The purpose of this privacy policy is to define the conditions under which Mensialis Recruitment Sàrl, having its registered office at 6 Rue d’Arlon, L-8399 Windhof, registered with the Registre de Commerce et des Sociétés de Luxembourg [Luxembourg Trade and Companies Register] under number B267814 (hereinafter referred to as “we,” “us,” or “Mensialis Recruitment“), collects and processes the personal information of any user (hereinafter referred to as “you,” or the “User“) of the website accessible at https://mensialis-recruitment.com (hereinafter referred to as the “Website“).

Mensialis Recruitment attaches great importance to respecting your privacy. Your personal data is processed by it, as data controller, in compliance with the applicable data protection legislation (namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the Act of 1 August 2018 on the organization of the National Commission for Data Protection and the general data protection regime on the protection of natural persons with regard to the processing of personal data, as well as any other subsequent regulations).

• The provisions of this Policy shall apply whenever you apply online for a job vacancy we have advertised on the Website, submit an unsolicited application to us via the Website or send us an enquiry via the contact form on the Website. This Policy sets out how we process the personal data you provide to us for these purposes.
• Personal Data means any information that identifies a natural person (surname, first name, email address, telephone number, CV, etc.) directly or indirectly.
• We do not collect Personal Data other than those indicated in this Privacy Policy.
• We use Zoho Recruit, a cloud-based application, to assist us in our recruitment process. Zoho Recruit processes Personal Data on our behalf and is authorized to process your Personal Data only in accordance with our instructions in a processor capacity.

1/ Data we collect when you browse the Website

Your visit to the Website is recorded. We may automatically collect certain information from your device, such as IP address, MAC address, your device ID, but also the operating system there (e.g. Windows, Mac OS), the pages visited, the requests made and the day and time of connection, through log files and cookies.

More specifically, we collect detailed information about your visits to the Website, including but not limited to traffic data, location data, web files and other communication data, the third party website that referred you to the Website, and the resources you access.

Under no circumstances is the full IP address of the User retained, but only a part thereof for the purpose of compiling statistics. It is not in the least possible to identify a particular User.

Such Visit Data enable us to collect and compile anonymous data for statistical purposes on the use of the Website. They are also useful to us for detecting fraud and breach in the use of the Website as well as any other incident likely to affect the security thereof.

The processing of this Visit Data thus allows us to improve the Website and to detect any fraud/abuse in its use. It is in our legitimate interest to serve our Users as well as to ensure the protection of our assets.  This aim is the legal basis for the processing of Visit Data to which we proceed. When you first visit the Website, a banner will appear at the bottom of the home screen informing you of the use of cookies during your navigation of the Website and the purpose of each cookie. It is up to you to choose whether or not to accept the deposit of cookies depending on the purpose of each cookie. Some cookies do not collect any personal data but simply provide a better browsing experience.

To find out more about the types of cookies and similar technologies we use, why and how you can manage cookies and withdraw your consent, please see our Cookie Management Policy.

2/ Data we collect about you as a potential candidate

We collect Personal Data about you from the following sources:

• You, the candidate, through the Website, a career website, by email, in person during video interviews, and/or by any other method. Please see the section below for details.
• The people who referred you (other candidates, employers, etc.) from whom we have collected your Personal Data such as forename and surname.
• Trusted third party suppliers who recommend you as a candidate for a specific vacancy or for our company more generally.
• Publicly available sources, such as LinkedIn or source boosters (Indeed, Monster, Career Builder, Dice, etc.), where we collect your full name, email address, work history, and other data included in your profile, in order to improve the information we have about you, and to complete your application package where appropriate.

a) Personal information we collect directly from you

When you apply online for a job vacancy that we have advertised on the Website or submit an unsolicited application to us via the Website, we collect the following Personal Data :

• Surname
• Forename
• Contact details (email, telephone number)
• Education
• Professional experience
• Skills/qualifications
• CV or transcripts and any supporting documentation attached to your CV, such as copies of certificates, passport, application letters, etc.

When you complete the contact form on the Website, we collect the following data:

• Surname;
• Forename;
• Name of company that employs you;
• E-mail address;
• Telephone number;
• Job title;
• Sector of activity;
• Content of messages intended for us.

By providing this information, you acknowledge that your Personal Information will be processed by Mensialis Recruitment for the purposes indicated in section 3 below and under the conditions described in this policy.

In addition, we collect your Personal Data when you contact us directly through any communication channel (e.g. when you send us an e-mail containing a comment or feedback).

b) Purposes of collection

We process your Personal Data to determine whether you are suitable for the job. It would be impossible for us to consider your application without said processing. We use your Personal Data to:

• Identify and assess candidates for potential employment, and for positions that may become available in the near future;
• Conduct background checks;
• Keep records relating to recruitment so as to document our activities;
• Communicate with you and respond to your requests or applications;
• Handle contact and/or information requests made via the Website;
• Handle requests for demonstrations of our services;
• Contact you about various events organized by Mensialis Recruitment, including updates to our services;
• Obtain information about your marketing preferences: we collect such information whenever you subscribe or unsubscribe;
• Improve the functionality of the Website;
• Fulfil our legal obligations;
• Manage requests for access, rectification, objection and other such rights relating to Personal Data;
• To manage any disputes that may arise.

In the event of further processing for a purpose other than those listed above, we undertake to apprise you of such other purpose in advance.

c) Legal bases for processing the data we collect about you as a potential candidate

The Personal Data processed by Mensialis Recruitment are strictly necessary in order to provide the services requested by the potential candidate or the User, as well as to enable Mensialis Recruitment to fulfil its legal obligations. These purposes constitute the legal basis for the processing of data by Mensialis Recruitment.

When you apply for a job offer through our job website integration and rapid application service providers, you expressly accept that this data will be transmitted to said service provider on the basis described below.

d) Recipients of the data

Personal Data are processed internally by duly authorized persons, within the scope of their respective responsibilities.

They may be communicated to recruiting companies or companies with vacancies, as well as to our subcontractors and service providers (such as auditors, legal advisors, trusts, providers of analytical solutions or payment services, companies and organizations specializing in fraud protection and the reduction of the risk of non-payment, etc.), to the extent strictly necessary and subject to contractual guarantees so as to ensure the security and confidentiality of said data.

In this regard, your Personal Data is passed on to our cloud service provider Zoho Recruit as well as to third party integrations provided by Zoho Recruit for background checks, assessments, etc., which use your Personal Data in accordance with your instructions and in strict compliance with the legislation on the protection of personal data. Except in these cases, and unless otherwise provided by law or requested by the competent administrative and judicial authorities, we will not disclose the information you send us without your express consent.

 

For example:

1. When you apply for a job vacancy via our Website, and provided you have consented to such disclosure, we will disclose to the service provider certain personal data in our possession which includes but are not limited to a unique identifier used by the service provider to identify you, and information about your progress through our recruitment process for the vacancy in question,  as well as any tangible, intangible, visual, electronic, present or future information we have about you, such as your name, contact and other details involved in the data analysis process relating to you as a job applicant (collectively referred to “Disposition Data”). The service provider’s Privacy Notice on how it uses such shared data will be available on its website.

As a general rule, no data are transferred outside the European Union.

However, when your personal data are transferred (including in the case of remote access) to a country outside the EU which is not subject to an adequacy decision by the European Commission, appropriate safeguards are put in place pursuant to Chapter V of the GDPR, including a contract that complies with the standard contractual data protection clauses adopted by the European Commission.

3/ Data retention period

We determine appropriate retention periods with due consideration of the purposes indicated in this privacy policy and the applicable legal requirements. For more information on how long we keep your data, you can contact us at the address indicated below.

4/ Security

Mensialis Recruitment undertakes to implement technical and organizational measures of such nature as to ensure the security of data.

The personal data collected are kept in a secure environment. Persons working for Mensialis Recruitment are required to respect the confidentiality of such data.

Mensialis Recruitment undertakes to maintain a high degree of confidentiality by integrating the latest technological innovations so as to ensure the confidentiality of Personal Data.

In the event of a security breach, we will notify you and any competent regulator when legally required to do so.

5/ Your rights

As a natural person, you have a certain number of rights concerning your Personal Data within the limits provided by the applicable legislation, namely:

• the right of access to data: You may request at any time access to your data, confirmation as to whether your Personal Data are being processed, information for at least – but not limited to – the purposes of the processing, the categories of data concerned and the recipients or categories of recipients to whom the data are disclosed, as well as a copy of such data;
• the right to request rectification of data: You may request at any time that inaccurate or incomplete data be rectified;
• the right to request the removal of data: You may request that your data be removed when, for example, the data are no longer necessary for the purposes for which they were collected or processed;
• the right to request a restriction of the processing of your data: You may request that Mensialis Recruitment restrict the processing of data if, for example, you dispute the accuracy — or object to the processing – of the data concerning you;
• the right to data portability: You have the right to have your data transferred to another controller in a structured, commonly used and machine-readable format, if the processing is carried out by automated means or is based on prior consent;
• the right to object to the processing of data: You may object to the processing of your data on grounds relating to your particular situation where the processing is based on our legitimate interest;
• the right to withdraw your consent if the processing is based on consent, for example if the data are used for marketing purposes.

To exercise your rights, please contact us at the following email address: contact@mensialis-recruitment.com

Your request will be processed within 1 (one) month as of the confirmation of your identity. You will not be charged a fee for accessing your Personal Data (or for exercising any of your other rights). We may however charge you a reasonable fee if your request for access is manifestly unfounded or inappropriate. We may also refuse to process your request for the same reason.

We may ask you to provide us with a scan/paper copy of your identity document so that we can verify your identity before processing your request. This is a security measure to ensure that your personal information is not disclosed to any unauthorized person.

If you are not satisfied or if the applicable rules on personal data protection are breached, you may file a complaint with a supervisory authority such as the Commission Nationale pour la Protection des Données (CNPD) [National Commission for Data Protection], having its registered office at 1 Avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette: https://cnpd.public.lu/.

 

6/ Hyperlinks

Hyperlinks lead to other websites.

This policy applies solely to Personal Data collected via the Website and to the manner in which Mensialis Recruitment processes them.

Visits to external websites are governed by the privacy policy of the website visited. We are in no way responsible for the privacy practices of other websites or the content thereof.

7/ Updating of this policy

Mensialis Recruitment reserves the right to modify or update this policy at any time. We will inform you of applicable changes by posting an updated version of this policy on the Website, and, where applicable, by notifying you by email in the event of a major change.

Any changes will enter into force immediately upon such notification.