To successfully pursue its business activities, Emakina Group needs to process personal data about individuals. This may include prospective clients, customers, job seekers, journalists, vendors, investors, competitors, former employees and other people the organisation has a relationship with or may need to contact. 1
Emakina Group is committed to respecting the rights of the people whose personal data is being processed. The group is committed to complying with data protection regulations such as the General Data Protection Regulation2 (“GDPR”) and the national laws of the countries in which it operates.
This privacy statement describes what personal data we collect, why we do it, how long we keep it and the rights you can exercise with regard to your personal data. It applies to all personal data submitted to Emakina Group via the website, by email, or by any other means.
ControllerThe controller is an entity within Emakina Group, and personal data have effectively been collected through its website. You will find the full contact details of the controller at the bottom of the website. The controller is referred to as “Emakina Group” throughout this document.
Personal data we collect about you
If possible, we try to collect personal data directly from the person concerned. However, it may be necessary to collect personal data from third parties in the context of building future relationships (e.g. with customers or candidates).
I. Information you provide us includes:
contact form filled out by you (website): name, email, company, phone, function, subject and message;
job applications (websites or via recruitment company): application forms, CV, interview notes and related recruitment information;
content of correspondence with us (by email, phone, letter, …);
information from social media when you link to our website (online);
contact details of past, present and future suppliers, vendors, investors or other stakeholders.
II. Information we may automatically collect if you visit our website includes:
technical information, including IP address, login information, browser type and version;
III. Use of children’s data:
Emakina Group does not knowingly collect, process or store any personal data about children under the age of 16 and we do not offer any products or services directly to children under this age.
IV. Finally, information collected on our site may be stored and processed into anonymous statistics or log files for internal use.
In general, we may need to process all types of personal data to comply with applicable legal or regulatory requirements, relevant industry standards and our policies, and for litigation or defending claims. This includes:
Supplier, vendor, journalist, consultant and other stakeholder personal data: we process your personal data to conclude and execute our agreements and manage our relationships;
Investor and shareholder data: we use your personal data in order to manage our relationship and our obligations to you. We maintain contact details for external communications and to respond to your queries;
- Student and job seeker data: your personal data are stored for recruitment and selection procedures. More specifically, your personal data are processed to assess your profile and skills to fit a job and to make you specific job offers;
- Subject to your explicit consent, we may use your contact details to send you our newsletter, mailings and to invite you to events. We also may use this personal data in other ways, for which we provide specific notice at the time of collection.
Additional notification: in order to implement or enforce the Terms of Service of the relevant Emakina Group site, Emakina Group may use personal data to contact users on an individual basis.
Retention of your personal data
Your personal data is kept in our information systems only for as long as is necessary for the purposes for which it was collected (as described above). It will be deleted once it is no longer needed by us and once all legal requirements have been met.
We will retain and use your personal data for as long as reasonably necessary to perform our agreements or to consider tenders, to comply with our legal obligations (such as accounting and tax obligations) and to resolve disputes or enforce our agreements. This means that your personal data will be held during the duration of our contractual relationship and for up to 10 years afterwards.
Application forms (CVs), interview notes and references of unsuccessful candidates are kept for a period of 24 months following the closure of the hiring process. If we would like to stay in contact with an applicant who was not chosen for the job he/she applied for, we will ask for his/her consent to keep the CV in our application pool for another two years.
In all cases, personal data may be kept for a longer period of time if there is a legal or regulatory reason to do so, or for a shorter period if the individual objects to the processing of their personal data and there is no longer a legitimate purpose to retain it.
Emakina Group only processes your personal data if at least one of these grounds applies:
For the preparation or performance of a contract;
In order to comply with the legal and regulatory obligations to which we are subject;
For legitimate business interests, in which case we always seek to strike a balance between that interest and respecting your privacy;
If none of the above, where we have your explicit consent.
Disclosure to third parties
Emakina Group does not share your personal data with third parties, apart from:
with our legal successors and other affiliated companies within the Emakina Group, for the same purposes as specified in this Privacy Statement;
with subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you;
with third party service providers who perform services on our behalf to help us with our business activities. These service providers are limited to only using your personal data as instructed to carry out their tasks;
as permitted or required by applicable law or regulatory requirements;
with law enforcement authorities or other government officials;
with other third parties, with your consent.
Transfer to third countriesWhen we transfer your personal data to other countries, outside of the European Economic Area, Emakina Group will take measures to ensure that your personal data is exclusively processed in accordance with this Privacy Statement and that adequate levels of protection have been implemented in order to safeguard your personal data. These arrangements can include Binding Corporate Rules for transfers within the Emakina Group, standard contractual clauses or approved certification mechanisms. A copy of any such applicable arrangements can be obtained by sending a request to privacy@Emakina.com.
In accordance with the GDPR, Emakina Group will respond to your requests in the GDPR-mandated time to exercise the following rights:
Right to be informed
Emakina Group is transparent, providing you any information relating to the processing of your personal data via this privacy statement or specific information notices at the time of collection.
Right to access
You have the right to request a copy of the personal data that Emakina Group holds about you. We may require proof of identity before fulfilling such requests.
Right to rectification
If the personal data that Emakina Group holds about you is inaccurate or incomplete, you have the right to ask us to update or rectify it.
Right to be forgotten
You have the right to request Emakina Group to erase all your personal data. We will delete your personal data without undue delay if we do not have any legal reason or legitimate purpose to continue to process it.
Right to restrict processing
In some specific cases, you have the right to ask Emakina Group to restrict how we process your personal data.
Right to data portability
This right only applies to personal data that you have provided to Emakina Group, based on consent or for the performance of a contract. Emakina Group will provide your personal data in a structured, commonly used and machine-readable format to be able to transmit it to another controller, or have it directly transmitted by Emakina Group if technically feasible.
Right to object
You have the right to object to the processing of your personal data if the processing is based on the legitimate interest of Emakina Group or on public interest. Emakina Group will discontinue the processing of your personal data, unless we can demonstrate compelling legitimate grounds which override your interests or rights, or for the establishment, exercise or defence of legal claims.
Right to withdraw consent
Where your consent was required for the collection or use of your personal data, you have the right to withdraw your consent at any time. For example, you may choose to stop receiving our newsletter by following the unsubscribe instructions included in the emails.
Right to lodge a complaint
You have the right to lodge a complaint with the competent supervisory authority if you consider that the processing of your personal data infringes this Privacy Statement or the GDPR.
You can exercise your rights by sending a request by email to privacy@Emakina.com or use the form on the website.
Data securityEmakina Group has security policies and procedures in place to protect your personal data from unauthorised loss, misuse, alteration or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats.
To the best of our ability, Emakina Group has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information. These actions may include physical security measures, network security measures, and organisational measures such as confidentiality clauses and restricted access.
Limitations of responsibilityEmakina Group has links to other websites, whether owned or controlled by Emakina Group affiliates or unrelated third parties. Emakina Group is not responsible for the privacy policies and practices of such linked websites.
User names and email addresses (as well as any additional information that a user may choose to post) are publicly available on the Emakina Group blog, unless a user elects to "opt out" of such display of personal information. However, in cases where users voluntarily and publicly disclose personal information, which may contain Personal Data, it is their sole responsibility.
Surveys and Resulting Information:
Emakina Group may conduct surveys or other studiesof its customer base for marketing and planning purposes. Users choose whether or not to participate; Emakina Group does not conduct mandatory surveys. With respect to information collected from such surveys or studies, and in the event that responses are to be publicly disclosed, users will be notified at the time they take the survey and Emakina Group will disclose only aggregate information regarding its users and not personal information identifying any specific individual. Circumstances under which Emakina Group would publicly disclose such aggregate information include, but are not limited to, sharing survey results with the site population, providing data to Emakina Group' advertisers on user preferences and/or demographics, and publicising overall usage data in press communications.
In cases where surveys allow users to submit written comments, and where Emakina Group advises users of the possibility of such disclosure at the time they take the survey, Emakina Group reserves the right to disclose text information provided by any user through such a survey, provided that no personal information identifying that user is disclosed.
1 Employees of Emakina Group can consult the Privacy Statement Employees on our intranet.
2 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.