Privacy

Thank you for using fairception! Welcome to the Privacy Policy.

We appreciate that you put your trust in us when you provide us with your information, and we do not take this lightly. Your privacy is at the core of the way we design the Services and Products we provide, so that you can fully trust them and focus on mapping your skills and interacting with other users through feedback and be an active member of the fairception community.

The protection of your personal data and privacy is our priority, we understand that we are dealing with data related to YOU and your personality, therefore we wish you inform you transparently through the policy below, which explain in detail wh

 

1. WHO WE ARE ?

 

Thentik SAS is a French company (Société par Actions Simplifiée) with a share capital of €95,000 (RCS Annecy 891 053 464) having its registered office 5, rue de l’Industrie, 74000 Annecy, France. The website and app services are hosted by Scaleway, with all services located within the European Union or in Switzerland , and protected by their regulations. This allows us to offer you a GDPR compliant cloud platform.

The company responsible for your information under this Privacy Policy (the “data controller”) is Thentik SAS (hereafter “fairception”, ‘’Skillerz’’, ‘’Scouterz’’, “us”, ‘’the Company’’, “our”, “we”).

The Company enables users (thereafter ‘’User’’, ‘’you’’, ‘’your’’) registered on the website fairception.com or through the app fairception to benefit from an enhanced user interface. fairception is a community of skills that allows Users to map their soft skills in a safe and credible way and discover their strengths through the eyes of others. Users can then be identified for jobs based on their profile. To use the Service, the user must create an account. Please read the Terms & Conditions for more information regarding the Services.

 

2. WHERE THIS PRIVACY POLICY APPLIES ?

 

This Privacy Policy applies to websites, apps, and other services we operate under the brand fairception. For simplicity, we refer to all of these as our “Services”, ‘’Service’’ or our ‘’platform’’ in this Privacy Policy.

By agreeing on this Policy, the User allows the use of Personal Data by the Company in line with this Policy.

The Policy is accessible at any time on the fairception website or through the fairception app. It might be updated from time to time. The most recent version will always be available on our platforms and prevails over any previous versions.

 

3. INFORMATION WE COLLECT & PURPOSE

 

It goes without saying, we can’t help you identifying your strengths and develop meaningful connections without collecting and processing some information about you. That personal data for example includes, and not limited to, name, address, phone number, e-mail address or feedback you receive from others. When we say that we process personal data, this means that we collect, store, use, analyze,  or delete such data.

We also collect information about your use of our services such as access logs, or the way you interact with the feedback tool.

 

1. About the information you give us

fairception collects and processes your personal data in the following cases:

• when you visit us on our website without being a member
• when you create an account and populate your User profile
• when you contact us directly (e.g. directly via our platform or on social media), we collect the information you give us during the interaction and your details
• when you install our fairception app
• when you leave feedback to a fairception member without being a fairception member yourself
• when you share with us information about other people
• When you request/receive feedback from others
• when you subscribe to a fairception paid or free service or make a purchase directly from us using a payment provider or your personal wallet
• When you choose to participate in our promotions, events or questionnaires, we collect the information that you use to register or enter

Once you have signed up for a fairception account, we will provide you with access to an online database over which you will be able to interact with other fairception-registered users (also known as members) by viewing their public profile, check the Leaderboard, leave or receive feedback about them.

In order to provide you with the fairception service as described in the General Terms and Conditions, we need to use your personal data. If you do not want us to use your personal data or parts thereof, we will not be able to provide you with the Service. You will also need to provide us with special categories of personal data (i.e. sensitive personal data, such as how you perceive the personality of others and your own personality).

Please see below for further information about the types of personal data we collect when you use our Services.

 

2. Data processing through app stores

Our app is available on different app platforms. Before you can install our app, you may have to enter into a user agreement with the relevant app store operator (e.g. Google or Apple) depending on your particular operating system.

In order to install and use our app via these app stores, you will need to have a valid account with the app store operator as well as a compatible device (e.g. a smartphone). fairception has no control over the collection, processing and use of personal data in this respect. fairception is the data controller with respect to your personal data only when you use the fairception app.

 

3. Registration process

• When you create an account, you provide us with at least your login credentials (username, email, password), as well as some basic details necessary for the service to work and to manage this account from creation to deletion, such as your firstname, lastname, phone number and nationality.

Our Service works by mapping similar personalities based on soft skills hence providing in an anonymised fashion some of your profile information (“profile”) and your processed data and match scores to potential missions’ holders. In order to set up your fairception profile and get the full benefit of our Service, we will ask you to provide us with and let us gather & process additional data about yourself.

 

4. Profile filling

• When you complete your profile, you share with us additional information, such as a self-assessment on your hard skills, expertise, languages, soft skills, work aspirations, work and academic history and other details about you (phone number, gender, current company) as well as content such your photo or your motto. To add certain content, like pictures, you may allow us to access your camera or photo album. We also collect your date of birth to verify that you are above 16 years old age.

By giving us this information, you agree that we store, process and use this information for matching purposes.

However, please note that you do not have to have a fully complete User profile in order to use the fairception Service, however your level of profile completeness will directly impact the level of quality and/or access to some functionalities of the Services provided.

Please note that, although you will be able to view a representation of your User profile and scores in your private space, your full User profile is not publicly visible to other fairception members unless it is anonymised first.

Only some information in your talent card is available publicly. This include your top soft skills with details on the main ones only, labels on your transferable skills, expertise scores, split of feedback received, top archetypes without scores. You can also decide to share all the data of your personal talent card by using a dedicated feature.

 

5. Leaving a feedback

As a fairception user you will be able to leave feedback to an existing member whether you have been asked to do it or not, or to a person who is not a fairception member. We collect information when you provide answers to the questionnaires related to relationship with the person, soft skills, transferable skills, expertise and additional questions. We collect information related to the circumstance of the feedback (for example, but not limited to date, time, duration of feedback, account and profile details of the person who left and received a feedback).

When you leave feedback to a person who is not a fairception member you provide information about that person, who will be notified about your feedback being received. The person should activate the fairception account within 60 days, if not the details of the person will be deleted or anonymized.

Anonymity

Leaving anonymous spontaneous feedback is an essential element of fairception. Under no circumstances, when you leave a feedback the person who receives the feedback

• knows who has left the feedback (but might be notified that a feedback is received)
• will be able to see your input directly. Data are aggregated, processed and presented to the person when at least 3 users have provided feedback

The only exception to the above is the case when you leave feedback to a person not yet registered on fairception. The person will be notified that you specifically have left feedback but will still need to collect additional feedback from other users to see aggregated data in his/her profile. Individual feedback is never shared.

 

6. Receiving a feedback

As a fairception user you will be able to receive feedback from an existing member whether you have proactively asked for it or not, or from a person who is not a fairception member but who you would have invited to do so. We collect information about you when you receive feedback such as declared relationship with the person, soft skills ranking, transferable skills /expertise endorsements and answer to additional questions. We collect information related to the circumstance of the feedback (requested/spontaneous, date, time, duration of feedback).

When you have received feedback from at least 3 persons, we process data to map your soft skills, unicity, transferable skills, expertise and other information collected in the questionnaire. We process data to minimize as much as possible any bias linked to feedback and aim to provide a balanced picture of yourself.

Anonymity

Under no circumstances, when you receive a feedback you will

• know who left feedback (but might be notified that a feedback is received)
• know the detail of individual feedback. Data are aggregated and presented to You when feedback has been received from at least 3 different users (see section data available)

The only exception is when you are not yet a fairception registered member and someone has left you a feedback, you will know who left you a feedback. However, you will need to collect 2 additional feedback to start seeing aggregated data about yourself.

The app is protecting anonymity of individual feedback to ensure authenticity / credibility of the questionnaire process and quality of the Service we provide, and therefore anonymity should always be preserved. By design any User is discouraged from attempting to get detailed information on individual feedback, even anonymized, as it would impact the trust other users might have in this service and could compromise the nature of the service provided.

 

7. What information does fairception collect when using the fairception website?

Every time you access the fairception website, we will collect your usage data. This means that, even if you have not signed up as a fairception member, we might collect and use this information about you. This data is sent to us by your Internet browser and is stored in log files. This data includes:

• Information about your browser type and your internet service provider, as well as your operating system (for example Windows 7, Apple OS, etc.)
• The IP address (Internet Protocol address) of the device you use to access our website or Service. We will also compare your IP address against a geo-database to collect information about your location
• Information about the page that you have accessed
• The date and time that you used the website
• The referrer URL (origin URL) from which you came to the page that you have accessed
• Status message as to whether you were successfully able to access the website
• Screen resolution used on your device

When you contact using our feedback form we will collect your data.

 

8. What information does fairception collect when using the fairception app?

When you use our services, this generates technical data about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:

• Usage Information
• Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, the date and time that you used the app, the time you have spent on some screens, actions taken, information shown to you, language setting, internet service provider) and your interactions with other users (request sent, feedback given, feedback received)

 

• Device Information

We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, identifiers associated with cookies or other technologies that may uniquely identify a device or browser, service provider.

 

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

 

The Company is willing to understand how users interact with its Services and need to process various browsing information resulting from Cookies which qualify as Personal Data, for the performance of analytic operation related to the Services’ use.

 

When you browse our Website, cookies may be placed on your terminal equipment, either directly or after having obtained your consent when required by the regulations on cookies. Those might be session cookies that disappear as soon as you leave the website or permanent cookies that remain on your device until their lifetime expires or until you delete using your browser.

 

Cookies are pieces of information placed on the Internet user's terminal equipment by the server of the website visited. They are used by a website to send information to the Internet user's browser and to allow this browser to send information back to the website of origin.

 

5. HOW WE USE INFORMATION?

 

The main reason we use your information is to deliver our services and improve the performance of the contract you have entered into by registration of an account.

Additionally, we use your info to help keep you safe, and to provide you with advertising, stats about yourself, how you are perceived and about job/career opportunities that may be of interest to you.

Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

1. To administer your account and provide our services to you

For example, it includes account creation and management, customer support, communication about the Services of offers

2.  To help you evaluate your strengths and build your talent card

For example, it includes the main characteristic of your soft skills and hard skills. Data are used to evaluate how you compared in certain fields compared to other users in a particular community.

3.  To process feedback you send

4.  To operate advertising and marketing campaigns

For example, it may include an evaluation of the performance of our services or communication about products or services that we believe may be of interest to you, provided or not by third parties

5.  To improve our services, develop new ones

This includes the administration and the development of social groups linked to fairception stats, to  highlight your profile in the community (Leaderboard) when you stand out

6.  To prevent, detect and fight fraud and other illegal or unauthorized activities

This includes

• Find and address ongoing, suspected or alleged violations of our Terms & Conditions, notably through the review of reports and interactions between members, including during the calls
• Better understand and design countermeasures against violations of our Terms
• Retain data related to violations of our Terms to prevent against recurrence
• Enforce or exercise our rights, for example our Terms&Conditions
• Communicate to users what we’ve done as a result of their reports

 

7. To ensure legal compliance

To process your information as described in this Privacy Policy, we rely on the following legal bases:

• Provide our service to you: The reason we process your information is to perform the contract that you have with us. For instance, when you are using our service to map your strengths, build your talent card or get noticed, we use your information to update your account and your profile, make some information visible to other users publicly or use your information anonymously for job match

• Legitimate interests: We process your information also based on our legitimate interest. For instance, we analyze users’ behavior on our services to continuously improve our Service, ensure that users comply with the community rules and provide fair feedback, and to keep our users safe. We also process data where necessary to enforce our rights and enable us to defend ourselves in the event of a legal action

• Comply with applicable laws and regulations: We process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents users give us and decisions they may have taken to opt-out of a given feature or processing

 

6. HOW WE SHARE INFORMATION ?

 

The Company may share your Personal Data with third-party service providers, partners and suppliers which assist the Company in fulfilling the purposes specified in this Policy and operating the Service. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

• Furthermore, as the case may be, the Company may share 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, the Company communicates your Personal Data to the above recipients on a strictly need-to-know basis and only as necessary for fulfilling duly identified processing purposes.

Since our goal is to help you make meaningful connections, you mainly share information with other fairception users. You also share information with anyone when you voluntarily disclose information on the service (including - but not limited to - your public profile or your talent card).

 

7. YOUR RIGHTS

 

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

• Your right of access. You have the right to ask us for copies of your personal data. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR).
• Your right to rectification. You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
• Your right to erasure. You have the right to ask us to erase your personal data in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the personal data for one of the following reasons:

• To exercise the right of freedom of expression and information
• To comply with a legal obligation
• To perform a task in the public interest or exercise official authority
• For archiving purposes in the public interest, scientific research, historical research or statistical purposes
• For the exercise or defense of legal claims

In case of account closure, and depending on the circumstance Company might remove any feedback left to others with that account and reprocess information accordingly, or fully anonymise the account and keeping the feedback and associated information live and active for others

Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages from them through our service, the other user will have to contact us to submit a separate request for their information. We may also ask them to provide proof of identity before we can answer the request.

To exercise his rights mentioned aboveor for any question on Personal Data protection, the User shall make a request accompanied by proof of identity by mail addressed to Thentik SAS, 5 rue de l’Industrie 74000 Annecy, France. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

The Company shall strive to reply without undue delay and at the latest within one month of receipt of the request. The Company reserves the right to extend this period to three (3) months in case of a complex request or implementation.

• Finally, the User has the option to refer to the competent supervisory authority, the Commission Nationale Informatique et Libertés (“CNIL”), in order to submit a claim.
• The Company is committed to protect your Personal Data and comply with the applicable data protection legal framework.

• The Company requires your assistance to this end. Thus, you commit to inform the Company in case the Personal Data you shared with the Company would become obsolete or inaccurate.
• Access / Update tools in the service: Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service.
• Device permissions: Mobile platforms may have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain fairception app services may lose their functionality.
• Uninstall: You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. Remember that uninstalling an app does NOT close your account. To close your account, please use the corresponding functionality on the app.

Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 16 years of age or older.

 

8. HOW LONG WE RETAIN YOUR INFORMATION?

 

With respect to the management of your account, the Company will retain your Personal Data until the closure of your account.

If you decide to stop using our services, you can close your account and your profile will stop being visible to other users. Depending on the circumstances, we my might decide to anonymize your account and the feedback you have provided to other people. After your account is closed, we will delete your personal information, as laid out below:

• To protect the safety and security of our users, we implement a safety retention window of three months following account closure. During this period, we keep your full information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims. However, if the Company needs to retain your Personal Data for evidential purposes beyond the 3-month period, then the maximum applicable retention period will be in accordance with the statutory limitation periods and will not exceed the period for which the Company must retain the data for evidential purposes
• Personal Data processed by the Company to perform analysis on your profile will not be retained by the Company after such operations have been completed and the relevant reports/outputs have been produced.
• We maintain limited data to comply with legal data retention obligations: for example, transaction data might be kept for up to 10 years for tax purposes
• When the Company collects and processes User’s Personal Data for the use of the Services, Personal Data is kept for fifteen (15) months from the last activity

• Nevertheless, the Company may store some Personal Data for a longer duration than required in the immediate and current needs due to legitimate interests and legal obligations.
• When the relevant retention period expires, the Company will delete your Personal Data or will irrevocably anonymise it so that you can no longer be identified.
• If the Company considers that it is not necessary to keep your Personal Data in its active database, it will archive it and ensure that access to it is restricted to a limited number of persons with a genuine need to access it.

 

9. CHILDREN’S PRIVACY

 

Our services are restricted to individuals who are 16 years of age or older.

 

10. PRIVACY POLICY CHANGES

 

Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes

 

11. SECURITY

 

• The Company has implemented measures to protect the confidentiality, security and integrity of your personal data, against unauthorised access and disclosure, modification, alteration, damage, accidental loss or accidental or illicit destruction, as well as against any other form of illicit processing or communication to unauthorized persons
• Access to personal data is restricted to those employees, partners and service providers who need to know the information, to whom we impose strict security and information protection rules
• However, the Company cannot guarantee you against any loss, destruction or damage of your personal data. The Company is not held, or able to carry out a safeguard of your data present on your personal space
• In addition, when you need to choose a password to access certain parts of the Website that require you to log in to your personal space, it is your responsibility to choose a secure password (strong, unique (i.e. not used for another site and/or application, etc.) and to keep it confidential

 

12. JURISDICTION AND APPLICABLE LAW

 

• The Policy is governed and interpreted according to French and European law
• Unless otherwise provided by the law, the Policy will subject Users to the exclusive jurisdiction of the French courts