Comptoir des Cotonniers is committed to respecting the privacy rights of users to its Talents website.
This Policy provides you with details about the types of personal data that we collect from you, how we use your personal data and the rights you have to control our use of your personal data.
When we say “Comptoir des Cotonniers”, “us”, “our” or “we” in this Policy, we are referring to COMPTOIR DES COTONNIERS, a simplified joint stock Company with share capital of 24.592.504 euros, whose registered office is located at 151 rue Saint Honoré – 75001 PARIS (FRANCE), registered in the Paris Commercial Register under number 47 720 802 776.
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”), Comptoir des Cotonniers is the “data controller” (as defined in the GDPR) of the personal data, when it determines the purposes and means of the processing of personal data.
In addition, under the GDPR :
« personal data » means any information relating to you and that identifies you, directly or indirectly;
« processing » means any operation or set of operations which is performed on personal data or on sets of personal data.
Which categories of personal data do we collect from you and for which purposes ?
We collect personal data, either directly from you, most of the time obtained through forms on our Site, or indirectly when you interact with us.
Some data are mandatory regarding the monitoring of your application or to comply with legal requirements.
We collect your personal data for the following purposes :
Recruitment: we collect data such as your name, your email address, address, phone number, and you resume.
Analysis of the ergonomy of our Site via some cookies or other technologies allowing us to collect information about your online browsing, such as information regarding your browser type, the country code where your device is located, the pages of our website that were viewed during your visit, the advertisements you clicked on, and any search terms that you entered on our Site. Nevertheless, this involves statistical data on the ways and means our users browse the Site and does not allow us to identify you.
Any personal data not necessary for the recruitment but nevertheless given by the candidate, on the resume for example, will be protected with the same care than the personal data mentioned above.
Legal basis for processing your personal data is a follows :
Regarding Recruitment process: the personal data processing involved will be based on your consent.
Processing linked to the ergonomy of our Site and the development of statistics is based either on our legitimate interests for the cookies used to improve our website and to ensure it functions properly and it is secure and safe, or on your specific consent for all the other cookies (to run statistics). For more information, please refer to our “Cookies” below section.
Who may access your personal data ?
We will treat all your Personal Information as confidential.
Information about our candidates is important and protecting your privacy is essential to us, we do not share your personal data with any third parties other than for the limited reasons specified below.
We will only disclose data to :
Other companies within our Group of companies.
Suppliers we engage to process data on our behalf.
Government bodies and law enforcement agencies to comply with legal obligations or protect some rights.
Successors in title to our business (in the case of a transfer of assets or if we sell any or part of our business).
We share personal data on a limited basis with trusted suppliers we use to perform operations on our behalf. These suppliers can assist us by providing us our Internet platform, in the evaluation of candidates and the monitoring of applications.
We only provide them with personal information they need to perform their services and we ask them to commit to use your data only for specific listed purposes. We will always use our best efforts to make sure that these third parties will keep your personal data secure and confidential.
We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Policy; or protect the rights, property or safety of the Site, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. However, this does not include selling, renting, sharing, or otherwise disclosing personal information for commercial purposes in violation of the commitments set forth in this Policy.
Where do we store your personal data ?
Internet is used in a global environment, using it to collect and process personal data involves the transmission of data on an international basis. The data that we collect from you may be transferred to, accessed in and stored at, a destination outside the European Economic Area ("EEA"), these data will always be held securely and in line with the requirements of any applicable regulations regarding data protection.
It may also be processed by third-parties operating outside the EEA (for example in Japan), working for us or for one of our suppliers. Such third parties may be engaged in, among other things, the fulfillment of support services. When we transfer personal data to third parties outside the EEA, we ask them to provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the EU regulation and ensure the protection of your rights as data subject. When necessary, we rely on the Commission Adequacy decision on the EU-Japan Privacy Shield or we may ask them to enter into contracts based on the template adopted by the European Commission according to Article 46.2 of the GDPR (Adequacy decision and model clauses adopted by the EU Commission are available via this page).
How long do we keep your personal data ?
We will keep your personal data for as long as we need it to achieve the purpose for which it has been collected or to meet our legal obligations.
- Regarding Recruitment, we keep the data related to the application for two years following the last contact with the candidate, unless the candidate requests the deletion of his/her file before this deadline.
- Personal data within cookies set on your terminal will be kept for as long as we need it to achieve the purpose for which it has been collected (e.g. session identification cookies are just kept for the duration of the ongoing session), and for a maximum duration of 13 months.
We might keep some personal data for a longer time to comply with legal or regulatory obligations (e.g. to meet our obligations linked with invoicing) or to protect our legitimate business interests (e.g. to bring a claim before the Court).
When accessing our website, information about your browsing may be saved in some "cookies" files installed on your device.
Please note that only the issuer of a cookie may read or modify information contained therein.
Cookies we install on your device allow us to recognize your browser when you connect to our website.
We issue cookies for the following purposes :
Establish traffic statistics (number of visits, page views, abandonment during the order process) to monitor and improve the quality of our services.
Adapt the presentation of our website to the display preferences of your terminal.
Memorize information entered in forms, manage and secure access to specific and personal places such as your account.
You can configure your browser software so that cookies are saved in your device or, in order they are rejected, either systematically or according to their issuer.
You can also configure your browser so that the acceptance or rejection of cookies is offered to you punctually, before a cookie is likely to be registered in your device.
You can also use our cookie management tool, which you can access via the cookies banner that appears when you first visit the site and is also available here.
If your browser is set to refuse all cookies, your browsing experience will be different and you will not be able to take advantage of essential features of our Website, such as keeping products in your cart or receiving personalized recommendations. The configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to change your wishes for cookies. You will find more information on how to eliminate or control cookies on www.AboutCookies.org.
Your rights on your personal data
You have the followin
- The right to request access
- The right to request from us rectification of any personal data that is inaccurate or incomplete;
- The right to request erasure (‘right to be forgotten’) of personal data if these data are no longer necessary in relation to the purposes for which they were collected or otherwise processed or if you withdraw your consent (we might have to keep some personal data to meet legal requirements or legitimate interests though).
- The right to obtain restriction of processing where one of the following applies:
- If you have contested the accuracy of your personal data, processing shall be restricted for a period enabling us to verify such accuracy,
- When processing is unlawful and you oppose to the erasure of your personal data and request the restriction of their use instead,
- If we no longer need the personal data for the purposes of the processing but they are required by you to establish, exercise or defend your legal claims,
- When you have objected to processing based on legitimate interests, processing shall be restricted for a period enabling the verification whether our legitimate grounds override yours.
- The right to object, on grounds relating to your particular situation, where processing of your personal data is based on our legitimate interests. You also have the right to object at any time to processing for direct marketing purposes (including profiling to the extent that it relates to such direct marketing);
- The right to data portability meaning you have the right to receive the personal data we hold about you in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller where the processing is based on your consent or on a contract and is carried out by automated means. You have also the right to have your personal data transmitted directly from us to another controller where technically feasible;
- The right not to be subject to a decision based solely on automated processing including profiling, , which produces legal effects concerning you or similarly significantly affects you (unless if this decision is necessary for entering into, or performance of, a contract between you and Comptoir des Cotonniers or is based on your explicit consent);
- The right to lodge a complaint with a supervisory authority if you have reasons to think that your rights on your personal data are infringed by Comptoir des Cotonniers.
- The right to define specific or global requests regarding the deletion of your personal data after you passed away. Those global requests define the way you want your rights to be handled after you passed away. You can modify or cancel those requests at any time.
Note that we may ask you additional information necessary to confirm your identity to exercise your rights.
Personal data security
We are committed to offering our customers a safe and secure environment. Whilst we take appropriate technical and organizational measures to safeguard the personal data that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal data that you transfer over the Internet to us.
If you are using a computer or terminal in a public location, we recommend that you always log out and close the website browser when you complete an online session for your security. In addition we recommend that you take the following security measures to enhance your online safety:
- Keep your account passwords private. Remember, anybody who knows your password may access your account.
- When creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this by going to ‘My Account’ and clicking ‘Change name, email or password’.
- Avoid using the same password for multiple online accounts.
Links to third party websites
We will never ask you to confirm any account or credit card details via e-mail. If you receive an e-mail claiming to be from Comptoir des Cotonniers asking you to do so, please ignore it and do not respond.
If you have any questions or concerns relating to this Policy or any other privacy-related questions or if you would like to exercise any of your rights above described, please contact us at: firstname.lastname@example.org
Or by writing to the following address :
Comptoir des Cotonniers
Service Ressources Humaines
151 rue Saint Honoré
Last update as of April 2020