PRIVACY POLICY

DATA PROTECTION

HIGH FLYERS AGENCY, a simplified joint stock company with a capital of €23,391, registered under the number 814 113 205 RCS Paris, whose registered office is located at 50 rue de Rennes - 75006 Paris - France (hereinafter "HIGH FLYERS AGENCY") operates and publishes the website located at the following address https://www.highflyers.agency (hereinafter the "Site"). HIGH FLYERS AGENCY is likely to collect and process personal data relating to individuals who access the Site (hereinafter the "Users") in the context of their browsing on the Site. In this respect, HIGH FLYERS AGENCY acts as the data controller (hereinafter the "Data Processor").

For the sake of transparency, the Data Controller takes care to inform, through this Data Protection Policy, the natural persons concerned of each of the data processing operations that concern them in accordance with the provisions of Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms in its amended version as well as in compliance with other applicable French and European Union texts and in particular the General Data Protection Regulation (Regulation (EU) 2016/679 of April 27, 2016, hereinafter "GDPR").

The processing operations not listed herein are subject to their own information notices, in particular with regard to legal entity customers, employers likely to use the Services available on the Site (hereinafter the "Customers").

The Data Controller is available to provide any necessary clarification concerning its Data Protection Policy at the address indicated in Article 7 of this policy.

Article 1: Definitions

Personal Data: means information, in any form whatsoever, relating directly or indirectly to an identified or identifiable natural person such as surname, first name, date of birth, information transmitted by this person, IP address, connection data ....

Controller: means HIGH FLYERS AGENCY which, alone or jointly with others, determines the purposes and means of processing Personal Data.

Services: means all the services that HIGH FLYERS AGENCY offers to Users on the Site.

Subcontractor: refers to any company that processes Personal Data on behalf of the Controller.

User: refers to any Internet user, natural person of legal age, accessing the Site.

Article 2: Origin and categories of Personal Data collected

Within the framework of its activities, the Data Controller collects various categories of Personal Data relating to Users via navigation on the Site and subscription to the Services. This Personal Data is processed in accordance with the General Terms of Use of the Site, the General Terms of Use of the Services and the Cookies Policy:

Origin of the Personal Data

Categories of Personal Data

Browsing on the Site

Concerns the Users of the Site.

Connection data: connection and usage logs, IP address

Data related to the navigation on the Site: pages consulted, clicks made

Registration form for the Services

Contact information: surname, first name of the User, e-mail address, telephone number.

Professional information: curriculum vitae, link to the User's LinkedIn profile, purpose of registration (to apply online for a job or to be contacted by a consultant for this or another position), professional skills, specifics of his or her working conditions, possible Skype identifiers, type and size of the company in which he or she would like to work, position and place of work desired, professional achievements, desired remuneration.

Some Personal Data are mandatory, others are optional according to what is indicated to the User at the time of collection of his Personal Data. Failure to fill in the mandatory fields could affect access to the Services.
The User agrees to provide true, accurate and complete information. To ensure that the Data Controller has up-to-date information, the User is invited to notify the Data Controller of any change in his/her contact details or any other Personal Data concerning him/her, by contacting the Data Controller at the address indicated in Article 7 of this Policy.


The Site is not intended to contain so-called sensitive Personal Data (racial or ethnic origins, political, philosophical or religious opinions, trade union membership, health status, genetic and biometric data). Users are solely responsible for the information they provide on these data. The Data Controller reminds the User that he/she must refrain from making any mention of his/her origin, political opinions, family status, sexual orientation, state of health, morals, physical appearance (photograph), trade union activities, membership or non-membership of an ethnic group, nation, race or religious beliefs.


If they communicate such information, it is with their express consent that they authorizes the Data Controller to use it and to transmit it, if necessary, to the Clients. Any User engages his responsibility towards the natural persons concerned in case of voluntary or involuntary seizure of sensitive Personal Data concerning other persons.

Article 3 - Purposes and legal basis of Personal Data processing

The collection of Personal Data is intended to optimize the management of the various relationships that the Data Controller has with the User.

More specifically, the processing of Personal Data meets the following purposes (non-exhaustive list):

Legal basis

Purposes

Consent

- Sending newsletters

- Depositing cookies, in particular, to personalize content and advertisements, to optimize the Site's functionalities, to measure the audience of the latter and to offer targeted advertising. See the Cookies Policy


Contractual obligation

- Management of Users in accordance with the General Terms and Conditions of Use of the Services, including the evaluation of the User and the publication of applications and transmission to Clients

- Follow-up of applications

Legitimate interest

- Management of complaints

- Management of requests to exercise the User's rights

- Statistical analysis for the purpose of managing and improving the Services

Article 4 - Recipients of Personal Data

The Data Controller applies strict security measures that allow the Personal Data it processes to be transmitted only to persons authorized to have access to it internally, according to their respective authorizations. These persons are bound by an obligation of confidentiality.

The User's Personal Data is disclosed to Customers who have positions that may be of interest to the User, under the conditions set forth in the General Conditions of Use of the Services.

The Data Controller may also use service providers, commercial and technical subcontractors, to whom the Personal Data may be transmitted or made accessible in a temporary and secure manner, such as

suppliers of software and correlative applications as well as maintenance providers; these services may sometimes have access to the data in order to carry out the tasks requested;

marketing agencies for the realization of advertising, marketing and sales campaigns.

Guarantees have been taken to ensure a sufficient level of protection of the Personal Data concerned with regard to the requirements of French and European regulations.

Article 5 - Duration of retention of Personal Data

The duration of retention of Personal Data varies according to the purpose of their collection.

The Personal Data of the User are kept for two (2) years following the last contact with the User, if necessary increased by the legal periods of archiving, conservation of certain data and prescription of the applicable actions in responsibility.

The Personal Data of Users who have subscribed to the newsletter are kept for a period of three (3) years from the last contact between the User and the Data Controller unless the User objects.

The Personal Connection Data is kept for a period of twelve (12) months from the date of its collection in accordance with the applicable legal provisions.

Article 6 - Rights of the persons concerned

The Data Controller is particularly concerned with respecting the rights of the persons concerned by the data processing that it implements and therefore recognizes the existence of the following rights:

the right to information ;
the right of access; and
the right of rectification;
the right to erasure ("right to be forgotten");
the right to object;
the right to limitation of processing;
the right to portability;
the right to define specific and general directives relating to the conservation, deletion and communication of its post-mortem Data.


Article 7 - Duration of retention of Personal Data

The duration of retention of Personal Data varies according to the purpose of their collection.

The Personal Data of the User are kept for two (2) years following the last contact with the User, if necessary increased by the legal periods of archiving, conservation of certain data and prescription of the applicable actions in responsibility.

The Personal Data of Users who have subscribed to the newsletter are kept for a period of three (3) years from the last contact between the User and the Data Controller unless the User objects.

The Personal Connection Data is kept for a period of twelve (12) months from the date of its collection in accordance with the applicable legal provisions.

Article 8 - Rights of the persons concerned

The Data Controller is particularly concerned with respecting the rights of the persons concerned by the data processing that it implements and therefore recognizes the existence of the following rights:

the right to information ;
the right of access; and
the right of rectification;
the right to erasure ("right to be forgotten");
the right to object;
the right to limitation of processing;
the right to portability;
the right to define specific and general directives relating to the conservation, deletion and communication of his post-mortem Data.
The Data Controller is able to respond to requests to exercise the rights of the Data Subjects throughout the processing, in compliance with the conditions and deadlines established by the applicable regulations.

Requests for the exercise of rights by the data subject shall be made, unless otherwise requested

electronically at the following address: contact@highflyers.agency or
by post to the following address: 50 rue de Rennes - 75006 Paris - France
The person concerned must clearly indicate his/her surname(s) and first name(s), attach a copy of an identity document and indicate the address to which he/she wishes the reply to be sent.

The Data Controller informs any data subject who wishes to exercise his/her rights if it is impossible to respond to his/her request.

Any person also has the right to lodge a complaint with a supervisory authority such as the Commission Nationale Informatique et Libertés www.cnil.fr

Cookies Policy

HIGH FLYERS AGENCY, a simplified joint stock company with a capital of €23,391, registered under number 814 113 205 RCS Paris, whose registered office is located at 50 rue de Rennes - 75006 Paris - France (hereinafter "HIGH FLYERS AGENCY") is likely to use "cookies" when any user (hereinafter the "User") consults the website at the following address https://www.highflyers.agency (hereinafter the "Site"), regardless of the terminal used (computer, tablet, smartphone...).

This Cookie Policy provides information on how HIGH FLYERS AGENCY uses cookies and how the User can control them. 

What is a cookie?

A cookie is a connection indicator which, subject to the User's choice, is recorded on the User's terminal in the form of a text file when the Site is consulted and allows its issuer to identify the terminal.

Cookies have many functions. In particular, they allow Users to navigate between pages efficiently, they remember their preferences and generally improve the User experience. They can also make online advertisements more relevant to Users' interests. For more information on cookies, the User should visit www.allaboutcookies.org.

There are different types of cookies:

1. session cookies that disappear as soon as the User leaves the Site;
2. permanent cookies that remain on the User's terminal until their lifetime expires, unless the User objects.

The User is informed that, during his visits to the Site, cookies may be installed on his terminal equipment.

Why does HIGH FLYERS AGENCY use cookies?
HIGH FLYERS AGENCY uses cookies in order to ensure the functioning of the Site and to provide Users with an optimal browsing experience on the Site.


To this end, HIGH FLYERS AGENCY uses cookies in order to:

to measure and improve the services offered on the Site;
analyze the traffic and the use of the Site, in order to improve the browsing experience;
to make the Website more user-friendly and interactive.


session cookies that disappear as soon as the User leaves the Site;
permanent cookies that remain on the User's terminal until their lifetime expires, unless the User objects.
The User is informed that, during his visits to the Site, cookies may be installed on his terminal equipment.

What cookies does HIGH FLYERS AGENCY use?

The Site uses both :

1. Cookies issued by HIGH FLYERS AGENCY, placed directly by it on the User's computer when he/she consults the Site;
2. Third-party cookies, issued by HIGH FLYERS AGENCY's partners on its behalf to help it analyze the use of the Site.

The deposit of third-party cookies is subject to the prior consent of the User. The processing of the User's data by the partner issuing the third-party cookies is done under their own responsibility, in accordance with their own data protection policy. HIGH FLYERS AGENCY invites the User to take cognizance of the said policies and informs him/her that he/she can refuse third-party cookies by making the appropriate settings in his/her browser.

The cookies that may be used on the Site have been classified according to the following categories.

- Type of cookies

- Purpose

1. Operating cookies

These cookies allow HIGH FLYERS AGENCY to provide a personalized interface depending on the tool used to access the Site (desktop version, mobile version).

These cookies also allow the User to use the main features of the Site. These cookies are necessary for the functioning of the Site and therefore cover authentication cookies or interface personalization cookies. Their deletion may lead to navigation difficulties as well as the impossibility of connecting to the Site. These cookies are exempt from consent.

2. Analysis and audience measurement cookies

These cookies allow HIGH FLYERS AGENCY to count visitors and identify the way they use the Site, for example, the pages most often consulted, the terms searched for, the duration of the visit, etc., with a view to improving the interest and ergonomics of the services. Audience measurement cookies are exempt from consent if they meet the following conditions:

- These tracers must have a purpose strictly limited to the sole measurement of the audience on the site or the application for the exclusive account of the publisher.

- In particular, these tracers must not allow the global tracking of the navigation of the person using different applications or navigating on different websites.

- Likewise, these tracers must only be used to produce anonymous statistical data, and the personal data collected may not be cross-referenced with other processing or transmitted to third parties, these different operations not being necessary for the functioning of the service either.

3. Personalization cookies

These cookies allow HIGH FLYERS AGENCY to improve its offer, to personalize the User's browsing experience and to better target his expectations according to his previous visits. They are subject to the User's consent.

4. Social Network Cookies

These cookies allow the User to connect to his social networks and to share content from the Site on social networks in order to improve the usability and interactivity of the Site. They are subject to the User's consent.

The maximum retention period for cookies is set at between 6 months and a maximum of 13 months (audience measurement cookies not exempt from consent) from the date of their deposit.

If the User interacts with the social network buttons accessible on the Site, the corresponding information will be transmitted and recorded on the social network server. The deposit of social network sharing Cookies is subject to obtaining the prior consent of the User.

These Cookies are deposited by the social network provider thanks to the insertion of a module ("plug-in") by HIGH FLYERS AGENCY on the Site. HIGH FLYERS AGENCY and the social network provider are to be considered as Co-Processors for this processing only. It is not responsible for further processing by the third party, involving the processing of Personal Data, for which the said third party remains the sole Data Controller.

Finally, if the User is connected to a social network while browsing the Site, the social network will be able to directly link his visit to his user account of said social network. If the User does not want the social network to link the information collected through the Site to his social network user account, the User must disconnect from the social network before consulting the Site.

HIGH FLYERS AGENCY does not store sensitive personal information in the cookies it uses. HIGH FLYERS AGENCY does not resell the information recovered thanks to the cookies.

How to manage cookies?
The User has several options to manage, in particular to deactivate and authorize, cookies and other tracking devices.

During his first visit to the Site, a banner informs the User of the presence of these cookies and invites him to indicate his choice. They are deposited only if the User accepts them, except in the case of cookies exempt from consent. The User has the option of choosing to accept all cookies or to choose which ones he/she accepts according to their sender. The User may at any time choose to modify the cookie settings (enable or disable) by clicking HERE.

The User can also set his computer to accept or reject certain cookies. If the User is using different computers at different locations, the User should verify that each browser is set to its cookie preferences.

The User can regularly delete cookies from his terminal via his browser. However, it is important to remember to set the parameters of all the browsers of the different terminals (tablets, smartphones, computers...).

The configuration of each browser is different. It is described in the browser's help menu, which will allow the User to know how to modify his wishes regarding cookies. As an example, here are the links to the help pages of the main browsers:


Internet Explorer™
Safari™
Chrome™
Firefox™
Opera™

However, HIGH FLYERS AGENCY draws the attention of Users to the fact that by setting their browser to refuse cookies, certain functionalities, pages, areas of the Site will not be accessible, for which HIGH FLYERS AGENCY cannot be held responsible.

Opposition platforms

Several platforms of advertising professionals also offer the possibility of refusing or accepting cookies used by the companies that are members of them. These centralized mechanisms do not block the display of advertisements but only prevent the installation of cookies allowing the adaptation of advertisements to the Users' interests.

The User can, for example, go to the site https://www.youronlinechoices.com to prevent the installation of these cookies on his terminal. This site is proposed by digital advertising professionals grouped together within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France.

This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralized interface that allows users to refuse or accept cookies that may be used to adapt the ads that may be displayed to their terminal's navigation.

HIGH FLYERS AGENCY 2023. All rights reserved.

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