The JJA, Créateur de Tendances® site is distributed by the company JJA

A French simplified joint stock company, and a registered capital of 4.497.000 euros
Registered in the Nanterre Trade and Companies Register under number 308 972 181
Having its registered office at 176 avenue Charles de Gaulle
92522 Neuilly sur Seine Cedex - France
VAT number: FR75308972181
Tel : +33 1 48 65 85 00

Publication directed by : Mr Jacques-Olivier Abiteboul

The site www.jja-sa.fr is hosted by Webpopulation,
which has the following address 11bis-13 rue du Colisée - 75008 Paris
and telephone number : +33 1 42 46 02 28

DATA PROTECTION POLICY: MANAGING RECRUITMENT 2023 

To respect the privacy of job applicants on this website www.jja-sa.fr (hereinafter the "Site"), JJA undertakes to process applicants' personal data (hereinafter the "Applicant(s)") in accordance with the provisions of Regulation (EU) 2016/679: General Data Protection Regulation (hereinafter the "GDPR"). 

The purpose of this Personal Data Protection Policy (hereinafter referred to as "the Policy") is to inform Applicants in particular of the methods used to process the personal data collected on the Site, the security procedures put in place and the rights they have with regard to their personal data. 

1. IDENTITY OF THE DATA CONTROLLER 

JJA is responsible for the processing of personal data collected on the Site, during recruitment interviews or via publicly accessible sources. 
The contact details are as follows: JJA, whose registered office is located at: 176 Avenue Charles de Gaulle - 92200 NEUILLY-SUR-SEINE, registered with the Nanterre Trade and Companies Register under number 308 972 181. 

2. DATA PROTECTION OFFICER 

JJA has a DPO whose contact details are as follows: 
Group Legal Department - ZAC des Tulipes Nord - 4, rue de Montservon - 95500 GONESSE - France 
E-mail: dpo@jja-sa.com 

3. CATEGORY OF DATA COLLECTED AND DATA SOURCE 

The following personal data are collected directly by JJA: 

Identification data (surname, first name, e-mail address, telephone number), position applied for, CV and data appearing on the CV: training (diplomas and educational and university background), professional experience, knowledge (IT, languages), mobility, areas of interest, photo, covering letter, Data provided spontaneously or collected during interviews, Date and minutes of interview(s), Action taken on the application, Copy of residence permit for workers of foreign nationality (i.e. outside the European Economic Area, Switzerland, Monaco, Andorra, Saint Martin), Where applicable when justified by the nature of the position: request for presentation of bulletin n°3 of the criminal record, salary positioning and desired income, Type and duration of contract proposed in the event of a positive response. 

The following categories of personal data may be collected through temporary employment agencies, recruitment agencies, schools and universities, JJA Group companies in the event of mobility within the Group, and publicly accessible sources, such as professional social networks and including LinkedIn. 

Identification data (surname, first name, e-mail address, date of birth), academic background, applicant profile and suitability for the post to be filled. 

JJA may also request references from the Applicant's former employers or from other JJA Group companies in the event of mobility within the Group. 

All the information collected in this article constitutes the application file. 

If your application is accepted, JJA may ask you for additional information at the time of recruitment for the purposes of the employment contract and to meet its social obligations, such as civil status, home address, social security registration number, bank details, emergency contacts, beneficiaries for social services or benefits, etc.). The provision of the information requested will be a condition for the conclusion of the employment contract. 



4. PURPOSES OF PROCESSING AND LEGAL BASES 

JJA carries out the following processing operations: collecting, sorting, organising, consulting, storing, communicating and deleting Applicant data for the following purposes and reasons: 

Managing recruitment 

We will collect data to manage recruitment within JJA and JJA Group companies and for the purposes of verifying the professional aptitudes of an applicant for a job or internship following a response to a job offer or following an unsolicited application. 

To apply for a job with JJA or one of its group companies, you must complete all the sections of the online questionnaire. Incomplete applications will not be considered. 

The legal basis is the performance of a pre-contractual measure by the Applicant in order to assess their application. 

Create a CV database for future opportunities 

JJA may wish to keep the application file to offer the Applicant future employment opportunities. 

The legal basis is the Applicant's consent given by sending an unsolicited application or by responding to a vacancy. 

In the event of a negative response to an application, the recruiter has a legitimate interest in keeping the Applicant's application file. The Applicant may object to this by ticking the box provided for this purpose on the data collection form or at any time by making a simple request to the DPO, whose contact details are given in Article 2. 

If the Applicant objects to their application file being kept, their data will be deleted from the CV database, and they will no longer be contacted for new vacancies. 

Managing claims and disputes 

JJA keeps the application file for a period of five years from the end of the recruitment process in the event of discrimination actions or disputes following the rejection of an application. 

The legal basis is the employer's legitimate interest. 

Managing requests to exercise data protection rights 

JJA uses data processing to manage requests concerning the exercise of personal data rights in accordance with the GDPR. 

The legal basis is compliance with a legal obligation. 

5. DATA RETENTION PERIOD 

Data are kept for the periods indicated in the table below: 

Application data for recruitment management and the CV database 

Duration of the recruitment process and two years from the last contact with the Applicant, unless the Applicant objects to the data being kept. 

Managing claims and disputes 

Five years from the end of the recruitment process 

Exercising rights to personal data 

Five years from the date of the request to exercise the right 

Applicants are informed that if their application is successful, their personal data may be kept for a longer period in accordance with the legal retention periods applicable to the performance of the employment relationship and the employer's legal and social obligations. The Applicant will be informed of these retention periods at the time of recruitment. 

6. APPLICANTS' RIGHTS TO THEIR DATA AND EXERCISE OF THEIR RIGHTS 

Applicants are informed that they have the following rights with regard to their personal data: 

(i) Right of access, i.e. the Applicant's right to request a list of their personal data processed by JJA; 

(ii) Right of rectification, i.e. the right to request that inaccurate or incomplete information be corrected; 

(iii) Right to erasure ("right to be forgotten"), i.e. the right to request, for legitimate reasons, the deletion of personal data, except where JJA needs to retain the data for legal reasons or for the establishment, exercise or defence of their legal rights; 

(iv) Right to withdraw consent, i.e. the Applicant's right to withdraw their consent to the processing of their personal data; 

(v) The right to object, i.e. the right to object on legitimate grounds to the use of personal data at the end of the recruitment process; 

(vi) Right to data portability, i.e. the possibility of obtaining and re-using personal data for personal purposes and requesting its transfer to another company, where technically possible; 

(vii) Right to limitation, i.e.: (i) the Applicant's right to challenge the accuracy of the personal data and request that JJA no longer process the data during the verification period; (ii) the limitation of the use of the data in the event that the processing is unlawful; (iii) the retention of the personal data to enable the Applicant to establish, exercise or defend their legal rights.  

(viii) Right to lodge a complaint: the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) or any competent supervisory authority. 

All of the aforementioned rights may be exercised directly with JJA's DPO, whose contact details are given in Article 2 above. 

If the Applicant makes their request electronically, the information will be sent to them by the same means unless the Applicant requests to receive the information by another means of their choice. 

To provide the information requested, the DPO may need to verify the Applicant's identity and, if necessary, ask for proof of identity. If the Applicant's identity cannot be verified, the Applicant is informed that their application may be refused. 

7. DATA SECURITY 

JJA takes all necessary steps to ensure the confidentiality and security of Applicant data and to ensure that its staff and subcontractors meet these obligations. 

JJA deploys security measures against loss, fraudulent intrusion, misuse and alteration of personal data entrusted to it. All data collected is backed up and stored on a backup medium for the legal retention period as specified in Article 5 above. 

The Site uses only full HTTPS and SFTP for transfers with access only via certified IPs. 

JJA employees and their subcontractors have access to personal data only to the extent necessary to perform their duties. Each of them is subject to an obligation of confidentiality and security. 

8. CATEGORY OF DATA RECIPIENTS 

Your application will be treated as confidential. Access to your data is restricted to: 

human resources managers, department managers interested in your application at JJA and within JJA group companies, recruitment agencies from which JJA may seek advice and assistance in the recruitment process, online service providers: LinkedIn and Welcome to the Jungle (WTTJ) when the applicant responds to an advertisement published on these sites. 



9. DATA HOSTING LOCATIONS 

The data are hosted on computer servers located in France 

10. UPDATING AND AMENDING THE POLICY 

The Policy may evolve. These changes may concern the processing of new Applicant data, and Applicants will be informed of this prior to collection or may be due to updates following legislative developments such as recommendations from the CNIL, guidelines, recommendations and best practices from the European Data Protection Committee (EDPS) and relevant court and tribunal rulings. 

11. APPLICABLE LAW AND SETTLEMENT OF DISPUTES 

This Policy has been drawn up in accordance with the provisions of the GDPR. Any dispute relating to the interpretation and implementation of this policy will be subject to the provisions of these texts. 

In the event of a dispute arising in connection with the performance of this Agreement, the Parties will use their best endeavours to settle the dispute amicably. In the event of a complaint, the Candidate may submit their request to JJA's DPO.   

Candidates may also lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) or contact their local personal data protection authority if they do not reside in France. 

If no amicable solution can be found, any disputes will be referred to the competent courts. Any action against a controller shall be brought before the courts of the Member State in which the controller has its registered office or, at the choice of the data subject, before the courts of the Member State in which the data subject has their habitual residence. 

The Candidate may also have recourse to any other alternative dispute resolution method, such as conventional mediation.

WEBSITE USAGE POLICY 
Access to the www.jja-sa.fr website (the "Site") and use of its content, including photographs, are subject to the conditions of use described below. 
Visitors accessing and browsing the Site, accept the following provisions without reservation. 
1. PURPOSE OF THE SITE 
The Site is a non-commercial site accessible via the Internet. It presents the JJA Group's activities, in particular its various brands and latest news, and allows applicants to submit an application with a view to recruitment. 
2. INTELLECTUAL PROPERTY 
a) Trademarks owned by JJA 
JJA is the owner of the following French and Community trademarks, among others: ʺJJAʺ, ʺHespérideʺ, ʺAtmosphera Créateur d'intérieurʺ, ʺ5five Simply smartʺ, ʺSecret de Gourmetʺ ʺEasyré@ʺ and ʺThe Good Living Projectʺ, as well as the domain name ʺjja-sa.frʺ. 
Any use of the aforementioned names or associated logos to designate identical or similar products or services on any medium whatsoever is strictly prohibited and would constitute an infringement of the trademarks of the owner company as provided for and sanctioned by articles L.713-2 and seq., L.716-1 and seq. and L.717-1 and seq. of the French Intellectual Property Code. 
Article L.716-9 of the French Intellectual Property Code states that "it is punishable by four years' imprisonment and a fine of 400,000 euros for any person, with a view to selling, supplying, offering for sale or hiring goods presented under a counterfeit trademark: 
a) Importing, exporting, re-exporting or transhipping goods presented under an infringing trademark; 
b) industrially producing goods presented under an infringing trademark (...);". 
Article L.716-10 of the same Code stipulates that any person is liable to three years' imprisonment and a fine of 300,000 euros: 
a) Unlawfully possessing, importing or exporting goods presented under an infringing trademark; 
b) Offering for sale or selling goods presented under a counterfeit trademark; (...)". 

b) Intellectual property rights relating to the presentation and content of the Site and its images 
The Site, its presentation and its content, including the texts and all the photographs, are protected by the provisions of the French Intellectual Property Code, and in particular by articles L.122-1 and seq. of the French Intellectual Property Code. 
The Site, its presentation, its content and all of its photos and images are and shall remain the exclusive property of JJA, which alone is entitled to use and exploit the intellectual property rights and personality rights attached to the Site, in particular the designs and models, copyright and image rights, either originally or by virtue of an assignment or licence to use them. 
Under the French Intellectual Property Code and, more generally, international treaties and agreements containing provisions relating to the protection of copyright, visitors are prohibited from reproducing, downloading, selling, distributing, issuing, disseminating, adapting, modifying, publishing or communicating in any form whatsoever and on any medium whatsoever, the presentation, organisation or content of the Site, including all photographs. 
Any violation of the rights and obligations listed above would constitute an infringement of the intellectual property rights of JJA as provided for and sanctioned by articles L.331-1 and seq. and articles L.335-1 and seq. of the French Intellectual Property Code. 
3. SITE ACCESS 
Access to all or part of the Site may be suspended or withdrawn at the sole discretion of JJA in the event of, but not limited to, force majeure, computer or technical difficulties, difficulties related to the structure of telecommunications networks, blocking of telecommunications networks, strikes, national or local states of emergency, or inclement weather. 
Similarly, access to the Site may be interrupted at any time without notice for maintenance reasons. 
The Site may be modified or upgraded at any time, including in terms of functionality, without prior notice of any kind and without the visitor being able to claim any prejudice whatsoever. 

4. LIABILITY OF JJA 
a) Unauthorised access by a third party 
To the extent permitted by law, JJA shall not be liable for any imprecision, inaccuracy, omission or for any damage resulting from the intrusion of a third party leading to a modification of the information made available on the Site, in the event of damage caused by the access of an unauthorised third party to the Site or making access impossible. 
b) Hypertext links to other sites 
The Site may include links to other websites or other Internet sources. Insofar as JJA cannot control these external sites and sources, it cannot be held responsible for the availability of these external sites and sources, and cannot be held responsible for the content, advertising, products, services or any other material available on or from these external sites or sources. Furthermore, it may not be held liable for any damage or loss, whether actual or alleged, arising from or in connection with the use of or reliance on the content, goods or services available on these external sites or sources.

TEXT AND DATA MINING POLICY < TDM-RESERVATION: 1> 
JJA is opposed to all harvesting and data mining operations within the meaning of article L. 122-5-3 of the French Intellectual Property Code. This objection covers the entire Site and the Content to which it provides access. All harvesting operations and text and data searches targeting the Site and its Contents, including using automated data collection devices, therefore constitute acts of counterfeiting, unless JJA has given its express consent. 
As article R. 122-28 of the French Intellectual Property Code specifies that the objection referred to in III of article L. 122-5-3 may be expressed by any means, including by recourse to the general terms and conditions of use of an internet site or service, the absence of metadata associated with the Site, Site directories and Site Content has no effect on the exercise of the right of opposition expressed in these general terms and conditions of use. To make this right of opposition easier to read by any automated data collection device, this opposition is also expressed as < TDM-RESERVATION: 1>.