“Personal Data” is defined in data protection laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
We are part of the Aspen Group which has databases in different jurisdictions. We may transfer your data to one of the Group’s databases outside your country of domicile. These other countries will either have different data protection laws than your country of residence or they will not have data protection laws. They may not be deemed by the European Commission as providing adequate protection for Personal Data. Even if the country to which the data is to be transferred does not require us to provide adequate protection for your data, we will nonetheless seek to ensure that data transfers to Aspen Group databases in that country are adequately protected.
Personal Data collected from you include the following:
|Categories of Personal Data||Purpose||Lawful basis|
|Application data (e.g. name, CV)||Processing of this personal data is required to enable ASPEN NDB to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews.||Processing is necessary for us to entering into a contract with you.|
|Contact information (e.g. full name, postal address, e-mail address, employer/business and professional information, job titles, telephone and fax numbers)||Managing and responding to your queries.||Performance of contract and legitimate interests – it’s important that we can respond to your enquiries.|
|Browsing information (IP address, browser information)||Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality.||Legitimate interests – we need to perform this limited routine monitoring to make sure our website work properly, to diagnose any problems with our server and administer our Site|
|All information||Establishing and enforcing our legal rights and obligations and monitoring to identify and record fraudulent activity
Complying with instructions from law enforcement agencies, any court or otherwise as required by law
For our general record-keeping and customer relationship management
Managing the proposed sale, restructuring or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation
Resolving any complaints from or disputes with you
|Legitimate interest (see column on left).|
In summary, we need certain categories of Personal Data because that is necessary in order to administer any contract with you (where relevant). Certain other Personal Data is processed for our legitimate interests in cases where this does not result in prejudice to you.
We may convert your Personal Data into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from that data. We may use this aggregated data to conduct market research and analysis, including to produce statistical research and reports.
In particular, we use technology to collect anonymous information about the use of this Site. For example:
We use this anonymous data to improve the content and functionality of this Site and consider areas and subjects which are attracting interest so that we can focus our e-mail updates (for those that wish to receive such communications). This allows us to better understand our Site visitors’ interest areas generally and therefore to improve our Site and products and services we offer.
The cookies that our Web sites may deploy can be divided into four categories:
These cookies are essential, because they enable you to move around our Web sites and use certain features, e.g., to access secure areas of the Web site or in connection with information searches. Without these cookies, certain services you may ask for could not be provided.
These cookies may be used to collect information about how you use our Web sites, for example which pages you visit most often. These cookies do not collect information that identifies you. These cookies are only used to learn how our Web sites are performing and make relevant improvements.
These cookies may be used to allow our Web sites to store information about choices that you make and provide you with more personal features. We may also use such cookies to ensure that onsite marketing and experience is relevant to you. The information these cookies collect may be anonymous and they cannot track your browsing activity on other Web sites.
These cookies may be used to deliver advertisements that are more relevant to you and your interests. They are usually placed by advertising networks with our permission.
We use Google Analytics on our Site with the extension “anonymizeIP()”, IP addresses being truncated before further processing in order to rule out direct associations to persons.
You can disable cookies using your Internet browser settings. Please consult your browser’s help function for information on how to disable cookies. Note that if you disable cookies, certain features of our Site may not function properly.
We may disclose your Personal Data to third parties, including but not limited to as follows:
We endeavour to use appropriate technical and physical security measures to protect Personal Data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with our Site. These measures include computer safeguards and secured files and facilities. Our service providers are also selected carefully and required to use appropriate protective measures. In certain areas, ASPEN NDB uses industry-standard SSL-encryption to protect data transmissions. Most current browsers support the level of security needed to use these areas.
In particular, we endeavour to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymisation (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Data, (c) ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and (d) ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational security measures.
We keep your Personal Data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above.
The criteria we use to determine data retention periods for Personal Data includes the following: (i) Retention in case of queries. We will retain it for a reasonable period after the relationship between us has ceased (up to 6 months) in case of queries from you; (ii) Retention in case of claims. We will retain it for the period in which you might legally bring claims against us (in Germany this means we will retain it for 10 years) if and to the extent we have entered into any contract with you; (iii) Retention in accordance with legal and regulatory requirements. We will consider whether we need to retain it after the period described in (ii) because of a legal or regulatory requirement.
If your application for employment is successful and you commence employment with ASPEN NDB, your Personal Data will be transferred to your personnel file and will be processed for employment purposes. If your application for employment is not successful, we will keep your Personal Data for a period compliant with applicable laws, after notification that your application was not successful.
If you would like further information about our data retention practices please contact us (see “Contact Us” below).
You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Data we hold about you; the right to rectification including to require us to correct inaccurate Personal Data; the right to request restriction of processing concerning you or to object to processing of your Personal Data, the right to request the erasure of your Personal Data where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Data in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent. Please be aware that some of these rights will only become relevant when changes to data privacy laws come into force in May 2018. You can also lodge a complaint with a supervisory authority in the country of your residence.
Please see “Contact Us” if you wish to exercise any of these rights (as relevant).
There are Terms and Conditions associated with your usage and viewing of this site. Please view these here: http://www.aspenndb.com/disclaimer-fr/?lang=fr.
Alternatively, write to
Attn: Compliance Officer / Responsible Conformité
1, rue de l’Abbaye – 76960 Notre Dame de Bondeville – France
Phone: +33(0) 35 14 58 39
Be sure to include your email address and telephone number with your correspondence.
Last updated: 03 August 2018