Privacy Policy

GENERALITIES

This Privacy Policy applies to PENTALABBS’s website (the “Website”).

1. INTRODUCTION

Since its creation, PENTALABBS has put privacy at the heart of its business.

PENTALABBS is therefore committed to the protection of and respect for the fundamental rights guaranteed by the laws and regulations in force, in particular the General Data Protection Regulation (‘GDPR’) in force from 25 May 2018.

PENTALABBS’s Privacy Policy (the ‘Policy’) is intended to inform you, in a transparent manner, of practices regarding the collection, use and sharing of information you may need to provide on the website.

This Policy (and all documents to which it refers such as the Cookie Policy) describes how PENTALABBS processes the personal data collected and provided by you. PENTALABBS recommends you to read this document carefully to familiarize yourself with and understand its practices regarding the processing of your personal data.

The terms used in this Policy have the meaning of the definitions set out in the law in force and/or the GDPR.

2. DATA COLLECTED BY PENTALABBS

PENTALABBS may collect and process data relating to:

  • Candidates for positions within PENTALABBS;
  • Prospects;
  • Contacts;
  • Clients;
  • Suppliers;
  • Visitors of the website.

3. HOW DOES PENTALABBS USE THE DATA COLLECTED?

PENTALABBS uses the data collected for the purposes of:

3.1. Assessing candidates for positions offered;

3.2. Due diligence: preparatory step for the signing of an employment contract;

3.3. Due diligence: in order to confirm Candidates’ identities;

3.4. Sending targeted offers and marketing communications;

3.5. Communicating with Prospects;

3.6. Answer to a request made via a contact form;

3.7. Due diligence: preparatory step for the signing of a contract with a client or supplier;

3.8. Communicating with interested parties.

4. WHO RECEIVES THE INFORMATION COLLECTED BY PENTALABBS AND WHY IS THIS INFORMATION IS TRANSFERRED TO THEM?

4.1. For the purpose of making best use of its services, some information that you share with PENTALABBS is transferred on to other companies in the PENTALOG Group, in accordance with this Policy.

4.2. PENTALABBS works in close collaboration with companies of PENTALOG Group and third-party companies who may have access to your personal data. This is particularly the case:

  • for technical services;
  • to confirm your identity;
  • for suppliers;
  • for internal administrative and accounting matters;
  • for recruitment when using its affiliate SkillValue to assess applications.

4.3. PENTALABBS only shares data with the third parties mentioned in article 4.2. in the following cases:

  • 4.3.1 When PENTALABBS uses suppliers to improve and optimise its Website and services;
  • 4.3.2 When using communication tools (social networks) and email clients to communicate with you;
  • 4.3.3 When PENTALABBS is (1) legally required to comply with a request from the legal authorities, (2) an emergency poses a risk to an individual’s physical safety, (3) when PENTALABBS needs to implement a contract or prepare for the implementation of a contract between its users and its clients, (4) to guarantee the rights of PENTALABBS;
  • 4.3.4 In the event of the sale or purchase of a company or assets, PENTALABBS reserves the right to share its users’ personal data with the potential seller or buyer of this company or these assets.
  • 4.3.5 If PENTALABBS or all or part of its assets are acquired by a third party, the data in its possession shall, where required, be transferred to the new owner.
  • 4.3.6 Under the regulations in force and with its users’ consent, PENTALABBS may, where necessary, aggregate data and send it to companies in the PENTALABBS Group, including all or part of its users’ personal data and the cookies collected. This information shall be used strictly for the purposes described above.
  • 4.3.7 By allowing PENTALABBS to access personal data via social networks, their privacy policy and terms of use become effective for users. PENTALABBS has no control over the collection or processing of data collected by these networks.

5. HOW DOES PENTALABBS USE AND MODERATE COMMENTS?

PENTALABBS reads comments posted on its blog and ensures that comments do not contain inappropriate content.

6. EMAILS SENT BY PENTALABBS

6.1. PENTALABBS may only use your data provided on its Website in accordance with the legislation in force and with your consent where required, in particular to send targeted marketing content, ((1) send a newsletter, (2) respond to an information request made by a Visitor on the Website, and (3) send an event invitation.

6.2. In accordance with its legitimate interests, PENTALABBS may send you emails if you are likely to be interested in its services or if you have shown an interest in its services.

6.3. Pursuant to the legislation in force, you may decide to stop receiving emails from PENTALABBS, at any time, by withdrawing your consent. To do so, you must unsubscribe via the link included at the bottom of every marketing email or by emailing PENTALABBS with the details of the request at the following address: contact@PENTALABBS.com.

6.4. For personal data collected indirectly by PENTALABBS, the right of information as defined by the GDPR shall be respected at all times by PENTALABBS from the first communication with the data subjects. They may decide, at any time, to exercise the rights set out in article 6.3.

On social networks (for example, Facebook and Twitter), you can oppose the processing of your data at any time by configuring your account settings relating to advertising;

On third-party websites: you can refer to the Cookie Charter to find out how to withdraw your consent.

7. WHERE AND HOW DATA IS SHARED BY PENTALABBS ?

PENTALABBS stores your personal data within the European Union.

7.1. However, in the course of using the Website, some user data may be transferred to other countries whose local personal data protection laws differ from those in the user’s country of residence.

7.2. This happens, in particular, when data is transferred via third-party application software. PENTALABBS uses this third-party application software to operate its services, communicate with you, and transfer information in preparation for the signing of a technical services contract.

7.3. This is also the case for companies in the PENTALABBS Group located outside the European Union to which PENTALABBS may transfer some data as part of the provision of services in these countries or certain administrative and accounting tasks.

7.4. When data is transferred, PENTALABBS shall ensure that it is processed in accordance with this Policy and guarantees users an adequate level of personal data protection through the use of either the standard contractual clauses of the European Commission or membership of the Privacy Shield.

7.5. In the interests of full transparency towards its users, PENTALABBS undertakes to provide on request the list of countries in which users’ personal data is stored in the European Union, and the list of countries to which data is occasionally transferred.

8. Security measures

PENTALABBS takes all the necessary technical and organisational measures in accordance with the GDPR to guarantee the best possible level of security, ensuring comprehensive protection of the personal data collected

These security measures will oblige for example PENTALABBS to verify the requested identity of an individual in case of exercise of the rights provided in the article 9.

If you believe your personal data has been infringed, please contact PENTALABBS immediately in accordance with article 13.

9. Your rights over your personal data

9.1. Under applicable law and in accordance with articles 12 and seq. of the GDPR:

9.1.1. You have the right to access your personal data processed and held by PENTALABBS.

9.1.2. When such a request is made by a user, PENTALABBS may, before responding, confirm the user’s identity by asking them to provide more information.

9.1.3. In the case of requests which, due to their number or repetitive or systematic nature, are manifestly unreasonable, excessive or unfounded, PENTALABBS may either refuse to pursue the request by demonstrating its manifestly excessive or unfounded nature, or request the payment of reasonable fees that take into account the administrative costs incurred in providing the information, sending correspondence or adopting the measures requested.

9.2. Under applicable law and in accordance with articles 12 and seq. of the GDPR, PENTALABBS shall respond to you as soon as possible and, in any case, within one month of receipt of the user’s request, or within two months taking into account the complexity and number of requests.

9.3. In this case, PENTALABBS shall inform you of the reasons for extending the deadline of one month from receipt of the request.

You may correct, change or remove any incorrect information.

9.4. It is your responsibility to provide PENTALABBS with full, accurate and up-to-date information. You may withdraw your consent at any time.

9.5. Any request to change or remove data must be made by contacting PENTALABBS directly in accordance with article 13, below.

9.6. PENTALABBS may store some of its users’ personal data if required by the legislation of an EU Member State in which it operates or EU legislation. This shall also be the case when PENTALABBS has a legitimate interest in doing so under the terms of the applicable law or the GDPR.

9.7. Under the applicable law, when this is the case, in particular in France pursuant to the new article 40-1 of the Data Protection Act, you may give instructions relating to the storage, deletion and disclosure of your data after your death.

10. COOKIES

Pursuant to its Cookie Charter, PENTALABBS uses cookies to customise and optimise browsing and time spent online. Refer to the Cookie Policy for more information.

11. LINKS TO OTHER WEBSITES AND SOCIAL NETWORKS FROM THE PENTALABBS’S WEBSITE

The Website may contain some links to the websites of companies in the PENTALOG Group or third-party companies. PENTALABBS hereby informs you that companies in the PENTALOG Group have a very strict and transparent privacy policy, which can be viewed on their website or will be available shortly. As for third-party companies, it is the users’ responsibility to familiarise themselves with their privacy policies before submitting their personal data. PENTALABBS may not be held liable for use of this data by these third-party websites and shall not, under any circumstances, be responsible for the privacy policy of these third-party websites.

12. CHANGES TO THE PRIVACY POLICY

PENTALABBS reserves the right to change its Privacy Policy at any time.

PENTALABBS shall visibly publish any substantial changes on its Website and they shall take effect from the date of publication. In this case, PENTALABBS shall contact you via email if necessary. PENTALABBS is committed to full transparency regarding the use of your data, subsequent uses and the third parties to whom PENTALABBS intends to disclose it.

13. CONTACT PENTALABBS

Users of the Website can contact PENTALABBS with any queries relating to this Policy or any requests relating to their personal data.

PENTALABBS can be contacted via its website, at the email address or, to exercise the rights guaranteed by the applicable laws and the GDPR, by sending this form by specifying the purpose of your request.

14. SUPERVISORY AUTHORITY

You may contact the relevant supervisory authority:

Commission Nationale de l’Informatique et des Libertés – CNIL

8 rue Vivienne, CS 30223

F-75002 Paris, Cedex 02

Tel.: +33 1 53 73 22 22

Fax: +33 1 53 73 22 00

Site internet: http://www.cnil.fr

SPECIFICITIES ON OTHER TYPES OF PROCESSING

Category of data subjects concerned Direct sources Indirect sources Legal ground for processing Purpose of the processing Retention period
Contacts, prospects, clients, providers – through contact with the Client or Supplier as part of their business relationship

– when requesting an information on Pentalabbs Website

– by posting a message on the Pentalabbs Blog

– data publicly and directly accessible

– via a website or a third party

– through an employee of a Prospective Client, Client or Supplier

– via a social media

– Preparation of a contract.

– Legal requirement: Pentalabbs shall process a Client’s or Supplier’s personal data if legally required to do so (e.g. duty to pay a tax, etc.)

– Processing is necessary for the purpose of legitimate interests pursued by Pentalabbs

– Consent

– Commercial prospection;

– Marketing;

– Administrative and financial services;

– Service for Equity

– Pentalabbs does not intend to store its clients’ or suppliers’ personal data any longer than is necessary. Pentalabbs’s key objective is to maintain some strong ties with its Clients while complying with the law.

– Therefore, when data is collected for a specific purpose, once this has been achieved, Pentalabbs shall not store the data on its systems. The only exceptions to this are where data retention is required by law or in the case of legitimate interests that would not call into question the rights and responsibilities of the individuals concerned

Visitors of the website – When a Visitor send a request at the contact email address or via the contact form – When visiting the Website using cookies – Pentalabbs is committed to ensuring that Visitors to its Website are aware of all the consequences of their actions.

– To this end, Pentalabbs ensures that it has obtained the consent of all Visitors when they visit its Website.

– If Pentalabbs processes its Visitors’ personal data without their consent, Pentalabss shall ensure that this processing complies with the GDPR; for example, it is based on the legitimate interests of Pentalabbs.

– Pentalabbs uses the personal data of Visitors to its Website in a manner consistent with the principles set out in the GDPR

– Pentalabss also wants to be clear about this type of processing in order to build a trusting relationship with the Visitors of its Website.

– Pentalabss uses the data of Visitors to its Website to analyse the performance of its Website and to improve the services it offers via its Website.

– For more information on the use of cookies by PENTALOG, please refer to the Cookie Policy.

– Pentalabbs does not intend to store the personal data of Visitors to its Website any longer than is necessary.

– To this end, when the purpose of collection has been achieved, Pentalabbs shall delete the data concerned.

Candidates – A Curriculum Vitae is sent to PENTALOG.

– A Candidate applies directly for a job or internship published on a PENTALOG Group website.

– A Candidate who applies for a job published on a third-party website.

– A Candidate whose profile matches a job offer may be identified on a public platform on which Pentalabbs employees are also registered (e.g. LinkedIn, Viadeo, etc.)

– The Candidate may come from a specialist third-party job hunting website on which Pentalabbs is registered as a recruiter

– An application may be received through a recommendation of a Pentalabbs

– Pentalabss may also receive an application for a job offer advertised by a partner

– Pentalabbs may receive an intra-group application or an application from a supplier such as SKILLVALUE, a company in the PENTALOG Group

– Preparation of a contract with a Candidate

– Legal requirement: Pentalabb shall process a Candidate’s personal data if legally required to do so

– Processing is necessary for the purpose of legitimate interests pursued by Pentalabbs

– Consent: This is obtained when a Candidate applies directly for a position. If consent is not obtained, Pentalabbs uses another legal basis for processing

– Skills assessment: If an employment contract is offered, Pentalabbs may decide at any time to carry out a skills assessment

– Assessing applications and confirming information provided by Candidates

– Creating a Candidate file on Pentalabbs’s internal system to track conversations, follow-ups and the signing of the employment contract

– Putting the Candidate in touch with managers for the position that may be offered or for which they have applied

– Due diligence: preparatory step for the signing of a contract with the Candidate

– Communicating with Candidates and building a professional relationship with them

– Managing the Website to maintain an optimal level of use by our technical teams

– Pentalabss does not intend to store the personal data of Candidates any longer than is necessary.

– Pentalabss may store Candidates’ data for the following reasons:
the Candidate remains in contact with Pentalabbs; Pentalabbs and the Candidate communicate by email or telephone; The Candidate interacts with Pentalabbs by opening newsletters, etc.

– For all marketing communications, Candidates’ personal data shall be stored for two (2) years from the date of last communication with the Candidate or from the date the Candidate has unsubscribe from Pentalabbs emails campaign.

Document updated on May 25th 2018.