Contentsquare Job Candidate Privacy Policy

Effective Date:  July 27, 2022

1. Introduction

This Job Candidate privacy policy (“Job Candidate Privacy Policy”) provides information on the collection, storage, use, sharing, disclosure and transfer (“Processing”) by the Contentsquare group of companies (“Contentsquare”, “we”, “our”, or “us”) in connection with job and internship candidates and applicants (collectively - “Candidates” or “you”) with respect to our application and recruitment processes. It also provides you with information about your privacy rights in relation to such Processing of your Personal Data.

If you are applying for a role at Contentsquare in France, a specific Notice applies to you, available here (available in French only).

As used in this Privacy Policy, “Personal Data” means information that relates to an identified individual or to an identifiable individual, as defined under applicable data protection laws.

 

2. Scope of the Job Candidate Privacy Notice

This Privacy Policy applies to the Processing of Candidates’ Personal Data in relation with our hiring practices only. The other Processing activities performed by Contentsquare in relation with our products, customers, and employees are governed by separate Privacy Policies. For more information on such Processing of Personal Data please visit this link.

 

3. Who is responsible for processing your Personal Data?

 

Data Controller’s identity and contact details

Contentsquare is responsible for processing your Personal Data. 

See the list of Contentsquare entities, the registered address and contact details for each entity here.

For the purpose of such Personal Data Processing activities identified under this Privacy Policy, Contentsquare is deemed Data Controller or Business, as such are defined under applicable data protection law.

 

Controller’s representative

Content Square SAS has been designated as Contentsquare’s representative in the European Union for data protection matters pursuant to Article 27 of the General Data Protection Regulation (“GDPR”).

 

Data Protection Officer and contact details

Contentsquare has appointed data protection officers (“DPO”) to oversee the protection of your Personal Data. If you have any questions about this Privacy policy or about our data protection practices, you can contact our DPOs at:

  • Global DPO: Content Square Inc., Attn: Global DPO, 53 Beach St New York, NY, 10013-2304 United States. Email to [email protected]
  • EEA DPO: Content Square SAS, Attn: EU DPO, 7 rue de Madrid 75008 Paris, France. Email to [email protected]

 

4. Which Personal Data do we process about you and how?

Contentsquare collects and processes Personal Data that directly identify you (e.g., name, email, contact details, etc.), your professional or employment-related data (e.g., educational records, work history, relevant qualifications, data contained in your resume/CV, etc.), data relevant to the position you apply for (e.g., current annual salary, desired annual salary), public information in professional social media, data related to any assessments you complete as part of your hiring process, and any other Personal Data that you present us with as part of your application related to the fulfillment of the role. Contentsquare also collects and processes Personal Data that indirectly identify you (e.g., unique identifiers, behavioral data, etc.).

We collect and process Personal Data about you from the following sources: 

When you provide such personal data directly to us

When you submit an application, request information, or otherwise contact us, we collect the following categories of Personal Data about you: 

 

Category of Personal Data

Examples of Personal Data

Identification and contact data

First and last name, email address, and telephone number

Professional or Employment-Related Data

Educational records, work history, current job position, workplace, and industry, current annual salary & desired annual salary, resume/CV data, professional memberships

Demographic data

Gender, nationality/citizenship, racial or ethnic origin

Data related to background checks

Criminal record information, driving record information, reference checks, credit report, social security number verification

Any other Personal Data you voluntarily choose to provide

Personal Data you provide to us as part of your application related to the fulfillment of the role, such as the results of position-specific assessments completed during your application process

 

When you provide such personal data indirectly to us

We may collect Personal Data about you with the help of third parties and from publicly available sources and professional social media. 

 

When you use our Contentsquare Sites and such personal data is collected automatically

When you visit or interact with Contentsquare websites that refer or link to this Job Candidate Privacy Policy (collectively - the “Sites”), we may collect or generate through cookies the following categories of Personal Data about you: 

 

Category of Personal Data

Examples of Personal Data

Unique Identifiers

IP address, cookie IDs, device IDs, web beacons, pixels, and other similar technologies (as described in our “Cookies Policy")

Device and technical data

Domain server, type of device/operating system/browser used to access the Sites, local and language settings; session logging, heatmaps and scrolls; screen resolution, ISP, referring or exit pages; and date and time of your visit.

Digital behavior data

Web page interactions (clicks, browsing, zooms and other interactions), referring web page/source through which you accessed the Sites, and statistics associated with the interaction between device or browser and the Sites.

 

5. Why do we use your Personal Data?

We process your Personal Data for various purposes including to process your application, assess your skills and qualifications, and to communicate with you regarding such processes. 

Purpose of Processing

Legal basis

Consider, process your application and assess your skills and qualifications for the job you have applied for and for subsequent job opportunities (if you consent). 


We may deploy specific technologies (including AI) for the purpose of assessing your skills and qualifications for the job. Contentsquare does not make any automated decision in relation to your application without human involvement. 

Legitimate interest

Verify your employment reference(s) that you have provided, backgrounds checks and related assessments

Consent 

Communicate with you regarding the application process

Legitimate interest

Consider your application for alternative positions and communicate with you regarding future opportunities

Consent 

Carry out satisfaction surveys to improve our recruitment process 

Legitimate interest 

Fulfill your requests and respond to your inquiries, such as to send a requested report

Legitimate interest

Administer and manage your Human Resources file (in case your application is successful and you become a Contentsquare’s employee)

Performance of a contract 

Conduct statistical analysis on recruitment and diversity monitoring (where permitted by applicable law)

Legitimate interest and/or compliance with a legal obligation 

Comply with legal requirements, including monitor diversity requirements under applicable local law 

Compliance with a legal obligation

Respond to a regulator, law enforcement authorities, other governmental officials or your data subject requests

Compliance with a legal obligation

Resolve disputes and defend a legal claim

Compliance with a legal obligation

 

6. How long do we keep your Personal Data?

Your Personal Data will be stored by us and our service providers in accordance with applicable data protection laws and data protection authorities guidelines to the extent necessary for the processing purposes set out in this Job Candidate Privacy Policy. Subsequently, we will delete your personal data in accordance with our Data Retention, Archiving and Disposal Policy or take steps to properly render the Personal Data anonymous, unless we are legally obliged to keep your personal data longer (e.g. for legal compliance, tax, accounting or auditing purposes).

Purpose of Processing

Data retention if your application is unsuccessful

Data retention if your application is successful

Assess your skills and qualifications

7 months after the end of the application process. At the end of that period, your Personal Data is anonymized. 



Personal Data gathered during the recruitment process will be transferred to your Human Resources file and kept 6 months after the end of your employment. 

Verify, consider, and process your application and candidacy for any of our positions

6 months after the end of the application process. At the end of that period, your Personal Data is anonymized. 



Personal Data gathered during the recruitment process will be transferred to your Human Resources file and kept 6 months after the end of your employment. 

Communicate with you regarding the application process

For the duration of the application process. At the end of that period, your Personal Data is anonymized. 



Personal Data gathered during the recruitment process will be transferred to your Human Resources file and kept during your employment. 

Consider your application for alternative positions*


*only if you consent

1 year or once you withdraw your consent

N/A

Fulfill your requests and respond to your inquiries, such as to send a requested report

For the duration of the application process. At the end of that period, your Personal Data is anonymized.

Personal Data gathered during the recruitment process will be transferred to your Human Resources file and kept during your employment. 

Protect the rights, safety, property, or operations of Contentsquare, you, or others

As required by applicable law or regulation

Respond to a regulator, law enforcement authorities, other governmental officials or your data subject requests

For the time necessary to respond to the request or communication and then archived as required by applicable law or regulation

Resolve disputes and defend a legal claim

In case of a dispute, until the settlement of the dispute ; in case of a legal claim, for the duration of the proceedings and until the ordinary and extraordinary means of recourse are exhausted with regard to the decision rendered.



7. When and to whom we share your Personal Data?

Your Personal Data is shared for business purposes throughout Contentsquare and with third parties such as service providers, and, upon request and in line with our Public Authorities Access Request Policy, with government, judicial and law enforcement entities.

In connection with one or more of the purposes outlined in the Section 5 above, we may disclose your personal data to:

 

Contentsquare subsidiaries and affiliated companies

We may share, disclose and transfer your Personal Data with our current (consult the list here) and future subsidiaries and affiliated companies for all purposes mentioned in Section 5 above.

 

Service providers

We may share your personal data to third parties (including our affiliates) to perform services complementary to our own, namely - recruitment firms that have referred you to us (or vice versa), candidate evaluation centers, background check providers, recruitment software providers, data and cyber security services, web analytics, and our business, legal, compliance, and financial advisors (collectively, “Third-Party Services”). Third-Party Service providers may perform the services on our behalf, under our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your personal data. 

Please see here for the current list of service providers used by Contentsquare as processors.

 

Other third parties

We may disclose your personal data to third parties, including government authorities or public authorities, courts, intergovernmental or supranational bodies for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:

  • To comply with laws, regulations, legal process or to respond to lawful requests;
  • To enforce or apply our agreements;
  • To protect the rights, interests, property, or safety of Contentsquare, our customers, you and others;
  • In connection with claims, disputes, or litigation;
  • To protect you and others from fraudulent, abusive, or unlawful use of the Sites, and other fraudulent activity.

Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

 

8. How do we transfer your Personal Data globally?

Your Personal Data may be accessed, processed and stored in other countries in which Contentsquare has operations, including countries outside of the European Economic Area (EEA).

Contentsquare has implemented safeguards to ensure an adequate level of data protection where your personal data is transferred to countries outside the EEA, such as:

  • the recipient country has an adequacy decision from the European Commission;
  • the European Commission’s Standard Contractual Clauses for the transfer of personal data.

To see in detail the countries where your Personal Data may be transferred, please click here.

 

9. How do we secure your Personal Data?

In order to protect your Personal Data held with us and our service providers, we use industry-standard physical, procedural and electronic security measures, which can be consulted here. 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 as described in Section 6 above.

 

10. What are your privacy rights and how to exercise them?

You have rights for the Personal Data we process about you. You can choose to object to, restrict our use of your Personal Data, delete, change or correct your Personal Data, access your Personal Data by filling out our Data Subject Request Form.

Subject to applicable data protection laws, you have multiple privacy rights in respect of the Personal Data we process about you:

  • request confirmation that we are processing your personal data;
  • request a copy of personal data we hold about you;
  • request that we update personal data we hold about you or correct such data that is inaccurate or incomplete;
  • restrict the way in which we use your personal data (e.g., if we have no legal right to keep using it) or limit our use of your personal data (e.g., if your personal data is inaccurate or unlawfully held);
  • object to our processing of your personal data relating on grounds to your particular situation or if your personal data is processed by us for direct marketing purposes, object at any time to the processing of your personal data for such marketing;
  • withdraw the consent that you have given us to process your personal data (where we process your personal data on the basis of your consent);
  • request that we delete the personal data we hold about you; and
  • lodge a complaint with the relevant data protection authority regarding our processing of your personal data.

If you want to exercise one or more of the rights mentioned above, you can submit your request using our Data Subject Request Form. Please note that as part of your data subject request, we may require additional information and documents, including personal data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 5 above.

 

11. Children’s Privacy

Our Website and open positions are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using our Website or submitting applications to any of our open positions, we will prohibit and attempt to block such use and will make reasonable efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us via our Data Subject Request Portal here.

 

12. How to contact us?

If you have any comments or questions about this Job Candidate Privacy Policy or our handling privacy practices, please contact us at [email protected]. You can also contact our DPOs at:

  • Global DPO: Content Square Inc., Attn: Global DPO, 53 Beach St New York, NY, 10013-2304 United States. Email to [email protected]
  • EEA DPO: Content Square SAS, Attn: EU DPO, 7 rue de Madrid 75008 Paris, France. Email to [email protected]

 

13. Updates and Amendments to this Job Candidate Privacy Policy

We may update and amend this Job Candidate Privacy Policy from time to time. The “Effective Date” at the top of this webpage mentions when this Job Candidate Privacy Policy was last revised. Any changes will become effective when we post a revised version of this Job Candidate Privacy Policy on these Contentsquare Sites. Your use of our Sites is subject to the terms in the version of this Privacy Statement that is posted on this Site at the time of your visit. We encourage you to review this Privacy Statement periodically to remain informed about how we are protecting your data.