Privacy Policy




Preamble

Cognitys is particularly committed to respecting privacy and protecting personal data.

Cognitys, which collects or uses personal data for the needs of its activity, acts as Data Controller (within the meaning of the regulations in force) and undertakes to implement adequate measures to ensure the protection, confidentiality and security of personal data of any person from whom data is collected, in compliance with legal requirements, in particular European Regulation 2016/679 on the protection of personal data ("GDPR"), applicable national laws in the European Union as well as the standards issued by the CNIL.

Scope of application

This Data Protection Policy applies to all personal data processing, implemented by Cognitys, as Data Controller, within the European Union, relating, in particular, to customers, prospects, partners, recruitment candidates, users of our products and services, suppliers, service providers, internet users.

Definitions

Personal data

Any data allowing direct or indirect identification of a natural person.

Data processing

Operations performed on personal data, including collection, recording, use, transmission or communication.

Data Controller

Legal entity responsible for determining the purposes of processing and the means implemented.

Data Processor

Legal entity that processes personal data on behalf of the Data Controller.

Collected data

Cognitys ensures to collect and process personal data that is relevant, adequate, not excessive and strictly necessary to achieve the purposes that have been previously determined.

Cognitys takes all useful measures to ensure that your data is accurate, complete and, if necessary, updated.

Cognitys undertakes to obtain the consent of the data subjects whenever this is required and to inform them about the processing of their data.

Personal data concerning you that you are likely to communicate to us is processed, particularly during the following operations:

  • When you browse our sites

  • When you apply for a job at Cognitys

  • When you wish to contact us for any information request.

In this context, Cognitys may notably be required to collect and process the following personal data:

  • Your identity: first name, last name

  • Your contact details: email, phone number

  • Your application information: CV, cover letter

  • Your technical and browsing information on our sites

  • Any other information that you provide to us directly and voluntarily in the context of using our sites, services and contracts that we may have concluded with you.

The mandatory nature of the information you must provide is generally indicated at the time of data collection on the corresponding forms by an asterisk. Any failure to respond may result in the inability to take your request into account.

You commit to ensuring that the personal data concerning you communicated to Cognitys is up-to-date, accurate, complete and unambiguous.

Collection purposes

Personal data is collected fairly and lawfully for specific objectives (purposes).

The processing implemented by Cognitys responds to explicit, legitimate and determined purposes, which are brought to the attention of the data subjects.

Your data may notably be processed for the following purposes:

  • To manage contractual relationships with our clients, service providers and partners (contract management, orders, deliveries, invoices, public relations, etc.)

In this context, the legal basis for processing is the execution of the contract between Cognitys and you.

  • To send you commercial information about us

In this context, the processing is based on Cognitys' legitimate interest, more specifically its economic interest in communicating personalized offers to you, better understanding your needs and offering you adapted services.

  • To analyze your browsing on our sites and improve their use

In this context, the legal basis for processing is Cognitys' legitimate interest, more specifically its economic interest in permanently improving its sites and services and understanding your needs to meet your expectations.

  • To respond to your questions / information requests

In this context, the legal basis for processing is Cognitys' legitimate interest, more specifically its economic interest in communicating clearly with you and understanding your needs and expectations.

  • To follow up on your application submitted online on our sites.

In this context, the legal basis for processing is Cognitys' legitimate interest, more specifically its interest in responding to your application requests and finding profiles adapted to positions available within Cognitys.

  • To allow you to subscribe

In this context, the legal basis for processing is the execution of the contract between Cognitys and you.

Recipients of collected data

In accordance with European and national regulations in force on the protection of personal data, Cognitys undertakes to inform you about the processing of your personal data.

Thus, Cognitys informs you, clearly, during each collection of your data, notably:

  • the identity of the data controller (this is the legal entity of Cognitys responsible for processing your data)

  • the purpose for which your data is collected

  • the optional or mandatory nature of responses

  • the recipients of the data

  • the existence and methods of exercising the rights of inquiry, access, rectification and opposition regarding all data concerning you.

Data confidentiality and security

Cognitys ensures the security and confidentiality of personal data by implementing data protection through the use of physical, logical and organizational security means.

Subsidiaries or service providers to whom Cognitys may communicate your personal data may be domiciled abroad and notably outside the European Union. The data subjects are precisely informed of this, and specific measures are taken to frame these transfers. Indeed, Cognitys will then require that they take, in accordance with the regulations in force, all organizational and technical measures allowing to ensure an adequate level of protection of personal data, notably through the implementation of Standard Contractual Clauses (SCC) approved by the European Commission.

Data retention

Cognitys retains personal data as long as necessary for the achievement of the purposes for which they were collected and processed. However, Cognitys may retain them longer to comply with legal obligations and notably applicable limitation periods.

In order to define an adequate data retention period, Cognitys uses in particular the following criteria:

  • Data relating to your subscription is retained for the entire duration of the subscription then in compliance with applicable limitation periods

  • Data relating to the management of commercial relationships with our clients, service providers and partners is retained for the entire duration of the contractual relationship then in compliance with applicable limitation periods

  • When you have consented to receive commercial prospecting, Cognitys retains your personal data until you express your wish to no longer receive communications, otherwise in accordance with a duration defined by applicable legislation

  • When your data is collected in the context of requests/questions relating to IT services and applications, Cognitys retains this data for a period of 3 years from the last contact

  • Candidate files may be retained for up to 2 years from the last contact with said candidates, except with their consent for a longer retention period; in this case, the data is archived in compliance with applicable limitation periods.

Rights of data subjects

In accordance with applicable legislation on the protection of personal data, all necessary means to guarantee the effectiveness of individuals' rights over their personal data are implemented:

  • Clear and complete information on data processing implemented

  • Facilitated access to data: any person has rights over the data concerning them, which they can exercise at any time and free of charge.

Thus, individuals can access all their personal data, and in certain cases have it rectified (inaccurate, incomplete data), deleted, or request to temporarily limit its use. Individuals also have a right to portability regarding data they have personally provided and insofar as this data has been provided on the basis of the explicit consent of the person or the execution of a contract.

These requests should be addressed to the Data Protection Officer (DPO) by email at yann@cognitys.com or by postal mail to the following address: COGNITYS – 14 rue du Vieux Faubourg 59800 Lille, attaching a copy of an identity document to your request.

Modification of the personal data protection policy

COGNITYS may update this Data Protection Policy at any time to take into account legislative and regulatory developments and any change in the internal organization of COGNITYS, or in the offers and services provided.