Recruitment Privacy Policy
Last updated: September 19th, 2024
This Privacy Notice ("Notice") explains how Mirakl collects and uses your Personal Data in connection with Our recruitment activities. It applies to applicants for training contracts, internships, together with applicants for fixed term and permanent vacancies. It also applies to individuals who undertake a period of work experience or apprenticeship or internship with Us.
References in this notice to “you” or “your” are references to individuals whose Personal Data Mirakl processes in connection with the items listed above. For the avoidance of doubt, any reference in this policy to our “clients” or “suppliers” includes their employees or other staff whose personal data we process;
References in this notice to “Mirakl”, “we”, “us” or “our” are references to Mirakl SAS and the other Mirakl Affiliates. Mirakl SAS is a Société par Actions Simplifiée established 12, rue de Lübeck 75016 Paris .
We recognise that the use and disclosure of personal data has important implications for us and for the individuals whose personal data we process. To ensure that we handle personal data properly, we have adopted a global approach to privacy compliance.
It is important that you read this notice together with any other notices we may provide on specific occasions when we are collecting or processing your Personal Data, so that you are fully aware of how and why we are using your Personal Data. This notice supplements the other notices and is not intended to override them.
1.Who is the controller for the personal data processed?
A “controller” is a person or an organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed.
This notice is issued on behalf of Mirakl as controller. Unless we notify you otherwise Mirakl is the controller for your personal data.
2.How to make a complaint about the use of your personal data by us
If you have any concerns or would like to make a complaint about our processing of your personal data, please complete this form or send an email to privacy@mirakl.com
You may raise your concerns with your local data protection authority directly. However, we would encourage you to contact us in the first instance as we aim to promptly, efficiently and satisfactorily resolve any concerns or complaints you may have in relation to Mirakl’s processing of your personal data.
3.How we collect your information
When you apply to work for us, the initial data about you that we process are likely to come from you.
Where necessary, and in accordance with this Notice, we will require references and information to carry out pre-engagement screening or background checks.
We may also receive data from third party recruiters, agents or other intermediaries as part of the recruitment process, or as a referral from one of our employees or clients.
4.What personal data are processed?
”Personal Data” includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked in an individual (anonymous data).
We collect and process the following Personal Data:
Information that you provide when you apply for a job opening. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
In particular, We process personal details such as name, email address, address, date of birth qualifications, experience, information relating to your employment history, skills and experience that you provide to Us.
If you contact Us, We may keep a record of that correspondence.
A record of your progress through any hiring process that We may conduct.
Where your application is successful, to carry out our obligations arising from any contracts entered into with you and to administer your ongoing relationship Us, We process information that is needed to begin your onboarding: bank account details; information regarding your right to work in the jurisdiction in which you have applied, etc.
5.For what purposes is your personal data used?
We will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing.
Purposes | Examples of use of your personal data | Legal bases |
Management and processing of applications | To consider your application in respect of a role for which you have applied. To consider your application in respect of other roles. | Processing necessary to perform a contract or to take steps at your request, before entering a contract |
Management of the relationships with recruitment agencies and institutions (eg. universities) for the recruitment | To find appropriate candidates to fill Our job openings. | Processing necessary to perform a contract or to take steps at your request, before entering a contract |
Responses to candidates | To communicate with you in respect of the recruitment process. To enhance any information that We receive from you with information obtained from third party data providers. | Processing necessary to perform a contract or to take steps at your request, before entering a contract |
Conditional offer process | To carry out pre-employment checks. | Our legitimate interest to confirm the identity of our staff and their right to work in the country where the job is located, and seek assurance as to their trustworthiness, integrity and reliability. |
Final offer process | To properly onboard you at Mirakl | Processing necessary to perform a contract or to take steps at your request, before entering a contract |
Creation and maintenance of a CV library | To find appropriate candidates to fill Our job openings. | Your consent is given when you consent to the processing of your personal information |
Newsletters | To keep you posted with Mirakl’s updates | Your consent is given when you consent to the processing of your personal information |
Pre-litigation or litigation management | to take action against any identified breach to manage any dispute or litigation | Our legitimate interest to defend our rights and interests |
Compliance with legal and regulatory obligations | to comply with legal and regulatory obligations to process your requests to exercise your rights | Legal and regulatory obligations to which we are subject |
Statistiques | to conduct data analytics studies to assess and better understand job application rates and the efficacy of our recruitment processes | Our legitimate interests to improve our recruitment activities |
6.How we make decisions about recruitment?
We do not take automated decisions about you using your Personal Data or use profiling in relation to you.
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take account of all the information gathered during the application process.
You can ask about decisions on your application by speaking to your contact in our recruitment team or by emailing privacy@mirakl.com.
7.Who can access your personal data?
Except as specified herein or permitted or required by applicable law, we do not generally share personal data about you with any third party without your permission and we do not allow third parties to collect personal data from you.
This does not include trusted third parties who assist us in operating our electronic portals and platforms, conducting our business or serving you, as long as those parties agree to keep this information secure and confidential. Those third-party providers shall only be granted access to the information they need to perform their designated functions and will be subject to confidentiality and data protection obligations regarding such information and will not be authorized to use your personal data for their own business purposes. We shall in no event be released from our obligations towards the users to the extent it uses such third-party providers.
More specifically, part of your personal data may be transmitted to the following recipients:
Recipients | Purposes |
Mirakl and its duly authorized employees | To process Your application and If you accept a final offer from us, your HR and payroll information will be held on BambooHR to enable us to provide HR services and process your salary payments. |
Companies of our group and their duly authorized employees | To process Your application |
Greenhouse | To operate our online application system and to produce anonymised management information about campaigns, as well as to receive and manage job applications sent to us by selected recruitment agencies. Here is the link to Greenhouse Privacy Notice. |
Bamboo | To enable us to provide HR services and process your salary payments. Here is the link to Bamboo Privacy Notice. |
Third party providers to carry out reference checks and on-boarding activities in the event you accept an offer of employment or engagement from us. | to enable us to provide HR services |
Our payroll service, insurers and other benefits providers, our bank | to enable us to provide HR services |
Mirakl’s subcontractors (hosting providers, support service provider, logs monitoring, etc.) | Technical services |
Administrative or judiciary authorities | Exclusively in the case of an express and justified request or in case of an alleged violation of legal or regulatory provisions |
Lawyers and other interested parties | Exclusively in the case of the management of possible disputes and other legal matters where appropriate |
Other third parties | Following or during a restructuring, reconstitution, acquisition, debt financing, merger, sale of assets or a similar transaction, as well as in case of insolvency, bankruptcy or receivership where personal data are transferred to one or more third parties as our assets |
8.Third-party marketing
We do not share your personal data with any organisations outside of Mirakl for marketing purposes.
9.Will your personal data be transferred outside of the European Economic Area?
If you are located in the European Economic Area (EEA), as far as possible, your personal data are processed within EEA. However, some of the companies of our group, as well as our services providers being located outside of the EEA, your personal data may therefore be processed in those countries.
When your personal data are transferred outside the EEA, we will, in the absence of an adequacy decision and after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient of your personal data is established, implement all necessary measures through the adoption of appropriate safeguards (such as standard contractual clauses).
10.How do we protect your personal data?
We have implemented technical and organizational measures to protect your personal data, in particular, against potential data breaches likely to cause, either by accident or unlawfully, the destruction, loss, modification, unauthorized access or divulgation of your personal data. These measures will guarantee a level of security adapted to the data and will take into account the state of the art and the cost of implementation in relation to the risks and nature of the data to be protected. We use SSL certificates to encrypt this Website and only a limited number of staff have access to your personal data.
We guarantee that our personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of personal data, including the technical and organizational security measures put in place to protect your personal data. In this context, we review and update our practices regularly to enhance your privacy and ensure that its internal policies are followed.
If you have found a vulnerability or would like to report a security incident, please visit vdp.mirakl.com.
11.For how long are personal data stored?
Generally, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfill legal or regulatory obligations.
For all applications, We will retain Your Personal Data for two years from the last contact (in CV library in case of consent).
12.What are your rights regarding your personal data?
Under certain circumstances, you might have the following rights under data protection laws over your Personal Data
Right to be informed about how personal data is used – you have a right to be informed about how we will use and share your personal data. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language;
Right to access personal data - you have a right to obtain confirmation of whether we are processing your personal data, access to your personal data and information regarding how your personal data is being used by us;
Right to restrict processing of personal data in certain circumstances - you can request the restriction of the processing during a limited period of time, in particular in order to carry out some verifications, where one of the following applies:
you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for us to verify the accuracy of such personal data;
you object to the erasure of your personal data on the ground of the processing being unlawful and you request the restriction of their use;
we no longer needs your personal data for the purposes of the processing, but you need them for the establishment, exercise or defense of legal claims;
you have objected to the processing, which is thus restricted pending the verification of whether the compelling of our legitimate grounds may override your interests, rights and freedoms.
Right to object to processing of personal data in certain circumstances, including where personal data is used for marketing purposes - you have a right to object to processing being carried out by us if (a) we are processing personal data based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal data for direct marketing purposes, or (c) if information is being processed for statistical purposes. You will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information; and
Right to data portability – in certain circumstances you can request to receive a copy of your personal data in a commonly used electronic format. This right only applies to personal data that you have provided to us (for example by completing a form or providing information through a website). Information about you which has been gathered by monitoring your behaviour will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the personal data must be processed for the performance of a contract and the processing is carried out by automated means (i.e. electronically);
Right to have personal data erased in certain circumstance - you can request the deletion of your personal data (or right to be forgotten), where one of the following legal grounds applies:
you object to the processing of your personal data and there are no overriding legitimate reasons justifying to maintain the processing of your personal data , such as an obligation for us to keep certain documents with personal data;
you object to marketing activities;
you decide to withdraw your consent on which the processing is based;
your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
the use that is made of your data does not comply with the applicable legal or regulatory provisions.
If you are based in France, you can define either general or specific guidelines regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You may revoke your instructions at any time.
If you are based in USA, you have additionally:
the right to request us to restrict the use of your sensitive personal information such as social security number, religious beliefs etc. by limiting its use and disclosure for specific business purposes;
the right to opt out of the sale of your personal information to third parties. Note we are not selling your personal information nor planning to sell it.
the right to know that is materialized by the existence of this policy.
Under certain circumstances, we may ask you for specific information to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.
If you have any questions or wish to exercise your rights, you may fill in this form or directly contact us by sending an email to privacy@mirakl.com.
If needed, you may also lodge a complaint with your national data protection authority. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third party assistance for the procedure.
13.Changes to this policy
This privacy policy may be amended from time to time, in particular to reflect the changes in the Website or the applicable regulations. Therefore, we recommend you review this privacy policy each time you use our electronic portals and platforms.
Should you have any questions, you may directly contact us by sending an email to privacy@mirakl.com.