We design, deliver and differentiate customer experience on behalf of some of the world’s most respected brands.
1. WHO IS ACCOUNTABLE FOR PROCESSING MY PERSONAL DATA?
ACR – Advanced Customer Relation S.á r.l.
43, boulevard Pierre Frieden
Email: [email protected]
is responsible for processing your personal data on this website (hereinafter referred to as “we”).
We process personally identifiable information (“personal data”) in accordance with GDPR provisions and the German Federal Data Protection Act (BDSG).
You can contact our designated Data Protection Officer at the address indicated above by using the reference ‘For the attention of the Data Protection Officer’ or by writing to: [email protected]
Local specific details for data controllers
Majorel Georgia LLC
34 Chavchavadze Ave., 0179 Tbilisi, Georgia
Email: [email protected] / [email protected]
2. WHAT DATA IS COLLECTED?
When you visit our website, the data of the computer you use to access our website is automatically logged (“access data”). This access data includes server log files that generally consist of information pertaining to your web browser type and version, your operating system, your internet service provider (ISP), the date and time you used the website, the websites previously visited by you and the websites you accessed from our website, in addition to the IP address of your computer. With the exception of your IP address, the information contained in the server log files is not personally identifiable. An IP address is personally identifiable when it is static (permanently allocated when using internet access) and the ISP is able to attribute it to a specific person.
Some features of our website require that you divulge personal information to us. In this case, the information provided by you is used to provide the service requested by you or process a matter submitted by you (e.g. search queries, entries made in forms or contracts, job application, click data).
3. WHAT COOKIES ARE USED?
As a general principle, cookies enable online recognition without reference to a specific person. Cookies may become personally identifiable when the information they contain is merged with other information apart from the information generated by the cookies themselves. Here a distinction is made between cookies that are necessary for the provision of website features, and cookies that are required for other purposes, e.g. analysis of user behaviour or displaying advertising-related content.
The cookies that are required for the provision of website features include the following in particular:
- Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
- Quriobot and Watson: Used to set start and end of a conversation
- Google Tag Manager: Used to manage third party tools
- Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
- Polylang: Used to remember user’s choice of prefered language
- Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
- Google Analytics: Used for tracking customers behaviour
- Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
4. WHAT PERSONAL DATA IS COLLECTED AND FOR WHAT PURPOSE?
The purpose of data processing may be based on technical, contractual or statutory requirements or result from consent having been given by the user.
We use the data described in section 2 for the following purposes:
- To provide website features and content and ensure technical security in trouble-shooting technical issues and also to ensure that unauthorized persons do not gain access to our website systems;
- To conduct marketing reach measurements and web analyses in order to make our website more efficient and interesting for you, and for market research purposes;
- For communication, completion of precontractual procedures, and customer care purposes;
- To send out newsletters via email;
- For event registration and participation; and
- Founding an employment relationship.
4.1 PROVISION OF THE WEBSITE
4.1.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
In order to enable the proper functioning of our website, security analyses to be conducted, and denial-of-service attacks to be prevented and stopped, server log files are automatically collected and saved on a short-term basis as an integral part of access data that is created by the system of the visiting computer upon accessing our website and while using it (see section 2). The content of the server log files is not merged with other data. We use the server log files for statistical analyses to troubleshoot and remedy technical issues, prevent and defend against denial-of-service attacks and attempted fraud, and to optimize the proper functioning of our website.
4.1.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for the creation of server log files follows from Art. 6(1)(f) GDPR. Our legitimate interests lie in the proper functioning of our website, conducting security analyses and defending against threats.
4.1.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
When the pages of our website are accessed, information is logged to server log files that are stored on our web server; the IP address contained in them is deleted after 7 days at the latest. No analysis is conducted during this time unless there is a denial of service or other attack.
4.1.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your data contained in the server log files provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1.
4.2 CONTACT FORM, EMAIL, CHATBOT AND TELEPHONE CONTACT INFORMATION
4.2.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On our website and social media channels you have the option of contacting us by way of a contact form, by email, messaging, by telephone or by chatbot using the designated email address and phone number. If you take advantage of this option, the information you enter in the contact form, your email address and/or your phone number are disclosed to us. Depending on the reason you are contacting us (questions our jobs openings, pursuing your rights as a data subject, e.g. submitting a request for information) your contact details are processed (with the assistance of service providers). If necessary for processing your request, this information may be shared with third parties (e.g. partner companies).
4.2.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your contact details follows from Art. 6(1)(f) GDPR. We have legitimate interests in processing your request and in continued communication. If the purpose for your establishing contact with us is to enter into a contract with our company, the legal basis for processing your contact details follows from Art. 6(1)(b) GDPR.
4.2.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
Your contact details are deleted once your request has been processed and further communication has been discontinued. This does apply if the purpose of your establishing contact with us is to conclude a contract or you wish to exercise your right as a data subject (e.g. request information). In this case your details are stored until all contractual and/or statutory obligations have been fulfilled and statutory retention periods (currently 5 to 10 years) do not prevent this information from being deleted.
4.2.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You have the right to lodge an objection to the processing of your contact information provided that there are cogent reasons that arise from your specific situation. If you would like to exercise your right to lodge an objection, please write to the contact address in section 1. If you lodge an objection, communication with you cannot be continued. This does not apply if the storage of your contact details is necessary for completing precontractual procedures, fulfilling a contract or exercising your rights as a data subject.
4.3 ASSERTING YOUR RIGHTS AS A DATA SUBJECT
4.3.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
On the website you have the possibility of asserting your rights as a data subject, e.g. request information on your personal information that is currently stored by us. In order to assert your rights as a data subject, it may be necessary that you provide us information pertaining to your person and the specific information that has been processed. Without providing this information, we are not able to cater to your rights as a data subject.
4.3.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for processing your personal information in asserting your rights as a data subject follows from Art. 6 (1) point c GDPR, “Complying with a legal obligation”.
4.3.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
We store the correspondence exchanged with you in relation to your asserting your rights as a data subject for a period of three years. This does not apply to information obtained to clarify your identity, e.g. by way of a labeled photocopy of your personal identity card, where we have been provided one. It will be deleted within one week at the latest of establishing your identity.
4.3.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR INFORMATION REMOVED
The processing of your information is required for complying with your rights as a data subject, and to that extent you have no right to revoke your consent to its processing.
4.4 APPLICATION FOR EMPLOYMENT
4.4.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
Job advertisements are published on our social media pages as well as on the recruiting website. The specific job pages in both our websites or social media channels require a set of information from you in order to apply for a specific vacancy. Your provided personal data/ application will be forwarded to our email and afterwards to our local internal recruiting portal, which collects and processes your data for recruitment purposes.
In some cases when applying via the our online channels, you submit a short application. With the short application you can draw attention to yourself as a suitable talent without referring to a specific job posting. To assess your talent and contact you for suitable vacancies, you must provide your first and last name, email address and telephone number as well as information about the languages you speak, where you live, if you are legally allowed to work in a specific country or other such information for our recruitment team to find a suitable position for you. By providing your data and consenting to data processing, your email address will be used for your authentication by providing you with a confirmation email and after for the recruiters to get in contact with you. The short application as well as the application for a job advertisement in the job section of the social media channels and recruiting websites is voluntary and consent can be revoked at any time with effect for the future.
4.4.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
Your application data will be processed in order to assess your talent and to be able to contact you in suitable vacant positions. The legal basis is Art. 6 sec. 1 lit. a GDPR, by submitting your application you give your consent to the data processing.
4.4.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
After your consent has been given, your short application will be stored for 6 months, unless you withdraw your consent prematurely. This shall not apply if statutory retention obligations oblige us to a longer storage period. Your consent, on the other hand, will be stored 3 years after deletion and/or revocation in order to be able to prove that we have complied with our legal obligations – to let you consent to data processing.
4.4.4 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You can obtain your consent any time without any formality by contacting ACR – Advanced Customer Relation S.ár.l. (L-1543 Luxembourg, 43, boulevard Pierre Frieden, Email: [email protected]). The same applies to the individual companies in the group. The corresponding address can be found in Section 1 or in the consent.
4.7.1 GOOGLE TAG MANAGER
This website uses Google Tag Manager. Google Tag Manager managers „tags“ (placeholder for website code). Google Tag Manager does not collect data and data collected by the tags cannot be accessed by the Google Tool Manager.
4.7.2 GOOGLE ANALYTICS
This website uses Google Analytics. Google Analytics is a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as described in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing contract we have concluded with Google Inc.
4.7.3 GOOGLE ADS
4.7.4 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
The legal basis for collecting and analyzing pseudonym usage profiles follows from Art. 6(1)(f) GDPR / Section 15(3) German Telemedia Act (TMG). We have a legitimate interest in optimizing the user-friendliness of our website and performing marketing reach measurements.
4.7.5 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
As a general rule, the data that is collected and analyzed in association with Google and Adobe Analytics remains stored until you raise an objection to it being used in this manner. Analytics cookies are stored for a maximum of 24 months.
4.7.6 OPTIONS FOR LODGING AN OBJECTION AND HAVING YOUR DATA REMOVED
You can raise an objection to the use of Google Analytics by changing your browser settings and/or clicking on the following links to download and install the browser plug-ins and/or opt-out:
● Google Analytics: https://tools.google.com/dlpage/gaoptout
4.8 EXTERNAL SERVICES AND CONTENT ON OUR WEBSITE
We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.
That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.
- YouTube: https://support.google.com/youtube/answer/7671399
- Google Maps: https://maps.google.com/help/terms_maps.html
4.9.1 DESCRIPTION AND SCOPE OF DATA PROCESSING
Our website offers the possibility to subscribe to a free email newsletter. The data entered in the contact form will be collected by us processed with involvement of data processors and used to provide you with the requested information. By subscription we will collect a consent and refer to our Data Protection Notice, where we provide further information how we process personal data. There is no transmission of your data to third parties. The only mandatory information for a subscription to our newsletter are a name (so we can address it accordingly) and a valid Email-address. The so provided information will firstly be processed in order to verify the validity of the consented Email-address by means of an Opt-In. Additionally provided data are not mandatory.
4.9.2 PURPOSE AND LEGAL BASIS OF DATA PROCESSING
For the provision of the requested newsletter we will process your entered data accordingly. The legal basis for this is to be found in Art. 6 sec. 1 lit. a GDPR.
4.9.3 DURATION OF STORAGE OR CRITERIA APPLIED IN DEFINING THIS PERIOD
For the time of your subscription we will store the data needed for the provision of the newsletter. The data will be processed only for this purpose and in order to demonstrate to authorities that we have obtained a valid consent for this processing. Where you withdraw your consent, we will delete all data about you, unless they are needed to demonstrate that we have complied with your withdrawal.
4.9.4 RIGHT TO OBJECT
You can unsubscribe from our newsletter at any time by using the unsubscribe button at the end of any newsletter or by sending an email with the subject “[Your email address] Unsubscribe [Name of the newsletter]” to [email protected] You will get a confirmation mail for your revoked subscription.
5. WHO COMES INTO POSSESSION OF MY PERSONAL DATA?
Majorel Georgia LLC
34 Chavchavadze Ave., 0179 Tbilisi, Georgia
Email: [email protected] / [email protected]
HR/Recruting Contact: [email protected] / [email protected]
Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.
No sharing of information with other recipients such as advertising partners, providers of social media services or credit institutions (“third parties”) takes place.
6. WHAT DATA PRIVACY RIGHTS DO I HAVE?
You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data portability).
If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future. Your notice of revocation is to be addressed to us by writing to the contact address indicated in section 1.
Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to raise an objection to the processing of your data that is done on the basis of Art. 6(1)(f) GDPR. You also have the right to lodge an objection to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.
You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:
Commission nationale pour la protection des données
1, avenue du Rock’n’Roll
Telefon: +352 26 10 60-1
You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.
7. TO WHAT EXTENT DOES AUTOMATED DECISION-MAKING TAKE PLACE?
We do not use any fully automated decision-making processes for any of the purposes set out in section 4.
9. IS PROFILING DONE?