Privacy protection charter
Updated on July 24, 2019
« Cookie »: A cookie is information which is placed on the hard drive of an online user by the website server last visited. It contains several data: the name of the server which deposits it, a unique number as an identifier, an expiration date (twelve months for Golden Bees cookies). This information is stored on the computer in a simple text file, which a server may access to read and save information.
« Intermediaries»: refers to the organizations to which Golden Bees entrusts the search for the most relevant locations, in order to display job or training offers based on user profiles. These partners do so to comply with the legal rules regarding privacy and data protection.
«Golden Bees Website» : refers to the Golden Bees websites which can be accessed through: URL www.goldenbees.io and www.wan2bee.fr.
« Partner Website »: refers to the websites, customers of Golden Bees, through which the Golden Bees cookie is deposited. Partner sites mostly belong to companies looking for employees or websites with job or training offers. Golden Bees and the Partner Websites are contractually bound and are jointly responsible for processing, while collecting user data and processing this data, during the recruitment campaign.
« Users »: refers to the natural persons who benefit from the service offered by Golden Bees, which means having a Golden Bees cookie on their computer.
How is the data processing carried out? The Golden Bees cookie placed on the User's computer makes it possible to collect data for the purpose of targeting in order to provide the User with adequate job or training ads that correspond to the user’s profile (center of interest, location,…). The purpose is therefore to display job or training offers instead of advertisements while the User is browsing the web, according to the User’s profile. To make sure that the job or training offers displayed are relevant, Golden Bees creates segmentations by User profile (location, job, etc.). Reports are also sent to Golden Bees customers so that they can keep track of the campaign carried out for them. This report only includes aggregated and fully anonymized data (number of clicks, etc.). The collected data helps improve the algorithm developed by Golden Bees. When Golden Bees is responsible for processing or co-responsible, the User may see job advertisements from various companies. When Golden Bees only works as a subcontractor, the User will only see employment or training offers from the Golden Bees partner, who is responsible for processing.
The User's consent to deposit the cookie and the processing that follows.
In order to obtain a valid consent, Golden Bees asks partner sites to comply with the information rules related to depositing the cookies, in accordance with the Data Protection Act dated January 6, 1978 as amended. The User's consent is materialized through a positive act such as the validation of an acceptance box for the registration of cookies, before the cookie has been deposited. The User can also, before depositing the cookie, and after having read the required information, refuse this deposit, mainly by changing the settings of the browser as explained below.
There are two possibilities for depositing a Golden Bees cookie:
By browsing one of the Partner Websites or the Golden Bees Site:
By clicking and viewing an advertising banner/job or training offer from one of Golden Bees' clients and for which a recruitment campaign is underway.
The User can, while this option is available, click on the button in a corner of the advertisement (YourAdChoices) in order to refuse the deposit of cookies.
Golden Bees does not collect any directly identifying data (such as name, e-mail address, etc.). Golden Bees does not know the identity of the User. Furthermore, Golden Bees does not collect any sensitive information (such as religion, political opinions, health conditions, etc.). The data collected is information which makes it possible to optimize the relevance of the job or training offers that are shown to the User. Golden Bees can send job or training advertisements which correspond as closely as possible to the interests of the User in terms of job search. More specifically, the data collected by Golden Bees are as follows:
Data relating to the Golden Bees cookie deposited and the allocation of an associated technical identifier, as well as information on the browser and the OS.
Job or training offers that the User has viewed on Partner Websites and/or the Golden Bees Website.
The pages visited on Partner Websites but also the dates, times, and frequency of viewing of the page. As such, the User is informed that once the cookie has been placed, information concerning them is collected on all Partner Websites each time they visit.
Location related data, with a maximum level of precision to the city name. The IP address is used in a truncated way, and the information concerning the location of the User isn’t precise. This geolocation makes it possible to offer job or training ads at the national, regional, local or city level corresponding to this location. Geolocation is updated every five (5) days in order to offer only relevant job or training ads within the location of the User.
Job or training advertisements viewed and clicked on through the various advertisements displayed to Users.
Golden Bees also collects data related to the User's browser and device’s operating system.
The data collected makes it possible to create segmentations by type of job sought and location of the research so that the offers suggested to the User correspond as much as possible to their profile. When the User uses the online application service suggested on the website www.wan2bee.fr, the User is informed that links are made between the data collected by the cookie, and the data from the forms completed on the website www.wan2bee.fr and the CV application sent online.
The collected data is shared with:
Golden Bees subcontractors (OVH website hosting company, as well as The Trade Desk, which is a Demand Side Platform and to whom the data is communicated after segmentation);
Intermediaries (Facebook and Instagram) after segmentation.
The Golden Bees cookie contains trackers from The Trade Desk and Facebook which are deposited at the same time as the Golden Bees cookie. The Trade Desk will then communicate the User's profile to partners making advertising space available on their own websites, through a real-time auction buying system (RTB - Real Time Biding). In all cases, the data is communicated to The Trade Desk, Facebook and Instagram in the form of a user segment, anonymly. The data will not be shared for purposes other than displaying job or training offers matching the User’s profile.
The user's consent, given upon visiting a Partner Website and through which the Golden Bees cookie is placed, is valid for a period of twelve (12) months. This means that the cookie will be automatically deleted from the User's computer after a period of twelve (12) months, afterwards the User must consent to the placement of cookies once again, to continue benefiting from the services offered by Golden. Bees. This time period is considered justified by Golden Bees, as it is the general time needed to look for a job. In the same way, the data collected by Golden Bees shall be deleted from all of its databases once this twelve (12) month period has gone by. Each time the User agrees to the deposit of the cookie, a twelve (12) month period renews. The User's location through the IP address is updated every five (5) days during this 12-month period, in order to provide the User with increasingly relevant offers depending on its location.
Golden Bees takes appropriate technical and organizational measures to prevent unauthorized access or disclosure of User data. This security has been implemented following state of the art practices. However, no online transmission or electronic storage is completely secure. Golden Bees is subject to an obligation of means. Golden Bees uses the services of the OVH hosting company, which guarantees the security of the servers and data backup. OVH's servers are located in France.
Golden Bees may be required to disclose data in response to legal requests from authorities, mainly to comply with the law or national security requirements. In the same way, the data may be shared with a third party in the event of a merger, acquisition, end or sale of all or part of its assets.
User data is only transferred to one third country: The United States: Trade Desk and Facebook are American companies. Trade Desk and Facebook are committed to securing data and keeping it confidential. Trade Desk and Facebook guarantee to apply the GDPR reglementation and are registered on the Privacy Shield list. Registration on this list forces the listed companies to ensure a level of protection which is considered to be adequate in terms of the level of protection required by European regulators.
Users have the right to withdraw their consent, at any time, concerning the cookies they have accepted.
To do this, Users have several means:
When they see a personalised advertising banner displayed, they can click on the blue button in the corner of the advertisement (YourAdChoices) to withdraw their consent from depositing cookies related to this advertisement.
Facebook being a different environment, it may take up to five weeks for the User to request it. If Users wishes to end the display of our ads on their Facebook account, they must change the settings by clicking here: Facebook Settings
Users can set their preferences in terms of cookies directly through their browser: each browser software has its own cookie management settings. The procedures are described in the browser help menu:
> Internet Explorer™ : here
> Safari™ : here
> Chrome™ : here
> Firefox™ : here
> Opera™ : here
Users can apply their right of access, allowing them to get confirmation that personal data concerning them is or isn’t processed by Golden Bees. When it is the case, they can access to such data but also the following information:
> the purposes of the processing.
> the categories of personal data concerned
> the recipients or categories of recipients to whom the personal data have been or shall be shared with, in particular recipients who are established in third countries or international organizations
> when possible, the planned retention period for personal data or, when this is not possible, the criteria used to determine this period.
> the existence of the right to request Golden Bees to rectify or erase personal data
> the right to file a complaint with a supervisory authority
> the existence of automated decision-making, including profiling, and, at least in such cases, useful information regarding the underlying logic, not to mention the importance and the expected consequences of this processing for the person concerned.
Users may ask Golden Bees to moderate the processing of their personal data, in particular when they dispute the precision of the data, for the period allowing the controller to ensure the accuracy of the data; if the processing is unlawful but the Users do not wish their data to be erased; if Golden Bees no longer requires the data but the Users need it for the establishment, exercise or defense of legal claims. Users may request Golden Bees to erase their personal data, in particular when they have withdrawn their consent for processing their data or when the data is no longer necessary for the purpose for which Golden Bees needed to process it. Users have the right to request the transfer of the data they have provided to Golden Bees. Golden Bees shall transfer to the Users all the provided data, in a structured, commonly computer-compatible format, or will transmit them, on request, directly to another data controller, designated by the Users. Each User has the right to exercise the following rights, with the Data Protection Officer (DPO) of Golden Bees:
through email at the following address: firstname.lastname@example.org;
or by mail accompanied by a signed identity document to the postal address DPO -GOLDEN BEES – 157 Boulevard Macdonald 75019 Paris, France.
Golden Bees shall strive to respond to the User's request within one month of receipt. However, Golden Bees does not possess identifying data directly, a period is therefore necessary to approach partners allowing it to de-anonymise the User's cookie ID. If the response provided by Golden Bees does not satisfy the User or if they wish to dispute it, they can make a complaint before ICO ( https://ico.org.uk/make-a-complaint/ )
Golden Bees has inserted “social network” buttons (LinkedIn, Golden Bees, Twitter) on its website https://www.goldenbees.io , and www.wan2bee.fr allowing to collect and share User's personal data to the mentioned social networks, whether the User is registered on social networks or not. This type of CV application button can allow the social network to follow the User's browsing on Golden Bees websites simply because their account linked to the social network was activated on their device (open session) while browsing the Golden Bees website. Golden Bees has no control over the process used by social networks to collect information related to User browsing on websites published by Golden Bees. Golden Bees invites the User to consult the privacy protection policies of these social networks in order to be aware of the purposes of use, mainly advertising, browsing information that they collect using these CV application buttons:
The User can refuse the deposit of cookies from these networks through means of the CMP provided for this purpose.