Privacy Policy

Introduction

At MakiPeople SAS, located at 37 Avenue Trudaine, 75009, Paris, (“MakiPeople”, “we”, or “us”), we care about your privacy and the protection of your personal data.

This Privacy Policy explains how we collect, use and protect your Personal Data when you visit our website or use our Platform. For the purposes of this Privacy Policy, the “Platform” means the MakiPeople website, application and services made available by MakiPeople in connection with assessments, recruitment and career development.

In this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable person, as defined by applicable data protection laws, including the General Data Protection Regulation (“GDPR”).

We encourage you to read this Privacy Policy carefully. As we may update it from time to time, please review it regularly to stay informed about how we process your Personal Data.

By checking the box “I have read and accept the Platform Terms of Use as well as I have read the Privacy Policy”, you confirm that you have read and understood this Privacy Policy. .

1. Scope of this Privacy Policy 

MakiPeople is a platform used by employers and recruiters to organise assessments and tests for recruitment and career development purposes. 

MakiPeople acts as a data controller for certain processing activities carried out for its own purposes, such as operating and improving the Platform and services, ensuring their security, managing user accounts, communicating with users, complying with legal obligations, handling data protection requests, and managing disputes. This Privacy Policy applies only to those processing activities.

MakiPeople may also process Personal Data as part of the provision of its services on behalf of employers and recruiters and acts as a data processor. This Privacy Policy does not apply to these processing activities where MakiPeople acts as a data processor. 

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2.  Categories of Personal Data we process 

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a) Personal Data you provide to us 

We may collect Personal Data that you choose to provide when you interact with us through the Platform either as a professional user of the services on behalf of employers or recruiter or as an employee or candidate who will carry out assessments. This may happen, for example, in connection with the offering of our services when we act as data controller, when you contact us (via the contact form) and subscribe to receive our news. 

The type of personal data you may provide include:

• Identity and contact data, such as your first and last name, email address, phone number and postal address;
• Account information: login credentials; affiliation with an organization, role; 
• Demographic data, such as employees or candidates’ country of residence, language proficiency, age group, gender, sexual orientation, ethnicity, disability, highest degree, where relevant and permitted by applicable law;
• Communication data, such as the content of your exchanges with us when you contact us;
• Assessment and career-related data, such as employees and/or candidates’  responses to assessments, CV, qualifications, skills, video recordings, images, voice or audio data, and transcripts; 
• Activity data, such as professional users’ comments on candidate results, overrides of candidate scores, decisions to move a candidate to the next stage etc; 
• Feedback about the assessment. 

This information may be collected directly from you or through an employer/recruiter using our services.

b) Personal data we collect automatically 

We may also collect certain Personal Data automatically when you access or use the Platform. This may include (i) technical data, such as your IP address, device type, browser information, and other information about how you interact with our website or the Platform (Technical data); (ii)  webcam video, audio, screenshots, behavioral and environmental indicators, automated alerts for test integrity to ensure the integrity, fairness, and authenticity of online assessments (Proctoring data); and (iii) candidates and employees assessment scores, results, reports and time of assessment (Assessment results). 

We also use cookies and similar technologies. Cookies are small files stored on your device that help us ensure the proper functioning of the Platform, remember your preferences, and understand how our services are used. 

When you first visit the Platform, a cookie banner informs you about the existence of cookies and their purposes. . Except for cookies that are strictly necessary for the operation of the Platform, the placing and reading of cookies on your device are subject to your prior consent, which you may provide by clicking “I accept”. However, you may configure your browser to refuse cookies or customize your cookie settings by clicking the “Learn More” link. If you accept the use of cookies, your agreement will be valid for 13 months. It will then be necessary to renew your agreement at the end of this period. Please note that only the refusal or disabling of strictly necessary cookies may affect the proper functioning of certain parts of our Platform.

3. Purposes of processing and legal basis 

The table hereunder summarizes the legal basis and the purposes of the Personal Data collected when You registered on the Platform:

Purpose of our processing

Categories of Personal Data 

Lawful basis of our processing

To create and manage your account 

Identity and contact data, Account information, Technical data, Cookies and similar technologies

The performance of the contract between you and MakiPeople for employees and candidates

Our legitimate interest in administering the Platform and services for professional users

To provide the MakiPeople services, including assessment and recommendations, services support and surveillance of the integrity of the assessments

Identity and contact data, Account Information, Technical data, Cookies and similar technologies, Assessment and career-related data, Activity data, Proctoring data, and Assessment Results. 

The performance of the contract between you and MakiPeople

To improve fairness and unbias in the handling of assessments results

(NB: this data processing is optional) 

Identity and contact data Account Information, Technical Data, Demographic data, Assessment and career-related data, Activity Data, Assessment Results

Our legitimate interest in improving the fairness  of our services. 

Where special categories of Personal Data are processed, MakiPeople relies on your explicit consent as required under applicable data protection law.

To improve our anti-cheating tools

Technical data, Assessment and career-related data, Proctoring data, Activity Data, Assessment results

Your consent 

To improve our services and the Platform (for debugging for instance, or for monitoring reliability and performance of the scoring features). 

Technical data, Assessment and career-related data, Activity Data, Cookies and similar technologies, Assessment results, Technical data, Feedback 

Our legitimate interest in improving the reliability, accuracy and quality of our services

To protect the Platform from misuse

Identity and contact data, Technical data, Activity  data, Cookies and similar technologies

Our legitimate interest in ensuring the security of its Platform  

To communicate with you 

Identity and contact data,  Account information, Communication data, Technical data

The performance of the contract between you and MakiPeople 

To enforce our contractual terms with candidates / employees or with the employers and recruiters 

Identity and contact data, Account information, Communication data, Technical data, Assessment data and career-related data, Activity data, Proctoring data

Our legitimate interest in protecting and exercising our contractual rights 

To resolve disputes between you and MakiPeople 

Identity and contact data, Account information, Communication data, Technical data, Assessment data and career-related data, Activity data, Proctoring data, Assessment results

Our legitimate interest in protecting and exercising our legal rights 

The performance of the contract between you and MakiPeople 

To manage our contractual and business relationship with employers and recruiters

Identity and contact data, Account information, Communication data, Technical data, Activity data

Our legitimate interest in managing our contractual relationship

To invoice our services

Identity and contact data, Account information, Communication data, Technical data

Legal obligations

To reply to your requests to exercise your rights on your personal data 

Identity and contact data, Account information, Communication data, and information needed to verify and handle your request

Legal obligations 

To respond to any other applicable legal obligation

Identity and contact data, Account information Communication data, Assessment data and career-related data, Activity data, Assessment results, Proctoring data, Demographic data, Technical data

Legal obligations

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4. Retention period 

We keep your Personal Data only for as long as necessary for the purposes described in this Privacy Policy and in accordance with applicable law. The main retention periods are as follows:

• Account information: for as long as your account remains active, and for up to 2 years from your last login to the Platform or from the deletion of your account;
• Non-essential cookies: for as long as you consent to their use, and in any event no longer than the applicable validity period of your consent.

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5. Communication to Third Parties

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We may share your Personal Data only with the persons that need it for the purposes described in this Privacy Policy. This may include: 

• Our service providers, such as technical and hosting service providers, security and fraud prevention providers, and providers helping us with customer support or user satisfaction surveys.
• Employers and recruiters for whom you have fulfilled the online assessment/test following an invitation to do so.. In that regard, we share results, analytics, and feedback of those online assessments and tests (including any snapshots taken during the assessments). 
• Our advisors, such as lawyers, accountants, who process Personal Data strictly as necessary to conduct their mission. 
• A buyer, successor or transferee, in the event of a merger, acquisition, restructuring, bankruptcy, liquidation or other similar transaction; and
• Public authorities, courts or other authorised third parties, where disclosure is required by law or is necessary to establish, exercise or defend legal rights, or in connection with an investigation or legal proceeding.

MakiPeople undertakes to communicate your personal data only to authorized and trusted service providers, who process them on our behalf, according to our instructions and in accordance with this Privacy Policy and in compliance with any other appropriate security and confidentiality measures.

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6. Security

We implement all necessary organizational and technical security measures to protect your Personal Data from unauthorized access, disclosure, modification, damage, or destruction of the data we hold.

To this end, we and our technical and hosting service providers implement appropriate measures to ensure the integrity, confidentiality and security of your Personal Data (in particular by complying with ISO standards and the requirements of applicable personal data protection regulations). 

7. Transfer of your Personal Data outside the European Union 

We may use service providers located outside the European Union, or service providers that process Personal Data from outside the European Union. In such cases, we ensure that these transfers are carried out in accordance with applicable data protection laws and are subject to appropriate safeguards designed to ensure an adequate level of protection for your Personal Data. You may request more information about these safeguards by contacting us by e-mail to: privacy@makipeople.com. 

8. Your Rights

Under applicable data protection laws, you have several rights regarding your Personal Data. Depending of the circumstances, you may have the following rights: 

• The right to access the Personal data we hold about you (e.g. to check the data we keep about you), 
• The right to rectify or update inaccurate or incomplete Personal Data; 
• The right to delete your Personal Data; 
• The right to transfer (right to portability) your Personal Data,
• The right to restrict the processing of your Personal Data; 
• The right to object the processing of your Personal Data, including where processing is based on our legitimate interest or used for direct marketing purposes; 
• The right to lodge a complaint before the competent data protection authority; and
• The right to tell us how you would like us to process your personal data after your death.

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You also have a right to withdraw your consent at any time where the processing is based on consent without prejudicing its lawfulness prior to withdrawal.

In addition, it should be noted that these rights allow you to change your notification preferences at any time, by accepting or refusing to allow your Personal Data to be used in connection with our marketing or promotional activities.

You can exercise these rights by e-mail to: privacy@makipeople.com. We will respond to your request as soon as possible and, in any event, within the time limits required by applicable law.

You can find more information about how our tests are scored by clicking [here] and you will have the opportunity to review this information after each assessment. 

Our services are intended to enhance and not replace human decisions of recruiters and employers. Accordingly, our services do not constitute automated decision making that significantly affects candidates and employees within the meaning of applicable data protection regulation. Please reach out to your employer and / or recruiter if you wish to obtain more information about the role of our services and other criteria chosen by employers and recruiters in their decision making process.   

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