Personal data protection policy and cookies charter

The Personal Data Protection Policy (“the Policy”) and the Cookie Charter (“the Charter”) are intended to provide you with information regarding the way in which Publicis Conseil uses and protects your personal data (“Personal Data”) collected via the website http://www.publicisconseil.fr/ (“the Site”). If you have any questions about the way in which your Personal Data are collected, we request you to contact Publicis Conseil's Personal Data Protection Officer at the following address: privacyofficer@publicisgroupe.com.

The Personal Data collected by the Site will only be used to enable us to respond to your requests, manage your applications, update our files, send you marketing messages, and analyse traffic on the Site. Once collected, the Personal Data will not be used for other incompatible purposes without your consent. Publicis Conseil, 133, Avenue des Champs-Elysées, 75008 - Paris, registered in the Commercial Registry of Paris under the number 304 765 332, is considered to be the Data Controller of this Site. We take the protection of Personal Data very seriously. All Personal Data collected by the Site will be treated as strictly confidential, and will only be used as described in this Policy and in accordance with applicable laws. Therefore, please read this Policy carefully. If you disapprove of the way in which your Personal Data will be used, please do not use this Site or provide your Personal Data through this Site. We may include links on the Site to other websites, including social networking platforms. This Policy only covers how we use Personal Data, and does not cover these other websites. We encourage you to read the privacy statements available on the other websites that you visit.

PERSONAL DATA PROTECTION POLICY

I. Purposes for processing Personal Data

The purposes for which the Site collects Personal Data are the following:

  • Responding quickly and efficiently to your requests via the contact e-mail addresses indicated on our Site;
  • Managing your job applications and, if necessary, building a pool of candidates;
  • Maintaining our database of current and potential clients
  • Obtaining statistics on the use of the Site, in order to improve its operation and services
  • Maintaining and preserving the security of the Site; however, please note that we use Statistical Data wherever possible;
  • Responding to your requests on social networks, and getting to know you better;
  • Processing and responding to your request to exercise your rights as listed in Article V hereof.

II. What Personal Data do we collect and process?

By Personal Data, we mean any information relating to an identified or identifiable natural person (i.e. any living person). We collect the following Personal Data through the Site:

  1. Your personal information
    We collect certain pieces of personal information such as your first name, surname, and e-mail address. We may also collect your job title, company address, and telephone number if you provide us with such data in the body of your message and/or request.

  2. The content of the messages and/or requests that you send to us, including, if applicable, information about your professional and educational background if you are applying for a job.

  3. Browsing information
    We also collect, through cookies and other trackers, a limited amount of Personal Data related to your use of the website, such as your IP address, browser type, operating system, and the websites you visit before and after our website. For more information on this subject, please refer to the Charter on cookies, social networks, and other tracking technologies.

  4. When you browse the Site, information related to your browsing and use of the Site's pages, as described in the Cookies Charter below, may be collected.

III. What legal basis do we have to do so?

The processing of Personal Data collected on the Site is based on:

  • the execution of pre-contractual measures, when we process your messages sent by e-mail when this request has a commercial scope (requests relating to our services or our offers);
  • our legitimate interests, when we process your job applications and store your CV and cover letter in our CV database so that we can identify a suitable position for you in the future;
  • our legitimate interests, when we process your data in the context of maintaining and implementing measures to preserve the security of the Site;
  • our legitimate interests, when we process data collected via social networks in order to get to know our subscribers better and to understand the public's reaction to our products and services;
  • your consent, when we carry out statistical analyses regarding visits to our Site by means of the data collected through cookies;
  • our legal obligation, when we process those of your requests related to the exercise of your rights as listed in Article V hereof.

You may send us a request in order to obtain further information about the checks that we have carried out to ensure that we could process your Personal Data on the basis of legitimate interest.

IV. With whom do we share your Personal Data?

When it is justified, your Personal Data may be shared within the organisations of the Publicis Group and its subsidiaries in France. In the event that you wish to exercise your rights as listed in Article V hereof, your request will be collected by means of the form provided by our partner TrustArc, which acts on our instructions and on our behalf as a sub-contractor as defined in European Regulation 2016/679 on the protection of personal data (“GDPR”). As soon as your request is validly transmitted to the Publicis Group, TrustArc will immediately delete it from its servers and other IT tools. Your Personal Data will not be passed on to third parties, unless otherwise specified in this Policy. Your Personal Data may be passed on:

  • in the context of a merger, acquisition, or sale of all or part of the assets of the agency, to the successors in title to our business, or
  • to establish, exercise, or defend our rights, or
  • when required by law, to respond to requests from legal or administrative bodies, government authorities, or courts.

If the services of third parties are required for the technical maintenance of the Site or the software processing your Personal Data, or for the hosting, backup, administration, or processing of the Data and/or our e-mails, these third parties will have access to Personal Data only to the extent necessary to ensure the smooth and/or secure technical operation of the Site and our software. In any case, such access to your Personal Data will only be provided in accordance with applicable law, including with respect to Data confidentiality, privacy, and security obligations.

V. Your rights regarding your Personal Data

In accordance with the applicable regulations, you may exercise the following rights with respect to those of your Personal Data that we hold:

- Right to information:

You have the right to obtain clear, transparent, understandable, and easily accessible information about how we use your Personal Data, and about your rights. That is why we are providing you with such information in this Policy.:

- Right of access to your Personal Data::

You can access all the Personal Data that we hold about you, learn of the origin of this Personal Data, and obtain a copy of them in an understandable format.: You may also exercise your right of access to your Personal Data in order to check the accuracy of the data and have them corrected or deleted. You do not have to indicate a reason to exercise your right of access;:

- Right to rectify your Personal Data::

In order to prevent inaccurate or incomplete Personal Data regarding you from being processed or disseminated, you can ask us to rectify them;:

- Right to have your Personal Data deleted::

You may ask for the erasure or deletion of the Personal Data held by us. This is not an absolute right, as we may be required to retain your Personal Data for legal or legitimate reasons. For example, you can exercise your right to deletion in the following cases:: o if you have withdrawn your consent to processing (see below);: o if you have validly objected to the processing of your data (see below);: o when the data are not or are no longer necessary for the purposes for which they were originally collected or processed;: o the data have been processed unlawfully (e.g. publication of hacked data);:

- Right to object to the processing of your Personal Data::

When we process your Personal Data on the basis of our legitimate interests (to find out what kinds of processing this may involve, please refer to Section III of this Policy), you may at any time object to the processing of your Personal Data on grounds relating to your particular circumstances. However, we may turn down such a request depending on the case if there are compelling legitimate grounds for processing such data which override your interests, rights, and freedoms, or if such data are necessary for the establishment, exercise, or defence of legal claims;: You may unsubscribe from or object, at any time and without indicating any reason, to direct marketing messages. All you have to do is either (i) click on the link in the footer of the message you have received from the agency; or (ii) use the hyperlink below.

- Right to restrict the processing of your Personal Data:

The right to restrict processing complements the other rights that you have. This right means that the processing of your data by us is restricted, so that we may retain the data, but we may not use or process them in any other way. This right applies in specific circumstances, namely: o if you dispute the accuracy of your Personal Data. The processing is then restricted for some time, allowing the agency to verify the accuracy of the Personal Data; o in cases where the processing is unlawful and you object to the erasure of your Personal Data, and instead ask for their use to be restricted; o in cases where we no longer need the Personal Data for the purposes mentioned above in Section I, but where they are still necessary for you to establish, exercise, or defend legal claims; and o in cases where you have objected to processing based on the legitimate interests of the agency: you may request that processing be restricted for the time necessary to determine whether we can comply with your objection (i.e. the period necessary to verify whether or not the legitimate interests of the agency prevail over yours).

- Right to the portability of your Personal Data:

You may submit a request to obtain the Personal Data that you have provided to us, in a structured, commonly used, and machine-readable format, for your own use or to send them to a third party of your choice. This right applies only to the Personal Data that you have provided to us directly or indirectly and that have been processed using automated processes, where the processing is based on your consent or the performance of a contract. We invite you to peruse the list of the legal bases for our processing of Personal Data (in section III of this Policy) to find out whether our processing is based on the performance of a contract or on consent;

- The right to give instructions as to what is to be done with your Data after your death.

You can define guidelines regarding the retention, erasure, and disclosure of your Personal Data after your death. These directives can be general, i.e. concerning all the Personal Data about you, or specific, i.e. concerning only certain kinds of processing.

Please click this link and follow the instructions if you wish to exercise any of the above-mentioned rights - https://submit-irm.trustarc.com/services/validation/870dd17a-045b-4047-94ca-c0b161679de7 If we have reasonable doubts about your identity, we may ask you to attach any document that proves your identity, in order to prevent identity theft. Insofar as your request is received electronically, we will respond electronically unless you specify, in the comments area of the form to exercise your rights, that you wish to receive a response by another means, for example by post.

We will reply as soon as possible, and in any case within one month of receiving your request. This period may be extended by two months in order to handle the complexity of the request or the number of requests received. In such a situation, we will inform you of this no later than one month after receiving your request, and will specify the reasons for the extension of the response time. If you feel that we are not complying with this Policy, if you are not satisfied with the way we have handled your request, or if your request has been turned down, you may also make a formal complaint to the competent authority for the protection of Personal Data (in France, this is the Commission Nationale de l'Informatique et des Libertés (CNIL): https://www.cnil.fr). However, we invite you to contact our Data Protection Officer at the following address: privacyofficer@publicisgroupe.com before filing a complaint with the competent Data Protection Authority.

VI. Retention periods

We retain your Personal Data in accordance with the applicable legal data retention requirements and our internal policies. The retention of data will vary according to the type of data and the purposes for processing them.

Your Data are stored for the entire duration of our contractual and/or pre-contractual relationship. After this period, your Data will be archived for the applicable duration which, in France, is 5 years after the end of our relationship and/or the last time that we had contact with you.

As for the Personal Data collected in the context of your application for a position, they are stored:

  • for a period not exceeding 2 (two) years after the last time we had contact with you if you are unsuccessful in your application, unless you indicate that you do not want us to retain your application after the recruitment process, in which case your Personal Data will be deleted immediately;
  • for the duration of your presence at Publicis Conseil, if your application is accepted.

VII. Data security

We use a variety of methods, such as firewalls, intrusion detection software, and manual security procedures, to protect your data against loss or damage, to help protect the accuracy and security of Personal Data, and to prevent unauthorised access or misuse. If you believe that the Site or any piece of Personal Data is not secure or that there has been unauthorised access to the Site or your Personal Data, please contact privacyofficer@publicisgroupe.com immediately.

VIII. Data transfer

Due to the international nature of our business, your Personal Data are transferred outside the European Union. The Personal Data collected about you are transferred to the United States. As this country is not considered by the European Commission to offer an adequate level of protection, we ensure that all data transfers comply with the applicable legal requirements by signing, in accordance with Article 46 of the GDPR, standard data protection clauses adopted by the European Commission, with our co-contractors.

If you would like to know more about how the Data are protected, or if you would like to request a copy of the relevant safeguards, please send an e-mail to privacyofficer@publicisgroupe.com.

IX. Notification of changes

This Policy may be modified by Publicis Conseil due to changes in the functionalities of the Site, the Services offered, and the laws applicable to the activities of Publicis Conseil. These modifications and updates are binding on the User, who must therefore regularly refer to this section and check the Personal Data Protection Policy in force. If you wish to save this text, please select all of it with your mouse and copy-paste it using Ctrl+C.

X. Additional information

For more information on Publicis Conseil, please visit our website - http://www.publicisconseil.fr/. If you feel that we are not abiding by this policy or if you have any questions about it, please contact privacyofficer@publicisgroupe.com.


CHARTER ON COOKIES, SOCIAL NETWORKS, AND OTHER TRACKING TECHNOLOGIES

The purpose of this Charter is to provide you with information regarding the storage and use of cookies, social networks, and other tracking technologies, as well as the means made available to you to object to them. We may update our Charter at any time, and such changes will be effective immediately. We encourage you to refer to it regularly so that you are familiar with its latest available version.

I. Social networks

If you follow us on social media (through our LinkedIn, Facebook, Twitter, Instagram, and YouTube accounts), we will also collect personal data about you in order to get to know our subscribers better and to understand the public’s reactions to our products and services. We may use this information to contact you / send you marketing information that we think may be of interest to you / collect social feedback to identify and evaluate what is being said publicly about us in order to understand industry trends and market sentiments. The use of Personal Data mentioned above is only carried out in accordance with the applicable laws (for example, if you request us to contact you or if your specific express consent is required). We have no control over how social networking platforms use your Personal Data. We encourage you to read the privacy statements of the various social networking platforms that you use. To learn more about how these social networking platforms use your Personal Data:

Facebook - https://www.facebook.com/privacy/explanation

Twitter - https://twitter.com/en/privacy

YouTube (Google's general privacy policy) - https://policies.google.com/privacy?hl=en

Instagram - https://help.instagram.com/519522125107875

LinkedIn - https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy

If you have any questions about the way in which your Personal Data are collected, we request you to contact Publicis Conseil's Personal Data Protection Officer at the following address: privacyofficer@publicisgroupe.com.

II. Cookies

1) What is a Cookie?

A “Cookie” or “tracker” is a small text file that is saved in the memory of your browser on your hard disk when you visit a website, read an e-mail, and install or use software or a mobile application, and that makes it possible to record and track data concerning your use of the website. These data do not identify you directly, but they may provide information about your preferences or your device. They are mainly used to ensure the proper functioning of the Site, as well as to enable us to obtain statistics and details about Site visits. These data do not generally identify you directly, but they can provide you with a personalised web experience.

2) Who stores Cookies?

The Cookies used to measure the audience of our site are stored by Google LLC - https://policies.google.com/privacy

3) What Cookies are used?

Audience measurement Cookies: these traffic log Cookies are used to identify which pages are visited, and to measure and track the performance of our Site. This helps us analyse web page traffic data and improve our Site to better suit your needs. We only use this information for statistical analysis. Cookies used:

  • « _gid » ;
  • « _gat » ;
  • « _ga »)

Different retention periods apply to the different types of Cookies stored, depending on whether they are session Cookies (i.e. Cookies temporarily placed on your device that appear when you access the Website and disappear when you close your web browser window) or permanent Cookies (i.e. Cookies that will remain on your device for a certain period of time in order to enable us to remember your preferences during future visits). In any case, Cookies will never be stored on your device for more than 6 to 13 months, depending on the purpose of the Cookies concerned..

4) How do I manage Cookies?

You can choose to accept or decline some or all Cookies. On your first visit, by clicking the “Cookie Settings” link on the Cookie banner, you will be able to set your preferences according to the type of Cookies. You can change your Cookie preferences at any time using the following link: “Cookie Settings”.

Last updated on: 22 February 2021

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