CONFIDENTIALITY POLICY
Updated on September 2018
Respect and transparency are at the core of TOD values. We commit ourselves to protect the personal data of all the members of our community, talents, partners, and clients. The confidentiality of all data processed on the www.yourtod.com platform is essential to us. We have therefore updated our confidentiality policy to clarify the following questions:
– what kind of data we collect about you;
– why we collect them;
– how we store and use them;
– when and with whom we share them.
In accordance with the General Data Protection Regulation (GDPR) in effect since May 25 2018, our new policy informs you of your rights relating to the confidentiality of your data and explains how to exercise these rights, so you can have a better control over your personal data on www.yourtod.com.
You will be notified of any other notable amendment to the present Confidentiality Policy by email and through your personal account, to give you the opportunity to review its content before these changes enter into force and to close your account if you are opposed to any one of the proposed changes.
1- INTRODUCTION
TOD is a simplified stock corporation under French Law (“Société par actions Simplifiée”) with a capital stock of 17 494 euros and headquartered at 10 rue Chevreul, 92150 Suresnes, registered to the RCS of Nanterre under number 829 775 980. Through its www.yourtod.com platform, TOD is offering a new approach to talent experiences or hiring experiences for businesses by connecting the professional aspirations and human values of current or future employees with the needs and challenges of companies.
The www.yourtod.com platform aims to form a community of talents selected for and bound together by shared human values and to connect the professional aspirations of such talents with the human resources needs of our clients.
In order to do so, the platform collects a certain amount of personal data related to the talents who joined the community so we can combine their profiles with the requests of client companies. In addition to data freely provided by talents when signing up, the platform also processes answers to an online test to also establish a profile of human values and behavioral strengths, to guarantee a better adequacy between talents and their assignments.
2- COLLECTED DATA
2.1 Data you are providing us with:
Signing up as a talent: when you are creating your Talent account, we explicitely ask you to review our confidentiality policy (box to check) and you must provide us with:
o your full name and e-mail
o your phone number
o your date of birth
o elements about yourself and your professional aspirations (as answers to the questions “Who am I?” and “What do I dream of?”)
o Then, once your email address has been confirmed, you must take the “Spirit of TOD” test and we collect your answers to its 120 questions.
Enhancing your talent profile:
You are then free to provide us with any information you find useful for us to show you the work opportunities that are most in line with your expectations, through the following sections:
o your experiences
o your education
o your achievements
o your certifications, awards, publications
o your professional expectations (position, location, compensation, conditions of intervention…)
o your availabilities
Add recommendations: You are also free to ask other people to complete your profile with recommendations (request sent by email to the person of your choice, their answer is then automatically added to your profile).
Test order: When as a talent, client, or natural person, you order a test, we keep all the information related to the order for accounting purposes for two years. Your credit card information however are stored for only a month to ensure reimbursement of associated costs in the event of the cancellation of an order.
Signing up as a client: when you are creating your Client account, we explicitely ask you to review our confidentiality policy (box to check) and you must provide us with:
o your full name, position, phone number, company, division, business sector, type of enterprise
Expressing your need: you are then free to order tests on the website and to explain to us your needs in terms of assignments and their description. Data related to the expression of any such need are not considered personal but rather professional data related to your company’s activities. TOD however still ensures the full confidentiality of such data and the rights to access these data are identical to those that exist for personal data.
2-2 – Cookies:
The www.yourtod.com platform uses trackers (cookies). The website may thus have access to information already stored in in your terminal equipment for electronical communications and to add to those information. The website only uses so-called “strictly necessary” trackers, that do not require your prior consent. We use these trackers in order to facilitate your use of the website, including by saving your browsing preferences during your session, and to provide you with the services you expressly require, such as directly signing in to your account, remembering your setting and producing anonymous visit statistics in order to optimize your experience of the website. The time period for cookie storage is determined by the duration of your use of the website and of its services, such as talent or client accounts.
After one year of inactivity, accounts and their related cookies are deleted.
These trackers cannot be technically disabled from the website directly. However, you can prevent the use of any such trackers exclusively through the settings of your browsers. How you can change your settings depend your browser of choice but is generally simple: usually, you can either set your browser in private mode or simply forbid or restrict the use of trackers (cookies). It is possible that trackers have been stored on your terminal before you changed the settings of your browser; in this case, be careful to delete your browsing history, also through the settings or your browser.
The use of trackers is governed by article 32 II of the Law no. 78-17 of 6 January 1978, implementing article 5.3 of Directive 2002/58/CE of the European Parliament and Council of 12 July 2002, as amended by Directive 2009/136/CE. To read more about cookies and trackers, please go to the CNIL website: www.cnil.fr.
2-3 – Other collected data:
In addition to data you are providing us with and data stemming from the use of cookies, the website also collects and stored elements relating to the time of your connexion, of submission of your application to join the community, of your test… any date or time corresponding to a specific action (test order, talent request…), for the sole purpose of honouring our service commitments.
3- USE OF YOUR DATA
The answers to the Spirit of TOD test are processed in a specific manner which allows us to determine your “TOD” profile, to evaluate your personal values and to identify your strengths and what motivates your commitment. This allows us to better understand you and to offer you optimal opportunities with regards to our clients’ needs.
You will find a summary in your talent account.
Then, and more generally, your data are used for only two purposes:
– e-mailing campains: invitations to the different events of the community, sharing information that might interess you (new features, client events… ). You can always unsubscribe to any emailing list.
– matching talent profiles with client requests.
4- DATA SHARING
Personal data related to clients or talents are stored in their respective accounts and are never publically disclosed on the website, in part or in full. No information is disclosed or shared by TOD in any way with our partners.
Personal data from talents and information regarding their profile can only be disclosed so they can answer the existing need of a client the talent has given their explicit consent to apply for the assignment or the position in question. The talent shall give their consent through their personal account. Regarding information stored on client accounts, only the necessary and relevant information relating to the assignment or position that needs to be filled shall be disclosed to the talents that have been pre-selected for this assignment or mission.
5- LEGALITY OF DATA PROCESSING AND APPLICABLE CONDITIONS TO CONSENT(art 6 and 7 of GDPR)
Consent by a client or a talent for personal data processing is systematically obtained through a box to be checked for one or more purposes. As an example, when a client or a talent account is created, users must check a box to confirm they have reviewed the Terms and Conditions and the Confidentiality Policy. The talent or client account can be created only once the user has clicked on the email sent to the address they have entered.
6- DATA PRESERVATION
Data collected on the www.yourtod.com website are stored for a maximum period of three years for talents or five years for clients after they have last used the platform. An email will inform them when their account and all of their personal or professional data will be deleted, unless the user then explicitly asks otherwise.
When as a talent, client, or natural person, you order a test, we keep all the information related to the order for accounting purposes for two years. Your credit card information however are stored for only a month to ensure reimbursement of associated costs in the event of the cancellation of an order.
Deleted data undergo an anonymization process so they can be archived without any personal data in independent storage that are not accessible to production systems. (Any name, email address, and phone number of all the persons who are concerned are thus deleted). Archived data are only accessible by duly authorized and qualified persons and can only be used for statistical purposes.
7- INDIVIDUAL RIGHTS(Articles 16 to 20 of GDPR) and Data Protection and Freedom of Information Law (article 12 of the Terms and Conditions)
In accordance with the French Data Protection and Freedom of Information Law (Loi Informatique et Liberté) no. 78-17 of 6 January 1978, clients and talents have the right to access, modify, rectify or delete any personal data concerning them and can exercise this right by contacting TOD. To exercise this right, please write to: TOD/Data protection, 10 rue Chevreul – 92150 Suresnes, FRANCE.
TOD is committed to giving within two months to every person that request it all of the personal data it possesses concerning them, in a legible forms.
The talent can also ask at any time to delete their account and all of their personal data directly from their account.
8- DATA AND DATA PROCESSING SECURITY(article 32 of GDPR)
All the data collected on the www.yourtod.com website and their processing are hosted by TOD. Only duly authorized members of our teams and of our administration have access to information collected on the website.
9- DATA BREACH AND COMMUNICATION WITHIN 72H (articles 33 and 34 of GDPR)
In the event of a breach or suspected breach of personal data, TOD and its subcontractors shall notify the CNIL (the French regulatory authority), 72h at the latest upon discovering such breach.