Privacy Policy

The website https://humakina.com (the “Website” or “humakina.com”) offers features that allow you, as a user, to:

access a directory of human resources specialists;
create a profile for your employer and for yourself;
communicate with other listed specialists;
participate in evaluations and voting processes related to HR partners;
manage your Employer Brand using data collected online.

All of these features are described in more detail in Annex A “Description of Services” of the Website’s Terms of Use (the “Services”).
This Privacy Policy (“Policy”) explains how your personal data is processed as a result of your browsing on the Website and use of the Services.

For information on cookies, please refer to our Cookie Policy.

Roles and responsibilities for processing your personal data
Categories of personal data processed through the Website
Purposes and legal bases for processing
Processing of data in the context of votes and evaluations
Recipients of your personal data
Transfers of personal data outside the EEA
Your rights over your personal data
Data retention periods
Data security
Contact
Changes to this Policy

1) Roles and responsibilities for processing your personal data

DATAPUNK S.A., a public limited company incorporated under Luxembourg law, having its registered office at 5 rue de l’Industrie, L-1811 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B247671 (the “Company”), manages the Website and is the data controller for personal data processed through it.

The Company is committed to respecting your privacy and protecting your personal data.

2) Categories of personal data processed through the Website

We collect the following categories of personal data directly from you:

Identification details: last name, first name, job title, login ID, password;
Contact details: email address and phone number (necessary to respond to your requests and contact you if needed).

Mandatory information required to use the Services is marked with an asterisk. Without this information, certain Services may not be available.

We also automatically collect certain personal data when you access the Website or use the Services, such as:

Connection and browsing data (device used, IP address, browser type, pages visited).

Data related to evaluations and votes
In the context of rating and evaluation features, we collect: name, surname, company, and email address of the voter.
This data is necessary to verify voter identity, ensure uniqueness of votes, and maintain the integrity of the results.

3) Purposes and legal bases for processing

We process your personal data for the following purposes and on the following legal bases:

A/ Contractual necessity (performance of contractual or pre-contractual measures):

To allow you to create a User account;
To enable use of the Services, in accordance with the Terms of Use.

B/ Consent:

To personalize the Website interface according to your preferences;
To generate audience and usage statistics, as described in the Cookie Policy.

C/ Legitimate interests (operation and security of the Website):

To ensure the proper functioning of the Website;
To maintain security.

D/ Legitimate interests (relationship management):

To maintain an up-to-date central database of Website and Service users;
To respond to your requests or complaints;
To manage potential disputes.

E/ Legitimate interests (integrity of votes and evaluations):

To control the uniqueness and validity of votes;
To secure evaluation processes;
To prevent fraud or duplicate votes.

4) Processing of data in the context of votes and evaluations

When you take part in a voting or evaluation process on the Website, your identification details (name, surname, company, email address) are collected.

These details are used solely by the Company to manage and technically verify the voting process.

If you choose to vote anonymously, your identity will not be disclosed to partners, candidates, or other users.
Under no circumstances will your data be shared with candidates or partners being evaluated, unless legally required.

Data is retained only as long as necessary for the organization and security of the vote, and may be archived securely for up to three (3) years in case of disputes.

You may request deletion of your voting or evaluation data at any time, without affecting the validity of overall results.

5) Recipients of your personal data

Your personal data is shared only with:

Authorized personnel of the Company (technical management, user relations);
Service providers engaged for technical or logistical purposes (hosting, maintenance);
Third parties only when required by law, regulation, or judicial decision.

Voting data is never communicated to evaluated candidates or partners.

6) Transfers of personal data outside the EEA

Some data may be transferred outside the European Economic Area (EEA) when necessary for hosting or maintenance. Such transfers will only take place subject to appropriate safeguards (e.g. EU Standard Contractual Clauses).

7) Your rights

You have the following rights regarding your personal data:

Right of access and rectification: obtain a copy of your data and correct inaccuracies;
Right to erasure: request deletion when data is no longer needed;
Right to object and restrict: object to or limit processing, unless legally required or contractually necessary;
Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of prior processing;
Right to portability: receive your data in a structured, commonly used format;
Post-mortem instructions: define what should happen to your data after your death.

You may exercise these rights by emailing rgpd@datapunk.ai or by writing to:
Data Protection Service – DATAPUNK S.A., 5 rue de l’Industrie, L-1811 Luxembourg.

You also have the right to lodge a complaint with the CNPD (https://cnpd.public.lu/fr.html) or any competent supervisory authority.

8) Data retention

Account data: retained as long as the account is active; archived for three (3) years after inactivity.
Complaints: kept during handling, then for three (3) years after last contact.
Cookies: retained in accordance with the Cookie Policy.
Votes and evaluations: kept for the duration of the process, then archived up to three (3) years in case of disputes.

9) Data security

The Company implements appropriate technical, organizational, and administrative measures to ensure the confidentiality, integrity, and resilience of your data.
Access is strictly limited to authorized persons and subject to controls.

10) Contact

For any questions, you can reach us at:

Email: rgpd@datapunk.ai
Mail: DATAPUNK S.A., Data Protection Service, 5 rue de l’Industrie, L-1811 Luxembourg

11) Changes to this Policy

This Policy may be updated to reflect legal, technical, or organizational changes. The updated version will be published on the Website, with the date of the last modification clearly indicated.

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