Privacy Policy
for Fin Path
HR Path respects your privacy and agrees that the collection and processing of your datafrom visiting, www.hr-path.com, comply with the General Data Protection Regulations (GDPR) and the Computer and Liberties Law.
1. Introduction
This Privacy Policy tells you how the HR Path Group make use of your personal data when you visit our website, interact with us, and buy our goods and services.
It also tells you about your privacy rights and how the law protects you.
It is important that you read this Privacy Policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.
This Privacy Policy was last updated on 16th of May 2018 and historic versions can be obtained by contacting us.
If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this Privacy Policy. See ‘How to contact the HR Path Group about confidentiality’ below.
2. Our website
Our website, www.hr-path.com promotes our specialized human resources services for small and large companies. Our site also allows us to provide information on Human Resources in the form of a blog.
3. The personal data we collect about you
Personal data, or personal information, means any information about an individual that can be used to identify them. This does not include information where the identity is hidden (anonymous data).
We collect a variety of information about our customers and visitors to the HR Path website. This personal data is divided into different categories: Identity Data includes title, first name, last name, company and function. Contact Data includes e-mail address and phone numbers. Technical Data includes your IP address, login details, type and version of your browser, time zone and location, browser plug-in types and versions, your system and operating platform, and other technologies on the devices you use to access this website. Usage Data includes information about how you use our website and our services.
Tracking Data includes information that we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixel tags, or mobile identifiers.
We collect anduse Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may come from your personal information, but is not considered as such by law, as this data does not directly reveal your identity. For example, we can aggregate your Usage Data to calculate the percentage of users who access a specific feature of the website. For the purpose of providing better content and services, the HR Path website uses the Google Analytics website analytics service that logs actions and browses our website. Google Analytics does not follow your browsing habits on third party websites. The information about you to which Google Analytics has access doesn’t contain any personal data about you. Please consult their Privacy Policy.
However, if we combine Aggregated Data with your personal data, so that it may identify you directly or indirectly, we will treat that combined data as personal data that will be used in accordance with this Privacy Policy.
We do not collect Special Categories of Personal Data (this includes details about your race or ethnicity, your religious or philosophical beliefs, your sex life, your sexual orientation, your political opinions, your trade union membership, information about your health, genetic or biometric data). We also do not collect information about criminal offenses or convictions.
Remember that if you choose not to share personal data with us or refuse certain contact permissions, we may not be able to provide the requested services and information.
4. How is your personal data collected?
We use various methods to collect data about you, includingdirect interactions. You can provide us with your Identity Data and your Contact Data by completing our forms or by contacting us via mail, phone, e-mail, chat or social network. This includes the personal data that you give when you:
- Sign up to receive the HR Path Newsletter;
- Ask questions or ask to receive information;
- Order our services;
- To contact us on social networks;
- Participate in a contest, promotion or survey;
- Contact customer service;
- Meet HR Path personnel at an event
5. How we use of your personal data
We do not rely on consent as the legal basis for processing your personal information, except where required by law, for example for sending direct marketing communications.
When the legal foundation is based on consent, you have the right to withdraw your consent at any time.
See ‘Explanations’ of the legal basis governing the treatment we do of your personal data to learn more about the legal principles on which we rely to process your personal data.
6. Explanations of the legal basis governing the treatment we do of your personal data
The table below describes all the ways in which we intend to use your personal data and the legal principles we use to do so. We have also indicated our legitimate interests, if any.
| Purpose / activity | Data types |
| Subscribe to HR Path newsletter | Identity Data Contact Data |
| Information request | Identity Data Contact Data |
| Quotation request | Identity Data Contact Data |
| Request for an appointment | Identity Data Contact Data |
| Other request | Identity Data Contact Data |
| Job application | Identity Data Contact Data |
| Contact us on social networks | Identity Data Contact Data |
| Order our services | Identity Data Contact Data |
| Participate in a contest, a promotion, a survey | Identity Data Contact Data |
| Contact customer service | Identity Data Contact Data |
| Meet HR Path personnel at an event | Identity Data Contact Data |
Please note that we may process your personal data according to different legal basis depending on the specific purposes for which we use your data.
We don’t perform automated decision making. Feel free to contact us with any questions about this (see below: ‘How to contact HR Path about confidentiality’)
7. Your advertising, marketing and communication preferences
We may use your Identity Data, your Contact Data, your Technical Data, your Tracking Data and/oryour Usage Data in order to get an idea of what you might want or need or what might interest you.
This is how we decide which services and offers are relevant to you and inform you. This is what we call direct marketing communication. This can be conducted by e-mail, phone, SMS or mail.
For example, you may receive the HR Path Newsletter in your inbox or an interesting advertisement via SMS.
On our site, we do our best to make it clear what we are doing and what communications you will receive, whether you decide to subscribe to the Newsletter orwhen you make contact or meet with a member of theHR Path Group at an event.
You also have the right to change your mind at any time and to also decline. The simplest way to refuse is to click on the unsubscribe link at the bottom of the communication.
There are of course many ways to advertise and you will see ads for HR Path in various places. These methods are not all based on the use of personal data.
Sometimes, as before, we buy advertising spaces in the real world or on websites and social networks. If you see advertisements from the HR Path Group on websites and social networks, they may not be aimed at you personally, it is possible that we have just reserved the space.
Some of the actions we lead are specifically for you:
- E-mails, for example the Newsletter;
- Phone calls to give you relevant information for you and your business.
8. Cookies
After reading the previous paragraph, ‘Your preferences in advertising, marketing and communication’, you know that cookies are a tool that we (and any online business) use for advertising. But this is only one aspect of the interests brought using cookies. They are usually smart.
Some cookies collect information about how visitors use hr-path.com. For example, which pages are most often visited or if error messages have appeared on certain pages. These cookies do not collect information to identify a visitor. All information collected by these cookies is aggregated and used to improve the functioning of hr-path.com
These cookies can also be used to save your text size, font or other portions of the Internet pages that you can customize. They are also used to provide services that you have requested, such as watching a video or commenting on a blog.
Some cookies collect information about your browsing habits to provide more relevant advertising (see Your advertising, marketing and communication preferences above). They are usually placed by ad networks with our permission. They keep in mind your visit to a website and this information is shared with other companies such as advertisers. Often, targeting or advertising cookies will be linked to the features of the site provided by the other company.
When you use hr-path.com, your device or browser may receive third-party cookies, for example when using embedded content and social networking links. It is important for you to know that we have no access or control over the cookies used by these companies or third-party sites.
We advise you to consult the website of the third-party for more information about their cookies and how to manage them.
FIN Path obtains your consent in accordance with the policies and technical specifications of the IAB Europe Transparency & Consent Framework. It uses the Consent Management Platform n°92.
You can change your choices at any time by clicking here.
9. Disclosure of your personal data
Your personal data may be shared with the parties listed below for the purposes set out in this Privacy Policy. Your personal data may also be shared if the law allows it.
Your personal data may be shared with the following categories of third-parties:
- The companies of the HR Path Group
- Professional auditors and advisors such as bankers, lawyers, accountants and insurers
- The government, regulators and the police
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, modified, disclosed or accessed without authorization. In addition, access to your personal data is restricted to employees, agents, contractors and other third-parties on a need to-know basis. They will process your personal data in accordance with our instructions and are subject to the obligation of confidentiality.
We have procedures in place to deal with any alleged violation of personal data. You and any competent regulator will be notified of such violation when required by law.
11. Links to third-party sites
This website may contain links to sites. Clicking on these links may allow others to collect or share information about you. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our site, we advise you to read the Privacy Policy of each site you visit.
12. Retention of data
Your personal data will only be kept for the time necessary to implement what they were collected for. This includes legal, accounting or reporting requirements. We suggest you delete your data at any time by contacting our teams (See: ‘How to contact HR Path about confidentiality’)
To determine the appropriate period of retention of your personal data, we take into account the quantity, nature and sensitivity of such data, the potential risk of harm caused by unauthorized use or disclosure, the purpose of their processing and the possibility of achieving this goal by other means, and the applicable legal requirements.
In some cases, you may ask us to delete your data. See ‘Your legal rights’ below for more information.
In some cases, we anonymize your personal data (so that they are no longer associated) for statistical or research purposes, in which case we may use them indefinitely, without further notice.
13. Your legal rights
If the General Data Protection Regulation applies to you because you are in the European Union, you have the following rights regarding your personal data, in accordance with data protection legislation:
- The right to be informed: we have the obligation to inform you of how we use your personal data (what we do in this Privacy Policy);
- The right of access: the right to make a request for access to your personal data so you can receive a copy of the personal data that we hold about you;
- The right of rectification: the right to ask us to rectify personal data about you that is incomplete or inaccurate;
- The right to erasure, also known as the “right to be forgotten”. In some cases, you can ask us to delete the personal data we have about you (except if there is a legal reason imperious which obliges us to preserve them);
- The right to limit processing: you have the right in some cases to ask us to suspend the processing of personal data;
- The right to portability of data: you have the right to request a copy of your personal data in a common format (for example a .csv file);
- The right of opposition: you have the right to oppose the processing of your personal data (for example, by prohibiting us from processing your data for direct marketing purposes); and Automated Decision and Profiling Fees: You have the right to ask us to be transparent about any profiling we do or any automated decision.
The exercise of these rights is subject to certain rules. If you are interested, you will find more information on this subject on the .
Contact us if you wish to exercise any of the rights described above (see ‘How to contact HR Path for confidentiality’)
You will not have to pay any fees for access to your personal data (or to exercise any other right). However, we may charge you a reasonable fee if your request is manifestly unfounded, repetitive or excessive. In this case, we may also refuse to respond to your request.
We may ask you for specific information to confirm your identity and to ensure your right of access to your personal data (or to exercise any other right). This is a security measure to ensure that this personal data is not delivered to a person not authorized to receive it. We may also contact you to obtain more information about your request, to give you a faster answer.
We try to answer all legitimate requests within a month. This period of one month may be exceeded if your request is particularly complex or if you have submitted more than one request. In this case, we will notify you and keep you informed.
We have appointed a Manager of Confidential Information to oversee matters regarding this Privacy Policy. If you have any questions about this Privacy Policy or if you want to exercise your legal rights, please contact the Manager of Confidential Information as described in the paragraph below.
Contact HR Path for confidentiality.
You have the right at any time to file a complaint with the National Commission for Data Protection and Liberties (CNIL), the supervisory authority for data protection issues in France –https://www.cnil.fr/
However, we would like to have a chance to respond to your concerns before you contact the CNIL.
Please contact us first.
14. How to contact Fin Path / HR Path about confidentiality
If you have any questions about this Privacy Policy or to exercise any of your rights, please contact us by e-mail or by mail addressed to:
HR Path
Tour Franklin, étage 11
100-101, Terrasse Boieldieu
92042 Paris La Défense Cedex
FRANCE
Tel : +33(0) 153 622 214
15. Changes to the Privacy Policy
The General Data Protection Regulation is recent and the CNIL continues to issue new advice to companies to respect it. Thus, you will see updates to our Privacy Policy in the coming months.
Please feel free to read and review at your convenience.
Thank you