Privacy Policy
This Privacy Policy and Personal Data Protection Statement is issued by RINGO (trading under the name
"MODJO"), a simplified joint-stock company with a share capital of €34.918,40, registered with the Nanterre
Trade and Companies Register under number 879 606 283, and headquartered at 59 Avenue Sainte Foy, 92200
Neuilly-sur-Seine, France.
This Privacy Policy describes how MODJO collects, stores, uses and discloses the following categories of
personal data:
- Customer Data: Personal data (as defined in Section 2) that we collect, process and manage on behalf
of our business customers (each, a “Customer”; collectively, “Customers”), as part of the MODJO
services described on the order forms signed with our Customers.
We process Customer Data on behalf of and as directed by our Customers, in line with the terms
outlined in our Data Processing Addendum. As a result, this Privacy Policy, which outlines MODJO’s
privacy and data processing practices, does not govern the privacy or data processing practices of our
Customers. For information about our Customers' privacy policies and practices, please reach out to
them directly. - 2. User Data: Personal data related to individuals representing our Customers in their interactions with
Modjo, including account administrators, users of the Platform on behalf of the Customer, billing
contacts, and authorized signatories (collectively referred to as “Users”). This also includes
information about the Customer’s business needs and preferences, either provided directly by them
or inferred through our interactions. - 3. Prospect Data: Information about individuals such as visitors to our website (modjo.ai), participants at
our events, and potential customers, users, or partners (collectively referred to as “Prospects”) who
engage with our website, online advertisements, content, emails, integrations, or other
communications managed by us (collectively referred to as the “Sites,” and together with the
Platform, the “Services”).
You are not legally obligated to share any personal data with us. If you prefer not to provide your personal data
or do not wish for it to be processed by us or our Service Providers (as defined below), please refrain from
sharing it and avoid engaging with our Sites or using our Services.
Data Controller / Processor
MODJO as Data Controller:
MODJO acts as a data controller when processing personal data of prospects, website users, and recruitment
candidates, determining the purposes and means of processing such data in accordance with applicable data
protection laws.
MODJO as Data Processor:
Modjo acts solely as a data processor for users accessing the platform through their employer, our Customer.
Our Customers are solely responsible for deciding whether and how to use our Services. They must ensure that
all individuals using the Services on their behalf or at their direction, as well as any individuals whose personal
data is included in Customer Data processed through the Services, receive appropriate notice and, where
required, provide informed consent for the processing of their personal data. Customers must also ensure that
all legal obligations related to the collection, storage, use, or other processing of data through our Services are
fully complied with, particularly in the context of employment relationships. Additionally, our Customers are
responsible for managing data subject rights requests in accordance with applicable laws, whether from their
Users or other individuals whose data they process through the Services.
Data Collection and Processing
When we use the terms “personal data” or “personal information” in this Privacy Policy, we mean information
that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be
linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is
maintained in a form that is not reasonably capable of being associated with or linked to an individual.
We may collect or generate the following types of personal data about individuals through the Services:
- Information concerning our Customers, Users and Prospects contact and business details including
name, email address, phone number, job title, workplace, and related business insights; our
communications with these individuals (such as correspondence, sensory information like call and
video recordings, along with their transcriptions and analyses); feedback and testimonials received;
contractual and billing information; as well as any expressed, inferred, or identified needs,
preferences, attributes, or insights relevant to our current or potential engagement. - Personal data contained in Customer Data which is provided by our Customers or processed on their
behalf and under their instruction. This may include any of the types of personal data described above
(with respect to Users or other individuals whose data is contained in the Customer Data), in
accordance with our Data Processing Addendum with them. - Information concerning job applicants such as the CV you send us, in particular when you apply via
Welcome To The Jungle, the information provided on your Linkedin profile and our communications
with these individuals (such as correspondence, sensory information like call and video recordings,
along with their transcriptions and analyses). - Usage, login credentials, and device information concerning Users and Prospects (information
relating to your use of our sites and services, including data traffic and records of the choices you
make online, log files and statistics relating to actions taken on our sites and services, technical
information about any device and operating system you use when you visit our sites, including your
device identifier, your Internet Protocol (IP) address, your device's browser version, the pages of our
service you visit, the time and date of your visit, the time spent on those pages and other statistics).
We use cookies to collect and process tracking data on our sites; For a better understanding of how it
works and what it is used for, you can consult our Cookie Policy available on our website.
Purposes and Processing bases
We process personal data as required to deliver our Services (“Performance of Contract”); to fulfill our legal
and contractual obligations (“Legal Obligation”); and to advance our legitimate interests, such as improving and
maintaining our Services, understanding how they are used and how our campaigns perform, gaining insights
to allocate resources more effectively, marketing and promoting our Services, providing customer and technical
support, and ensuring the protection and security of our Customers, Users, Prospects, our company, and our
Services (“Legitimate Interests”).
More specifically, we collect and process the following data according to and for the following purposes:
Customer and User personal data
For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
- To facilitate, operate and provide our Services (Performance of Contract; Legitimate Interests);
- To provide our Customers and Users with assistance and support, to test and monitor the Services, or
diagnose or fix technology problems (Performance of Contract; Legitimate Interests); - To optimize marketing, ad management, and sales operations, and deliver targeted advertisements for
our products and services, including contextual, behavioral, and interest-based ads based on your
activity, preferences, or available data (Legitimate Interests; Consent).
Job applicants data
- To comply with our legal obligations relating to recruitment (Legal obligations);
- To facilitate and improve the recruitment process (Legitimate interests);
We record telephone calls and video conferences between our employees and clients or prospects for the
following purposes:
- To support employee training
- To enhance the tracking and management of interactions and business relationships with clients and
prospects - To promote collaboration among teams
Data Retention
RINGO is committed to retaining personal data entrusted to it only for durations limited to the provision of
services or as required to meet its contractual or legal obligations. Once again, this table only concerns data
that Ringo collects in its capacity as data controller.
Specifically:
Data Location
With regard to data hosting and storage, RINGO requires its hosting service providers to host the data entrusted to it in France. RINGO's websites and databases are therefore hosted by AWS on servers located in France and in the European Union. If, for technical reasons or for specific needs related to the maintenance of certain applications, personal data is transmitted or made accessible to RINGO's service providers located outside the European Union, RINGO first ensures that these service providers guarantee an adequate level of protection for this data and comply with the GDPR. Accordingly, RINGO only uses subcontractors with an adequate level of data security and protection, for example through the supervision of data transfers outside the EU by binding company rules or through the adoption of the European Commission's standard contractual clauses.
Data Disclosure
Only persons authorised by RINGO may access the data and only in the context of the tasks entrusted to them. Thus, the only potential recipients of personal data are authorized RINGO employees and sub-contractors with a sufficient level of security. These service providers may include hosting and server co-location, communication tools, data security, billing and payment processing, web and product analytics, email distribution and monitoring, session or activity recording, remote access, content transcription and analysis, data optimization, marketing services, social and advertising networks, customer support, enablement, customer relationship management systems, and our legal, financial, and compliance advisors (collectively, “Service Providers”). As part of its commercial prospecting operations, RINGO may share with partners the names of client companies or prospective clients (legal entities) that they have in common. These partners are subject to confidentiality clauses. This does not include identity data and contact details. In the context of recruitment, RINGO may share information relating to candidates with external organisations involved in the recruitment of candidates (sub-contractors) such as recruitment agencies or SaaS recruitment software.
Data Subject Rights
The information that you agree to entrust to us, through the use of our sites and services, remains your
personal data.You have the following rights with regard to your personal data:
- the right of access enabling you to access all the information that concern you and to obtain a copy of
- it; you may be charged a fee not exceeding the cost of reproduction;
- the right of rectification, enabling you to request that your data be rectified, completed or updated, as
- appropriate;
- the right to object, enabling you to object to the processing of your data for commercial prospecting
- and, under certain conditions, to the processing of your personal data for purposes other than
- commercial prospecting;
- the right to limit the processing of your data, allowing you to restrict the processing of your personal
- data;
- the right to erasure, allowing you to request that your personal data be deleted.
You can exercise your rights in writing by sending us an e-mail to the following address: dpo@modjo.ai. Your requests will be processed within one month of receipt.This period may be extended by two months if necessary due to the complexity or number of requests. We reserve the right to ask you for a copy of an identity document in order to verify your identity if we have reasonable doubts as to your identity. You may also object verbally, during a telephone conversation or videoconference with a RINGO employee, to the processing of your personal data recorded during this exchange. In this case, your request will be met immediately and the data will not be processed. To find out more about your rights, please consult the CNIL website: www.cnil.fr. You also have the right to lodge a complaint with the CNIL.
Data Security
We implement systems, applications, and procedures aimed at securing your personal data and reducing the risk of theft, damage, loss, unauthorized access, or misuse. However, we cannot guarantee that our Sites or Services will be completely free from malfunctions, unlawful access, or other forms of misuse. For each new processing operation implemented by RINGO, our DPO, as part of an internal prior approval procedure, checks its purpose and legitimacy with regard to the company's needs, but also and above all with regard to the risk of infringement of data protection and the privacy of the persons concerned.
When certain services require the use of a third party (subcontractor), RINGO selects its service providers on the basis of strict security and confidentiality criteria defined in advance in the light of the issues at stake, and systematically requires its subcontractors to have a level of security that guarantees an adequate level of protection for the personal data they process on our behalf.
For more information, please visit our Trust Center : https://www.modjo.ai/en/trust-center.
Additional Notices
Updates and Amendments: We may revise this Privacy Policy periodically by publishing an updated version on our Services, which will take effect from the date of publication. If we believe the changes significantly impact your rights, we will notify you in advance through available communication channels or directly via the Services. Following the notice period, the updates will be considered accepted by you.
Contacting Us: If you have any questions about our Privacy Policy or, more generally, about the collection and processing of your personal information by RINGO, please do not hesitate to contact us at the following e-mail address: dpo@modjo.ai.
