Last updated: November 7, 2022

The website www.qair.energy (hereinafter the “Site”), published by the company Qair France International SASU (hereinafter “Qair,” “we,” or “our”), presents the activities of the Qair Group.

In the course of accessing, consulting, browsing, and using the Site and its services, you may be required to provide personal data about yourself.

We appreciate your attention to this policy, which explains how Qair uses your personal data in connection with the Site and how you can exercise your rights in this regard. This policy complements the General Terms of Use of the Site, as well as any document or information referring to this policy.

If needed, you can direct all your questions to Qair by sending an email to the following address: contact@qair.energy.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

• Qair, as the publisher of the Site, is responsible for processing personal data collected in the context of the administrative, operational, and commercial management of the Site and its services, including facilitating the connection between you and the Qair Group entity concerned by the job offer to which you have applied, if applicable.
• Subsequently, the Qair Group entity concerned by the job offer to which you have applied, as the recruiter, is responsible for processing personal data collected in the context of your application.

 

2.WHAT PERSONAL DATA MAY BE PROCESSED BY QAIR?

All data you provide on the Site or when communicating directly with Qair, including:

Categories of Data	Examples of Data
Contact Request Data	Name, surname, email, subject, and content of your request, exchanges with Qair services related to your request
Job Application Data	Position you are applying for, CV, cover letter, current position, education, professional experience, photograph, any other information spontaneously provided in the context of your application

Some of this data is mandatory, while others are optional. The mandatory or optional nature of the personal data to be provided is indicated at the time of collection. If you refuse to provide the required data, Qair will not be able to respond to your request.

In addition, some data is automatically collected by the Site through cookies and other trackers, including:

Categories of Data	Examples of Data	Purposes
Connection and Navigation Data	Connection date and time, IP address, device, browser, operating system, system configuration data, pages viewed	This data is necessary for the proper technical functioning of the Site and its services, as well as for audience measurement. For more information, please refer to the Cookie Management Policy.

 

3. WHY DOES QAIR USE YOUR PERSONAL DATA?

Qair uses your personal data only for the following reasons:

Purposes	Examples of Use of Your Personal Data	Legal Basis
Contact Requests
Processing of your contact requests	To respond to your requests To contact you if necessary	Legitimate interest of Qair to respond to your contact requests
Electronic Communications	To send you electronic communications about Qair Group activities that may interest you as a professional	Legitimate interest of Qair to inform you about its activities
Job Applications
Processing of your job application	To transmit your application to the Qair Group entity concerned by the job offer To review your application If your application is successful, to arrange an interview to assess your suitability for the job and your professional skills To contact you if necessary	Pre-contractual measures
Constitution of a CV Database	To contact you to inform you of any new job offers that may interest you	Legitimate interest of Qair to establish a CV database of potential candidates for its future job offers
Site Management
Improvement of the Site and its services, as well as your user experience on the Site	To evaluate and improve the Site and the services it offers To facilitate your navigation on the Site To ensure the security of the Site	Legitimate interest of Qair to improve the Site and its services, as well as your user experience on the Site
Pre-litigation or Litigation Management	To sanction any identified violation To manage any dispute or litigation	Legitimate interest of Qair to defend its rights and interests
Compliance with Legal and Regulatory Obligations	To comply with legal and regulatory obligations To respond to your requests to exercise your rights	Legal and regulatory obligations imposed on Qair

 

4.WHO MAY ACCESS YOUR PERSONAL DATA?

In the course of accessing, consulting, browsing, and using the Site and its services, your personal data may be communicated to the following recipients:

Recipients	Purposes
Qair and its authorized personnel	For the administrative, operational, and commercial management of the Site and its services, as specified in section 3 of this policy
Qair Group entity concerned by the job offer to which you have applied	For the purposes of forwarding your application to the Qair Group entity concerned by the job offer to which you have applied so that it can examine it and contact you if necessary.
Qair’s sub-contractors (hosting company, IT maintenance provider, etc.)	For exclusively technical or logistical purposes relating to the management of the Site and its services.
Administrative or judicial authorities	Only in the event of an express, reasoned request on their part or in the event of a proven breach of legal or regulatory provisions.
External advice	Only in connection with the management of potential disputes and other legal matters as appropriate.
Other third parties	As a result of or in connection with the restructuring, reconstruction, acquisition, debt financing, merger, sale of Qair assets or similar transaction, as well as in the event of insolvency, bankruptcy or receivership in which personal data is transferred to one or more third parties as an asset of Qair.

 

5. ARE YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION/EUROPEAN ECONOMIC AREA?
To the extent possible, your data is processed within the European Union (EU)/European Economic Area (EEA). However, some entities of the Qair Group, as well as certain Qair service providers located outside the EU/EEA, may process your personal data in a third country.

In the event that the third country does not provide a level of protection for personal data equivalent to that of the European Union, Qair ensures, in the absence of an adequacy decision, and after conducting an assessment of the level of protection of your rights in the third country where the recipient is established, to take all necessary measures to ensure the protection of your personal data based on appropriate safeguards (such as the standard contractual clauses of the European Commission). You can obtain these safeguards directly from Qair by sending an email to the following address: contact@qair.energy.

Recipient Name	Third Country	Adopted Guarantee
Qair Tunisia	Tunisia	Standard Contractual Clauses
Qair Morocco	Morocco	Standard Contractual Clauses
Qair Mauritius	Mauritius	Standard Contractual Clauses
Qair Chad	Chad	Standard Contractual Clauses
Qair Burkina Faso	Burkina Faso	Standard Contractual Clauses
Qair Brazil	Brazil	Standard Contractual Clauses
[To be completed]	[To be completed]	[To be completed]

 

6. HOW DOES QAIR PROTECT YOUR PERSONAL DATA?
Qair has implemented technical and organizational measures to protect your personal data, particularly against potential breaches that could lead to the accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure of your personal data. These measures ensure an appropriate level of data security and take into account the state of knowledge, implementation costs compared to risks, and the nature of the data to be protected. Qair also ensures that its staff members and anyone else processing your personal data adhere to the internal measures and procedures put in place to protect your personal data. In this context, Qair’s practices are regularly reviewed and updated to ensure the confidentiality of personal data.

If you discover a vulnerability or want to report a security incident, please send an email to contact@qair.energy.

7. HOW LONG ARE YOUR PERSONAL DATA RETAINED?

In general, your personal data will only be retained for the period necessary to achieve the purposes for which the data was collected or to comply with applicable legal or regulatory requirements.

Exceptions include:

• Data collected in the context of your contact requests is retained until the complete processing thereof ;
• Data collected in the context of your job application is retained for two (2) years from your last contact with the Qair Group entity concerned by the job offer you applied for unless your file is integrated into the Qair Group’s CV database or you request the destruction of your file ;
• Connection and browsing data are retained for thirteen (13) months.

Beyond these periods, your data is retained for:

• Three (3) years for data retained for prospecting purposes ;
• Five (5) years for data retained as evidence.

 

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
In accordance with data protection regulations, you have the following rights regarding your personal data:

Your Rights	Scope of Your Rights
Right of Access	You have the right to request: Confirmation of whether Qair processes your personal data or not; Clear, transparent, and understandable information about how Qair uses your personal data and your rights (as provided in this policy); A copy of your personal data.
Right to Rectification	You have the right to request the rectification of your personal data, allowing you to obtain the modification of your personal data if it is outdated, inaccurate, or incomplete.
Right to Erasure	You have the right to request the erasure of your personal data (or the right to be forgotten) when one of the following grounds applies: You object to the processing of your personal data, and there is no compelling legitimate reason for continuing the processing (such as Qair’s obligation to retain certain documents containing personal data); You object to commercial prospecting operations; You decide to withdraw your consent on which the processing is based; Your personal data is no longer necessary for the initial purposes that justified their collection or another type of processing; The use of your data does not comply with applicable legislative or regulatory provisions.
Right to Restriction	You have the right to request the temporary restriction of the processing of your personal data, particularly for verification purposes, namely: When you dispute the accuracy of your information, allowing us time to verify that it is correct; If the processing is unlawful and, instead of requesting their erasure, you prefer to limit their use; If Qair no longer needs the data for processing but they are still necessary for you to establish, exercise, or defend a right in court; If you object to processing under your right to object, during the verification period to confirm that Qair’s legitimate grounds prevail over yours.
Right to Data Portability	You have the right to request the portability of your personal data, allowing you to receive the personal data provided in a structured, commonly used, machine-readable format and to have them transmitted to a third party if technically feasible. This right is not exercised in all circumstances; it only applies if it meets all the following conditions: It concerns only your personal data, excluding all anonymous data or data from third parties; It does not infringe on the rights and freedoms of Qair (especially trade secrets) or third parties (especially intellectual property rights); It concerns personal data processed automatically (paper files are therefore not affected); The processing is based on your consent or the performance of a contract concluded with Qair (to check this, please refer to Section 2 of this policy).
Right to Object	You have the right to object to the processing of your personal data when it is based on Qair’s legitimate interest. Thus, Qair will cease processing unless there are compelling legitimate grounds that override your interests, rights, and freedoms, such as compliance with a legal obligation or the establishment, exercise, or defense of a legal right.
Right to Withdraw Consent	You have the right to request the withdrawal of your consent when it has been obtained, without affecting the lawfulness of the processing carried out before the withdrawal.

It is specified that the exercise of these rights depends on the legal basis of the processing, as indicated in the table below:

Access	Rectification	Erasure	Restriction	Portability	Objection
Consent	Yes	Yes	Yes	Yes	Yes
Pre-contractual measures	Yes	No	No	No	No
Contract	Yes	Yes	No	No
Legitimate interest	Yes	No	Yes	No
Legal obligations	No	No	No	No

If you are French resident, you also have the right to establish general or specific directives regarding your personal data in the event of your death (for example, their deletion or transmission to any person of your choice). You can revoke your directives at any time.

In certain circumstances, Qair may ask you for specific information to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to a person who does not have the right to receive it.

For any questions and to exercise your rights, you can directly contact Qair by sending an email to the following address: contact@qair.energy. If needed, you can file a complaint with the Commission Nationale Informatique et Libertés (CNIL) via its website or by mail at 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07. This right can be exercised at any time free of charge, except for any postal fees, and potential costs of assistance or representation if you choose to seek help in this process from a third party.

9. UPDATING OF THIS POLICY
This policy on the protection of personal data is precisely dated and may be modified and updated by Qair at any time, especially in the event of changes to the services offered on the website or applicable law. Therefore, we recommend checking the personal data protection policy each time you access the site. If applicable, the updated policy will be communicated to you by any appropriate means.