Privacy Policy

1. Introduction and Scope

The GDPR builds on the French “Informatique et Libertés” law of 1978, amended by the law of June 20, 2018, concerning the protection of personal data, establishing rules for the collection and use of data on French territory. It was designed around three objectives:

Strengthening individuals’ rights
Holding data controllers accountable
Ensuring regulatory credibility through enhanced cooperation between data protection authorities

This Privacy Policy describes how we collect and process personal data of internet users navigating on our Digital Platforms, as well as any person using or benefiting from our Services.

This policy applies to any processing of personal data carried out through our Websites and Mobile Applications, referred to as “Digital Platforms,” and therefore complements the General Terms of Use or the General Terms of Sale of our products and the Contribution Policy for publications, which defines the principles applied to the moderation of online contributions on Digital Platforms.

Its goal is to inform you about the processes for collecting and using your personal data, as well as the options and rights you have.

It may be modified at any time, particularly to comply with regulatory, case law, editorial, or technical developments. The latest version is updated on our website.

For any further questions, you can contact our Data Protection Officer, Serge Roukine, at the following address: dpo@freeland.com

In any case, we are committed to respecting the following principles:

Your personal data is used only for explicit, legitimate, and determined purposes related to the different Services offered;
Only the personal data necessary for these purposes are collected and processed.

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2.Identification of the Data Controller

The Digital Platforms are published by the company Asenium, Data Controller, registered with the Commercial Register under number 799 984 760 000, with its registered office located at 141 Avenue de Clichy, 75017 Paris.

This personal data protection policy informs you of the processing activities carried out by Asenium, hereinafter referred to as the “Publisher” or “We.”

Asenium is the data controller, within the meaning of the regulations regarding personal data, notably the General Data Protection Regulation (EU) 2016/679, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter “GDPR”).

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3.Purpose of the Processing

We collect data in the context of your use of our Digital Platforms, our contractual relationships, or services to which you have subscribed or to which you have consented.

When using our Digital Platforms or subscribing to one of our Services, certain personal data is required, notably to enable contractual execution. If you do not provide this personal data, we will not be able to provide the requested services or respond to your request.

Additionally, we may adapt the content of our Digital Platforms to your preferences or usage according to your interests. This will involve periodically asking you for your preferences.

We also collect data to contact you directly or indirectly, through partners, social media, or our subcontractors.

The purposes of this processing are as follows:

Connecting clients (who are looking for skills) with freelancers (who are looking for missions)
The legal basis for this processing is as follows: Consent.

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4.Categories of Data Collected

Personal data refers to information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or one or more elements specific to that person, such as their name, date of birth, or location data.

Your personal data, as a visitor or user of the Digital Platforms, may be collected in the following circumstances:

From the Publisher’s partners, with your prior consent and information;
During visits and navigation on the Website or Digital Platforms;
When creating a personal account on the Website or Digital Platforms;
When placing an order, registering for a training course, or subscribing to one or more Services;
During exchanges with the Publisher;
When subscribing to the newsletter;
During exchanges and/or contact between you and the Publisher.

While using the Digital Platforms, and in the context of this processing, the Publisher and its partners may collect and/or process the following data:

Email address
Postal address
Date of birth
Name and surname
Phone number
Facial photo
CV
Industry sector

In general, we will never ask you to provide sensitive data for our processing; we thank you for ensuring that you do not provide it voluntarily.

If you contribute to recruitment spaces, forums, blogs, or brand communities on social media, the content of the messages published and displayed will be visible to all users. It will not be used for other purposes by the Publisher.

Certain information and comments or content (e.g., photographs, profile description, working methods) that you provide voluntarily may, under your responsibility and at your initiative, reveal sensitive data such as your ethnicity, nationality, or religion. By providing this optional information, you assume full responsibility for the dissemination of this sensitive information.

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5.Recipients of the Data

Your personal data may be processed by the following parties:

Authorized members of the Publisher or Freeland group companies, as long as they are involved in processing your registration or providing the Services;
Service providers authorized by the Publisher;
Suppliers of IT systems and support services for the Publisher’s business activity (e.g., IT service providers, hosting and maintenance providers, secure payment solution providers).

Your personal data will not be disclosed to third parties without your consent.

The third parties with whom the Publisher shares your personal data are limited (by law and contract) in their ability to use your personal data for the specific purposes identified by the Publisher.

In any case, the Publisher makes its best efforts to ensure that the recipients of your personal data are bound by confidentiality and security obligations in accordance with this Privacy Policy, applicable laws, and particularly the GDPR and the French “Informatique et Libertés” Law in its latest version.

Finally, you are informed that the Publisher may share your personal data in order to comply with its legal obligations (e.g., transmitting data to administrations).

Here are the subcontractors currently involved in our processing on the Digital Platforms:

Microsoft Sharepoint
Salesforce

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6.Data Transfer Outside the European Union

The Publisher may use a file storage and sharing service and a rights management provider whose servers or systems may be located outside the European Union.

These transfers are carried out in exchange for appropriate security and confidentiality guarantees in compliance with the applicable regulations (particularly standard contractual clauses, in accordance with models approved by the European Commission).

Information from cookies and other trackers may also be transferred outside the European Union for hosting and processing purposes, particularly for advertising or audience measurement purposes.

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7.Data Retention Period

We ensure that your data is retained only for the period necessary to achieve the purposes for which it was collected, including for legal and accounting requirements.

This period may vary depending on the nature of the data and the purposes of their processing, while respecting the principles of minimization and effectiveness.

Data retention periods are regularly reassessed to ensure their relevance and compliance with legal provisions and/or the latest recommendations from the CNIL.

In the context of processing, your data may be retained for up to 5 years.

In line with our commitment to protecting your personal data, we ensure the deletion or anonymization of your personal data as soon as they are no longer necessary for the purposes for which they were collected.

Furthermore, we fully respect your right to control your data. Thus, upon your request, we will delete your personal information from our systems, except in cases of legitimate interests or legal obligations.

This practice is an essential part of our privacy policy, aimed at giving you full control and peace of mind regarding the management of your personal data.

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8.Data Security

We are committed to taking all necessary precautions, organizational measures, and technical safeguards to preserve the security, integrity, and confidentiality of the data we process, notably preventing them from being altered, modified, or deleted, or from being accessed by unauthorized third parties.

These measures are tailored to the sensitivity level of the personal data processed and the risk level associated with their processing or implementation.

If a security breach occurs regarding your personal data, the Publisher will inform you within the time frame and in the manner specified by applicable legal and regulatory provisions.

However, we cannot guarantee the complete elimination of the risk of data misuse. It is essential that you maintain the confidentiality of your credentials to prevent unauthorized use of your account.

Here are the non-exhaustive measures we commit to taking:

MFA (Multi-factor Authentication)
Password-secured access
Encrypted connection
Data encryption on hard drives
Subcontracting agreements
Staff management
Data minimization
Secure IT channels

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9.Procedures to Exercise Your Rights

As a data subject in the processing of personal data, you have several rights.

These rights are not absolute and are subject to certain conditions, in accordance with the GDPR and other applicable laws, particularly the French “Informatique et Libertés” Law No. 78-17 of January 6, 1978.

For more information on your rights:

Right of Access: You have access to the personal information we hold and can request communication of it.
Right to Rectification: You can request the correction of your information if it is inaccurate or incomplete and ask us to correct any errors in the information we hold.
Right to Erasure: You can request the deletion or removal of information we hold about you. Deletion is possible for data used for marketing purposes, data processed unlawfully, and generally, all data that is not necessary for the contract with us or compliance with legal obligations.
Right to Withdraw Consent: You have the option to withdraw your consent at any time when the Publisher processes your personal data based on consent. However, you are informed that the withdrawal does not affect the lawfulness of the processing carried out before the exercise of this right.
Right to Data Portability: You have the right to receive the data you have provided to us, in a structured, commonly used, and machine-readable format, and/or, where technically feasible, request the transfer of the data to a third party.
Right to Object: You have the right to object to certain processing activities. This right applies if it concerns processing that does not conflict with the execution of a contract or a legal obligation.
Right to Limitation: You can request a temporary freeze of the use of your data while a rectification, objection, or deletion request is under review. During this period, we will no longer use this data but must retain it.
Right to Organize the Fate of Your Data After Death: You can set directives regarding the fate of your personal data after your death.

To learn more about your rights, you can visit the CNIL website: https://www.cnil.fr/fr/mes-demarches/les-droits-pour-maitriser-vos-donnees-personnelles.

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How to Exercise Your Rights?

If you wish to exercise any of your rights, you can contact us at the following email address: dpo@freeland.com

When requesting to exercise your rights, an identity document may be required if necessary, particularly to ensure the security of the processing being requested.

A response will be provided to you, depending on the complexity of your request, within the time frames prescribed by Article 12.3 of the GDPR.

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Right to File a Complaint with the CNIL

If you are not satisfied with the Publisher’s response to your complaint or if you believe that the processing of your personal data does not comply with applicable data protection regulations, you can file a complaint with the competent data protection authority.

The French Data Protection Authority (CNIL) is the authority responsible for data protection in France.

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10.Use of Cookies

What is a cookie or tracker?

A cookie, or more generally a tracker (hereinafter referred to as “Cookie(s)”), is a file or identifier that can be stored on your device (computer, tablet, or smartphone) and/or when accessing a service via a web browser, via the Digital Platforms.

It allows the concerned device to be recognized each time it accesses digital content containing Cookies from the same issuer and, depending on the Cookie, collects additional information on your behavior within the services.

What is the role of cookies?

The cookies issued are notably used to secure your navigation and to carry out audience measurements in order to optimize the content offered on the Digital Platforms.

Thus, we use several types of cookies:

Cookies strictly necessary for navigation on the Digital Platform;
Preference cookies;
Cookies that help establish traffic statistics.

These cookies also allow us to provide our services and better understand your needs.

Who uses cookies?

Cookies may be placed by various recipients, including the Publisher, its technical service providers, partners, or third parties. Only the recipient for whom the Cookie is placed can read it; they are responsible for its use, the data it collects through it, and the recipients to whom they transmit it.

How can I object to them?

Depending on their purpose and usage, Cookies are strictly categorized by the CNIL. “Strictly necessary service cookies” or “cookies exempt from consent” may be placed on your device from your first visit. Other types of cookies require prior consent for placement or reading.

How do I give my consent?

You can express your choice to accept or reject Cookies through the window that appears during your first visit. The consent you provide is valid for a maximum of six (6) months from the first placement in your device.

If you do not consent to the placement of Cookies or if you delete them, your navigation and experience on the Digital Platforms may be degraded, and your browsing history may not be taken into account.

You can also configure your browser to ask you for consent each time a Cookie is placed. We encourage you to consult your browser’s instructions.

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11.Revisions

Our activity is constantly evolving, and this document changes accordingly. We invite you to regularly visit our website to stay updated on the latest changes. However, please note that we will never make substantial changes to our policies and practices in a way that would reduce the protection of customer information collected in the past, without the consent of the affected individuals.