Privacy Policy
The individual who provides TWININ with personal data concerning themselves through the forms provided for this purpose on the website accessible at www.twinin.fr (hereinafter the « Site ») through the sections « Contact » (hereinafter the « Prospect ») or “Our professions” (hereinafter the « Candidate »), is informed as follows.
✔ Identity of the data controller
TWININ, a simplified joint-stock company, registered with the Paris Trade and Companies Register under number 520 301 557, with its registered office at 229 rue Saint-Honoré – 75001 Paris, represented by the company RUDSI INVEST (RCS 813 960 739), itself represented by Mr. Jérémy Duris, in his capacity as President, implements personal data processing in the context of its relationship with Prospects and Candidates.
In this respect, it assumes the role of data controller under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
Data Protection Officer of TWININ :
– Mr. Jérémy DURIS
– Contact email address : jeremy.duris@twinin.fr
✔ Data collected
The personal data processed are as follows (hereinafter referred to as « Personal Data »):
For Prospects:
| Categories of Personal Data | Liste des Données Personnelles traitées |
| Identification data | – First name, last name – Email address – Professional position |
| Data relating to exchanges with Prospects as part of prospecting actions | Any personal information that the Prospect chooses to provide using the free text in the « message » section |
Of Candidates :
| Categories of Personal Data | Liste des Données Personnelles traitées |
| Identification data | – First name, last name – Email address – CV |
| Data related to exchanges with Candidates as part of recruitment actions | Any personal information that the Candidate chooses to provide through the free text section of the « message » field or on their CV |
They relate to the natural person whose Personal Data has been provided through the forms accessible via the « Contact » or « Our Professions » sections.
In accordance with the principle of data minimization or « Privacy by default » TWININ ensures to collect only the data strictly necessary for the purpose for which they are processed.
✔ Purposes of processing and legal bases
These Data are processed to meet the following purposes and have the following legal bases:
Personal Data of Prospects :
| Purpose(s) | Basis(es) |
| – Execution of requests made through the Site – Solicitations and commercial prospecting – Promotion of TWININ’s services – Improvement of navigation on the Site – Sending newsletters | The performance of contractual or pre-contractual measures and/or the legitimate interest of TWININ and/or the consent of the Prospect |
Personal Data of Candidates :
| Purpose(s) | Fondement(s) |
| – Execution and management of job applications submitted through the Site – Improvement of Site navigation | Execution of contractual or pre-contractual measures and consent of the Candidate |
✔ Recipients
The processed Data is intended, as needed :
– to authorized departments of TWININ ;
– to control services (including chartered accountants and auditors) ;
– to potential subcontractors of TWININ, as necessary ;
– to public authorities, when required by law.
✔ No transfer and assignment
The Personal Data collected will not be transferred, leased, or exchanged to benefit a third country or an international organization.
✔ Exercise of the rights of the data subjects
| Right to access data | The data subject has the right to obtain from TWININ access to the personal data collected by it. |
| Right to rectification of data | The data subject has the right to obtain from TWININ, without undue delay, the rectification of inaccurate personal data concerning him or her. They also have the right to have incomplete personal data completed. |
| Right to erasure of data | In the context of exercising their right to be forgotten, the data subject has the right to request the erasure of personal data concerning them. TWININ is obligated to erase personal data in the following situations: – When the personal data is no longer necessary for the purposes for which it was collected ; – In case of withdrawal of consent by the data subject on which the processing is based (and when there is no other legal basis for the processing) ; – In case of objection to the processing of personal data by the data subject (and when there is no overriding legitimate grounds for the processing) ; – When the personal data is being unlawfully processed ; – When the personal data must be erased for compliance with a legal obligation. |
| Right to restriction of processing | The data subject may, in the following cases, request TWININ to limit the processing of their personal data, meaning that their data will be temporarily made inaccessible: – When she disputes the accuracy of one or more of her personal data ; – When the processing is unlawful and the data subject opposes the erasure of the data and instead requests a limitation of their use ; – When the data subject needs their data for the establishment, exercise, or defense of legal claims, and TWININ no longer needs them for processing purposes ; – When the data subject has objected to the processing: in this case, the limitation will be effective while determining whether TWININ’s legitimate grounds override those of the data subject. TWININ undertakes to inform the data subject before making their data accessible again. |
| Right to object to processing | The data subject has the right to object, at any time, to the processing of personal data concerning them. |
| Right to data portability | The data subject can request from TWININ (i) to retrieve the personal data concerning them that they have provided to TWININ or (ii) to transmit them to another data controller, to the extent that the processing of this data is carried out by automated means. If this right is exercised, the transfer or transmission will be made in a structured, commonly used, and machine-readable format. |
| Right to lodge a complaint | The data subject may lodge a complaint with a supervisory or judicial authority. |
| Right to give instructions in case of death | The data subject has the right to give instructions regarding the fate of their data after death. |
| Right to withdraw consent | If the processing is based on the consent of the data subject, they may withdraw their consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. |
To exercise all of these rights, the data subject is required to send an email to TWININ at the following address: info@twinin.fr
Each request must be accompanied by proof of identity. In case of reasonable doubt regarding the identity of the requester, additional information may be requested to confirm their identity.
In the case of requests that are clearly unfounded, excessive, or repetitive, TWININ reserves the right to refuse to comply with them.
✔ Retention period of data
Personal data is kept for a period of three (3) years from their collection, subject to withdrawal of consent when processing is based on the consent of the data subject.
Regarding Prospects, it is specified that:
– This duration is renewed with each positive interaction from the Prospect following a personalized solicitation measure;
– When the Prospect objects to the processing of their Personal Data, TWININ ceases processing from the receipt of the objection request from the data subject.
✔ Data Security
TWININ ensures the security of Personal Data by implementing appropriate organizational and technical measures to guarantee a level of security adapted to the risk for the rights and freedoms of the data subjects.
✔ Statement
By checking the box provided for this purpose in the forms accessible via the « Contact » or « Our Careers » sections of the Site, the Prospect and the Candidate declare that they have read this privacy policy appearing on the Site.