PRIVACY POLICY AND DATA PROTECTION

This Privacy Policy applies to users of the website www.hujemax.com and aims to inform them about how their personal information may be collected and processed.

Respect for privacy and personal data is a priority for HUJEMAX, which is why we are committed to processing such data in strict compliance with the French Data Protection Act of January 6, 1978, as amended, and the General Data Protection Regulation (GDPR) (EU) 2016/679.

1. General Information and Identity of the Data Controller

The data controller is HUJEMAX, a simplified joint-stock company registered with the Paris Trade and Companies Register under number 881 933 097, with its registered office at 29 Rue de Courcelles, 75008 Paris, France.

HUJEMAX acts as data controller for processing related to:

Management of coaching services
Handling contact requests
Sending email campaigns
Managing data subject rights requests
Ensuring proper functioning and continuous improvement of the website

HUJEMAX acts as joint controller for processing related to candidate management.

Legal Reminder:

The data controller determines the purposes and means of processing. When two or more controllers jointly determine these, they are joint controllers. A processor acts on behalf of and under the instructions of the controller.

2. Definitions

“Data”: means the personal data processed under this Privacy Policy.
“Personal Data”: means personal data as defined in Article 4(1) of the GDPR.
“Company”: means any legal entity, client or prospect of HUJEMAX, seeking a Candidate or coaching for a specific Role.
“General Data Protection Regulation” or “GDPR”: means 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, repealing Directive 95/46/EC.
“User”: means any person browsing www.hujemax.com.
“Processing/To Process”: means any operation referred to in Article 4(2) of the GDPR performed on Personal Data under this Privacy Policy.
“Processor”: means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of HUJEMAX in accordance with Article 4(8) GDPR.

3. Purposes of Processing and Legal Bases

HUJEMAX only collects the Data necessary for the explicit and specific purposes set out below:

APPLICATION (CANDIDATE) MANAGEMENT

Processing details:

This processing covers the following purposes:

Processing Candidate applications
Selecting Candidates
Sending Candidate data to Client Companies

Legal basis:
Performance of a contract or performance of pre‑contractual measures taken at the request of the candidate (Article 6(1)(b) GDPR).

COACHING SERVICES MANAGEMENT

Processing details:

Organizing and monitoring training sessions

Legal basis:

Performance of the contract concluded with the User or the Company.

CONTACT REQUEST MANAGEMENT

Processing details:

Tracking and responding to Users’ contact requests

Legal basis:

Performance of a contract or performance of pre‑contractual measures taken at the request of the User.

EMAIL CAMPAIGNS

Processing details:

Sending email campaigns and other alerts to Users who have requested them

Legal basis :

User consent.

MANAGEMENT OF RIGHTS REQUESTS UNDER THE GDPR AND THE FRENCH DATA PROTECTION ACT (AS AMENDED)

Processing details:

This processing covers all operations necessary to handle rights requests addressed to HUJEMAX (qualification of the request, investigations, performance of specific technical operations, etc.). It only applies where HUJEMAX acts as data controller.

Legal basis:

Our legal obligation arising from Articles 15 et seq. of the GDPR and Articles 48 et seq. of the French Data Protection Act (Loi Informatique et Libertés).

PROPER FUNCTIONING AND CONTINUOUS IMPROVEMENT OF THE WEBSITE AND ITS FEATURES

Processing details:
Ensuring the proper functioning of the Website and the continuous improvement of the site and its features.

Legal basis:

Our legitimate interest in guaranteeing the best possible level of operation and quality of the Website, notably through visit statistics.
User consent where required.

4. Data Collected

The mandatory or optional nature of the personal data collected, as well as any potential consequences of failing to provide such data, are indicated at the time of each interaction with the data subjects.

You can consult below the details of the personal data we may hold about you.

Note: The information provided below is not intended to be exhaustive and primarily aims to inform Users about the categories of data that HUJEMAX may process.

Application (Candidate) Management

Identity data of Users: first name(s), last name, address, telephone number, email addresses
Candidate CVs

Contact Request Management

Identity and contact data: first name(s), last name, email address
Reason for the request

Coaching Services Management

Identity data of trainees: first name(s), last name, address, telephone number, email addresses
CVs of trainees

Email Campaigns

User contact data (first name, last name, email address)

Rights Request Management

Contact data: first name, last name, telephone number, email address
Where applicable, a copy of an identity document

Proper Functioning and Continuous Improvement of the Website

User logs and connection data, and identifiers related to IT equipment
Data collected via cookies and other trackers present on our Website; for more details, please refer to our Cookie Management Policy.

5. Automatically Collected Personal Data

When you browse the website www.hujemax.com, HUJEMAX automatically records information related to your navigation.

When you use our services, connection data may be automatically logged in our server logs, such as your IP address, unique identifier, operating system and its location, the type of browser you use, and the pages you have viewed.

6. Data Recipients

Only the authorized and specifically identified persons listed below may access Users’ data.

For data relating to Candidates

Client companies originating the recruitment need
Authorized HUJEMAX personnel

For data relating to Users

Authorized HUJEMAX personnel
Service providers responsible for managing the Website and HUJEMAX’s IT systems
Where applicable, the competent courts, mediators, chartered accountants, statutory auditors, lawyers, bailiffs, debt collection agencies, police or gendarmerie authorities in the event of theft or judicial requisition.

Your data is not disclosed, exchanged, sold, or rented to any other persons than those mentioned above.

7. Data Retention Periods

HUJEMAX undertakes to retain the data collected in a form that allows your identification for no longer than is necessary for the purposes for which such data are collected and processed.

For application (candidate) management

Data collected for the processing of applications of candidates who are not hired are stored for twenty-four (24) months from the last contact with the candidate, or longer where the candidate consents for HUJEMAX to retain their contact details and CV for future opportunities.

For training/coaching services management

Data are retained for the entire duration of the contractual relationship and then archived. They are subsequently stored for five (5) years for evidentiary purposes in accordance with the legal and regulatory obligations applicable to HUJEMAX. Accounting documents are retained for ten (10) years.

For contact request management

Data are retained for the time necessary to process the request.

For rights request management

Data related to the handling of rights requests are retained for the entire period necessary to process the request. They are then archived for the duration of the applicable criminal limitation period as intermediate archiving.

For email campaigns

Data are retained until the User unsubscribes via the dedicated link.

For ensuring the proper functioning of the Website

Cookies and other commercial trackers may be stored on the User’s device for a maximum duration of thirteen (13) months. Beyond this period, raw traffic data associated with an identifier are either deleted or anonymized.

Information collected via cookies and trackers is retained for twenty-five (25) months. After this period, such data are deleted or anonymized.

8. Your Rights

In accordance with the French Data Protection Act (Loi Informatique et Libertés) and the GDPR, you have the following rights:

Right of access (Article 15 GDPR), rectification (Article 16 GDPR), and update
Right to restriction or erasure of your personal data (Article 17 GDPR) where data are inaccurate, incomplete, ambiguous, outdated, or where collection, use, disclosure, or storage is prohibited
Right to withdraw your consent at any time (Article 13(2)(c) GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to object to processing (Article 21 GDPR)
Right to data portability for data you have provided, where your data are subject to automated processing based on your consent or a contract (Article 20 GDPR)
Right to lodge a complaint with the CNIL (Article 77 GDPR)
Right to define instructions regarding your data after your death and to choose whether we should disclose (or not) your data to a third party previously designated by you. In the event of death and absent any instructions from you, we undertake to delete your data unless their retention is necessary for evidentiary purposes or to comply with a legal obligation.

These rights may be exercised with the local platform with which you are in contact, by providing proof of your identity by any appropriate means.

You may exercise these rights by sending a simple request:

By email: [To be completed] –
By post: HUJEMAX, 29 Rue de Courcelles, 75008 Paris, France.

If a copy of an identity document is provided to verify your identity, we will retain it for one (1) year, or three (3) years where the communication is made in the context of exercising a right to object.

To learn more about your rights, you may consult the French website of the Commission Nationale de l’Informatique et des Libertés (CNIL): http://cnil.fr.

9. Security

HUJEMAX and its processors, where applicable, undertake to implement all technical and organizational measures to ensure the security of personal data processing and the confidentiality of your data, in line with the state of the art and in accordance with the French Data Protection Act (as amended), the General Data Protection Regulation (GDPR), and Law No. 2018‑133 of 26 February 2018 “containing various provisions for adapting EU law in the field of security.”

HUJEMAX takes appropriate precautions, considering the nature of your data and the risks inherent in our processing, to preserve data security and, in particular, to prevent data from being altered, damaged, or accessed by unauthorized third parties (physical protection of premises, client authentication mechanisms with personal and secure access via confidential IDs and passwords, connection logging, encryption of certain data, etc.).

10. Transfers Outside the EU

The Personal Data collected by HUJEMAX are stored and processed within the European Union (EU), where HUJEMAX or its processors are located or operate facilities.

HUJEMAX undertakes not to transfer Users’ data outside the European Union.

If HUJEMAX were required to do so, Users would be informed, with details of the measures implemented to govern such transfer and ensure the confidentiality and protection of their data.

11. Updates to Our Privacy Policy

This Privacy Policy may be amended, to reflect legislative and regulatory developments. The User may consult the most recent version directly on the Website.