engage|ats – data protection policy
engage|ats is a software product provided by Havas People. This website and the product engage|ats is legally owned by Havas People.
1. Havas People is committed to protect your personal data
Havas People is committed to protect your personal data and your privacy. We encourage you to carefully read this Data Protection Policy.
This Data Protection Policy informs you of our data protection and privacy practices and the way your personal data are collected online and how that data is used by Havas People. This policy will be readily available on our home page and at the bottom of each page of this Website.
Havas People strongly supports the fundamental rights to privacy and Data Protection as well as compliance with national and international privacy laws.
Havas People commits to maintain confidential any personal data and to strictly limit any disclosure in accordance with applicable local laws and regulations.
This policy is applicable to all Havas People Group entities for the collection, processing, use, transmission, transfer and storage of personal data unless national legislation imposes to some of them specific data protection rules.
2. How do we process your personal data?
Havas People respects the rights of each individual or candidate to have his privacy and personal data protected. Havas People will observe the following principles when processing your personal data:
- Processing your personal data fairly, lawfully and in a transparent manner;
- Collecting your personal data for specified, legitimate purposes and not processing further in ways incompatible with those purposes;
- Collecting your personal data which is relevant to and not excessive for the purposes for which it is collected and used. We may render personal data anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
- Maintaining your personal data accurate, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete data that is inaccurate or incomplete;
- Keeping your personal data only as long as it is necessary for the purposes for which it was collected and processed;
- Processing your personal data in accordance with the individual’s legal rights;
- Taking appropriate technical and organizational security measures to keep your data safe and prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal data;
- Processing your personal data only if it is lawful in accordance with a legal basis including if you have unambiguously given your consent to such process.
3. Why we collect your personal data?
Havas People may collect personal data from you to complete following operations:
- profile creation;
- information requests;
- subscriptions to newsletters and sending those letters;
- job applications.
4. What data is collected?
Havas People collects and uses your personal data with appropriate notice and consent when it is required, and after having informed you in a proper way.
Personal data means any information relating to an identified or identifiable natural person (‘Data subject’). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
This Policy does not cover personal data rendered anonymous. Personal data is rendered anonymous if individual persons are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or work. If personal data rendered anonymous become no longer anonymous (i.e., individual persons are again identifiable), or if pseudonyms are used and allow identification of individual persons, then this Policy will again apply.
It is always up to you whether to pass personal data on us, although if you elect not to do so, we reserve the right not to register you as a user or not to provide you with any services.
The types of personal data we collect from you may include:
- your name, surname, company, email address, phone number;
- educational and employment background, and job interest data (for candidates);
- your Havas People user ID and password (where applicable);
- IP address.
5. How we use your data?
We gather and use personal data for the following purposes:
Browsing and Searching:
Newsletters and promotional e-mails:
We collect personal data when you ask to receive newsletters. We use those data to provide you the information you request.
If you contact us, we keep a record of your correspondence or comments, including personal data, in a file specific to you. We use these data to help us provide you better service in the event you contact us again.
We process personal information of candidates to manage the recruitment process.
We’ll keep your personal data for the duration needed to complete the purpose for which they were collected.
6. What we do with your Personal data?
If you do disclose personal data to us, directly or not, we will:
- not sell or rent it to a third party without your permission
- take commercially reasonable precautions to protect the personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction;
- not process the personal data except:
- in the aggregate with other data in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
- as required by law, for example, in response to a subpoena or search warrant;
- to outside auditors who have agreed to keep the data confidential;
- as necessary to protect the rights, safety, or property of Havas People, its users, or others; this may include (for example) exchanging information with other organizations or public authorities for identification, fraud protection and/or risk reduction.
7. Your consent
By providing us with your personal data and/or using the websites and/or entering into a contract with us, you consent to our processing your personal data for the purposes described in article 3.
You also consent to our transferring your personal data to countries or jurisdictions which do not provide the same level of data protection as the EU, if necessary for the above purposes. If we do make such a transfer, we will provide appropriate safeguards to ensure that your personal data is duly protected. If you provide us with personal data about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data including sensitive personal data and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed. We do not process personal data of minors under 16 without the express consent of their parents or legal representatives.
8. Links to third-party websites
We may also provide social media links that enable you to share data with your social networks and to interact with Havas People on various social media sites. Your use of these links may result in the collection or sharing of data about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the data that may be collected, used, and shared by those sites.
If you post, comment, indicate interest, or share personal data, including photographs, to any public forum, social network, blog, or other such forum, please be aware that any personal data you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Havas People have control over. Havas People is not responsible for the personal data you choose to submit in these forums.
9. Your Data protection rights
- Right of access
As data subjects you may inquire as to the nature of the personal data Havas People owned about you. You will be provided access to your personal data regardless of the location of the data processing and storage. If you would like to make a DSAR please complete your details in our Privacy Centre
- Right to rectification
If your personal data is inaccurate or incomplete, you may request that the data be amended.
- Right to object of processing
You have the right to object at any time to the processing of your personal by Havas People.
- Right to erasure
You can ask for the deletion of your personal data when it is allowed by applicable data protection laws and regulations.
- Right to restriction of processing
You have the right to require a restriction of the processing of your personal data when it is authorized by applicable data protection laws and regulations.
- Right to data portability
If you meet the conditions settled by the applicable data protection laws and regulation, you have the right to receive a subset of your personal data and to transmit them from Havas People to another data controller. You can also require the direct transmission from Havas People to another controller when it is technically feasible.
- Right to lodge a complaint
You have the right to lodge a complaint with the competent supervisory authority. All requests for aforementioned rights, and any questions regarding this Data Protection Policy, may be sent to email@example.com.
10. Change in this Data Protection Policy
Havas People reserves the right to modify this privacy statement as needed, for example, to comply with changes in laws, regulations, Havas People practices and procedures, or requirements imposed by data protection authorities.
In this case, Havas People will inform Havas People candidates and other persons of any material changes in this policy. Havas People will post all changes on relevant internal and external websites.
Last update: 25 October 2022