The application Rhaegal4Smart (hereinafter “the Application”) is a set of tools for administrators (hereinafter “the Service”). These tools consist of the following options:

• User2Smart is an admin tool that helps You create or update easily Users into SmartRecruiters with a simple csv file.
• Org2Smart is an admin tool that helps You create or update easily Organisation data into SmartRecruiters with a simple csv file.
• Translate2Smart is an admin tool to upload translations into SmartRecruiters with a simple CSV file.
• Blind4Smart is a tool to trigger anonymization of candidate files based on application progress.
• Form4Smart is a tool used to collect information from candidates during the hire process.
• Maps4Smart is a tool that helps You create or update easily a standard career web site by geocoding publicly available job details.

By accessing the Application and using the Service, You agree as User or Client to have read and accepted the following Privacy Policy. This Privacy Policy is subject to change and any change will be incorporated into this document from time to time. If You do not agree with this Privacy Policy, please do not access the Application and use the Service.

1. Definitions

As used in this Privacy Policy, the following terms shall have the following meanings:
Application: means the admin tool named Rhaegal4Smart and its activated options (Users2smart, Org2smart, Translate2Smart, Blind4Smart, Maps4Smart, Forms4Smart) and the private interface created by RHAEGAL and dedicated to Client.
Application Host: means the company Amazon WebServices, 52 rue du port 92000 Nanterre France.
Client: means the company which is client of SmartRecruiters and which subscribes as a professional a Client Account to the Service.
Client Account: means the subscription by the Client to the Service. The Client will set up his profile by sending the required data (such as, first name, last name, email) to Rhaegal by email to sales@rhaegal.com. The Client will then receive a personal and confidential Rhaegal License Key. The Rhaegal License Key is mandatory to access the Application. There is no username or password per say as User2Smart and Org2Smart uses SmartRecruiters authentication mechanism.
Client Data: means all information, feedback or data (including Personal Data) fulfilled by Client in the Service.
Client Information: means all information or data (included Personal Data) provided by Client to RHAEGAL to subscribe to the Service, such as the email address of the Client.
Data Subject: means the natural person to whom the Personal Data relates.
Personal Data: means any information that is related to a (directly or indirectly) identified or identifiable individual.
Profile: means the interface dedicated to Client.
Service: means the services provided by RHAEGAL to Client as identified on the Application.
SmartRecruiters: means the services named SmartRecruiters (https://www.smartrecruiters.com/fr/home/) and provided by SMARTRECRUITERS Inc, a Delaware corporation with its principal offices located at 225 Bush Street, Suite #300, San Francisco CA 94101.
User: means any physical person who accesses the Application as a professional.
You/Your: The Client.
We: means the French company RHAEGAL SAS (1011 route de Montastruc – 33880 Baurech) or the Application.

2. Introduction

We respect and protect Your privacy. In the following, You can read about how we handle your Personal Data. This Privacy Policy complies with the EU General Data Protection Regulation 2016/679 (‘GDPR’) and French law.

To provide the Service, RHAEGAL is responsible for collecting, storing and processing Client Information as data controller.

To use the Service, the Client is responsible as data controller for collecting and transferring Client Data to RHAEGAL and RHAEGAL may process Client Data as data processor on behalf of the Client.

In any case, RHAEGAL and the Client undertake to respect the GDPR regulation.

3. Lawful basis for data processing

When We process Client Information or Client Data, the lawful basis for the processing is the contract between You and RHAEGAL.

If the lawful basis for processing is consent, You have the right to withdraw your consent as mentioned hereafter at any time, but this does not affect the legitimacy of the processing by RHAEGAL prior to your withdrawal of consent.

We shall also share Personal Data with law enforcement agencies or other governmental bodies because of legal obligation.

4. Purposes for process Personal Data

Regarding Client Information

We collect, store and process Client Information which may include an individual’s name, contact details (telephone, email…), job title and other information necessary for providing You the Service.

We may use Personal Data with Your consent, if such is required, to inform You of the RHAEGAL services. If You do not wish to receive any further information You can easily and free of charge unsubscribe from our newsletter anytime. You can find an unsubscribe link at the bottom of e-mails, or You can contact us by e-mail or post to unsubscribe. When You unsubscribe from receiving marketing communication, we will delete Your Personal Data immediately, unless We process Your Personal data for other purposes.

We will retain Client Information for the length of time needed to fulfil the purposes above mentioned.

Three years after termination or cancelation of the Service, RHAEGAL undertakes to delete all Client Information from our servers.

Regarding Client Data

We transfer Client Data to SMARTRECRUITERS in compliance with Your instruction as data controller.

We shall process Client Data only in relation to this relevant purpose, only to the extent necessary to provide the Service to You, and only as instructed by You, as data controller.

Client Data may include the following Personal Data: first and last names, professional email, professional addresses and job titles of Client’s employees licensed to use SmartRecruiters (Recruiters, Managers and employees when internal mobility is used). For the option Forms4Smart, Client Data may include sensitive data like social security numbers.

Client Data is not stored by RHAEGAL.

5. How we collect Personal data

We collect Personal Data, You provide us, when You create a Client Account, when You use the Service or other activities on our Application or otherwise interact with us.

The Client is the only one to know how Client data are collected. Collection of Data Client regarding GDPR regulation is under his own responsibility (especially the obligation to inform the Data Subject about the collection of his Personal Data, for what purpose and his data protection rights).

Unless the Client considers it necessary, the Client undertakes to not collect sensitive data as Client Data or Client Information.

6. Recipient of Personal Data

We will not share Your Personal Data, unless with SMARTRECRUITERS and our Application Host.

7. Your data protection rights

As Client

In accordance with GDPR, You may request access to the Personal Data which We store on You, to correct inaccurate or incomplete data and in certain circumstances You can ask for the data We store on you to be transferred to another controller, restricted or erased from our records (the rights as a person). You may also object against our processing of your Personal Data.

You may change your choices in terms of subscription to our emailing.

You may exercise your rights or request access to your Personal Data, by contacting: personaldata@rhaegal.com. We will respond to your request to exercise any of your rights within one month. If We extend the response period, We shall inform you within one month from your request.

If you have any questions regarding the specific Personal Data about You that We process or retain, please contact personaldata@rhaegal.com.

As Data Subject

If RHAEGAL receives a Data Subject Request, RHAEGAL shall promptly redirect the Data Subject to You as Data Controller, unless the Data Processor is entitled to handle such request itself.

RHAEGAL shall promptly notify the Client as data controller of any third party or Data Subject complaints regarding the processing of Client Data; or any government or Data Subject request for access to or information about the collection or processing of Client Data undertaken by RHAEGAL in the context of the Service.

8. Data security

The security, integrity and confidentiality of Your Personal Data are extremely important to us. We have implemented technical, administrative and physical security measures (such as regular backups) that are designed to protect Your Personal Data from unauthorized access, disclosure, use and modification. From time to time, We review our security procedures to consider appropriate recent technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

RHAEGAL shall ensure its employees process Client Data in accordance with data controller’s instruction, receive appropriate training on their responsibilities regarding the handling and safeguarding of Personal Data; and are subject to confidentiality obligation.

RHAEGAL shall ensure that access to Client Data and Client Information is limited to personnel who require such access to deliver the Service. After becoming aware of a Client Data breach, RHAEGAL shall:

a) promptly notify the Client as data Controller of the Personal Data breach,

b) immediately investigate the Personal Data breach and within a maximum of 24 hours provide the Client as data controller with information about the Personal Data breach, which enables the Client as Data Controller to notify the supervisory authority and Data Subjects,

c) take reasonable steps to mitigate the effects and to minimize any damage resulting from the Personal Data breach.

Save provisions above, RHAEGAL must assist the Client in ensuring compliance with the data controller’s obligations under article 32-34 of the General Data Protection Regulation. This assistance will consider the nature of the processing and the information available to RHAEGAL as data processor.

9. Data transfers and storage

Wherever Your Personal Data is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of Your Personal Data.

If the data is transferred to data processors outside EU/EEA, it must be stated that the data protection legislation applicable in the data controller's country applies to data processors outside EU/EEA.

Client Information is stored on servers located in France.

Any question or comment?

If you have a comment or question about our data processing, please email us at personaldata@rhaegal.com.

If you consider that we have failed in our data protection compliance, you may file a complaint to the CNIL via www.cnil.fr.