Updated on 1 February 2022

Club FREELANCE LIMITED , a company registered in England and Wales under number 9050953, with registered office at Biscuit Factory, 100 Drummond Rd, London SE16 4DG, United Kingdom (‘the Company’) attaches great importance to the protection of personal data which it has to collect and process in the course of its activity from both the users of its services and the platform it operates.

Thus, the collection and processing of personal data carried out by the Company in the course of the operation of its business and use of the goods and services, including the website operated by the Company at (‘the Site ’), are governed by this privacy policy (hereinafter referred to as ‘the Policy’).

The purpose of this policy is to present to data subjects:
  • The manner in which the Company processes personal data, as defined below, which it collects and which the data subjects, as defined below, provide with their consent to enable the supply of, inter alia, the Company’s products and services;

  • The rights of data subjects, as defined below;

  • The name of the processor, as defined below;

  • Any beneficiaries of a data transfer.

Data subjects are therefore invited to read this document carefully to find out and understand the company’s practices regarding the processing of users’ personal data.

1). Definition

Capitalised terms have the following definition. Terms have the same definition regardless of whether they are used in singular or plural.
  • Client (s) means any legal or natural person that has created an account and can offer a job offer or assignment for which users registered on the Platform can apply.

  • ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’).

  • ‘Controller’ means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union or Member State law, the controller may be designated or the specific criteria for its designation may be provided for by Union or Member State law. In the present case, the Company is the controller.

  • “Talent” means any person applying for a permanent job, or duly registered in any trade and company register or employed by an umbrella company and wishes to offer his services to Clients.

  • ‘Processing’ means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. General rules on the collection and processing of personal data

In accordance with Article 5 of the General Data Protection Regulation No 2016/679 (GDPR), personal data must be:
  • Processed lawfully, fairly and transparently in relation to the person concerned;

  • Collected for specified, explicit and legitimate purposes;

  • Adequate, relevant and limited to what is necessary;

  • Kept for no longer than is necessary for the purposes for which the data are processed;

  • Protected in their integrity and kept confidential.
In accordance with Article 6 of the GDPR, personal data shall be lawfully processed if such processing meets at least one of the following characteristics:
  • The person concerned has given his or her consent;

  • Processing is necessary for the performance of a contract;

  • Processing is necessary for compliance with a legal obligation;

  • Processing is necessary to protect the vital interests of the data subject;

  • Processing is necessary for the performance of a task carried out in the public interest;

  • The processing is in pursuit of the legitimate interests of the controller.

3. Nature of the collection of personal data

Data subjects may be required to provide the Company, in its capacity as Controller within the meaning of the GDPR, with information and personal data relating to them.
These elements can be grouped into two categories according to the data subjects, namely Talents and Clients.
For Talents, the following data are collected:
  • Identification data: surnames, forenames, date and place of birth, copy of your identity document, work permit;

  • Details of your contact details: postal address, e-mail address, mobile phone number;

  • Data on your economic and socio-occupational situation: professional experience, academic training, bank details, Curriculum Vitae, references to former clients or employers, current and envisaged remuneration;

  • Data on the legal structure of Talent: name of the company, identification number, legal representative of the company and legal documents.
For Clients, the following data are collected:
  • Surnames, forenames, gender, professional e-mail address;

  • Data on recruitment needs.
It should be noted that the controller is, in accordance with the applicable legislation, the entity which defines and limits the data to be collected and the purposes of processing.

Some personal data are required, while others are optional, to access or benefit from certain products and services of the Company.

In any event, such data shall be collected and processed on the basis of a legal obligation, a legitimate interest of the Company and/or the consent of the individual concerned.

If personal data of a mandatory nature are not communicated, Company will not be able to reply to your requests, if any.

4. Purpose of the collection of personal data

The Company, as the Controller, requests and collects personal data concerning the individual concerned when the latter wishes to acquire the products and/or services offered by the Company.
This information is necessary for the Company to perform the services properly and to enable it to comply with its legal obligations.
Without them, the Company might not be able to provide all the goods and/or services requested and ordered by the individual concerned.
The main purpose of collecting, storing and processing this information and personal data is to:
  • Offer clients recruitment services (permanent jobs or contracts);

  • Propose IT assignments or CDI permanent job offers to Talents Consultants;

  • Management of the customer relationship;

  • To fulfil contractual obligations;

  • Managing the Company’s platform user account;

  • Managing applications submitted by the Talents;

  • The Company’s communication campaigns;

  • Satisfaction surveys;

  • Market research.

5. Recipient (s) of the collection of personal data

The Company may share personal data collected for the purposes indicated below with the following recipients:
  • Subsidiaries: for more details on their location, click on this link .

  • Service providers: provision of services on behalf of the Company (for example: maintenance of the website, host, system management and security);

  • any administrative or judicial authority shall: upon request under the applicable law.

6. Storage period for personal data

Personal data and/or information will be kept only:
  • To enable the Company to pursue the processing purposes specified herein;

  • In order to comply with the legal and regulatory obligations relating to conservation and archiving.

7. Exercise of the rights of data subjects

In accordance with the rules on the protection of personal data, and in particular the General Data Protection Regulation No 2016/679 (GDPR), everyone has the right of access, rectification, restriction, deletion, where applicable portability of data concerning him or her, and the right to object, possibly subject to legitimate and compelling reasons, to the processing of information and personal data relating to him or her, to be exercised at any time by means of the data amendment request form:

Each individual concerned shall have the right to lodge a complaint with a competent supervisory authority.

8. Transfer of personal data outside the European Union

In general, the Company keeps the personal data of the persons concerned in the territory of the European Union.

However, since some of the Company’s partners and service providers may be located outside the European Union, personal data collected in this way may be transferred to countries which are not members of the European Union, whose legislation on the protection of personal data differs from the European Union. If the recipient country or countries do not ensure a level of data protection equivalent to the European Union, the company undertakes to take all appropriate safeguards, either on the basis of an adequacy decision or, in the absence of such a decision, on the basis of appropriate safeguards such as the standard contractual clauses adopted.

9. Links to other websites and social media

The site may occasionally contain links to the websites of our partners or third companies.

Please note that these websites have their own privacy policy and that the Company accepts no responsibility for the use by these websites and the information collected when you click on these links. The Company invites you to read the privacy policies of these sites before sending them your personal data.

10. Amendments to the Personal Data Protection Policy

The Company reserves the right to make any amendment to this Personal Data Policy at any time in accordance with this clause.

If the Company amends this Personal Data Protection Policy, it will publish the new version on its website and update the “Latest update” date at the top of this Personal Data Protection Policy.

The Company therefore invites you to consult this page regularly.


1) Definition of cookies

A cookie is a small file that is uploaded to a device (telephone, computer, etc.) when the user accesses an Internet site. Cookies are used by many websites, while others make it possible to remember user preferences, the language in which the website is displayed, to record the user’s basket on a shopping website, etc.

Cookies vary according to their origin and lifespan.
  1. Lifetime of cookies

    • Session cookies: are stored on your computer and are deleted when you leave your browser;
    • Persistent cookies: remain registered on your computer even when you leave your browser (are deleted after a deadline that is determined according to the purpose of cookies, the user also has the possibility to delete them manually).

  2. Origin of cookies

    • Internal cookies: are cookies created and used by the website;
    • Third party cookies: cookies created and used on the website by external providers.

2) Managing cookies

The Company and its providers use cookies to improve your digital experience and ensure better navigation security. You can accept or refuse these different operations at any time by clicking on "accept" or "refuse" in the cookie configuration panel.

In addition, you have the possibility at any time to delete or disable most cookies in your browser.

To set cookies on your browser, you will find below the browsers:

3) Cookies used by the company

Cookies strictly necessaryThese cookies are essential for the functioning of the site. In accordance with the applicable law, cookies strictly necessary for the operation of the website are exempted from collecting users’ consent.

However, you have the possibility to refuse these cookies by setting your browser. In such a case, the site might suffer partial malfunctions.

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Google tag managerConfiguration3 RD Party
EngageBaySending of e-mails3 RD Party
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Performance cookiesThese cookies allow us to assess the performance of the site and measure the audience. They also make it possible to find out which pages the users visit on our website. This information is collected by these cookies in anonymised form.
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Google AnalyticsSite analysis cookie3 RD Party
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NeuvooSite analysis cookie3 RD Party

Advertising cookiesThe Company can offer you advertising content that can be based on your interests.
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