Confidentiality

CHARTER ON THE PROTECTION OF USERS’ PERSONAL DATA

1.Definition and nature of personal data

When using the website www.pipplet.com (hereinafter the “Platform”), allowing companies, recruitment firms or training bodies to assess the linguistic skills of their recruitment candidates, their collaborators or employees (hereinafter the “Candidates”), you will be communicating your personal data, designating any data allowing to identify an individual directly or indirectly.

If you are a Candidate directed to our website through a third party service provider, please refer to the information for data subjects or privacy policy provided to you by such service provider for details on how we (as that service provider’s sub-processors) process your personal data. In case of any conflict between the information provided by the third party service provider and the below provisions, the information provided by the third party service provider supersedes the below provisions.

We will collect the following data in this regard:

1.1 Information that you communicate to us

For the proper execution of services that we offer via the Platform, we collect the following data:

1.2 Information that we collect from third parties

In terms of the execution of linguistic tests, we also collect any comments or remarks from the examiner on the Candidate, if applicable.

1.3 Information that we collect automatically

We may also automatically collect your personal data via tools and services proposed on the Platform, and notably the following data:

2. Purpose of this charter

The purpose of this charter is to inform you on the means that we implement to collect and process your personal data, in strict compliance with your rights.

We indicate to you that we comply with law no. 78-17 of 6 January 1978 regarding Information Technology, Files and Liberties, in its applicable version, as well as with the General Data Protection Regulation no. 2016/679 of 27 April 2016 in the collection and management of your personal data.

3. Identity of the data collector and controller

The collector and controller of your personal data is the company Pipplet, a simplified joint-stock company, registered at the Paris Trade and Companies Register under number 813 493 673, the registered office of which is located at 10 rue de Penthièvre – 75008 Paris (hereinafter referred to as “We”).

4. Collection and processing of personal data

Your personal data is collected and processed for one or more of the following purposes:

  1. Managing your access to the Platform and to services accessible on the Platform and their use, as well as responding to any request regarding your use of the services,
  2. Carrying out the operations regarding the management and the monitoring of our relationships with the users of our services,
  3. Assessing your oral and written linguistic skills,
  4. Creating a file of registered members and users,
  5. Sending newsletters, solicitations and promotional messages as well as any information messages regarding our news and/or any change in our Services. If you do not wish to receive them, we give you the option to express your refusal in this regard when collecting your data;
  6. Sending advertisements, and notably targeted advertisements. If you do not wish to receive them, we give you the option to express your refusal in this regard when collecting your data.
  7. Preparing commercial statistics of use and traffic of our services,
  8. Optimising the operation and efficiency of products and services that we offer,
  9. Managing people’s opinions on products, services or content,
  10. Managing outstanding amounts and any disputes regarding the use of our products and services,
  11. Complying with our statutory and regulatory obligations, if applicable.

We inform you, when collecting your personal data, if certain data shall necessarily be provided or if it is optional. We also indicate to you any consequences of a failure to respond.

5. Recipients of collected and processed data

Only the staff of our company (notably our examiners), the services in charge of the control (notably auditors) and our subcontractors shall have access to your personal data.

We will communicate your personal data to the company that registered you for the assessment of your linguistic skills for the strict necessity of the execution of services. This company may use the data provided for the same purposes and under the same conditions as those referred to in this Charter. Each company remains however solely liable for compliance with its statutory obligations in terms of its processing of your personal data, with its own means and for its own purposes. We are only liable for our use of your personal data, excluding any other use by a company using our services.

Your personal data may also be sent to public bodies, exclusively for the purposes of complying with our statutory obligations, court officers and public officers.

6. Transfer of personal data

Your personal data shall not be subject to transfers, leases or exchanges to the benefit of third parties, for the execution of one of the purposes detailed above and with the aforementioned reservations.

You are however informed that we reserve the option to communicate your fully-anonymised data to third parties in an aggregate form, that is in a form that does not allow for your identification in any manner whatsoever.

7. Storage period of personal data

  1. For data regarding the monitoring and management of relationships with users and data regarding your linguistic skills:

Your personal data is stored for a maximum period of twenty-four (24) months as from the collection date. We can delete your data upon simple request at any time.

However, data allowing to prove a right or a contract, to be stored in terms of compliance with a statutory obligation, shall be stored for the duration provided for by the applicable law, that is for a maximum duration of five (5) years as from the collection thereof, on an intermediary storage device.

  1. Regarding the management of objection lists to be received from prospection:

Information allowing to take into account your right to object is stored at least three (3) years from the exercise of the right to object.

  1. Regarding statistics of audience measurements:

Information stored on the users’ terminal or any other element used to identify the users and allowing their traceability or visit shall not be stored for more than thirteen (13) months.

8. Security

We inform you that every necessary caution as well as all appropriate organisational and technical measures to preserve the security, integrity and confidentiality of your personal data and notably to prevent any misuse of, damage or unauthorised third-party access to it.

9. Hosting

We inform you that your personal data is kept and stored for the entire duration of its storage on servers of the company Heroku located within the European Union.

Your data shall not be subject to any transfer outside the European Union in terms of the use of services that we provide to you. However, if it were to be transferred, we inform you that the transfer shall necessarily occur in terms of the execution of the purposes detailed in this Charter and to a country representing an adequate level of protection or after having concluded an agreement governing the transfer in accordance with the model agreement of the European Commission.

10. Cookies

Cookies are text files, often encrypted, stored on your browser. They are created when the browser of a user loads a given website: the website sends information to the browser, that creates a text file. Every time the user returns to the same website, the browser retrieves this file and sends it to the website server.

There are three types of cookies, with different purposes: technical cookies, social media cookies and advertising cookies:

We use technical cookies. These cookies are stored on your browser for a period of thirteen (13) months.

We use social media cookies, that we only place with your consent. You can find out more about their nature and accept or refuse them.

We also use advertisement cookies. These cookies are only placed with your consent. You have the possibility to deactivate these cookies in the parameters of your web browser.

We use Google Analytics, which is an audience statistical tool that generates cookies allowing to measure the number of visits on the Platform, the number of pages viewed and visitors’ activity. Your IP address is also collected to determine the city from which you connect. The storage duration of this cookie is mentioned in Section 7 of this charter.

We remind you, for all due intents and purposes, that you can object to the placing of technical cookies and cookies generated by Google Analytics, by changing your browser’s settings. Such refusal may however prevent the proper operation of the Platform.

11. Legal ground for the processing of your data

In terms of the services that we provide to you via the Platform, we collect and process your personal data that is necessary for the execution of the contract binding us for the following purposes:

Whenever your prior consent is necessary to process your personal data, we will ask you to consent with a box to tick directly on the form for the collection of your data. You will have the possibility to express your refusal in this regard on the occasion of the collection of your data. This is notably the case for the following purposes:

Lastly, you are informed that we collect your personal data without obtaining your consent beforehand for the purposes of our legitimate interest and notably for the following purposes:

12. Access to your personal data

You have the right to access your data to have it communicated to you and if applicable to rectify or delete it by sending us a mail at:

It is reminded that any person can request the restriction of processing of data concerning him/her or object to the said processing, on legitimate grounds.

We inform you that in case of rectification or deletion of your personal data, as well as in case of restriction of processing carried out following your request, we will notify the said changes to the persons to whom we communicated your data, unless this communication turns out to be impossible.

13. Portability of your personal data

You have a right to the portability of the personal data that you provided to us, understood as data that you actively and deliberately declared in terms of the access to and use of the Platform, as well as data generated by your activity in terms of the use of the Platform. We remind you that this right does not concern the data collected and processed on a legal basis other than the consent or the execution of the contract biding us, and notably the data collected in our legitimate interest or on a statutory basis.

This right may be exercised free of charge at any time, and notably when you close your account on the Platform, in order to recover and store your personal data. In this regard, we send you your personal data in a standard open commonly used and machine-readable format in any way deemed necessary, according to the state of the art.

14. Submission of a complaint before a supervisory authority

You are also informed that you have the right to submit a complaint to the National Commission for Information Technology and Liberties (Commission Nationale Informatique et Libertés) if you consider that the processing of your personal data, that is the subject matter of this Charter, constitutes a breach of applicable provisions.

This remedy may be exercised without prejudice to any other remedy before an administrative or judicial court. You in fact also have a right of effective administrative or judicial remedy if you consider that the processing of your personal data constitutes a breach of applicable provisions.

15. Communication regarding a breach of personal data

We will inform you as soon as possible if we observe a security breach in the processing of your personal data that can present a significant risk for your rights and liberties. On this occasion, we will provide you with the detail of the nature of the breach encountered and the measures implemented to put an end to it.

16. Amendments

We reserve the right to amend this charter at any time, in full or in part, at our sole discretion. These amendments shall enter into force as from the publication of the new charter that will be notified to you in any way deemed necessary. Your use of the Platform following the entry into force of these amendments shall constitute acknowledgment and acceptance of the new charter. Failing which and if you are not satisfied with the new charter, you should no longer access the Platform.

17. Entry into force

This charter enters into force on 01/01/2019