Privacy

Last update:

April 16, 2022

The terms defined with a capital letter shall have the same meaning as those defined in the Terms of Use.

The protection of your personal data is of crucial importance to Us. We take great care of your privacy. The purpose of this Privacy Policy is thus to specify how your personal information (hereinafter “Personal Data”) will be processed through our Platform. 

Personal Data shall be construed as defined in the European General Data Protection Regulation (hereinafter the “GDPR”). As a consequence, Personal Data is defined as any information relating to a specific individual that can be identified, directly or indirectly, such as the surnames, forenames, email and postal addresses of specific individual, his image on a photograph or video, an IP address, a location data, etc.

Our Privacy Policy details the Personal Data we collect and process through our Platform, the reasons for processing your Personal Data, how we use them and the features offered to enable you to access and update your Personal Data.

By checking the box “I have read and accept the Platform Terms of Use as well as I have read the Privacy Policy”, you confirm that you are aware of all the personal data processing carried out as a result of your use of the Services.

1. Categories of Personal Data processed 

a) Personal Data that you provide to the Company

We collect Personal Data from Users who wish to know more about our activities (via the contact form), receive our news, assess their skills , answer to an online test or assessment, apply for job offers posted on the Platform.

Access to and use of the Platform involves the collection and processing of your Personal Data, including, but not limited to, your first and last name, gender, telephone number, e-mail and postal addresses, IP address, resume, photograph, answers to the online assessments and tests and any other career related information relevant for the recruiting process. 

The above-mentioned information can be collected in several ways. As described in Article 3 of the Terms of Use, the User can either register directly on the Platform or be invited to do so by the Employer.

b) Cookies

A cookie refers to a text file that may be stored in a dedicated area on your device’s hard drive (computer, tablet, or smartphone) when you access a service that is accessible online. A cookie allows its issuer to identify the device in which it is stored, during the validity or registration of the cookie. When you visit the Platform, information relating to your browsing may be stored in cookies files installed on your device, subject to the choices you have made regarding cookies, which you can change at any time. These cookies allow the User to navigate in a personalized way and are also used for analytical purposes (audience measurement).

You will be informed of the existence of cookies and their purpose(s) when you connect to the Platform, by the presence of an information banner placed at the bottom or top of the home page.

You must give your prior consent to the placement and reading of cookies on your device by clicking on “I accept”. However, you can configure your browser to refuse cookies or customize cookie settings by clicking on a “Learn More” link. If you accept the use of cookies, your agreement will be valid for 13 months. It will then be necessary to renew your agreement at the end of this period.

In the event that you refuse cookies, or delete those stored on them, we inform you that you will no longer be able to benefit from a certain number of features that are nevertheless necessary to navigate in certain areas of our Platform. If necessary, we decline all responsibility for the consequences related to the degraded functioning of our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and that you have refused or deleted.

Finally, it is important to distinguish between the cookies we issue on our Platform and those issued by third parties. As such, please be aware that cookies may be placed from time to time on certain pages of Platform by third parties (advertisers or others).

2. Purposes of processing

Personal Data is collected and processed for defined and precise purposes, such as:

(i) Provide and manage our services, in particular offering of online assessments and tests; carry out and administer tests;

(ii) Manage the processing of your applications for prospective Employers;

(iii) Allow you to create and use your candidate space on the Platform;

(iv) Enable employers to create and monitor a job opening on the Platform and assist them in the monitoring and evaluation of the resulting applications;

(v) Communicate with Users and improve the quality of our services;

(vi) Combating online fraud;

(vii) Resolve any potential disputes or problems in connection with the use of our services.

The table hereunder summarizes the legal basis and the purposes of the data collected when You registered on the Platform:

Purpose: Account creation and management 

  • Data: Required User’s information (such as User’s identity and contact information), IP Address 
  • Legal basis: Performance of a contract (GDPR art.6.1.b)
  • Controller and potential Destinary: Maki is acting as Data Controller 
  • Data retention: Duration of the contractual relationship (as long as the User has an account) in active base - 3 years from the end of the contractual relationship in intermediate storage

Purpose: Performance of Maki’s Services towards the User (i.e. Assessments’ administration and analysis ; Processing of applications and User’s Profile for prospective Employers’ and  for recommendation of job offers and improvement area)

  • Data: User’s identity, answers to Assessments, Resume information, Cover letters, References, social media link
  • Legal basis: Performance of a contract (GDPR art. 6.1.b)
  • Controller and potential Destinary: Maki is acting as the Controller. In case of Data transfer to an Employer for the perk of Maki’s Services Performance, the Employer is acting as an independent Data Controller
  • Data retention: Duration of the recruitment process in active base or duration of the contractual relationship (as long as the User has an account) in intermediate storage

Purpose: To increase fairness and unbias in the handling of assessments results (NB: this data processing is optionnal)

  • Data: Gender, ethnicity, IP address, career related information, test answers, preferences
  • Legal basis: Explicit consent of the User (GDPR art.9.2.a)
  • Controller and potential Destinary: Maki is acting as the Controller
  • Data retention: Duration of the recruitment process on an active base or until consent is withdrawn

Purpose: Combating online fraud

  • Data: Content published by the User on the Platform, IP address
  • Legal basis: Legitimate interest of Maki in ensuring the security of its Platform (GDPR art.6.1.f)
  • Controller and potential Destinary: Maki is acting as the Controller
  • Data retention: Time required for verification operations

Purpose: Communication with the User and Dispute Resolution

  • Data: Online messaging, email, phone calls
  • Legal basis: Legitimate interest of Maki in handling complaints from its Users (GDPR art.6.1.f)
  • Controller and potential Destinary: Maki is acting as the Controller
  • Data retention: Duration necessary for the management of the conflict in active base, 3 years (statute of limitations) from the date of the dispute in intermediate storage

Purpose: To verify the identity of the User during the Assessments

  • Data: Snapshots taken at regular intervals via the User's camera during the Assessments
  • Legal basis: Legitimate interest of Maki in preventing fraud during the Assessments (GDPR art.6.1.f)
  • Controller and potential Destinary: Maki is acting as the Controller. Upon access to such Data by the Employer, the Employer acts as an independent Data Controller
  • Data retention: Duration necessary to verify the identity of the candidate or at the latest from the end of the recruitment process in active base

Any use of Personal Data for purposes other than those set out above in our data protection policy will require your express prior consent.

We undertake to keep your Personal Data only for as long as strictly necessary for the processing operation(s) declared for the purposes mentioned above, meaning for the duration of the use of our Services, and in any event within the limits imposed by law. 

Your Personal Data is deleted at the end of the different periods mentioned in the table below.

3. How did Maki get your email address

There are three possibilities. 

  • Either You directly registered on our Platform;
  • Either an Employer sent you a link to register to our Platform;
  • Either You have provided your email to an Employer which asked us – following its legitimate interest – to send you an invitation to our Platform to complete an Assessment. 

4. Communication to Third Parties

Your information and Personal Data may, if necessary, be transmitted only to appropriate third party subcontractors involved in the provision of our services (technical and hosting service providers, customer follow-up and satisfaction surveys, security incident management or fraudulent activity, etc.).

For the performance of our services, we share information with prospective Employers for which you have fulfilled the online assessment/test following an invitation to do so or spontaneously as a Self-registered Use. In that regard, we share results, analytics, and feedback of those online assessments and tests (including any snapshots taken during the assessments). Maki undertakes not to share any of the test results to third parties others than prospective Employers.  

The Company undertakes to communicate your information and Personal Data only to authorized and trusted service providers, who process them on our behalf, according to our instructions and in accordance with this Privacy Policy and in compliance with any other appropriate security and confidentiality measures.

In case of merger, acquisition, bankruptcy, dissolution, liquidation, your Personal Data will be processed by the buyer or transferee in respect of this Privacy Policy.

In addition, your information and Personal Data may be disclosed to a third party if the Company is required to do so by law, regulation, or court order, or if such disclosure is necessary for the purposes of an investigation, injunction, or judicial proceeding.

5. Security

We implement all necessary organizational and technical security measures to protect your Personal Data from unauthorized access, disclosure, modification, damage, or destruction of the data we hold.

To this end, the Company and its technical and hosting service providers implement appropriate measures to ensure the integrity, confidentiality and security of your Personal Data (in particular by complying with ISO standards and the requirements of applicable personal data protection regulations).As such, we have chosen to host your data on servers located within the European Union, by Google Cloud Platform.

6. Users’ Rights

You have a right of access (e.g. to check the data we keep about you), a right of rectification (to update or correct your data), a right to delete (e.g. to close your personal account) and a right to transfer (right to portability) your Personal Data, as well as a right to limit and to object to the collection and processing of all or part of them for commercial prospecting purposes, including profiling insofar as it is related to such prospecting; a right to lodge a complaint before the competent data protection authority.

You have a right to object on grounds relating to your particular situation to any processing based on Maki's legitimate interest, subject to Maki's legitimate and compelling reasons, and to request the restriction of processing under the conditions set out in the GDPR. 

You also have a right to withdraw your consent at any time where the processing is based on consent without prejudicing its lawfulness prior to withdrawal. 

In addition, it should be noted that these rights allow you to change your notification preferences at any time, by accepting or refusing to allow your Personal Data to be used in connection with our marketing or promotional activities.

You can exercise these rights by e-mail to: privacy@makipeople.com

If you exercise these rights, we will endeavor to respond to your requests as soon as possible and at the latest within one month.