Candidate Privacy Policy

The Comuto Group (“We”, “Us”)  is committed to protecting and respecting your privacy as per the applicable laws. This notice (the “Candidate Privacy Policy”) describes the data processing activities that are carried out during the recruitment process when individuals (“You”) apply or are considered for a position within the Comuto Group, including Comuto SA. 

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Comuto SA may conduct the recruitment process for its own hiring purposes, or may act on behalf of another entity within the Comuto Group to carry out the recruitment process for the hiring purposes of that entity. The entity with the power to conclude the employment contract acts as data controller for the processing activities that take place in the course of the recruitment process. 

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This Candidate Privacy Policy aims to provide You with information, in accordance with applicable data protection legislation, on the categories and scope of personal data (“personal information”) we process, to explain the means and purposes of data processing activities we carry out with Your personal information (e.g. collection, organization, consultation, conservation, communication, deletion of data), and to inform You of your rights.

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For information on how we process personal data in connection with the use of our website and mobile applications , please see the dedicated information available on our respective platforms. 

2.1 Only the personal information that is strictly necessary to assess your ability to hold the position for which you wish to be considered and to measure your professional skills will be requested from You. Failure to provide this information may affect our ability to assess your qualifications for the position and prevent You from participating in the recruitment process. Such information may include:

• Name, address, email address, telephone number, or other contact information,
• Information in your resume/CV, letters, diploma, other statements of experience and education that You may send to us in an electronic format or in physical form, decks, portfolios, and other content that You may share with us so that we can assess your qualifications and professional skills,
• Referral names and their contact information (in some cases),
• Interview dates, information about the position(s) for which you wish to be considered, your salary expectations, your willingness to relocate, 
• Information necessary for drafting the employment contract, such as social security number, postal address, IBAN information
• Work permit, visa information

2.2 In the event that we decide to enter into an employment contract with You, we will ask You to provide us with the information and the supporting documents necessary for the completion of mandatory formalities and processes. The conclusion of the employment contract with the selected candidates is contingent upon the provision of this information. In addition, the communication of certain categories of information and supporting documents (e.g. civil status, proof of residence, social security number, regularity of your stay) is of a regulatory nature for the selected applications. Failure to provide this information will prevent the conclusion of the employment contract.

Purposes 

Legal Basis

[1] To preselect candidates by way of classifying their CVs and applications 

Processing is carried out on the basis of our legitimate interest  (to choose the best candidates for the posted position)

[2] To interview candidates in order to evaluate their skills, experiences and qualifications 

Processing is carried out on the basis of our legitimate interest (to assess Your suitability for the position and to choose the best candidate for the posted position)

[3] To score the tests or case studies You take in the course of the hiring process 

Processing is carried out on the basis of our legitimate interest (to evaluate Your hard and soft skills and assessing Your suitability to the position)

[4] To select candidates by way of analyzing and assessing their qualifications

Processing is carried out on the basis of our legitimate interest (to choose the most suitable candidates for the relevant position) 

[5] To  prepare the employment contract 

Processing is carried out on the basis of contract, in order to take steps at Your request prior to entering into a contract (to draft the contract in accordance with Your personal circumstances, for instance, to define whether a visa application will be necessary and or not) 

[6] To create and manage administrative files of the hired candidates and for personnel administration 

Processing is carried out for the performance of the contract concluded between You and the Comuto Group entity You enter into contract with

[7] To collect Your feedback following the recruitment process via a survey 

Processing is carried out on the basis of our legitimate interest (to measure the effectiveness of our recruitment process and to improve it upon feedback) 

[8] To keep a pool of applications that have reached the end of the recruitment process

Processing is carried out on the basis of our legitimate interest (to facilitate the recruitment process concerning future job postings by making it easier for the Comuto Group entities to contact individuals who have shown their interest in the same or similar roles and were previously assessed by us for such roles)

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5.1 When You apply for a position with us, we may share your personal information with the recipients for the purposes outlined in this Candidate Privacy Policy. The recipients may include : 

• Other Comuto Group entities, as necessary, to allow the competent entity to proceed with the recruitment procedure,
• The references you provide, to collect further information necessary to assess your application,
• The employees of the respective entities within the Comuto Group, only those who are responsible for the departments that your application relates to and those in charge of the recruitment process (i.e., human resources,  team managers, general directors) who are authorized to access your personal data. Your file and all your information therein is treated confidentially. All personnel including those who have access to your data are subject to a contractual obligation of confidentiality.

5.2 In the event that we decide to conclude an employment contract with You, our human resources department may be required by the law to transmit some of the information collected to the organizations to inform them of your hiring and to finalize the recruitment process (e.g., unemployment insurance, health insurance, retirement, mutual insurance, visa application agencies.) 

5.3 We resort to third party service providers for recruitment purposes who may be the recipients of your personal data. These third party service providers, such as our sub-contractors, process your data on our behalf, and they are under a contractual obligation to act in accordance with all the applicable data protection laws and regulations. They help us in providing You with a better experience while facilitating and improving the quality of our recruitment process.

1. In principle, we store the personal data we hold about you within the European Union (“EU“). However, since  some of our third party service providers are based in countries outside of the EU  (“third countries”), we transfer some of your personal data to third countries. This may include third countries where the European Commission has not taken the decision that such a third country ensures an adequate level of data protection. In that case, we ensure that the transfer is performed in accordance with the applicable legislation and that appropriate safeguards have been put in place (especially the Standard Contractual Clauses (“SCC”) as issued by the European Commission) in order to guarantee a sufficient level of protection of individuals’ private life and fundamental rights.

2. If you wish to obtain further information on such appropriate safeguards,  You can send your request to our team (talentacquisition@blablacar.com). We can provide you with further details regarding such appropriate safeguards (for example, the SCC issued by the European Commission) upon  your request.

1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).
2. You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). In the case where we delete your personal data from our database, we may not be able to offer You a position because of the lack of information necessary to assess your application. 
3. You have the right to object at any time to processing of your personal data based on our legitimate interest (your right to object to processing).
4. You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether the legitimate reasons we are pursuing prevail over yours; or (iii) your personal data has been processed by us in an unlawful way and you request a restriction on their processing rather than erasure; or (iv) we no longer need the personal data for the purposes of processing, but they are still necessary for you to establish, exercise or defend legal claims.
5. You also have the right to make a complaint to a data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.
6. To exercise your rights, please reach out to us using the contact details provided in section 10 .

Any changes we may make to our Candidate Privacy Policy in the future will be posted on this page. Where appropriate, we will notify you.

1. We retain Your personal data for as long as You are under consideration for a position with us. 
2. If You are hired, Your personal data will be integrated into your administrative  file (employee files) and will be kept for the retention period applicable to it. 
3. If You are not hired but have reached the last phase of the selection prior to the conclusion of the employment contract, Your personal data will be kept with the aim of offering You, if this is the case, new job offers, for a period extending up to two years from the last communication You have with us. Your  personal data will be deleted following the end of this period except if:

• You ask for the destruction of your personal data earlier than the end of this retention period, or,
• You consent to a longer period for your personal data to be stored. You will receive an email from us before the expiration of the retention period, informing you that your personal data will be deleted unless you agree to a longer storage, i.e., for a further 2 year retention period,
• We believe that a rejected job applicant might bring a legal claim. In this case, Your personal data can be stored for the period of the statute of limitations.

1. We implement appropriate technical and organizational measures to keep your personal information secure. In determining the appropriateness of the measures to be implemented, we take into consideration the nature, likelihood and severity of the risks presented by the processing activity that is carried out as part of the recruitment process. These measures aim in particular to prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the personal data transmitted, stored or otherwise processed.  All these measures, including the standards and principles to be followed by all the Comuto Group employees at all times are set out in our Information Security Policy.
2. We implement measures to restore the availability of and access to the data in a timely manner in the event of a physical/technical incident and to ensure the ongoing confidentiality, integrity, and availability of systems and services used for processing. We conduct regular tests to assess and evaluate the effectiveness of our measures and update them accordingly. We have a defined procedure in place that enables us to analyze any data incident in collaboration with all stakeholders concerned, take necessary steps to mitigate the risks arising from the incident, and to comply with our legal obligations (e.g. notification of the data breach to the competent data processing authorities and/or to you). At the Comuto Group, access to personal information is granted only on a need-to-know-basis where this is necessary for the employees for the adequate performance of their tasks.

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1. For any questions or comments on this Candidate Privacy Policy, and for any requests relating to your Personal Data, please reach out to us by sending an email to : talentacquisition@blablacar.com. 
2. If you would like to contact us by post, please write to : Comuto SA,  Avenue de la République, 84, Paris, 75011.