Data Protection Policy

Data Protection Policy

For NeoXam, the privacy of your personal data is key. We are committed to the lawfulness, fairness, security and transparency of your user experience. Below you will find all the useful information to understand how NeoXam may protect your data and your rights, by the implementation of security measures.

Controller and Data Protection Officer

Details of Controller

This website www.neoxam.com (the “Website“) has been implemented by NeoXam Services SAS, whose registered office is at 46 rue Notre-Dame des Victoires, 75002 Paris, France, registered at the RCS of Paris under number 801 495 268 (hereinafter “NeoXam“). As data controller, NeoXam processes the personal data it collects about you via the Site (hereinafter the “Data“).

Details of the Data Protection Officer (« DPO »)

For any question related to the collection and processing of your Data operated by NeoXam, you can contact by email our Data Protection Officer in charge of data protection at the following address: nx.dpo@neoxam.com.

Data: purpose, legal grounds, retention period

The Data that NeoXam may collect and process are as follows:

Data processed Purposes Legal grounds Retention period
Last name First Name

Firm

E-mail address

Phone number

Collect data for surveys, answer your questions and requests via forms As the case may be:

Legitimate interest,

Your consent,

Execution of a contract

 

Completing the form is a clear positive act of your consent

If you are not a customer: 3 years from the last contact we had with you (e.g. request for documentation from you or click on a hypertext link contained in one of our emails)

If you are a customer: 3 years from the end of the business relationship (e.g. from a purchase, the end of a contract or the last contact with you)

 

 

To send you emails and/or call you to inform you of our offers, news and events (newsletters, invitations and other publications)

Your consent

 

By ticking the box provided for this purpose on the forms, you agree to receive solicitations from NeoXam

The information that you communicate to us via the transmission of your application and / or your curriculum vitae Take into account and manage your application, whether spontaneous or responding to one of our ads Your consent

 

Submitting your application is a clear positive step in your consent

2 years from the last contact with the candidate
Profile data (recruitment portal) Allow you to create and access your personal recruitment space on our dedicated web portal (user account) Your consent

 

Completing the form is a clear positive act of your consent

2 years from the last activity of the user account
Connection data Allow us to track and manage your account activity Legitimate interest

 

Tracking and managing the activity of your account is a legitimate interest for NeoXam, in particular because it allows us to secure your Data (e.g. detection of a suspicious activity that may result from hacking your account )

1 year

 

Data necessary to NeoXam to achieve the purposes described above are marked with an asterisk on the various forms of the Site. If you do not complete these required fields, NeoXam will not be able to respond to your requests and / or provide you with the desired services. Data not marked with an asterisk is optional: it allows us to know you better and to improve our communications and services to you.

At the end of the retention periods indicated above, we will delete your Data.

Before these deadlines expire, we may contact you again to find out if you still wish to receive commercial solicitations from us and / or if you agree to a longer retention period of your Data, in which case the deadlines given above will reboot.

Cookies

The navigation on the Site gives rise to a deposit of /plotters and/or cookies. Cookies are small text files stored on the user’s terminal, grouping a certain number of data on its navigation (e.g. date, time and number of visits, source of arrival, preferences). NeoXam uses them to:

  • Customize your navigation: the deposit of cookies allows us to memorize your navigation choices, to recognize you in case of a new visit and thus to activate the application of these personalized parameters (e.g. language, type of browser);
  • Analyze the activity of our Site: the deposit of cookies allows us to obtain information on the affluence and the traffic and thus to measure the performances of our Site;
  • Adapt the content to your interests: the deposit of cookies enables us to obtain information on your preferences and to submit you offers corresponding to your centers of interest;
  • Make social sharing buttons available to you: if you click on one of them, third-party website cookies may be placed on your device. These cookies are governed by the personal data protection policy specific to each third-party site, on which NeoXam has therefore no control.

Cookies are kept for up to 13 months. This period is not extended by your new visits.

The deposit of cookies on your terminal assumes the collection of your consent. Thus, upon your arrival on our Site, an information banner informs of our we use of this technology, and that by continuing your navigation, you accept the deposit of cookies on Paramétrer les cookies.

Security

NeoXam maintains appropriate technical and organizational measures to protect your Data against unauthorized or unlawful processing, accidental loss, destruction or damage, or other violation in compliance with the applicable law and regulation.

NeoXam only collects the Data strictly necessary for the processing, and access to your Data is only granted to those who have a legitimate need for the Data, within the consent granted by the data subjects.

Data recipients

Your Data is collected and processed by NeoXam and its subsidiaries, namely: NeoXam Singapore Pte Ltd., NeoXam Hong Kong Ltd, NeoXam Luxembourg S.à.r.l., NeoXam International S.à.r.l., NeoXam Germany G.m.b.H., NeoXam Switzerland AG, NeoXam USA Inc., and NeoXam Investment Accounting SAS.

In connection with the provision of our services, we may send or give access to your Data to our following subcontractors:

Gandi/LMC FRANCE, for Site hosting

Curious Limited, for the Site maintenance

Pardot, for the management and traceability of your data

Salesforce, as a customer relationship manager

Cornerstone, for the management of recruitment/employment data

SURVEYMONKEY, as data hosting provider collected via surveys

NeoXam may be required to disclose your Data to third-parties where such communication is authorized and required by law or court order, or if such communication is necessary to ensure the protection and defense of its rights.

In addition to these cases, your Data will not be assigned or made available to any third-party without your prior consent.

Data transfers to countries outside the European Union

Any transfer of your Data outside the European Economic Area, would be done with the appropriate guarantees, in accordance with the applicable regulations on the protection of personal data.

Since NeoXam has foreign subsidiaries and subcontractors located abroad, your Data may be transferred to the following countries:

Singapore: NeoXam Singapore Pte Ltd.

Tunisia: NeoXam Tunisia SARL

Hong Kong: NeoXam Hong Kong Ltd

Luxembourg: NeoXam Luxembourg S.à.r.l., NeoXam International S.à.r.l.

Germany: NeoXam Germany G.m.b.H.

Switzerland: NeoXam Switzerland AG, NeoXam Investment Accounting SAS

United States of America: NeoXam USA Inc.; SURVEYMONKEY, as data hosting provider collected via surveys

United Kingdom : CURIOUS LTD

GANDI

PARDOT/SALESFORCE

Transfers of Data to the aforementioned countries are legally governed by standard contractual clauses, established in accordance with the recommendations of the European Commission and the French Data Protection Authority, the CNIL.

Rights of data subjects

You have a right of access to your Data, the right to request modification, erasure or portability, as appropriate, and the right to set guidelines on the fate of your Data after your death. You also have the possibility to request the limitation of the processing of your Data, to withdraw your consent, but also to oppose to this processing, in particular when it is based on NeoXam’s legitimate interest or when it is for the purpose of prospecting. If this is the case, you can directly unsubscribe by following the dedicated link, present in each of our emails.

These rights can be exercised at any time by sending an e-mail to nx.dpo@neoxam.com, with a copy of one of your identification document.

You also have the right to refer to the French Data Protection Authority, the CNIL, 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, any claim relating to the processing of Data about you by NeoXam.