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Information note on the protection of the personal data of prospective employees of Club med company

The company Club Med (referred to hereinafter as “Club Med” or “we”), its subsidiaries and partner companies which own managed Club Med villages place a great deal of importance on the protection of your personal Data and pay close attention to compliance with both French and European legal and statutory provisions relating to the protection of privacy and the processing of personal data as well as the recommendations issued by its supervisory authority (referred to hereinafter as “the Legislation in force”).

Club Med refers in this context to internal policies governing the protection of personal Data and the security of information systems applying to all employees who are required to process such data.

Club Med undertakes to guarantee the integrity and reliability of the data with which it is entrusted notably by applying all the physical, organisational and logistic measures required to prevent the amendment or destruction of said data and in particular guaranteeing secure access exclusively to individuals who are authorised to process the latter.

The aim of this information note is to describe how and when Club Med (entered in the trade and companies’ register of Paris under number 572 185 684, whose registered offices are located at 11 rue de Cambrai, 75019 Paris), in its capacity as data controller, collects, uses and communicates information which directly or indirectly identifies individuals applying for employment on a Club Med site (“personal Data”). This document is also intended to inform you about your rights relating to the protection of your personal Data.

This note applies to all the Websites, sub-domains, customer areas and intranets as well as the other on-line recruitment activities of the company Club Med SAD (referred to hereinafter as the “Sites”). A complete list of the sites concerned is provided in Appendix 1.

Therefore, this note does not apply to third party Websites including those which are accessible via an Internet link.

1. What kind of personal Data is collected by Club Med?

Two types of personal Data are collected on our Sites:

• Data which is entered and sent via forms;
• Data which is collected automatically by means of audience measurement tools.

1.1 Data which you send us directly

You send us Data directly notably:

• When you complete different forms / questionnaires on the Sites;
• When you enter a competition;
• When you communicate with your recruitment department.

You will be asked to provide a certain amount of personal information which will be processed with your consent in order to enable us to process your application.

This personal Data will relate to:

• personal identification and contact details (marital status, age, nationality, email address, postal address, telephone number / numbers);
• availability dates and periods;
• skills (training, professional experience and languages);
• where applicable, other data which you have provided on your CV/supporting letter or via your profile on a social network (e.g. LinkedIn).

You may choose not to provide us with certain information which is not collected on a mandatory basis (required information is indicated by an asterisk). This will not affect the processing of your application.

1.2 Data which is collected automatically

When you browse the recruitment Sites, Club Med may collect Data, in strict compliance with the Legislation in force and your rights, relating to:

• the characteristics of the operating system, browser or devices (computer, tablet, smartphone) which you use to access our services;
• your location such as your IP address;
• your browsing history and your interactions with the content of these Sites such as pages visited, search keywords used, frequency of your visits to these Sites.

We mainly use cookies to recognise you when you connect again to our Sites and services and to display content which is likely to correspond to your interests.

In this case, you will be informed prior to the collection of your Data of the purpose of the latter and your rights, generally by means of an information banner at the bottom of the page.

2. How is the personal Data which we collect used?

Your personal Data will be used exclusively to manage your application and the pool of Club Med candidates. In this context, your Data will be used to:

• evaluate your application in the event of employment and, if applicable, to complete the employment procedure;
• allow you to join our pool of applicants so that you can be contacted by Club Med if job offers arise;
• carry out studies on the basis of your data to help us to get to know our applicants;
• if applicable, to personalise our responses and more generally the services that we offer as well as the information that we may send to you;
• measure the Site audience by analysing the number of pages consulted, the number of Site visitors, their activity on the Site, etc.;
• measure the opening rate of our emails so that we can adapt them to your requirements;
• guarantee the security of the Site or respect the applicable legal and statutory obligations;
• send you information, satisfaction surveys and offers which may be of interest to you relating to the information transmitted. The information which may be sent to you by email will under no circumstances include marketing communication; we will only send you information relating to employment with Club Med. You may opt not to receive these messages by using our Preference Centre at the bottom of the page.

3. Which cookies are used by Club Med?

3.1 What is a cookie?

When you use Websites, Club Med may deposit a file known as a “cookie” on your terminal (e.g. computer, tablet) using your browser software. For as long as it is stored on your computer, the cookie identifies the device when you make subsequent visits. This means that each time you visit the Sites, the Data can be retained from your previous visit.

3.2 Which cookies are used by Club Med?

Club Med uses the cookies listed in Appendix 2 of this document in particular.

The functional cookies that we issue allow us to:

• adapt the presentation of our Sites to your terminal's display preferences (language used, display resolution, operating system used, etc.);
• facilitate your searches by retaining your automatic searches;
• improve your user experience by pre-populating certain fields in our forms;

Analytical cookies allow us to improve our services by establishing site visit and usage statistics and volumes (headings and content visited, itineraries, etc..

With your prior consent, we receive and automatically record information from your computer and the browser used relating to:

• Your IP address;
• Your geographic area;
• The hardware used;
• The page visited;
• The action carried out on the site.

We use recognised tools such as Google Analytics to collect statistics concerning user behaviour.

3.3 Your choices relating to cookies

It is important to note that any adjustments that you make to your settings may alter your Internet browsing experience and the access conditions for certain services requiring the use of cookies.

If you refuse to save the latter on your terminal or if you delete the ones that you have saved, you will no longer be able to use a number of functions which may be required to browse certain parts of our Sites.

You may decide at any time to express or amend your requirements using the means provided by your software and configuring it so that cookies are saved on your terminal or, on the contrary, are rejected. Certain browsers allow you to define rules to manage these cookies.

The configuration of each browser is different for the management of cookies. It is described in your browser's Help menu which will show you how to alter your requirements:

• For Internet Explorer™: https://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• For Safari™: https://support.apple.com/kb/PH21411?locale=fr_FR
• For Chrome™: https://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• For Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies
• For Opera™: https://help.opera.com/Windows/10.20/fr/cookies.html

4. For how long will your personal Data be kept?

In general, your personal Data will only be help for as long as is necessary for the completion of the operations for which it was collected (see Article 2 of the note).

If your application is not successful, the Data will be kept for a maximum period of 2 years. Our recruitment teams with vacancies which may correspond to your profile will therefore be able to consult your file and contact you at any time. In addition, you may reapply via our Sites, either for the same type of position if your skills have been updated, or for other offers which are more in line with your profile.

All the Data collected via audience measurement tools will be kept for a maximum period of 13 months from the user's last browsing session.

5. Into which categories do recipients of personal Data fall?

We may share your personal Data with:

• The Human Resources departments of our subsidiaries and partner companies which own managed villages who are also required to comply with the provisions described in this note;
• Our suppliers and/or subcontractors called upon to process your data on our behalf according to our instructions for the purposes outlined in Article 2. We are particularly concerned to ensure that these third parties offer adequate guarantees so that your Data is protected and secure.
• If you are employed, the government bodies and social organisations which are to be informed in accordance with the legal and statutory obligations.

6. Will your personal Data be transferred outside the European Union?

We may transfer your Data to countries located outside the European Union exclusively for the purposes described in this note.

For each transfer, we will ensure that your Data is granted a level of protection equivalent to that offered within the European Union.

The transfers are made exclusively to countries which are recognised by the European Commission as providing an adequate level of data protection.

In the event that data is transferred to a country which does not offer an adequate level of protection, Club Med and its subsidiaries, partners or service providers undertake to transfer your Data in strict compliance with the Legislation in force and, where applicable, to associate the transfer with appropriate guarantees (certification mechanism or signing of the European Commission's standard contractual clauses) which you may ask to receive by post at the address provided in Article 7.3 below.

7. Your rights concerning your personal Data

7.1 Your rights to access, correct, delete and object to data

You may appeal to us to access, correct, update or delete the personal information which concerns you.

You also have the right to delete your personal Data in certain specific cases provided for by law, notably: Data which is no longer required in view of the purposes for which it had been collected or processed – objection to processing on your part.

You also have the right to object to the processing of your personal Data. This right is associated with a certain number of legal conditions, notably the data controller's requirement to provide evidence of the existence of legitimate, compelling grounds which may take precedence over the right to object (e.g.: enforcement of the employment contract)

7.2 Definition of guidelines concerning the use of your personal Data

You will have the right to define general or specific guidelines relating to the preservation, deletion and communication of your personal Data subsequent to its use.

7.3 Contacts

In order to exercise these rights, you must send a written request to the following address: Club Med, 11 rue de Cambrai, 75957 Paris Cedex 19, France, enclosing a copy of your identity document with your request, or by email to: CMJobs.Support@clubmed.com.

If at any time you consider that your rights have not been respected, you may present a claim to the Club Med DPO at: CLUB MED, DPO, 11 rue de Cambrai-75957-Paris Cedex 19, France, or to the supervisory authorities of the state in which your normal place of residence or place or work is located or the place in which the violation occurred (in France, the CNIL: www.cnil.fr).

8. Amendment of the information meeting

Club Med may be required to amend this information note, notably if the Legislation in force changes. Any amendments will be displayed on this page.

Version updated on March 24th 2021

Appendix: List of cookies used by Club Med

Name of cookie	Editor	Purpose	Cookie retention period	Installation
_ga	Google Analytics	Allows to identify the users who browse the site	13 months max	Every pages
_gid	Google Analytics	Allows to identify users who browse the site	24h max	Every pages
Linkedin	LinkedIn	Identifies users from Linkedin	24h max	Every pages
Facebook pixel	Facebook	Identifies users from Facebook	90 days	Every pages
Google Ads	Google	Measures the effectiveness of sponsored campaigns	15 days	Every pages
Golden bees	Golden bees	Measures the effectiveness of sponsored campaigns and / or publication of offers	12 months	Every pages
Indeed	Indeed	Measures the effectiveness of sponsored campaigns and / or posting offers	-	Every pages
Appcast	Appcast	Measures the effectiveness of sponsored campaigns and / or posting offers	-	Every pages
Neuvoo	Neuvoo	Measures the effectiveness of sponsored campaigns and / or posting offers	-	Every pages
axeptio_cookies axeptio_authorized_vendors	Club Med	Identifies the user's choice on the treatment of cookies	11 months	Every pages
_gat_UA-159112210-1	Google Analytics	Serves to limit the rate of requests	1 min. max	Every pages
Browser ID	Connexys	Analytics	2 months	Forms
Favorites	Club Med	Save favorites items	No expiration	Every pages
Alerts	Clud Med	Save alerts items	Session's end	Every pages