Date of update : 03/22/2022

We invite you to read this document carefully (hereinafter, the “Confidentiality Policy” or the “Confidentiality Rules”). All of the definitions contained in the General Conditions of Use and the General Conditions of Service are applicable to this document.

1. Preamble and scope

Refty is careful to preserve the confidentiality of the personal information of Candidates, Referrers and natural persons working for Clients (hereinafter referred to as “Users”) and attaches great importance to the protection of the privacy of Users of the Platform.

The purpose of the Privacy Policy is to define the rules applicable to the collection and processing of Users' personal information (hereinafter “Personal Data (s)”) via our Reference collection platform. Personal Data is defined as any information relating to a natural person who can be identified, directly or indirectly, such as the last names, first names, email and postal addresses of a natural person, their image in a photograph or video, an IP address, location data, license plate, etc.

These Privacy Rules detail the Personal Data collected and processed when using our Platform, the reasons for processing Users' Personal Data, the way in which Refty uses them and the features offered to allow Users to access and update their Personal Data.

The Privacy Policy is an integral part of the General Conditions of Use and Provision of Services of the Platform. It applies to users of the Platform regardless of their category: candidates, recruiters and other professional or non-professional natural persons, in particular Referrers.

2. Acceptance and update of our Privacy Policy

By checking online the box "I have read and accept the Privacy Policy of", the User confirms having read and accepting without restriction or reservation these conditions. In case of disagreement with one of its terms, the User is free not to no longer use our services (in particular in the event of modification of the terms of the Policy).

These Confidentiality Rules may change, it being specified that any reduction in the rights of Users cannot be applied without their consent. Also, Refty will publish the new versions of the Privacy Policy on the Platform and will alert Users by means of an email offering them the possibility of consulting them.

In general, the Privacy Policy is always easily accessible via the various pages of the site.

3. Person responsible for processing Personal Data

The processing of the Personal Data of Users registered on the Platform is subject to French law, in particular to law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended (known as the Data Protection Act ) as well as EU Regulation 2016/679 of April 27, 2016, known as the General Data Protection Regulation (GDPR).

According to the legislation in force, the Person in charge of processing Personal Data of the Users is the legal person in charge of the process of recruiting the Candidate, that is to say the Customers of Refty.

Refty processes Users' Personal Data under the direction of its Customers as a subcontractor. For more details on the processing carried out by the Refty Customer on whom you depend, we refer you to its data protection policy.

In this capacity, Refty undertakes to comply with the legal provisions in force and to carry out lawful, fair and transparent processing of Users' Personal Data. Refty also guarantees Users that this processing falls within the framework of the explicit and legitimate purposes determined by the Data Controller. The processing time does not exceed the time necessary for the purposes for which the Personal Data is collected and processed.

4. Categories of Personal Data collected and processed via the Platform

a) What Personal Data is collected and how is it processed?
For the purposes of performing the Service, Refty may collect several categories of Personal Data concerning Users, for different purposes, legal bases of processing and retention periods. Users will find a summary of all of this information below:

You can withdraw your consent as easily as you gave it. To do so, please do not hesitate to write to us at the email address specified at the end of this privacy policy.
b) Cookies

A "cookie" (or "tracker") is a connection cookie which designates a text file that can be saved in a dedicated space on the hard drive of your terminal (computer, tablet, or smartphone), on the occasion of the consultation of a service accessible online. A cookie allows its issuer to identify the terminal in which it is registered, during the period of validity or registration of the cookie. The cookie therefore does not identify the User as such; it is used to record the User's browsing information on the Platform.

When the User visits the Platform, information relating to their browsing may be recorded in “Cookies” files installed on their terminal, subject to the choices expressed by the User concerning cookies and which can be modified at any time. These cookies allow personalized navigation for the User and are also used for analytical purposes (audience measurem
The existence of cookies and their purpose (s) are indicated to the User as soon as they connect to the Platform, by the presence of an information banner placed at the bottom or top of the home page.

The placement and reading of cookies on the User's terminal requires their prior consent, obtained by clicking on "I accept". The user can, however, configure their browser to refuse cookies or customize the cookie settings by clicking on the "Find out more" link. The agreement given for the use of cookies is valid for 6 months. The user will be asked for their consent again when this period expires.

In the event of refusal of cookies, or deletion of those that are stored, the User is informed that they will no longer be able to benefit from a certain number of functions which are nevertheless necessary to navigate in certain areas of the Platform. Where applicable, Refty declines any responsibility for the consequences related to the degraded functioning of its Services resulting from the inability for Refty to save or consult the cookies necessary for the proper functioning of the Platform and which you have refused or deleted.

Finally, a distinction should be made between cookies issued on the Platform and those issued by third parties. As such, Refty informs the User that cookies may be placed from time to time on certain pages of the Platform by third parties (advertisers or others).

5. Conditions of use of Personal Data

Any use of Personal Data for a purpose other than those set out above in our Privacy Policy will require the express prior consent of the User.

Refty undertakes to keep the Personal Data of Users only for the period strictly necessary for the declared processing (s) for the aforementioned purposes, and in any event within the limits imposed by law.

In any event, Refty undertakes to erase Personal Data from its databases at the end of these different periods.

However, Refty may retain certain information for a period subsequent to the closure of the User's personal account in order to meet legal, accounting and tax obligations and in particular in order to prevent possible illegal behavior after the deletion of a personal account (reuse of an old account by a third party). In this case, the Personal Data will be deactivated and will no longer be accessible online.

6. Sharing of information with third parties

a) Lack of communication to third parties

Refty undertakes not to disclose to third parties the information and Personal Data communicated by Users. This information and Personal Data are used exclusively by the internal departments of Refty and the Data Controller and will under no circumstances be transferred or sold to third parties without your express prior consent.

b) Communication for external processing needs

The information and Personal Data of Users may, where appropriate, be transmitted to third party subcontractors involved in the provision of the Services (technical and hosting service providers, customer monitoring and satisfaction surveys, management of security incidents or fraudulent activities, etc.).

Refty undertakes not to communicate Users' information and Personal Data unless it has obtained the prior consent of the Data Controller. In such a case, Personal Data are only transmitted to authorized and trusted service providers, who process them on our behalf, according to our instructions and in accordance with these Confidentiality Rules and in compliance with any other appropriate security and confidentiality.

c) Communication for legal reasons

In addition, information and Personal Data may be disclosed to a third party if Refty is required to do so by law, a regulatory provision, or a court order, or if this disclosure is made necessary for the purposes of an investigation, injunction or legal proceedings, on national territory or abroad.

Likewise, Refty may be required to share information and Personal Data with companies, consultants or third parties in order to:

Enforce the Privacy Policy and the General Conditions of Use and Service of the Platform in force, including to note any breaches thereof;

Protect against any infringement of the rights, property or security of the company KARTEL and its users, in application and in compliance with the law.

7. Security of Personal Data

Refty implements all the security measures necessary to protect Users' Personal Data against any unauthorized access and disclosure, modification, damage or destruction of the data collected.

8. Respect for the rights of Platform Users

The User has:

a right of access, allowing them free access to the Personal Data collected about them;

a right of rectification, allowing them to update or correct their data,

a right of deletion, exercisable when the Personal Data is no longer necessary for the purposes for which it was collected or in the event that you withdraw your consent to the processing;

a right to object to the collection and processing of all or part of the data collected for the purposes of commercial prospecting, including profiling insofar as it is linked to such prospecting;

a right to limit the processing of Personal Data when:

a request for rectification has been made. The User can then request that the processing of their Personal Data be stopped for the time necessary to verify the accuracy of the requested corrections;

the User opposes the erasure of their Personal Data, the processing of which was unlawful;
Refty no longer needs the Personal Data for the purposes of processing but you still need it for the establishment, exercise or defense of legal claims;

The User makes use of their right of opposition. The User can then request the cessation of processing of their Personal Data for the period necessary to weigh their reasons against the legitimate reasons of Refty.

In addition, it should be noted that these rights offer the User the possibility of modifying their notification preferences at any time, by accepting or refusing that their Personal Data be used as part of Refty marketing or promotional actions.

You can exercise these rights at any time in two ways:

By post to the following address: 8 rue Sainte Marthe - 75010 Paris, France.

By e-mail to:

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