Privacy policy

Welcome to the website www.gladstone-search.com ("Site"), property of GLADSTONE, a simplified joint stock company with a single shareholder, registered with the Paris Trade and Companies Register under number 890 976 657, whose registered office is located at 16 Cours Albert 1^er 75008 Paris, contact: +33 1 83 75 64 01 and contact@gladstone-search.com ("GLADSTONE").

GLADSTONE is a company providing placement services, in the sense of article L5321-1 et seq. of the French Labour Code, aiming to match job offers and requests.

To simplify the reading of this document, "we" or "our" will be used to refer to GLADSTONE. Similarly, 'you' or 'your' will be used to refer to you individually, depending on the context, as:

• Person in contact with our consultants for the purpose of recruitment ("Applicant");
• Prospects or clients who are natural persons or professional contacts of law firms or companies wishing to benefit from a placement service ("Client"); or,
• Supplier - a natural person or our supplier's professional contact ("Supplier"). Together, we referred as the parties ("Parties").

This Privacy Policy details the terms of collection, use and sharing of personal data that you provide with us or we collected about you in the framework of our placement services or when you contract with us ("Privacy Policy").

We commit ourselves to respect your privacy and protecting your personal data, according to the enforceable regulations ("Regulation"), and in particular the General Regulation (EU) 2016/679 of 27 April 2016 on Data Protection ("GDPR") and the French amended "Loi Informatique et libertés" n°78- 17.

The information provided with our consultants are only intended for our authorized staff for administrative and commercial purposes, to enable us to provide you with recruitment or placement services and to contact us.

This information may constitute personal data as defined in the GDPR ("Data"), i.e., information relating to an identified or identifiable natural person ("Data Subject").

As recruitment service provider on third parties' behalf, we determine why and how your Data are processed to provide our services or for our commercial or administrative management. We are therefore a data controller within the meaning of the Regulation.

As an Applicant, when you are interested in a job opportunity, your Data may be transmitted to other recruiters or to our Clients who also act as data controllers. Consequently, the processing carried out by these recruiters or the Clients are subject to their own privacy policy, that you may consult.

The nine (9) sections hereafter will help you understand how we process your Data.

Applicants - We ask you to provide us with certain personal data in order to respond to your request and/or forward your application. The Data we collect and process may include:

• Identification data and personal details: in particular name and surname, title, contact details (postal address, phone number and personal and/or professional e-mail address);
• Recruitment data: information provided during the application process, communications or interviews we may have. We notably collected information related on your resume including, if applicable, photographs or your date of birth, education and work experience, recommendations or references, documents proving your right to work; qualifications and training; type(s) of employment agreement(s) sought; salary expectations.

Clients - The Data we collect and process may include:

• Identification data and professional details: in particular name and surname, title, current position, contact details (telephone number and e-mail address);
• Recruitment data: information provided in the context of placement services and during any communications we may have (expectations about the Applicant, general information about the Client's team involved in the placement services).

Suppliers - The Data we collect and process may include: nous collectons et traitons peuvent inclure:

• Identification data and professional details: in particular name and surname, title, current position, contact details (telephone number and e-mail address);
• Economic and financial data: data relating to transactions (invoices) and bank details (e.g. bank statement).

No Data is collected during your browsing on our website.

Applicants - We process your Data in order to:

• Provide recruitment and placement services, and notably to provide you with suitable job offers or missions and managing the application process for jobs and assignments (phone calls, interviews, reports, etc.);
• Follow up and manage our business relationships, such as informing you about news or professional opportunities, or to evaluate your satisfaction to improve our services;
• Build up a Candidates' databases to contact you when an offer may attract you.

The collection of Data is duly limited to the necessary information to fulfil the purposes described above. Such processing is based on:

• Our legitimate interest in managing our employment services, improving our work's organization and conducting our business development;
• Where applicable, your prior consent, which will be obtained in accordance with the Regulation.

Clients - We process your Data in order to:

• Ensure the conclusion and performance of the placement agreement, i.e., management of the pre-contractual relationship and contracting, establishment of the accounts and invoicing, recovery of unpaid;
• Provide placement services, i.e defining your needs, proposing candidates and managing the process and following-up of applications for jobs and assignments (telephone contacts, interviews, reports, etc.);
• Follow up and manage our business relationship, i.e updating you about us or about certain subjects related to your search for candidates, your branch of activity or your profession, or to evaluate your satisfaction in order to improve our services.

The collection of Data is limited to the information necessary to fulfil the purposes described above. Such processing is based on :

• The performance of the placement services agreement, if any, between us and you;
• Our obligation to comply with our legal or regulatory obligations;
• Our legitimate interest in managing our business, improving the work's organization and conducting our business development.

Supplier - We process your Data in order to:

• Ensure the conclusion and performance of our agreement, i.e. management of the pre- contractual relationship and contracting, administrative management of our suppliers, establishment of the accounts.

The collection of Data is limited to the information necessary to fulfil the purposes described above. Such processing is based on:

• The performance of the agreement between us;
• Our obligation to comply with our legal or regulatory obligations, if any.

In order to achieve the purposes described in the section 2, we may communicate your Data to the following recipients, in compliance with the Regulation:

• Our subcontractors, suppliers and partners: we may use other companies for certain services (IT support, hosting company, software publishers, accountants). Our relationship with such companies is governed by a subcontracting agreement and they are therefore subject to contractual and legal obligations in order to preserve your privacy and the confidentiality of your Data.
• To public entities, judicial or administrative authorities: if applicable, we may be required to transmit your Data to such entities in order to comply with our legal and regulatory obligations.
• For Applicants - If you are interested in a position, we provide your data to our Clients or other recruiters in order to provide service's placement, that's includes your resume and other information to enable the Client or recruiter to assess your application. Our relationship with our Clients is governed by a placement agreement which is subject to legal contractual obligations to safeguard your privacy and the confidentiality of your Data.

You are advised that the general principles of data retention are:

• For Applicants - -Your Data will be retained for a maximum of 2 years from the last contact;
• For Clients or Suppliers - Your Data will be retained for a maximum of three (3) years from the business relationship's ending.

Some of the specific Data processing operations that we carry out may have different retention periods (e.g., accounting). If you wish to obtain more details on the specific retention rules for a given processing operation, please contact us at the email address below (i.e section 7).

More generally, your Data are kept for the time necessary to achieve the purposes for which it were collected as set out above.

To determine the appropriate retention period for your Data, we consider the amount, nature and sensitivity of the Data, the potential risk arising from unauthorized use or disclosure of the Data, the purposes for which we process your Data and our legal obligations.

After the retention period, your Data will be deleted or archived in accordance with the Regulation.

We implement appropriate technical and organizational security measures, including:

• Restricted access to the records (digital and paper) to the authorized staff to perform their professional duties;
• Confidentiality and security obligations imposed on staff members authorized to process your Data as well as on our Clients, subcontractors, Suppliers and partners;
• Securing workstations and tools : automatic locking of workstations, password protection etc.;
• Technical security measures: traceability of accesses and incidents, regular backup of Data, installation of anti-virus or firewall software.

The measures are proportionate to the risks represented by the processing carried out and to the nature of the Data to be protected.

We may disclose your information for the purposes set out above to Suppliers, subcontractors and partners who perform services on our behalf; some of these entities may be located outside the European Union and outside of countries recognized by the European Union as having laws which ensure adequate protection of Data. In particular, your Data may be hosted in the United States of America and the United Kingdom.

In accordance with the Regulation, we implemented the necessary measures to ensure that the Data transferred are protected in terms of security, integrity and confidentiality. Any transfers of Data are carried out in accordance with the Regulation, and are governed in particular by the standard contractual clauses established by the European Commission.

As a Data Subject, you have the following rights:

• Right of access: You may request access to the Data and certain information we detained, how it is processed. In some cases, and upon your request, we may provide you with an electronic copy of your Data;
• Right to rectification: You may request to rectify any inaccurate or incomplete Data about you. In that circumstance, you must demonstrate how such information is/are incorrect;
• Right to restrict processing: in certain circumstances, a restriction of processing is possible. You may request it at any time and we will decide what action to take;
• Right to object: you may object to any processing based on our legitimate interests, on grounds relating to your particular situation;
• Right to erasure: in certain circumstances, you may request the deletion of your Data;
• Right to portability: In certain circumstances, you may request that we provide you with your Data in a commonly used machine-readable format. If technically possible, you may also request that we transfer your Data to another data controller;
• Right to withdraw your consent: if the processing of your Data is based on your consent, you may withdraw it at any time;
• The right to formulate directives: concerning the conservation, deletion and communication of your Data after your death.

You can exercise these rights by contacting our Data Protection Officer at contact@gladstone-search.com or by sending a letter to the following address: 16 cours Albert 1^er, 75008 Paris.

You also may lodge a complaint about the processing of your personal Data with the competent data protection authority: the Commission nationale de l'informatique et des libertés (CNIL).

As Applicant, you guarantee the truthfulness and reality of all the information you provide.

You undertake to provide us with sincere, real and fair information about yourself and in particular: your professional background, the qualifications you obtained, the duration of the positions you hold and their nature. These Data may be subject to verification. Any insincere or false information constitutes an unfair manoeuvre towards us and our Clients.

We reserve the right to unilaterally change the Privacy Policy at any time. You agree to review it regularly to be aware of any changes.