1. Who are we?
Smart (“Smart”, “our”, “us”, “we”) is a fully transparent ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher (“Clients”) inventory.
2. Purpose of the Website
3. Information we collect
We collect and process the Personal Data pertaining to your application(s), such as your name, surname, email address, phone number, CV and the link to your Linkedin profile, if provided. We may also collect information through other sources such as additional referees, previous employers, recruiting agencies.
During the recruitment process, we do not collect or process any sensitive Personal Data unless authorized by law or where necessary to comply with applicable laws. In some circumstances, we may need to collect some sensitive information. For example, information about your racial/ethnic origin, gender and disabilities may be collected for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations. Any reports prepared for this purpose would not contain Personal Data; the Personal Data would be anonymized and aggregated. Moreover, information about your physical or mental condition may be collected in order to consider accommodations we need to make for the recruitment process and/or subsequent job role.
You may provide, on a voluntary basis, other sensitive Personal Data during the recruitment process.
As detailed below, you can always modify your information later, however it is important for you to provide us with up-to-date information.
4. For what purposes will your Personal Data be processed?
Your Personal Data will be collected and used by us primarily for recruiting purposes – in particular, evaluate your application and skills and to make a hiring decision. This includes assessing your skills, qualifications and background for a role, checking your information and previous experiences, and generally managing the hiring process and communication with you regarding it.
If you enter the recruitment process, your Personal Data will be stored in our systems for administrative and recruitment management purposes.
If you are hired for a role at Smart, the information collected during the recruitment process will be processed in accordance with the applicable law, including any employee privacy notice, a copy of which will be provided when you are on-boarded as an employee, when applicable.
5. Who may have access to your Personal Data?
Your Personal Data may be shared internally for the purposes of the recruitment process, meaning that we take care to allow access to your Personal Data only to those who require such access to perform their tasks and duties, and to any third party who may have a legitimate purpose for accessing it (e.g. BambooHR, our recruitment management platform).
In limited and necessary circumstances, we may transfer your personal data outside of the European Union as part of its processing. In such case, we ensure that the organization receiving your Personal Data provides adequate safeguards to us, such as the adherence to the EU-U.S. Privacy Shield Framework, execution of the EU Standard Contractual Clauses for transfer to third countries or another specifically stated lawful basis for the transfer of personal data to a third country.
6. On which legal grounds do we rely to process your Personal Data?
Under European data protection regulation, our legal basis for collecting and processing your Personal Data will depend on the concerned information and the context in which we collect it.
Smart has a legitimate interest in processing personal data during the recruitment process and for keeping records of that process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom we offer a job.
We may also need to process data from candidates to respond and defend against legal claims. In some cases, we need to process your Personal Data to ensure that we are complying with our legal obligations, e.g. applicable immigration and/or employment laws and regulations.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and let you know whether the provision of your Personal Data is mandatory or not, as well as the consequences if you do not provide it.
In some cases, we will collect your informed consent to process your Personal Data for specific purposes. When we rely on your consent to collect and process your Personal Data, you have the right to withdraw your consent at any time.
7. What are your rights regarding your Personal Data?
According to the applicable data protection regulation, you may ask us at any time:
– to confirm your Personal Data is being processed and/or to provide you a copy of your Personal Data;
– to rectify your Personal Data if it is inaccurate or incomplete;
– to withdraw your consent;
– to erase your Personal Data, for instance if it is unlawfully processed or if you withdraw your consent;
– to opt out the process of any data;
– to restrict the processing of your Personal Data, (i) if the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending;
– to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party, if technically feasible (portability).
– If you have provided consent for the processing of your data, you have the right to withdraw that consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.
Should you have any request regarding your Personal Data, you can send your request to our Data Protection Officer:
– By email: firstname.lastname@example.org
– By mail: DPO Smart – 66 rue de la Chaussée d’Antin, 75009 Paris – France.
If you consider your rights have been infringed upon according to the current privacy regulation, or regarding the denial of a request, you may lodge a complaint towards your local competent supervisory authority. You can find a list of the European supervisory authorities here.
8. How long will your Personal Data be stored?
destroyed, if you did not express such request before the end of the two (2) years.
10. More questions?