Recruitment Privacy Notice
LAST UPDATED: MAY 4, 2026
1. Purpose of this notice
This notice aims to give you information about how Mirakl collects and processes your personal data. It explains how Mirakl collects, uses, retains, and protects the personal data you share with us in connection with our recruitment activities.
It applies to any person applying at Mirakl, whether for a training contract, fixed term, internship, apprenticeship, etc.
References in this notice to “you” or “your” are references to individuals whose personal data Mirakl processes in connection with the items listed above. References in this notice to “Mirakl”, “we”, “us” or “our” are references to Mirakl SAS and its affiliates. Mirakl SAS is a Société par Actions Simplifiée located at 12, rue de Lübeck 75116 Paris.
Mirakl SAS acts as the primary controller for the processing activities described in this notice. In some cases, Mirakl’s affiliates involved in the recruitment process may also process your personal data in accordance with this notice.
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 policies 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 policies and is not intended to override them.
2. 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.
3. How do 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. For instance, you may provide your personal data through forms when you apply for a job opening, or through emails, interviews, and other communications with us.
Where necessary, and in accordance with this notice, we may also collect information through references, pre-engagement screening, or background checks.
We may also receive data from third parties involved in the recruitment process, such as recruiters, agents or other intermediaries, or from referrals from one of our employees or clients.
In addition, information may be collected through interviews and during the broader recruitment process, including through recruitment support tools used for interview documentation and administration purposes.
4. What personal data are we processing?
The notion of “personal data” includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to 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. Personal information such as your name, email address, address, date of birth, qualifications, experience, information relating to your employment history, skills and experience, and any other information you choose to share with us as part of your application.
Information collected during the recruitment process and interviews, notably where interviews are transcribed or summarized using our support tools for note-taking and documentation purposes;
Your voice and likeness, where the interview is recorded with your approval, notably when conducted with Mirakl’s AI vocal agent;
Records of communications and correspondence, and any information they may contain, if you contact us during the recruitment process.
Information regarding your progress through any hiring process that we may conduct, including interview feedback and assessment outcomes.
If your application is successful, information necessary to prepare your onboarding and employment relationship, such as bank account details, information regarding your right to work in the jurisdiction in which you have applied, social security number, ID or passport, etc.
5. For what purposes do we use your personal data?
We will only process your personal data when the law allows us to, that is, when we have a legal basis for the processing activity.
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 (e.g., universities) for the recruitment | To find appropriate candidates to fill our job openings | Our legitimate interest in identifying and recruiting suitable candidates |
Responses to candidates | To communicate with you in respect of the recruitment process To enrich any information that we receive from you with information obtained from third party data providers | Our legitimate interest in managing the recruitment process |
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 is necessary to perform a contract or to take steps at your request, before entering a contract |
Creation and maintenance of a candidates database | To find appropriate candidates to fill our job openings | Our legitimate interest to consider your profile for potential future opportunities at Mirakl |
Newsletters | To keep you informed of Mirakl's updates | Your consent |
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 |
Statistics | To conduct 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. Is AI used in our recruitment process?
We use artificial intelligence ("AI") tools in parts of our recruitment process to help improve efficiency, consistency, and the candidate experience. These tools may assist with activities such as job descriptions drafting, interview note-taking, organizing candidate information, and supporting preliminary screening.
AI is used only as a support tool and always under human oversight. It does not replace human judgment or decision-making. We do not use AI to make fully automated decisions that have legal or similarly significant effects on candidates. All hiring decisions are made by qualified members of our recruitment team, with meaningful human review at every stage of the process.
We are committed to using AI responsibly, fairly, and transparently, while respecting candidate rights and applicable data protection requirements. More information about how AI may be used during the recruitment process is available in our AI Guidelines for Candidates and Interviews.
These guidelines also explain how candidates may use AI during the recruitment process. While AI may be used appropriately, candidates are expected to ensure that their applications and interview responses reflect their own skills, knowledge, and experience.
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 are only 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 you to the extent we use such third-party providers.
More specifically, part of your personal data may be transmitted to the following recipients:
Recipients | Purposes |
|---|---|
Mirakl, its affiliates, and its and their duly authorized employees | To process your application and if you accept a final offer from us, your HR and payroll information will be processed to enable us to provide HR services and process your salary payments. |
Applicant Tracking System (ATS) and HR Information System (HRIS) | 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. To enable us to provide HR services and process your salary payments. |
Third party providers to carry out reference checks and onboarding activities in the event you accept an offer of employment or engagement from us. | To enable us to provide HR services |
Our payroll services, insurers and other benefits providers, our banks | To enable us to provide HR services |
Mirakl's subcontractors (hosting providers, support service provider, logs monitoring, etc.) | To provide technical services necessary for us to carry out our processing activities |
Mirakl's AI support tools | To streamline certain aspects of the recruitment process, including interview transcription and summarization, candidate communications, outreach emails, etc. |
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. 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 the 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 the execution of the European commission's standard contractual clauses).
9. 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 disclosure 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. 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 our internal policies are followed.
If you have found a vulnerability or would like to report a security incident, please visit vdp.mirakl.com.
10. For how long are your 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. If your application is unsuccessful, your data will be deleted in accordance with our retention policies.
However, unless you object to it, we may retain your personal data for up to two years from your last contact with us, in order to consider your profile for potential future opportunities at Mirakl.
11. What are your rights regarding your personal data?
As a data subject, you are granted certain rights over your personal data, in particular under the General Data Protection Regulation (GDPR). You may therefore exercise the following rights, subject to the conditions and limitations set out in applicable law:
Right to be informed about how your personal data are used – you have a right to be informed about how we 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 your 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 are being used by us.
Right to restrict processing of personal data in certain circumstances – you can request the restriction of the processing activities we carry out 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 need 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 our legitimate interests may override your interests, rights and freedoms.
Right to object to the processing of your personal data in certain circumstances, including where personal data are 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.
Right to rectification – you may request that your data be rectified or updated, if you consider that the personal data we process is inaccurate or incomplete. We will in such a case proceed to the rectification you requested.
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, the data you provided to us when you filled out a form to apply to a job opening). 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 your personal data erased in certain circumstances – 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; and
the right to know, as reflected by this notice.
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 are 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.
12. How to contact us
If you have any questions, concerns, or would like to make a complaint about how we process your data, you may fill in this form or directly contact us by sending 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 our processing of your personal data.
13. Changes to this notice
This notice may be amended from time to time, in particular to reflect the changes in our recruitment activities or applicable laws and regulations. Therefore, we recommend you review this notice each time you use our electronic portals and platforms.