Business Data Protection

1. Data controller

The Whileresume platform (the “Platform”), operated by Mirtillo EURL, 2 rue de la Hollau, 67540 Ostwald, acts as the data controller for the personal data of recruiters and company representatives registered on the Platform.

2. Data collected

The following data may be collected and processed when the Platform is used:

• identification details (first name, last name, job title, business email address and business telephone number);
• company information (company name, industry, workforce size, contact details and SIRET/VAT number);
• connection data (login credentials, logs, IP address and strictly necessary cookies).

3. Purposes of processing

Recruiters’ personal data is collected for the following purposes:

• creating and managing recruiter and company accounts on the Platform;
• providing access to the CV database and enabling contact with candidates;
• managing billing, payments and the contractual relationship;
• ensuring security, technical monitoring and improvement of the Service.

4. Legal basis for processing

Data processing is based on:

• performance of the contract governing use of the Platform (Article 6(1)(b) GDPR);
• the Platform’s legitimate interest in ensuring its security, developing its service and preventing fraud (Article 6(1)(f) GDPR);
• compliance with legal obligations relating to billing and accounting (Article 6(1)(c) GDPR).

5. Data recipients

Recruiter data is accessible only to:

• registered candidates, when contact is established;
• technical service providers involved in operating the Platform—including hosting providers, payment services and IT support—who are subject to strict confidentiality obligations;
• the competent administrative or judicial authorities where required by law.

6. Retention periods

Data is retained for the duration of the contract governing use of the Platform and archived for up to five years after it ends in order to meet legal or evidentiary requirements.

Billing data is retained for ten years in accordance with statutory accounting obligations.

7. Rights of recruiters and representatives

Under the GDPR, each recruiter or company representative has the following rights:

• the right to access their data;
• the right to rectify inaccurate data;
• the right to erasure, subject to legal limitations;
• the right to restrict processing;
• the right to data portability;
• the right to object to processing.

These rights may be exercised at any time by contacting contact@whileresume.com.

8. Data security

The Platform implements appropriate technical and organisational measures to protect the confidentiality, integrity and availability of data, including secure authentication, encryption and backups.

9. Transfers outside the European Union

Recruiter data is hosted within the European Union. No data is transferred outside the EU without first ensuring a level of protection that meets GDPR requirements.

10. Complaints

If recruiters or companies encounter an issue concerning the management of their personal data, they may submit a complaint to contact@whileresume.com and, as a last resort, to the competent supervisory authority (the CNIL in France).