Golden Bees, a joint-stock company (SAS) with a share capital of €7,138 and registered offices at 57 Rue d’Amsterdam, 75008 Paris, France, filed with the Trade and Companies Register of Paris under number 812 622 371, with VAT no. FR75812622371, is a service provider specialized in displaying job postings and training courses that match the User’s profile.
Golden Bees has developed a support service for online recruitment that enables users browsing online to see ads for job postings and training courses instead of the ads that are normally displayed. Golden Bees works for businesses seeking employees as well as for websites advertising job postings and training courses in order to redirect Internet users to these websites and to ads that potentially match their job search criteria.
The objective therefore is to display job postings and training courses that match the user’s profile. To achieve this objective, Golden Bees uses tracking technology that enables it to collect information by means of Cookies that are added to the User’s browser. This tracking code takes the form of a technical identifier.
It is stored on the User’s computer when they browse the websites of businesses that use Golden Bees’ services, or when they visit any of Golden Bees’ websites. This tracking code can also be stored whenever an ad for a job posting or training course for a business that uses Golden Bees’ services is displayed to the User when they are browsing online.
Golden Bees undertakes to respect the privacy of its Users.
The purpose of this document is to outline the rules that regulate the processing of data collected within the scope of the services provided by Golden Bees as well as the processing of data on the http://goldenbees.fr website.
I – Definitions
- “Cookie”: A Cookie is a piece of information that is stored on a User’s computer by the server of the website that the User is visiting. It contains various data such as the name of the server that stored the Cookie on the computer, a unique numeric identifier, and an expiration date (Golden Bees Cookies expire in twelve (12) months). This data is stored on the computer in a basic text file that can be accessed by a server in order to read and save information.
- “Intermediaries” means the entities that Golden Bees entrusts with the task of searching for the most relevant placements for displaying ads for job postings and training courses based on the user’s profile. These partners undertake to respect the rule of law in relation to privacy and data protection.
- “Golden Bees Website” means the Golden Bees websites that can be accessed via the www.goldenbees.fr and www.wan2bee.fr URLs.
- “Partner Website” means the websites of customers of Golden Bees that are used to store the Golden Bees Cookie on the User’s computer. Partner Websites are typically the websites of businesses seeking employees or websites that display ads for job postings and training courses. Golden Bees and the Partner Websites are bound by a contractual agreement and are joint controllers within the scope of collecting the User’s data and processing this data as part of a recruitment campaign.
- “Users” means the physical individuals that use the service offered by Golden Bees, i.e. individuals that have a Golden Bees Cookie stored on their computer.
II – Who is the daya controller?
If the Cookie is stored as a result of the User visiting the Golden Bees Website, Golden Bees is the sole data controller.
In rare instances, it may be that Golden Bees is a subcontractor only. In this case, the data collected via the Cookie is used solely in the name and on behalf of the Partner Website, and exclusively within the scope of this customer’s recruitment campaign.
III – What is the legal basis and purpose for which the data is processed?
The Golden Bees Cookie that is stored on the User’s computer enables the collection of data for targeting purposes, so that the ads for job postings and training courses that are displayed to this User are tailored to their profile (area of interest, location, etc.) The purpose, therefore, is to ensure that when browsing the Internet, instead of seeing the ads that are usually displayed, the User sees ads for job postings and training courses that match their defined profile.
In order to ensure the relevance of the ads displayed for job postings and training courses, Golden Bees segments Users by user profile (location, position, etc.).
In addition, reports are shared with Golden Bees customers to provide them with an overview of the campaign that was carried out for them. This report only contains aggregated data that has been completely anonymized (number of clicks, etc.).
If Golden Bees is the data controller, or a joint data controller with another party, the User may see the job postings of a variety of businesses. If Golden Bees is acting as a subcontractor only, the User will only see the job postings and training courses of the Golden Bees partner that is acting as data controller.
– User consent for storage of the Cookie Consent can also form the legal basis for the processing of the collected data in cases where the Partner Websites on which the Cookie is stored have a CMP (Consent Management Platform) that enables the collection of consent for this purpose.
To ensure the validity of the consent that is obtained, Golden Bees requests that its Partner Websites comply with the data regulations relating to the storage of Cookies in accordance with the French Data Protection Act of 6 January 1978 as amended. Depending on the method chosen by the Partner Website, User consent is obtained by means of a positive response, such as closing the Cookie banner, continuing to browse the Partner Website, or checking a box in order to confirm acceptance of Cookies.
In addition, before the Cookie is stored on their computer and after having read the required information, the User can refuse to accept the Cookie, in particular, by modifying their browser settings, as explicitly indicated below.
– Legitimate interest in respect of the processing of personal data For Golden Bees and the Partner Website, this legitimate interest consists of displaying targeted ads for job postings and training courses to Users. The collected data is relatively nonintrusive, does not allow the direct identification of individuals, and is also secure, which ensures that the User’s rights and freedoms are safeguarded. Said user can also stop the processing of their data at any time. From the User’s perspective, the legitimate interest is their ability to view targeted ads for job postings and training courses instead of +++A specific forms of advertisement.
IV – How are Cookies stored?
Golden Bees Cookies can be stored on the User’s computer in two ways:
- By browsing a Partner Website or the Golden Bees Website
- By clicking on or viewing an advertising banner/ad for a job posting or training course for a Golden Bees customer for whom a recruitment campaign is currently in progress.
If this option is available, the User can click on the button in the corner of the advertisement (YourAdChoices) to indicate that he/she does not want Cookies to be stored.
V – What data does Golden Bees collect?
Golden Bees does not collect any directly identifiable data (such as last name, email address, etc.). Golden Bees does not ascertain the User’s identity.
Moreover, Golden Bees does not collect any sensitive data (such as information relating to religion, political opinion, health, etc.).
The data that is collected is information that is used to optimize the relevance of the ads for job postings and training courses that are displayed to the User. This in turn enables Golden Bees to target the User with ads for job postings and training courses that are of most interest in terms of their job search.
More specifically, the Data that is collected by Golden Bees is as follows:
– Data relating to the stored Golden Bees Cookie, the assignment of an associated technical identifier as well as information about the browser and operating system
– The job postings and training courses that the User has viewed on the Partner Websites and/or the Golden Bees Website
– The pages that the User visited on the Partner Websites as well as the date, time, and frequency of these page views. In this respect, the User is informed that once the Cookie has been stored, their personal data will be collected by all Partner Websites, each time the User visits these websites
– Data relating to the User’s geographic location, which can be narrowed down to the nearest city but no further. The IP address is used on a truncated basis, and the information relating to the User’s location is non-specific. This geodata enables the display of job postings and training courses that correspond to this geolocation – on a national, regional, or city level.. The geodata is updated every five (5) days to ensure that only job postings and training courses that are relevant to the User’s location are displayed
– The ads for job postings and training courses that were viewed and clicked on the various +++A forms of advertisement displayed to the Users
– Golden Bees also collects information relating to the User’s device and browser as well as their operating system.
The collected data can be used to segment Users by job type searched and search location, so that the job postings that are displayed to the User are optimally tailored to their profile.
If the User makes use of the online job application service provided by the www.wan2bee.fr website, he/she will be informed that the data collected by the Cookie will be combined with the data input on forms filled out on the www.wan2bee.fr website as well as with the data contained in the CV that the User submitted online.
VI – Who are the recipients of the data?
The collected data is shared with the following:
– Golden Bees’ subcontractor (OVH hosting provider)
– Intermediaries (The Trade Desk (demand-side platform), Facebook, and Instagram) after segmentation.
The Trade Desk will then share the User’s profile with partners that provide advertising space on their own Websites by means of a real-time bidding system.
In all cases, the data is shared with The Trade Desk, Facebook, and Instagram in a pseudonymized, user-segment format.
The sole purpose for which the data will be shared is therefore to display ads for job postings and training courses that match the User’s profile.
VII – How long is the data retained?
The User’s consent, which they provide when they visit a Partner Website and which is used as the basis for storing the Golden Bees Cookie on their computer, is valid for a period of twelve (12) months.
This means that the Cookie will be automatically deleted from the User’s computer after a period of twelve (12) months, and that if the User wants to continue using the services offered by Golden Bees, he/she must once again provide consent for the storage of Cookies. Given the typical length of time spent searching for employment, Golden Bees considers this to be a reasonable period of time. Similarly, the data that is collected by Golden Bees will be deleted from all of its databases once this period of twelve (12) months has passed. Each time the User gives their consent for the Cookie to be stored, this period of twelve (12) months will start again.
During this period of twelve (12) months, the User’s location is updated based on their IP address every five (5) days, so that the relevance of the ads that they see are tailored to their location.
VIII – Security
Golden Bees takes the appropriate technical and organizational measures needed to prevent unauthorized access to data and disclosure of User data. These security measures have been implemented in accordance with industry standards. However, there is no method of transferring data online or of electronically storing data that is completely secure. Golden Bees is subject to a best endeavors obligation.
Golden Bees uses the services of hosting provider OVH, which guarantees server security and safeguards the privacy of data. OVH’s servers are located on French territory.
IX – Requests to transfer data
Golden Bees may be required to disclose data in response to legal requests from the authorities, especially in order to ensure compliance with the law or to respond to requests related to matters of national security. Similarly, the data may be transmitted to a third-party company in the event of a merger, acquisition, dissolution, or sale of all or part of its assets.
X – Transfer of data to a third country
The User’s data is only ever transferred to one third country: the United States. The Trade Desk and Facebook are US companies.
The Trade Desk and Facebook undertake to ensure data protection and safeguard privacy. The Trade Desk and Facebook warrant that they are compliant with the GDPR (General Data Protection Regulation) and are also included on the Privacy Shield list.
Companies included on the Privacy Shield list are obliged to ensure an adequate level of protection that is on a par with the level of protection required under European regulations.
XI – What rights do Users have?
- Users have the right to withdraw their consent, at any time, in relation to any Cookies that they have accepted.
They can do this in several ways:
Whenever they see a customized advertising banner, they can click on the blue button in the corner of the advertisement (YourAdChoices) in order to withdraw their consent in relation to the storage of Cookies associated with this advertisement.
– Users can use the following button to deactivate Golden Bees ads for job postings and training courses displayed in the form of ad placements:
As Facebook is a different environment, Users’ requests may take up to five (5) weeks to be taken into account. If a User no longer wishes our postings to be displayed when logged in to Facebook, they must change the relevant settings by clicking the following: Facebook Settings
– The User can set their Cookie preferences in their browser directly: each browser has its own settings for managing cookies. The steps to be followed are described in the respective browser’s Help section:
- For Internet Explorer™: click here
- For Safari™: click here
- For Chrome™: click here
- For Firefox™: click here
- For Opera™: click here
- The User can exercise their right of access, whereby they can obtain confirmation about whether or not their liersonal data is processed by Golden Bees, and in the event that it is, they can access this data in addition to the following information :
The purposes for which the data is processed
The categories of personal data in question
The recipients or categories of recipient with whom the personal data has been or will be shared, where this includes, in particular, recipients based in third countries or international organizations
Where possible, the envisaged period for which the personal data is to be retained, or, where this is not possible, the criteria that is used to determine this duration
The existence of the right to request Golden Bees to amend or erase the personal data
The right to lodge a complaint with a supervisory authority
The existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
- The User may ask Golden Bees to restrict the processing of their data—especially in cases where they are contesting the accuracy of the data—if the processing is unlawful but the User does not want their data to be erased, or if Golden Bees no longer needs the data but the User requires it in order to establish, exercise or defend a legal claim, in which case said restriction is to apply for a sufficient period of time to enable the data controller to verify the accuracy of the data.
- The User may ask Golden Bees to erase their personal data, especially in cases where they have withdrawn their consent to have their data processed, or in cases where the data is no longer necessary for the purpose for which Golden Bees had needed to process it.
- The User has the right to request that the data that they provided to Golden Bees be made available to them in portable format. Golden Bees will send the User all of the provided data in a structured, commonly used and machine-readable format, or will send this data directly to another controller designated by the User.
All Users are entitled to exercise the following rights via the Golden Bees’ Data Protection Office (DPO), who can be contacted as follows:
- By email at: email@example.com
- By regular mail accompanied by a signed form of identity addressed to DPO -GOLDEN BEES – 157 Boulevard Macdonald 75019 Paris, France.
Golden Bees will endeavor to respond to the User’s request within a period of one (1) month of receiving such correspondence. However, given that Golden Bees does not have any directly identifying data, a period of time will be needed in order to engage with partners in relation to reversing the pseudonymization of the User’s Cookie identifier.
If the response provided by Golden Bees is not acceptable to the User, or if the User wants to contest this response, they must submit a complaint to the CNIL, France’s commission for information technology and civil liberties (www.cnil.fr/fr/plaintes)
XII – Social network cookies on the Golden Bees website
Golden Bees has integrated “social network” buttons (LinkedIn, Golden Bees, Twitter) into its http://goldenbees.fr and www.wan2bee.fr websites to enable the collection and transfer of the User’s personal data to the aforementioned social networks, irrespective of whether or not the User has subscribed to these social networks. This type of application button enables the social network to track the User’s browsing activity on the Golden Bees websites by sole virtue of the fact that their account that is associated with the social network was active on their computer (open session) at the time they were browsing the Golden Bees website.
Golden Bees has no control over the processes used by the social networks to collect data relating to the User’s browsing activity on websites published by Golden Bees. Golden Bees encourages Users to view the privacy policies of these social networks in order to learn about the purposes, in particular those relating to advertising, for which the browsing data collected by these application buttons is used:
- Facebook : https://www.facebook.com/help/cookies
- Linkedin : https://www.linkedin.com/legal/cookie-policy?trk=hb_ft_cookie
- Twitter : https://twitter.com/privacy
Users can refuse to accept these networks’ Cookies by using the CMP provided for this purpose.