The present privacy and cookie policy (hereafter « Privacy and Cookie Policy ») intends to explain our privacy practices for the activities described herein and under the CAREERINCONSULTING.COM Terms (both referred to as the « CAREERINCONSULTING.COM Services »). 

CAREERINCONSULTING.COM Services includes the services offered through the CAREERINCONSULTING.COM website. 

Please read this Privacy and Cookie Policy carefully to learn how we collect, use, share, and otherwise process information relating to individuals using our services (“Personal Data”), and to learn about your rights regarding your Personal Data.

The present Privacy and Cookie Policy forms part of the CAREERINCONSULTING.COM Terms of Service available on this page: https://careerinconsulting.com/terms-and-conditions/. 

Therefore, any term containing a capital letter that is not specifically defined herein shall have the meaning given to it under the CAREERINCONSULTING.COM Terms.

Definitions

Data Controller means the natural or legal person who determines the purposes and means of the processing of personal data as detailed under section 1 below;

Data Processor means a natural or legal person who processes Personal Data on behalf of the Data Controller;

Data Subject means a natural person to whom Personal Data relates;

GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data;

Recipient means a natural or legal person to which the personal data are disclosed, whether a third party or not.

Standard Contractual Clauses means the agreement executed between the Data Controller and the Data Processor pursuant to the European Commission’s decision (C(2010)593) of 5 February 2010 on Standard Contractual Clauses for the transfer of personal data to Data Processors established in third countries which do not ensure an adequate level of data protection;

Sub-processor means a natural or legal person other than the data subject, Data Controller and Data Processor who, under the direct authority of the Data processor, is authorized to process Personal Data

1. Who is the responsible entity?

The Data Controller for the processing of your Personal Data as described in this Privacy and Cookie Policy and under the CAREERINCONSULTING.COM Terms of services is Sébastien RITTER, Registered in the Paris Trade and Companies under number 811 021 369 00012, Located 56 rue VANEAU 75007 PARIS, FRANCE.

2. How we collect Personal Data?

In the course of providing the CAREERINCONSULTING.COM Services, We may process Personal Data relating to You that We collect, either directly from You, or from Your use of CAREERINCONSULTING.COM Services.

2.1 Personal Data We collect directly from You

We collect Personal Data directly from You when You perform the following actions :

• Creation of an account: When creating an account on the CAREERINCONSULTING.COM website, You are required to provide some Personal Data, such as name, email address, pseudonym, school attended, and your objectives.

• Filling out the form to receive tailor-made support: When connected to the CAREERINCONSULTING.COM website, You may decide to fill a form in order to let Us know what can of assistance You expect. Towards this end, you are invited to provide some Personal Data, such as name, email address, phone number, firms where you will have interviews, and the major points you struggle with. 

• Profile customization: Once registered on the CAREERINCONSULTING.COM website, Registered Members benefit from a personal account on which they may decide to publish some other Personal Data as they consider it to be relevant, such as, for example, a profile picture, or some more details regarding their qualification and background. 

• Contact CAREERINCONSULTING.COM: Registered Members are free to Contact Us through the Contact section or by email at [email protected] at any time for any question they might have (including for example to exercise their rights relating to data protection). To do so, they are required to provide their name and email address and may decide to provide some additional Personal Data within the body of their message.  

• Payment: In order to complete payment transactions on the CAREERINCONSULTING.COM website, it is required to provide identifying information such as name and email address, and payment data like credit card number, the purchase amount, date of purchase, payment method. Payment data are provided to the payment service provider acting as a Data Processor (as described notably under sections 4 and 5 below). We do not keep any banking data such as the credit card number.

2.2 Personal data we collect from your use of CAREERINCONSULTING.COM Services

When navigating on the CAREERINCONSULTING.COM website, Personal Data related to you may be processed after having been collected through the use of cookies or other technologies subject to your consent in compliance with the conditions described under the present Privacy and Cookie Policy.

3. Why we collect Personal Data and on which legal base?

Pursuant to applicable data protection regulations, We are only authorized to process Personal Data if We are compliant with one or more of the following legal basis: the execution of a contract, a legitimate interest, the fulfillment of a legal obligation, or the consent of the data subject.

3.1 Processing of personal data based on the execution of the contract

The main purpose of processing Your Personal Data is to provide You with the services offered on the CAREERINCONSULTING.COM website for access to the Solution which You have chosen to expressly accept the CAREERINCONSULTING.COM Terms (including this Privacy and Cookie Policy) and hereby enter into a contractual relationship with Us.

In particular, on the basis of the execution of the contract between You and Us, We process your Personal Data to :

• Ensure the creation and management of Registered Members’ accounts;

• Ensure the sending of emails and push notifications concerning your use of our services (e.g. email of booking confirmation, promotions, newsletter);

• Manage questions and complaints addressed to us through the contact section;

• Ensure the creation and management of a personal account for users willing to access the paid courses;

• Allow performing payment transactions on CAREERINCONSULTING.COM website.

3.2 Processing of personal data based on our legitimate interest

On the basis of our legitimate interest, We process Your Personal Data to :

• Make statistics and marketing analyzes in order to better understand how you use our services and optimize your user experience;
• Send you proposals of customized content and offers in order for you to benefit from our services in a customized manner;
• Allow management of Registered Candidates’ satisfaction in order to improve the quality of our services.

In compliance with the Data protection regulation, we commit to verifying that our “legitimate interest” never goes against the rights and freedoms of data subjects.

3.3 Processing of personal data based on your express and specific consent

On the basis of your express and specific consent, we may process Personal Data to :

• Send commercial prospecting by email;
• Use some cookies as described under this Privacy and Cookie Policy.

For the processing of Personal Data based on consent, such consent has to be free, informed, specific, and express. Data subjects can withdraw their consent at any time by making a request through the « contact » section, at the bottom of each email sent by CAREERINCONSULTING.COM, or by modifying their preferences under the « cookie » pop-up window.

3.4 Processing of personal data based on our legal obligations

Personal Data may be processed based on some legal obligations applicable to us, such as our obligation to keep invoices as well as other accounting documents.

4. To whom do we transfer Personal Data?

4.1 Transfer of Personal Data toward Data Processors

We transfer Personal Data to processors listed below, acting as Data Processors, for the performance of the following operations:

• The BlueHost company, located in the United States, for the following services: hosting and management of the CAREERINCONSULTING.COM website;
• The Stripe Payments Europe, Ltd company, located in Ireland, for the following services: payment transactions and related services on CAREERINCONSULTING.COM website;
• The PayPalEurope company, located in Ireland, for the following services: payment transactions for the CAREERINCONSULTING.COM website;
• The GetResponse Sp. z o.o. (Polish limited liability company), located in Poland, for the following services: sending and delivering of email communications;

4.2 Transfer of Personal Data due to a legal obligation

In order to be compliant with our legal obligations, your Personal Data may also be transmitted to authorized administrative and judicial authorities, only on judicial request.

5. Do we use international Data transfers?

In the course of providing CAREERINCONSULTING.COM Services, we use Data Processors as mentioned under section 4 above. This will generate international transfers of Personal Data that are legalized as follows.

5.1 Hosting and management of the CAREERINCONSULTING.COM website 

For the hosting and management of the CAREERINCONSULTING.COM website, We use the services of the BlueHost company which may imply the processing of Personal Data.

The latter being a company located in the United States, their storage and/or processing of Personal Data may involve transfers of those Personal Data outside EEA (including, but not limited to, to the United States). As a result, to legalize transfers of Your Personal Data to this Data Processor, We have entered into a data processing agreement that includes Standard Contractual Clauses. 

5.2 Payment transactions and related services on CAREERINCONSULTING.COM website

For payment transactions and related services on the CAREERINCONSULTING.COM website, We use the services of the Stripe Payments Europe, Ltd company and PayPal Pte. Ltd which both may imply the processing of Personal Data.

These 2 companies being companies located in the United States, their storage and/or processing of Personal Data may involve transfers of those Personal Data outside EEA (including, but not limited to, the United States). As a result, to legalize transfers of Your Personal Data to this Data Processor, it has implemented measures including the Standard Contractual Clauses.

5.3 Sending and delivering email communications on CAREERINCONSULTING.COM website

For the sending and delivering of email communications, we use the Services provided by the GetResponse company which may imply the processing of Personal Data.

The latter being a company located in Poland, their storage and/or processing of Personal Data may involve transfers of those Personal Data outside EEA. As a result, to legalize transfers of Personal Data to this Data Processor, We have entered into a data processing agreement that includes Standard Contractual Clauses.

6. Rights of Data Subjects

Pursuant to Articles 15 to 22 of GDPR, as Data subject of personal data collected through the CAREERINCONSULTING.COM website, you are entitled to exercise the following rights:

• Right of access: This is the right for a Data subject to obtain from the Data Controller a confirmation as to whether or not his/her Personal Data are being processed, and, in such case, to access those Personal Data and any additional information as stated under GDPR.
• Right to rectification: This is the right for a Data subject to obtain from the Data Controller without undue delay the rectification of inaccurate Personal Data relating to him/her. The data subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. Registered Members can also, at any time, modify his/her Personal Data of his/her personal profile, except the email address.
• Right to erasure (« right to be forgotten »): This is the right for a Data subject to obtain from the Data Controller the erasure of his/her Personal Data without undue delay within the conditions provided under GDPR.
• Right to restriction of processing: This is the right for a Data subject to obtain from the Data Controller a restriction of processing within the conditions provided under GDPR.
• Right of opposition: This is the right for a Data subject to object at any time to the processing of Personal Data within the conditions provided under GDPR.
• Right to data portability: This is the right for a Data subject to receive his/her Personal Data in a structured, commonly used, and machine-readable format and the right to transmit those data to another Data Controller within the conditions provided under GDPR.
• Right to object to automated individual decision-making: This is the right for a Data subject not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects within the conditions provided under GDPR. We confirm that We do not proceed to any automated individual decision-making.

To exercise these rights, we invite you to send us your request by email, together with an ID, at the following email address: [email protected].

We commit to providing information on action taken on a request under Articles 15 to 22 of GDPR without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

7. How long are kept Personal Data?

In compliance with GDPR provisions, Personal Data may only be kept in a form that permits identification of the individual for no longer than is necessary for the purposes for which it was processed. The retention period of your Personal Data may change depending on the purpose of their collection:

• Data related to accounts (such as name, service use history, imported CV, etc ) are kept for 3 years from the end of the commercial relationship;
• Accounting documents are kept for 10 years as required by our legal obligation;
• Payment data will be deleted by the Data Processor PayPal and Stripe Payments Europe, Ltd company at the end of the provision of its services unless further storage of the Personal Data is required or authorized by applicable law;
• Data that may be subject to a judicial requisition (connection data, identity, contact details, transaction data) are kept for 12 months from their collection.

8. The right to lodge a complaint with the « Commission Nationale de l’Informatique et des Libertés »

You have the right to lodge a complaint with the « Commission Nationale de l’Informatique et des Libertés » (CNIL) whose website is available at the following link: https://www.cnil.fr/fr.

9. Use of cookies similar tracking tools

When a user visits our website, We, or an authorized third party, may place a cookie on the user’s device that collects information, including Personal Data, about his/her online activities. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.

You can change your cookie settings and preferences at all times, by clicking on the « Cookie » logo at the bottom left of all pages of the CAREERINCONSULTING.COM website. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services.