Politique de confidentialité

INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA

Jobtome International SA, (hereinafter also “Jobtome” or the “Company”) wishes to provide, in accordance with and pursuant to Articles 13 and 14 of Regulation (EU) No 2016/679 on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”) and the art. 19 of the Federal Data Protection Act (“DPA”) of 25th September 2020, certain information on the purposes, methods and scope of the communication and disclosure of personal data provided by applicants over 18 years of age when they access or use the online services offered by Jobtome (collectively, the “Sites”) governed by these Privacy rules (hereafter also “Privacy Policy”).

This information is part of the Data Protection Contract (article 9 LPD - marginals 58 and 59 Guide to the processing of personal data in the LADI and LC areas (GPD LADI & LC) of 1 January 2024).

Jobtome aims to help people find the job that is best suited to them and employers to identify the right candidates. In order to achieve this objective, Jobtome collects and processes personal and non-personal data to select the offers deemed most relevant and make them available to you. Your personal data may be used to:

• create a personal user pages;
• send personalized notifications via email, SMS or push notifications containing job offers or links to Site search results or other promotional material;
• show the user relevant search results or job offers;
• associate users with job offers;
• carry out automation activities of the service offered;
• improvement and optimization of the service between the Sites;
• provide support to users through the contact pages;
• prevent fraud, spam and other potentially fraudulent or illegal activities
• collect application to job offers on behalf of Jobtome’s clients.

Services provided by Jobtome to users who are looking for a job are totally free of charge.

1. PURPOSE OF THE PROCESSING AND LEGAL BASIS FOR THE COLLECTION OF DATA BY JOBTOME

1. Your personal and non-personal data are collected in the following ways:

• through the Sites (e.g. forms and pop-ups);
• though personal pages;
• through your activity and interaction on the Sites;
• through user activity and interaction on Job Alerts;
• through user activity to collect the application to a job offer.

1. Jobtome collects user data when the user subscribes to the Job Alerts service, requests information, participates in a survey, updates their job preferences, creates, or modifies Job Alerts, or actively transmits data to the Sites.
2. Your data, such as contact information and your activity on the Sites, are also processed in order to send Job Alerts from one or more Jobtome Sites.

A Job Alert is a notification sent to you through telematic channels, including email, SMS and push notifications through your browser for which you have registered. Job Alerts can be triggered in response to a search query (for example, a keyword and/or location) performed or chosen by the user. Job Alerts may contain job offers and information about the employer. Job Alerts may also include job offers recommended for you based on your personal data and activity on the Sites. In addition, Job Alerts may also contain links to search results pages or recommended jobs on the Sites.

Jobtome reserves the right to change the frequency of sending Site Job Alerts.

3. Your data, such as contact information, education, professional experience and CV are also used to send applications to job offers published by the employers on the Sites. During the application process, Jobtome may request the users to insert personal information, contact information and attach a CV. Such information is needed to correctly forward the job application to the employer and for the application process. Jobtome may save this information in order to facilitate future applications of the user.
4. In order to optimize its services and improve quality, Jobtome may use your activities on the Sites (for example, your browsing history, searches, job offers clicked on, applications to job offers), survey responses and interactions with Job Alerts (for example, opening notifications and clicking on them) to determine relevant search results and select the best jobs. Jobtome may also use your information to enhance and customize your experience on the Sites to suit your preferences.

Jobtome may return different results for the same search query and reserves its discretion regarding the job offers proposed to the user for a search.

5. The legal basis applicable to the processing of your personal data for the purposes referred to in points 1.2, 1.3, 1.4 and 1.5  is your consent pursuant to Article 6(1)(a) of the GDPR and also art. 7 cpv. 3 LC and article 9 LPD, as well as the overriding interest of the data controller for the related processing. Or the execution of a contract related to the Job Alerts service, pursuant to Article 6 paragraph 1 letter b) of the GDPR and Article 31, paragraph 2, letter a) of the DPA.
6. Jobtome may use your information collected in accordance with the Privacy Policy to:

• check for problems with the Jobtome Sites, products or services offered;
• prevent any fraudulent or illegal activity;
• protect against activities that may have adverse effects on you or third parties.

Jobtome reserves the right to use different methods to detect and manage anomalous activities and content that represents fraud or spam. The Company may remove content from the Sites and may temporarily or permanently suspend users from the products or services offered by Jobtome if fraudulent activities or spam are detected.

Jobtome may investigate whether the user is involved in spam activity or any activity that may be fraudulent or harmful on the Sites, including sharing the information with law enforcement and authorities or third parties if they deem, in good faith, that the user is using the Sites in violation of the Privacy Policy or the Terms of Service.

7. The legal grounds applicable to the processing of your personal data for the purpose referred to in paragraph 1.6 are the legitimate interest of the Company (exercise or defense of legal claims) pursuant to Article 6(1)(f) of the GDPR and also artt. 30 and following LPD.
8. Your data may also be processed for the establishment, exercise, or defense of legal claims.
9. The legal grounds applicable to the processing of your personal data for the purpose referred to in paragraph 1.8 are the legitimate interest of the Company (exercise or defense of legal claims) pursuant to Article 6(1)(f) of the GDPR and also artt. 30 and following LPD.

2. INFORMATION COLLECTED FROM THIRD-PARTY SITES

1. The user may also subscribe to the service offered by Jobtome using third-party sites, such as, but not limited to, Google and Facebook.

If you choose to continue to subscribe to the Jobtome services through your Google or Facebook account, you agree to share personal information about your Google and Facebook accounts with Jobtome, including but not limited to your email address, first name, last name, and profile picture. Once authorized, the information will be shared with Jobtome. The shared information will be used for the products and services offered by Jobtome for the purposes and using the methods listed in point 1.

If the user should decide to continue to subscribe to the service through their Google or Facebook accounts, the latter may manage and perform authentication and redirecting to Jobtome. When you sign in using your Google or Facebook account, they may use cookies for authentication as Google or Facebook.

The relationship between you and Google, Facebook or any other third-party website is governed solely by the agreement between you and that third-party website.

2. The purposes and legal grounds applied for information shared with Jobtome by third-party sites in point 2.1 are the same as those listed in point 1.
3. When you click on an offer or advertisement on the Sites and land on a third-party site, Jobtome may receive information about your activity on that site, including by way of identification to join the third-party site, job applications or other interactions with the third-party site. When applying for a job on a third-party site, Jobtome may receive information about the status of the job application and the decisions made by the employer, such as the interview phase or acceptance of the proposal.
4. When the user sends a job application through the Sites, Jobtome may receive and share information with the user related to the status of the job application process if the employer is willing to share it with Jobtome, even with third parties services.
5. The purpose of using the information in point 2.3 is to enable Jobtome to improve and optimize the service offered to users by offering relevant job offers and advertisements in line with the user profile.

3. CATEGORIES OF DATA PROCESSED AND DATA SOURCE

6. “Personal data” means any information associated with an identified or identifiable individual.

“Non-personal data” means any information that does not identify you as an individual.

Jobtome collects user data when the user subscribes to the service, requests information, participates in a survey, updates their job preferences, creates, or modifies Job Alerts, sends an application to a job offer or actively transmits data to the Sites. This information may include, but is not limited to:

• first name and last name;
• email address;
• phone number (including cell phone number);
• interests;
• preferences concerning work;
• career goals;
• results obtained;
• CV;
• desired salary;
• answers to questions sent by Jobtome and replies given by the user to the questionnaires received or present on the Sites;
• IP address;
• you may provide data on your specific position in order to find more relevant job offers.

1. Jobtome will collect the following categories of common personal data, including but not limited to first name, last name, date of birth, address, email address and telephone contacts, CV.
2. Jobtome will collect the above data through the Sites, your interactions with the Sites or Job Alerts and from third-party websites or companies.
3. Please do not indicate any special data categories on the Sites (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation).

4. DATA STORAGE PERIOD

1. Jobtome retains your personal data for a period of for a period of 6 (Swiss Site’s domains) or 24 months from the date of their entry or your last interaction with the Site (access, update of data) or with Job Alerts (reading and interacting with notifications) or until the user asks for their erasure through their personal page.

1. Unsubscription from the Job Alerts service (through the appropriate links contained in the email or via SMS service) consists of the suspension of the service and does not automatically erase the personal data of the user who is still subject to the conditions stated above.
2. The user confirms to have understood the point 4.1. The user hereby declares to grant tacit renewal to Jobtome for the storage of personal data for an additional 6 (Swiss Site’s domains) or 24 months. The tacit renewal occurs solely following an interaction with the Site or with the Job Alerts, as described in point 4.1.1. He declares that he has understood how to proceed with the deletion of personal data through his personal area (this amounts to cancellation of the consent given through the Data Protection Contract).

2. In the case of the processing of data for purposes related to the establishment, exercise or defense of legal claims referred to in paragraph 1, the data shall be entered in a historical archive and kept for the duration of the dispute until the time limits for the admissibility of the actions of appeal have been exhausted.
3. After the above storage period, the personal data are destroyed or rendered anonymous.
4. Jobtome reserves the right to retain anonymous data regarding your interaction with the Sites, including, but not limited to, clicking on job offers, job offers displayed, surveys and interests, job applications.

5. NATURE OF THE PROVISION OF DATA AND CONSEQUENCES OF REFUSAL

Providing contact details (email or telephone number) is necessary in order to enable Jobtome to finalize the subscription to the Job Alerts service and to send job applications referred to in point 1 above.

By sharing your contact and personal information in the relevant sections on the Sites or by sharing your personal data through third-party websites or companies, you agree to subscribe to the services offered by Jobtome and for your information to be used for the purposes listed in points 1 and 2.

Failure to provide consent will prevent Jobtome from subscribing the user to the Jobtome services.

6. PROCESSING METHODS

The processing of data is based on the principles of fairness, lawfulness and transparency and data minimization (privacy by design). It can be carried out both manually and through automated methods suitable to store, process and transmit data and will be carried out by means of appropriate technical and organizational measures, mutatis mutandis and in the state of the art, to guarantee, inter alia, security, confidentiality, integrity, availability and resilience of systems and services, avoiding the risk of unauthorized loss, destruction, access or disclosure or, in any event, unlawful use, and by means of every reasonable step to ensure that data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

7. RECIPIENTS OF THE DATA

1. Your data is processed to allow Jobtome to help people find a job and companies to select the right candidates.

The user has the right to unsubscribe individually from the Job Alerts service of each of the Sites using the links contained in the email or the automatic SMS commands.

Jobtome gives you the option to delete your personal data through the user's personal pages and alerts management.

2. Your personal data may also be processed by external subjects, expressly appointed to be responsible for processing, who provide Jobtome with:

• Management and maintenance services of the Site;
• Management and maintenance of the candidates database;
• Archiving services;
• Communication mail services;
• Market research services.

Jobtome may share personal or non-personal data with third-party providers that offer support to the Sites so as to ensure the quality and maintenance of Jobtome's products and services and user security. For example, Jobtome may use suppliers to detect and prevent spam, fraud or any activity that is harmful to users or the Sites.

Jobtome may also use third-party cloud service providers that provide hosting, data storage and other services under standard terms and conditions that may not be negotiable.

3. By entering your data, you are expressly asked to give consent to the processing of the data by third parties by accepting the form visible at this link:

3. The updated list of recipients is available at our registered office or by sending an email to [email protected].

8. DATA TRANSFER

1. Your data is processed in Switzerland, where the level of data protection has been deemed adequate by the European Commission in accordance with Article 45 of the GDPR. Your data may be transferred to other countries belonging to the European Union, in compliance with Articles 16 and following of the DPA and Articles 8 and following of the DPO.
2. Any transfers to non-EU Member States or international organizations are allowed, in the absence of the above-mentioned adequate guarantees, on the basis of the exemptions provided for under Article 49(1)(b) and (c) of the GDPR, Article 17 of the DPA, and Articles 8 and following of the DPO. Specific notice of such transfers will be given to the data subject.
3. Adequacy decisions can be found at the following links:

Switzerland: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016D2295

4. Jobtome may send personal data of jobseekers to employers at the request of job seekers or employers. This transfer is necessary to allow you to proceed with the job search, application submission and selection process.

9. RIGHTS OF THE DATA SUBJECT

1. Data subjects are granted the rights set out in Articles 15 to 22 of the GDPR, where applicable, as well as the rights in Articles 25 and following of the DPA and Articles 16 and following of the DPO.
2. In particular, data subjects may ask data controllers for access to their data, their erasure, rectification, the completion of incomplete data as well as the restriction of processing in the cases provided for in Article 18 of the GDPR^[1], the provisions of the Articles 25 and following LPD are also applicable,  as well as Article 32 LPD.
3. The data subjects have the right to object, at any time, in whole or in part, the processing of the data necessary for the legitimate pursuit of the interests of the controllers.
4. Data subjects also, if the conditions for exercising the right to data portability as per Article 20 of the GDPR^[2] or Article 28 of the DPA are met, have the right to receive the data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and, where technically feasible, have the right to transmit those data to another controller without hindrance.
5. Data subjects have the right to lodge a complaint with the competent supervisory authority (in particular in the Member State of their habitual residence, place of work or place of the alleged infringement).
6. These rights can be exercised by means of a written notification sent to the address indicated below, or by email to the following address: ch.privacy@jobtome.com. It is understood that, where the request is made by electronic means, the information will be provided by a commonly used electronic means.

9. INFORMATION FOR CALIFORNIAN USERS

1. Californian residents are subject to the provisions of the California Consumer Privacy Act (CCPA) that allow these users to prevent the sale of personal data to third-party companies.

For the purposes of this document, the term “sale” means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration.”

2. Jobtome’s activities could fall under the CCPA's definition of “sale” in the following cases:

• allowing third-party cookies to optimize online advertising;
• sharing information between Jobtome affiliated brands for the purposes described in this Privacy Policy.

1. Jobtome does not, on the other hand, carry out:

• the sale of personal data with data brokers;
• the exchange of personal information with third parties for money.

1. The request to refuse the sale or transfer of data under the CCPA prevents Jobtome from providing the service. The user can opt out through their personal page for managing Job Alerts by requesting the erasure of their personal data.
2. California users will also be subject to the other personal data protection policies set out in the other sections.

10. WITHDRAWAL OF CONSENT

1. Data subjects have the right to withdraw their consent at any time by sending an email to ch.privacy@jobtome.com
2. The withdrawal of consent shall not affect the lawfulness of processing based on consent you have given before its withdrawal.

11. CONTACT DETAILS OF THE DATA CONTROLLER

The data controller is Jobtome International S.A. - Via San Martino 16/A, Mendrisio - Switzerland, in the person of the Legal Representative.

12. CONTACT DETAILS OF THE DATA PROTECTION OFFICER (DPO)

The Data Protection Officer (DPO) or Data Protection Consultant, pursuant to Article 10 of the DPA and Article 23 of the DPO, can be contacted at the following address: Via San Martino 16/A, Mendrisio - Switzerland, to the attention of the Data Protection Officer, email: [email protected].

THE DATA CONTROLLER

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