Privacy Notice for Recruitment

Last revised: 23 May 2025

Introduction
This Privacy Notice for Recruitment (“Privacy Notice”) provides information on how Valtech SE, its affiliates under common control and its subsidiaries operating in their offices (collectively referred to below as “Valtech”, “we”) processes and protects personal data of individuals applying for a job at Valtech (also referred to below as “you”, “your”).

The Privacy Notice explains (i) what personal data we process about you during and after the recruitment process, (ii) how we process this data and for what purposes. It also gives (iii) information on the rights you may have in relation to the processing of your personal data and (iv) an overview of the main recruitment-related processing activities conducted by Valtech.

The General Data Protection Regulation (“GDPR”) is considered to be the global leading standard where it comes to privacy regulation. Valtech has decided to abide by the GDPR standard in all the countries where it carries business with possible additional measures depending on applicable local laws, such as the UK Data Protection Act 2018 (“UK DPA”), the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”), and the Canadian Privacy Act and the Quebec Act Respecting the Protection of Personal Information in the Private Sector (the two latter hereinafter referred to as the “Canadian Laws”; and all collectively, the “Other Applicable Laws”).

Information about Valtech

Valtech SE is the leading company of the Valtech group, registered in the Grand Duchy of Luxembourg, under the Trade and Companies Register number B238451, having its registered office at 18 rue Erasme, L-1468 Luxembourg, Grand Duchy of Luxembourg and having offices in Paris registered in the Paris Trade and Companies Register under number B 389 665 167, based at 38 rue des Jeûneurs, 75002 Paris - France. Any contact or notices shall be addressed as described in the “Contact us” section below.

A list of our legal entities can be found at https://www.valtech.com/list-of-valtech-operational-entities/, each being possibly a “Controller” according to data privacy legislation if it processes your personal data.

1. Where your personal data may come from

As used in this Privacy Notice, “personal data” means information that relates to an identified or identifiable individual (e.g., name, email address, contact details, or other information gathered through your interactions with us).

We may collect or obtain your personal data in the following ways:

• Directly from you in any form, such as verbal, physical, or electronic,
• From third parties related to the recruitment process, such as recruiters, referees, etc.
• Through interactions with our website or other recruitment-related platforms,
• From your interactions with us, including interviews, communications, skills assessments, or tests etc.
• If you visit our offices or other locations associated with us,
• From publicly available sources, including professional networking sites such as LinkedIn and/or other social media platforms you direct us to.

2. What Personal Data we may collect about you

We may collect and process the following categories of personal data about you:

• Contact and Personal information: information which may include first name, last name, email address, telephone number, and other contact details, including location etc.,
• Career or Professional information: information which may include CV, employment history, job titles, and/or seniority levels etc.,
• Education, Qualifications and Skills: information which may include institutes attended, qualifications, courses taken, grades achieved, and any relevant knowledge, experience, or skills you may have etc.,
• Communications and interviews: information which may include all communications or interviews, whether in person or remotely, including notes or assessments made etc.,
• Tests or Assessment Results: information which may include any skills assessments or tests undertaken to evaluate your level of expertise etc.,
• Technical data: information which may include information generated when visiting our website or engaging with us on social media, such as IP addresses, interactions with emails/website, social handles or usernames, unique device IDs, language, and operating system etc.,
• Feedback and Opinions: information which may include your thoughts and opinions when you provide feedback on our business or services, or when participating in forums, surveys, etc.,
• Audio and Visual Recordings: information which may include recordings or photographs taken during any interactions with us etc.,
• Information necessary to offer you a role: information which may include national ID/passport, nationalities, residence and/or work permit status, social security number, or other taxpayer/government identification number etc.

We will only request the minimum amount of information necessary for recruitment. Except where permitted by local law, we will not ask for sensitive data and you shall refrain from sharing such data with us. Sensitive data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health or data concerning sex life or sexual orientation.

If you are unable to provide Valtech with the personal data mentioned above, please note that we may not be able to process your application.

3. How we may use your Personal Data

In compliance with GDPR and Other Applicable Laws, we may process your personal data for the following reasons:

• you have given your consent to the processing of your personal data;
• to perform a contract to which you or your employer are party, or to take steps at your request prior to entering into a contract;
• to comply with a legal obligation to which we are subject;
• when the processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, unless the country’s law does not accept legitimate interest as a legal ground. Our legitimate interests include, but are not limited to, recruiting new employees or contractors, evaluating and managing applications, and improving our recruitment process. 

4. Why we may need your Personal Data

We may collect or obtain your personal data to achieve the following purposes:

• identify and evaluate candidates for potential employment, as well as for future roles that may become available,
• communicate with candidates based on current and/or future recruitment needs,
• consider your application for a role you have applied for or other roles that may suit your profile,
• maintain records related to recruiting and hiring,
• foster diversity and inclusion programs and practices at Valtech,
• conduct analytics to improve our recruitment and hiring process and enhance our ability to attract talents,
• conduct analysis or for research purposes using aggregated/pseudonymized data.

5. How we may share or disclose your Personal Data

We may share your personal data:

• Internally within Valtech Group: your personal data may be shared with other Valtech group entities for recruitment purposes,
• Suppliers and Service Providers: we disclose your personal data only to suppliers who use it only in accordance with our instructions and as required by law,
• Authorities: Valtech may share your personal data with authorities to fulfil legal obligations or execute decisions.

Valtech will not sell your personal data to third parties.

6. International Transfers

Valtech is a global organisation having separate legal entities in many parts of the world and relying on an international infrastructure which usually results in global data flows. These flows may include countries around the world in which we have offices, access or host systems or where we conduct business, including countries located outside the European Economic Area.

Accordingly, we may share your personal data with other Valtech entities, for which we have appropriate legal documentation in place, including safeguards. 

On a case-by-case basis, we may also share your personal data with third parties. When relying on such third parties located outside the European Economic Area, we make sure to enter into the appropriate safeguards, such as:

• EU Standard Contractual Clauses,
• UK International Data Transfer Agreement or Addendum to the EU Standard Contractual Clauses,
• Similar clauses as may be required under Other Applicable Laws. 

7. Security of Personal Data

The security of your personal data is our priority. Taking into account the nature, scope, context, and purposes of each data processing, as well as the risks of varying likelihood and severity for your rights and freedoms, we implement all appropriate technical and organisational measures and policies to ensure the protection of your personal data and prevent any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by Valtech. 

8. Rights on your Personal Data

Data privacy laws around the globe may give you rights regarding your personal data. These rights may vary according to location and applicable law. However, they generally include the following:

• The right of access which allows you to access and receive a copy of the personal data we hold on you,
• the right to rectification which allows you to correct information we hold on you,
• the right to request erasure of your personal data,
• the right to restrict or object to the processing of your personal data in certain circumstances,
• where available, the right to data portability which allows you to obtain and reuse your personal data for your own purposes across different services,
• the right to limit the disclosure of data, request deindexation, opt out of sales or cross context behavioural advertising,
• the right to withdraw your consent at any time when the processing of your personal data is based on the collection of your consent.

You can exercise these rights at any time by writing to Valtech’s relevant local Data Protection Manager and/or to the Data Protection Officer as listed in the “Contact us” section below. 

Please note that Valtech does not sell personal information. However, if you wish to formally exercise your right to opt-out, please follow the process described below. 

There can be circumstances whereby Valtech has grounds to refuse your request, such as a right not being in your local legislation or the right being requested is not an absolute one. Should this occur, we will explain the reasons why your request was refused. 

In accordance with applicable data protection regulation, if you have any concerns about our use of your personal data, you also have the right to lodge a complaint with a supervisory authority. However, we request that you contact us in the first instance so we can discuss and find a prompt resolution to any potential concerns you may have in relation to Valtech’s privacy and data protection practices. 

9. Retention of Personal Data

Personal data used for recruitment purposes is typically retained for up to 12 months from the last contact with you. However, this duration can be increased or reduced in compliance with local laws or if you exercise your rights as mentioned in the “Rights on your Personal Data” section above.

Once the relevant above criteria are met, your personal information will be permanently deleted unless it is archived for research purposes or to be provided to judicial authorities. In addition, we may anonymise your data to produce statistical studies. 

10. Changes to the Privacy Notice

We may modify or amend this Privacy Notice from time to time at our discretion. When changes are made, we will update the revision date at the top of this page. We encourage you to refer to this Privacy Notice often to stay informed about our personal information practices. 

Arising a conflict between the English and other language versions of this Privacy Notice, the English version shall prevail.

11. Contact us

If you have questions, comments, or concerns regarding Valtech practices, compliance with local data privacy laws, our Privacy Notice, or Valtech web presence, please direct them in writing to our Group Data Protection Officer at Valtech SE, 38 rue des Jeûneurs, 75002 Paris, France or at GL.privacy@valtech.com. 

Valtech Representative in the EU is Valtech SE, having its office at office at Luxembourg, 18 rue Erasme, L-1468 Luxembourg. Any notices should be sent to Valtech SE, 38 rue des Jeûneurs, 75002 Paris, France and can also be contacted at GL.privacy@valtech.com. 

Valtech Representative in the UK is Valtech Limited, having its office at The Spitfire Building, 71 Collier Street, London, England, N1 9BE and can be contacted at GL.privacy@valtech.com.