PERSONAL DATA
1) Personal data and processing of personal data: what is it?
Personal Data is any information and data that makes it possible to identify or make identifiable a natural person (name, email address, telephone number or IP address, etc.) and processed electronically or not.
Processing of Personal Data means any operation or set of operations which may or may not be performed using automated processes and applied to personal data or sets of personal data, such as gathering, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limitation, deletion or destruction.
The User is designated, within the meaning of Article 4 1) of the RGPD, as a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number or an online identifier.
2) Categories of data processed, purposes and legal basis for processing
As the data controller, ACE Education ensures a high level of protection for the Personal Data of the persons concerned at all stages of processing (collection, storage, destruction, etc.).
Operating in France, ACE Education is committed to complying with current legislation and regulations on the protection of personal data, and in particular:
– EU Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of individuals with regard to the processing of personal data (RGPD);
– the French Data Protection Act (Loi Informatique et Libertés) and Order no. 2018-1125 of 12th December 2018 on the protection of personal data, amending Act 78-17 of 6th January 1978 on data processing, data files and individual liberties and various provisions concerning the protection of personal data;
ACE Education acts as data controller when it processes the User’s personal data in the following cases:
– Creating a personalised account on the basis of consent (Article 6 a) of the RGPD)
– Requesting information or downloading brochures on the basis of legitimate interest (Article 6 f) of the RGPD)
– Application for a job or internship based on consent (Article 6 a) of the GDPR);
To fulfil these purposes, the personal data collected is as follows:
– Data relating to identity and contact details (surname, first name, email address and telephone number).
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Further information about retention time
Personal Data collected for purposes related to the performance of a contract between ACE Education and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of ACE Education’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by ACE Education within the relevant sections of this document or by contacting ACE Education at privacy@ace-education.fr.
ACE Education may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, ACE Education may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Data processing method
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to ACE Education, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by ACE Education. The updated list of these parties may be requested from ACE Education at any time.
ACE Education subcontractor
ACE Education may, in the context of the products and services provided, qualify as a subcontractor within the meaning of the regulations relating to the protection of personal data.
Therefore, ACE Education undertakes to respect all the obligations imposed on subcontractors and to collaborate effectively with data controllers whenever its assistance and skills may be required.
3) The website and collect of cookies
The ACE Education website (https://www.ace-education.fr/) is hosted by ALLFIZZ under conditions that comply with the RGPD.
When you connect to and use the site, navigation data (cookies) may be collected and processed by the company or any service provider (third party) of its choice for the purposes of navigation on the site, statistics in order to improve the ergonomics of the site and to measure the number of pages viewed, the number of visits, as well as your activity and your path on the site.
4) Security of personal data
ACE Education undertakes to take all technical and organisational measures to ensure the protection, security and confidentiality of the Personal Data of the persons concerned, in particular against any loss, alteration, distribution or illegal use.
ACE Education ensures that such measures are put in place for all operations carried out in the context of its processing, and in particular during the collection of Personal Data, its storage and hosting.
Regarding this, ACE Education also ensures that any third parties it may call on (technical service providers, suppliers, etc.) comply with this requirement to protect Personal Data by implementing appropriate measures, in accordance with the RGPD. The technical and organisational measures implemented may include the use of secure registration forms, encryption and/or restricted access to Personal Data.
ACE Education invites the persons concerned to exercise the utmost caution when communicating their Personal Data to third parties, as well as their personal identifiers and passwords enabling them to access the site.
Some messages or solicitations received may come from ill-intentioned persons seeking to obtain personal information concerning the persons concerned with a view to fraudulent use (phishing). If you receive a message that appears to be an attempt at phishing, please do not reply to it and do not open any attachments, images or links contained in the message.
5) Your rights
You have a right of access, rectification and opposition as well as deletion and portability when your data has been collected on the basis of consent.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by ACE Education, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, ACE Education will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from ACE Education.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, and about the security measures taken by ACE Education to safeguard their Data.
To do this, you must send your request, with proof of your identity, to the following postal address: 18 rue Pétrarque 75020 Paris or to the following e-mail address: privacy@ace-education.fr.
In case of a dispute, the person concerned may submit a request directly to the competent supervisory authority (CNIL).
6) Student Mobile Application “ACE CONNECT”
ACE Education provides a mobile application for its students.
ACE Education undertakes to respect all of the necessary obligations as detailed in this document.
Users of this application have the same right of access, rectification and opposition as well as erasure and portability when their data has been collected on the basis of consent, detailed in this document.
Users have the option to delete their account at any time. To exercise this right, Users must go to the My Account section of the mobile application and click on the “Delete my account” button.
This action will have the effect of deleting all personal data as well as all data collected relating to the use of the application.
Personal data collected for purposes related to the execution of a contract between ACE Education and the user will be retained until this contract is fully executed.
REPRODUCTION RIGHTS
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