In particular, when transferring your Personal Data outside the EU, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented: (1) we will transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission (e.g. Israel); or (2) we will use specific contracts approved by the European Commission referred to as the “Standard Contractual Clauses” which offer sufficient safeguards for the Personal Data to be transferred internationally.

8. Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural, and electronic security measures, including encryption, where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.

9. Data Subject Rights

If you wish to exercise your rights under applicable law (e.g., the EU GDPR) to access, rectify, erase or transport your Personal Data held with Contentsquare, to restrict or otherwise object to its processing (in certain circumstances), then please visit our Data Subject Request Portal at: https://contentsquare.com/privacy-center/data-subject-request-portal/.

Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

10. Additional Information

This Notice does not form part of any contract of employment or other contract to provide services.

Updates and Amendments: We may update and amend this Notice from time to time by distributing an amended version. The amended version will be effective as of the published date. We will provide you with a notice in advance if any substantial changes are involved, via any of the communication means available to us. After this notice period, you acknowledge having been informed about all amendments shall be deemed accepted by you.

Additional Notices: We may provide you with other privacy notices on specific occasions (e.g. CCTV, event organized by Contentsquare,... ).

Questions, Concerns or Complaints: If you have any comments or questions about this Notice or if you have any concerns regarding your privacy, please visit our Data Subject Request Portal at: https://contentsquare.com/privacy-center/data-subject-request-portal/. Our Data Protection Officer may be contacted directly regarding similar matters at  [email protected] as well.

Representative in the EU: Contentsquare has designated Content Square SaS as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR and Content Square Limited been designated as Contentsquare’s representative in the European Union for data protection matters pursuant to the UK 2018 Data Protection Act. To make such an inquiry, please visit our Data Subject Request Portal at: https://contentsquare.com/privacy-center/data-subject-request-portal/. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority.