1. FOREWORD
Trinity Gate Investments France S.A. firmly believes that trust is key for developing successful and lasting relationships. In this respect, the protection of your personal data and privacy is no exception.
This is the reason why Trinity Gate Investments France S.A. puts great emphasis on collecting and processing your personal data with utmost care and in compliance with the applicable legal framework.
In order to inform you in the most transparent manner, Trinity Gate Investments France S.A. has prepared the privacy policy below, which explains in detail why and how your personal data are processed where you browse this website.
2. SCOPE AND PURPOSE OF THIS PRIVACY POLICY
This privacy policy (hereinafter the “Privacy Policy”) is intended to inform you, as an applicant using the Trinity Gate Investments website www.Trinity Gate Investments .com (hereinafter the “Website”), about the way Trinity Gate Investments France S.A. (hereinafter “Trinity Gate Investments ”) processes, as controller, information enabling to identify you either directly or indirectly (hereinafter “Personal Data”) in the context of your application through the Website.
CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING
Where you submit your application thanks to the Website, Trinity Gate Investments processes your Personal Data for various purposes, each of them being duly legitimated by a valid legal basis.
First, Trinity Gate Investments collects and processes your Personal Data, as part of its recruitment process, for managing your application submitted through the Website.
This processing requires that Trinity Gate Investments collect and process the following categories of Personal Data: (i) identification data (i.e. your first name, your last name, your contact details, and your photograph on your résumé as the case may be); (ii) data related to professional life (i.e. your résumé and the information available on your LinkedIn profile, the information obtained from the references you provided); (iii) data related to personal life (as may appear on your résumé and/or LinkedIn profile, such as your hobbies or your marital status); and (iv) the content of the application message submitted through the Website.
While processing your Personal Data for this purpose, Trinity Gate Investments relies on its legitimate interest, which consists in the performance and management of its recruitment operations.
Second, in case your application is unsuccessful, Trinity Gate Investments may be willing to retain your application file to recontact you in the event a subsequent job opportunity matches your profile. For this purpose, Trinity Gate Investments needs to process your Personal Data for setting up, managing and using its applicant pool.
In this context, Trinity Gate Investments needs to process the following categories of Personal Data: (i) identification data (i.e. your first name, your last name, your contact details, and your photograph on your résumé as the case may be); (ii) data related to professional life (i.e. your résumé and the information available on your LinkedIn profile, the information obtained from the references you provided); (iii) data related to personal life (as may appear on your résumé and/or LinkedIn profile, such as your hobbies or your marital status); (iv) the content of the application message submitted through the Website; and (v) the content of your application file.
Please note that the legal basis of this processing varies over the course of time.
Indeed, as such, the legitimate interest of Trinity Gate Investments is the legal basis of the processing and consists in the performance and management of Trinity Gate Investments ’ s recruitment operations. Nevertheless, should Trinity Gate Investments be willing to retain your application file more than two years following the last contact with you, then, after this two-year period, the legal basis of this processing will be your consent, which Trinity Gate Investments will then seek to obtain.
Please note that your Personal Data are obtained from you but also from the following other sources:
(A) your LinkedIn profile to the extent it is publicly accessible; and
(B) as the case may be, from references you shared with Trinity Gate Investments (e.g. you provide Trinity Gate Investments with the contact details of a former employer which you believe can support your application).
In any event, and disregarding the processing purpose at stake, please note that Trinity Gate Investments will comply with a strict data minimisation principle and will thus only collect and process Personal Data which is necessary for the above purposes.
Should your application be unsuccessful, Trinity Gate Investments will inform you if it intends to retain your application file as part of its applicant pool for subsequent potential job opportunities likely to be relevant for you. You will thus have the possibility to request the deletion of your application file.
Besides, please note that the provision of your Personal Data is a requirement necessary to enter into a contract. In this respect, sharing your Personal Data with Trinity Gate Investments is thus mandatory for your application to be considered by Trinity Gate Investments .
Should you decide not to provide Trinity Gate Investments with your mandatory Personal Data, Trinity Gate Investments would then not be able to let you take part in its recruitment process and your application would automatically be refused.
3. DATA RECIPIENTS
Trinity Gate Investments shares your Personal Data with third-party service providers and suppliers which assist Trinity Gate Investments in fulfilling the purposes specified in this Privacy Policy.
To the extent this is necessary, Trinity Gate Investments also communicates your Personal Data to other entities of the Trinity Gate Investments group (e.g. your open application is received by Trinity Gate Investments but another entity of the Trinity Gate Investments group is actually offering a job opportunity fitting your expectations).
Furthermore, as the case may be, Trinity Gate Investments shares your Personal Data with competent courts and any other governmental and/or public authorities requesting access to your Personal Data, within the extent legally permitted.
In any event, Trinity Gate Investments communicates your Personal Data to the above recipients on a strict need-to-know basis and only as necessary for fulfilling duly identified processing purposes.
4. TRANSFERS OUTSIDE THE EUROPEAN UNION
As indicated above, Trinity Gate Investments may need to transfer your Personal Data to other entities of the Trinity Gate Investments Group. Please note that some of these are located outside the European Union, in countries which are not regarded by the European Commission as providing an adequate level of protection to personal data (e.g. China, Singapore).
However, the Trinity Gate Investments group has implemented Binding Corporate Rules (“BCR”) to ensure that personal data transferred between the various entities of the Trinity Gate Investments group still benefit from an adequate level of data protection.
You can access the BCR by clicking here or by writing to our data protection officer by using the contact details specified below, in Section 7 (Contact details) of this Privacy Policy.
5. DATA RETENTION PERIODS
Trinity Gate Investments only retains your Personal Data for a retention period not exceeding what is necessary in light of the processing purpose at stake.
As a result, the data retention period implemented by Trinity Gate Investments depends upon the processing purpose as detailed below.
First, for managing your application made through the Website, Trinity Gate Investments will retain your Personal Data until the end of the recruitment process. Please note that, if you made an open application, this period corresponds to the timeframe necessary for Trinity Gate Investments to check whether your application can match Trinity Gate Investments ’s recruitment needs or not.
Second, to set up, manage and use its applicant pool, Trinity Gate Investments will inform you that it intends to retain your unsuccessful application file. Thus, you will have the possibility to request the deletion of your application file. Should you request such deletion, then Trinity Gate Investments will delete your Personal Data as soon as technically feasible following your request.
If you do not request the deletion of your application file, Trinity Gate Investments will retain it for two years following the last contact with you. Once this two-year period expires and should Trinity Gate Investments be willing to retain your application file longer, then Trinity Gate Investments would seek your express consent to this end and would then inform you about the intended retention period.
Where the applicable retention period expires, Trinity Gate Investments either deletes your Personal Data or irrevocably anonymises it so that you can no longer be identified.
Where Trinity Gate Investments considers it does not need to retain your Personal Data in its active database, it will archive it and will ensure that access thereto is restricted to a limited number of persons who have an actual need to access your Personal Data.
6. YOUR RIGHTS AND OBLIGATIONS AS DATA SUBJECT
As a data subject, you benefit from various rights regarding the processing of your Personal Data. These are as follows:
- right to request from Trinity Gate Investments access to and rectification or erasure of your Personal Data;
- right to request from Trinity Gate Investments restriction of the processing concerning you;
- right to object to the processing of your Personal Data;
- right to portability of your Personal Data;
- right to specify guidelines regarding the use of your Personal Data after your death;
- where you consented that Trinity Gate Investments retain your application file for more than two years following the last contact with you, right to withdraw the consent you gave, at any time and without affecting the lawfulness of processing based on your consent before withdrawal thereof; and
- right to lodge a complaint with the French Data Protection Authority (CNIL).
Trinity Gate Investments is committed to utmost care when it comes to protecting your Personal Data and complying with the applicable data protection legal framework.
This is the reason why Trinity Gate Investments requires your assistance to this end. Thus, you commit to inform Trinity Gate Investments in case the Personal Data you shared with Trinity Gate Investments would become obsolete or inaccurate.
In addition, in the event you would provide Trinity Gate Investments with information enabling to identify directly or indirectly any other natural persons (e.g. you share the contact details of your former manager for references purposes), you represent and warrant that, prior to sharing this information with Trinity Gate Investments , such other natural persons have been provided with this Privacy Policy and, to the extent applicable, have consented to the processing of their data.
7. CONTACT DETAILS
Should you have any questions or requests regarding the processing of your Personal Data by Trinity Gate Investments , including the exercise of your rights specified in Section 6 (Your rights and obligations as data subject) above, please feel free to contact Trinity Gate Investments ’ s data protection officer (DPO) by using the following contact details: Trinity Gate Investments , Data Protection, 20 Place Vendôme, 75001 Paris - dataprivacyofficer@Trinity Gate Investments .com