Confidentiality policy

1. Identity of the data controller and the subcontractor

The Seeqle platform is published by: Seeqle SAS, simplified joint stock company with a capital of 41,976 euros, registered with the RCS of Nancy under number 809 063 142, whose head office is located at 3 Place Simone Veil, 54000 Nancy.
In the context of the use of the Seeqle platform by its customers (companies, training organizations, etc.), Seeqle acts as a subcontractor within the meaning of article 28 of Regulation (EU) 2016/679 (RGPD). The client using the platform is the data controller.
When Seeqle collects data on its own behalf (for example in the context of managing its own recruitments or prospecting), Seeqle acts as data controller.
‍DPO contact: privacy@seeqle.com

2. Personal data collected

The categories of personal data processed within the framework of the Seeqle platform are as follows (see table below).

3. Purposes and legal bases of the treatment

The treatments implemented, their purposes and their legal bases are detailed in the table below.

4. Use of AI and automated decision-making

The Seeqle platform uses artificial intelligence technologies as part of its Match product to:
- Analyze and enrich candidate profiles (detection of skills, soft skills, hard skills)
- Assign a compatibility score with the proposed position
- Evaluate personality compatibility (MBTI profile)
- Sort applications in order of relevance
‍Important: These analyses are a decision aid and not an automated decision within the meaning of Article 22 of the GDPR. No recruitment decisions are made exclusively automatically. The recruiter (Seeqle customer) retains the final decision-making power on applications at all times.
‍In accordance with Regulation (EU) 2024/1689 on artificial intelligence (AI Act), AI systems used in recruitment are likely to be classified as high-risk systems. Seeqle is committed to complying with applicable transparency, technical documentation, and data governance obligations.

5. Data recipients

The data collected is accessible to the following recipients:
- the client (data controller) — recruiters and authorized users of the platform;
- Seeqle SAS (subcontractor) — for the execution of the Attract and Match services;
- subsequent subcontractors — detailed list in section 6.
Data is never sold to third parties. They are only transmitted to third parties within the strict framework of the execution of services or in the event of a legal obligation.

6. Subsequent subcontractors

Seeqle uses the following subcontractors to perform its services:

* For transfers to countries located outside the EU/EEA that do not benefit from an adequacy decision, Seeqle relies on the Standard Contractual Clauses (SCCs) adopted by the European Commission (implementing decision 2021/914) and, where appropriate, on additional measures in accordance with the recommendations of the EDPS.

7. International transfers

The personal data processed by Seeqle is mainly hosted within the European Union (AWS Ireland). Some subsequent subcontractors are located outside the EU/EEA, in particular in the United States.
For these transfers, Seeqle puts in place the following guarantees:
- European Commission Standard Contractual Clauses (SCCs) (June 2021 version)
- Transfer Impact Assessment carried out on a case-by-case basis
- Additional technical measures (encryption, pseudonymization) where appropriate
- EU-US Data Privacy Framework for certified subcontractors

8. Retention periods

At the expiration of the retention period or at the end of the contract with the customer, the data is deleted or anonymized within 30 days, unless otherwise required by law.

9. Security measures

Seeqle implements appropriate technical and organizational measures to guarantee the security of personal data, in particular:
- Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
- Role-based access control (RBAC)
- Logging and monitoring of accesses
- Regular backups and continuity plan
- Safety tests and regular audits
- Raising staff awareness about data protection

10. Cookies and trackers

The landing pages generated by Seeqle Attract may use cookies and advertising trackers to optimize targeting and measure the performance of campaigns. In accordance with the ePrivacy Directive and the recommendations of the CNIL, the user's prior consent is required for the deposit of non-essential cookies. This consent is collected by the customer (data controller) on its landing pages. Seeqle ensures that its technology respects the consent choices expressed by users.

11. Your rights

In accordance with the RGPD and the Data Protection Act, you have the following rights on your personal data:

As a subcontractor, if Seeqle receives your request directly, it will transmit it without delay to the customer concerned (data controller) and assist them in processing your request.Response time: 30 days from receipt of the request, which may be extended by 60 days in case of complexity.
‍Right to file a complaint: You have the right to file a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés), 3 Place de Fontenoy, 75007 Paris, www.cnil.fr.

12. Modification of this policy

Seeqle reserves the right to change this privacy policy at any time. In the event of a substantial change, candidates will be informed by any appropriate means. The current version is the one available on the Seeqle platform and on the site www.seeqle.com.

13. Contact

For any question relating to the protection of your personal data or to exercise your rights, you can contact:
Address: 3 Place Simone Veil, 54000 Nancy
E-Mail: privacy@seeqle.com