Recruiter Data Protection

1. Data Controller

The Whileresume platform (hereinafter “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

In the context of using the Platform, the following data may be collected and processed:

  • Identification information (first name, last name, position, professional email address, professional phone number);
  • Company information (legal name, business sector, number of employees, contact details, SIRET/VAT);
  • Connection data (login credentials, logs, IP address, cookies strictly necessary for the service).

3. Purpose of Processing

The personal data of recruiters is collected for the following purposes:

  • To create and manage recruiter/company accounts on the Platform;
  • To provide access to the CV database and enable connections with candidates;
  • To manage billing, payments, and contractual relationships;
  • To ensure security, technical monitoring, and service improvement.

4. Legal Basis for Processing

Data processing is based on:

  • Performance of the Platform usage contract (Article 6.1.b GDPR);
  • The legitimate interest of the Platform in ensuring security, developing its service, and preventing fraud (Article 6.1.f GDPR);
  • Compliance with legal obligations regarding billing and accounting (Article 6.1.c GDPR).

5. Data Recipients

Recruiter data is accessible only to:

  • Registered candidates, as part of the matchmaking process;
  • Technical service providers involved in the operation of the Platform (hosting, payment services, IT support), subject to strict confidentiality obligations;
  • Competent administrative or judicial authorities, where required by law.

6. Data Retention

Data is retained for the duration of the Platform usage contract and archived for up to 5 years after its termination to meet legal or evidentiary obligations.

Billing-related data is retained for 10 years in accordance with legal accounting requirements.

7. Rights of Recruiters and Representatives

In accordance with the GDPR, each recruiter or company representative has the following rights:

  • Right of access to their data;
  • Right to rectify inaccurate data;
  • Right to erasure, within legal limits;
  • Right to restrict processing;
  • Right to data portability;
  • Right to object to processing.

These rights may be exercised at any time by contacting [DPO or support email address].

8. Data Security

The Platform implements appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of data (secure authentication, encryption, backups).

9. Transfers Outside the European Union

Recruiter data is hosted within the European Union. No transfers outside the EU are carried out without ensuring a level of protection compliant with GDPR requirements.

10. Complaints

In the event of difficulties relating to the management of their personal data, recruiters or companies may file a complaint with [DPO contact] and, as a last resort, with the competent supervisory authority (CNIL in France).