Legal notice and privacy policy

LEGAL NOTICES

WEBSITE’S PUBLISHER

Organization & Development
Corporate Communications Department
43, quai de Grenelle – Tour Greenelle – 75015 PARIS
RCS Paris 445 260 169
SAS with a capital of 9 041 900 euros

EMBEDDERS

The site is hosted by :

PLATFORM.SH

SAS Simplified joint stock company with a capital of 360,590 euros

131 Boulevard de Sebastopol – 75002 Paris

521 496 059 RCS Paris

Telephone number: 01 40 09 30 00

SITE DESIGN

NIJI
9A, rue de Châtillon 35 000 Rennes – France Tel. : + 33(0)2 99 32 02 84

PHOTO CREDITS

Fotolia, Shutterstock Agence REA, Studio Chamberlin, Matthew Henry, Andre Hunter, Jonas Jacobsson, Thomas Lambert, Gaetan Luci / Princely Palace of Monaco, Flore Maquin, Sharon McCutcheon, Nathan Numlao, Nicolas Spuhler, Ian Schneider, Clark Tibbs, Olivier Plattner

PERSONAL DATA

OMNES Education’s COMMITMENT.

“OMNES Education. is committed to ensuring that the collection and processing of your data made from this site, comply with the General Data Protection Regulation (RGPD) and the Data Protection Act.”

OMNES Education GROUP PRIVACY POLICY.

Organisation et Développement, together with all its subsidiaries and more generally with all the Schools and entities of the OMNES Education group, are committed to protecting your personal data and your privacy. Personal data is information that directly or indirectly identifies a natural person (name, registration number, telephone number, photograph, date of birth, town of residence, etc.).

I – PURPOSE

The purpose of this Privacy Policy is to describe the type of personal data that we, i.e. Organisation and Development (O&D) together with all of its subsidiaries and more generally with all of the Schools and entities of the OMNES Education group, collect, or receive, how we use, share and protect it, how we use cookies and similar technologies and your rights and options.

II – TYPES OF DATA COLLECTED

1) PERSONAL DATA PROVIDED BY YOU

The personal data we collect is either :

• Personal data that you provide to us spontaneously;
• The personal data we ask you for when you :

– Contact us by e-mail, phone, post or any other way;

– Request a quote, help, downloads or information;

– Buy a training or a service;

– Create or manage a student account;

– Register or activate a device (PC, cell phone or smartphone);

– You register for events, webinars or services;

– Subscribe to newsletters, event alerts or information;

– Participate in surveys, contests or other promotional activities.

The type of personal data we may request from you may include but is not limited to:

• Your marital status;
• Your contact information (for example, your physical address, your e-mail address, your phone number…) ;
• Your possible professional data (for example, your job title);
• Your credentials (e.g., your user name);
• Your financial information (e.g., credit card number, bank account number, billing address);
• Etc.

We may ask you to provide additional personal data, for example, in the case of our online surveys to understand your needs. In this case, you will be informed at the time of collection.

2) PERSONAL DATA COLLECTED AUTOMATICALLY

In addition to the personal data you provide to us, our websites automatically collect the domain names of all visitors, and we also use third-party web analytics services that may collect information such as your IP address, the type of device you are using, your device ID, and other technical information through cookies and other similar tracking technologies. In some countries, including those in the European Economic Area, certain information may be considered personal data under applicable data protection laws.

Collecting personal data allows us to better understand the type of visitors who come to our sites, where they come from and what content they are interested in on our sites. We use this information for internal analysis and to improve the quality and relevance of our sites for visitors. Some of this information may be collected using cookies and similar tracking technologies. For more information, please see our Cookie Policy available on the websites in question.

3) PERSONAL DATA COLLECTED FROM THIRD PARTIES

From time to time, we may receive personal information about you from third party sources, but only when such third parties are authorized or required to disclose your personal information to us. The information we may collect from third parties includes your contact details, any professional data, educational data etc.

III – PURPOSES OF COLLECTION

We only use the personal information we collect from you for the purposes described in this Privacy Policy, for compatible purposes, or for the purposes we disclosed to you at the time we collected your personal information.

In particular, we use your information to:

• To provide the training and services you request, to respect the terms of our agreements with you and to manage our commercial relationship; more specifically, to manage our applicants and prospects, to manage your enrollment and your schooling, to manage your student file, to process your request for documentation and information on our training, etc. ;
• Activate, register or update the services you have purchased from us (e.g. access to a PC, cell phone, smartphone, access to an online teaching module, access to a digital library…);
• Send important notifications about our terms and conditions, registration requirements, privacy policies… ;
• Conducting business, evaluating and improving schools (including developing new courses; optimizing and improving our services; analyzing our courses/services;
• Meet the requirements imposed on us by administrative and financial controls and audits;
• Perform accounting, auditing, invoice reconciliation and collection, and other internal business functions;
• Conducting analysis and data processing (including market and consumer research, satisfaction studies, trend analysis, financial analysis);
• Protecting you and our staff from fraud and other illegal activities or from unfounded accusations; establishing, exercising and defending your rights and those of our staff; and complying with our applicable legal and regulatory obligations;
• Maintain the physical security of our premises (e.g., visitor logs) and computer/electronic security;
• Inform you of upcoming events, updates, new training/services and other offers according to your communication preferences;
• Operate and manage our websites.

We may also use your personal data in an aggregated form that does not allow for the identification of individuals in order to evaluate and improve our training and service offerings.

IV – LEGAL BASIS FOR PROCESSING PERSONAL DATA

For the European Economic Area, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific purposes for which we collect and request it. The legal basis for the processing is indicated in the information provided to you when your personal data is collected.

However, we collect personal data from you only when:

• you have given us your express prior consent;
• we need your personal data to provide a service (e.g.: cookies strictly necessary to navigate our websites, request for documentation), to execute a contract or an agreement concluded with you;
• where the processing is necessary to protect our legitimate interests while safeguarding your interests and your fundamental rights and freedoms with regard to the protection of personal data.

In some cases, we may be required by law to collect personal data from you or we may need your personal information to protect your own interests or those of a third party.

If you have any questions about the legal basis on which we collect and use your personal information, please contact us using the contact information in Article XI “Contact”.

V – METHODS OF PROCESSING PERSONAL DATA

1) RECIPIENTS OF PERSONAL DATA

Based on the above, we may disclose your personal data to the following recipients:

• All the subsidiaries of Organization and Development and more generally all the schools and entities of the OMNES Education group;
• Organization and Development and School’s subcontractors and/or partners, who provide services to us involving the processing of data or who otherwise process personal information for the purposes described in this Privacy Policy or for the purposes notified to you when we collect your personal data;
• Any relevant law enforcement agency, government agency, regulatory agency, court or other third party to whom it is necessary to disclose personal information (i) under applicable laws or regulations, (ii) to exercise, establish or defend our rights or (iii) to protect your interests or those of a third party;
• Any third party company that has made a proposal to purchase, merge, reorganize, acquire, dissolve or liquidate all or part of the OMNES Education Group, provided that we inform the interested third party that it must use your personal data only for the purposes set forth in this Privacy Policy ;
• Any partner organization located in a country outside the EU, particularly in the context of internships abroad or international exchanges of our students, subject to compliance with the provisions of Article IX ;
• Any other person to whom you have authorized us to disclose your personal data.

2) YOUR RIGHTS

Pursuant to the European Personal Data Protection Regulation No. 2016/679 (“GDPR”), you have the right:

• to access and obtain a copy of some of your personal data that we maintain;
• to update or correct inaccuracies in such data;
• to challenge our use of your personal information;
• to request the removal of your personal data from our database;
• to challenge the processing of your personal data by us;
• ask us to restrict the processing of your personal data;
• to request the portability of your personal data.

You also have the right to opt out of receiving marketing communications from us at any time. You can exercise this right by clicking on the unsubscribe links in the marketing emails we send you.

Similarly, if we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Please note that withdrawing your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor will it affect the processing of your personal data carried out on a lawful basis other than consent.

To exercise all your rights, please contact :
OMNES Education – DPO Service – Immeuble Greenelle – 43 quai de Grenelle – 75015 PARIS

We will process your request in accordance with the applicable data protection laws and regulations. To protect your privacy and security, we may verify your identity before granting you access to your personal data.

If you consider that our processing of your personal data is in breach of applicable law or your rights and freedoms, you have the right to lodge a complaint with your local data protection authority.

VI – SECURITY OF PERSONAL DATA

As the disclosure of personal data over the Internet cannot be fully secured at this time, we cannot guarantee that the risks associated with the operation of the Internet and their consequences for your personal data are fully controlled, and such data is deposited at your own risk.

However, we attach great importance to the protection of your personal data and privacy. For this reason, we have put in place the necessary technical and organisational measures (physical, logical and human security) to protect your personal data against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure and use.

VII – RETENTION OF PERSONAL DATA

1) LEGAL BASIS

We retain your personal data where we have a legitimate and continuing need to do so, for example, to provide a service to you, to enable you to access and complete training, or to comply with legal, tax or accounting requirements.

Where we have no legitimate business need to process your personal data, we will delete or anonymise it or, if this is not possible, including because your personal data is stored in a backup archive, we will store your personal data securely.

2) ARCHIVING TIME

We endeavour to respect the retention periods for personal data indicated below:

Documents and data relating to the commercial relationship with the customer

Data relating to commercial prospecting :

• Duration of conservation provided for by the CNIL (unless otherwise provided by law): 3 years from the end of the relationship or the last contact. Examples of a last contact: request for documentation, click on a hyperlink in an email.
  Note: opening an email cannot be considered as a contact
• Legal references: CNIL Decision n°2016-264 of 21 July 2016 (NS-048): N/A in education – reasoning by analogy
• Retention period implemented by OMNES Education: 3 years from the last contact

Processing for information and communication without prospecting :

• Length of retention provided for by the CNIL (unless otherwise provided for by law): Length of time required to achieve the defined purposes with annual updating of the data
• Legal references: CNIL decision n°2006-138 of May 9, 2006 (DI-007)
• Retention period implemented by OMNES Education: 3 years from the last contact

Student management data :

• Retention period stipulated by the CNIL (unless otherwise provided for by law): For the period necessary to manage the relationship (analogy with customer files)
• Legal references: CNIL Decision n°2016-264 of 21 July 2016 (NS-048): N/A in education – reasoning by analogy
• Length of retention implemented by OMNES Education: 2 to 50 years depending on the type of data

Contract and warranties with a student/learner :

• Legal retention period: 2 years
• Legal references: Article L. 218-2 of the Consumer Code
• Retention period implemented by OMNES Education: 2 years

Contract and guarantees concluded by electronic means with a consumer (for a sum equal to or greater than €120) :

• Legal retention period: 10 years
• Legal references: Article L. 213-1 of the Consumer Code
  Article D. 213-1 of the Consumer Code
  Article D. 213-2 of the Consumer Code
• Retention period implemented by OMNES Education: 10 years

Customer invoices :

• Legal retention period: 10 years from the end of the accounting period
• Legal references: Article L. 123-22 of the Commercial Code
• Retention period implemented by OMNES Education: 10 years

Documents relating to the rights and freedoms of the persons concerned

Identification documents for requests relating to the data subject’s rights of access and rectification :

• Legal retention period: 1 year
• Retention period provided by the CNIL (unless otherwise provided by law): 1 year
• Legal references: Article 9 of the Code of Criminal Procedure
  CNIL Decision n°2016-264 of July 21, 2016 (NS-048)
• Shelf life implemented by OMNES Education: 1 year

Identification documents for requests relating to the data subject’s right to object

• Legal retention period: 6 years (archiving only)
• Retention period provided for by the CNIL (unless otherwise provided by law): 3 years (archiving only)
• Legal references: Article 8 of the Code of Criminal Procedure
  CNIL Decision n°2016-264 of July 21, 2016 (NS-048)
• Retention period implemented by OMNES Education: 3 years from the last contact

Login data on ENT

• Retention period provided for by the CNIL (unless otherwise provided for by law): Until the student’s request for deletion with an explicit request for annual agreement when the student has left the school
• Legal references: Order of 30 November 2006 (RU-03) – under modification
• Retention period implemented by OMNES Education: 6 months after graduation or withdrawal from training

Log files/Log files

• Retention period provided for by the CNIL (unless otherwise provided by law): 6 months
• Legal references: CNIL Guides – 2008 Edition – The security of personal data
• Retention period implemented by OMNES Education: 3 years maximum

VIII – HYPERTEXT LINKS

Our websites and educational platforms may contain links to the websites of third parties. We are not responsible for the content or the privacy practices employed by these websites.

IX – INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your personal data may be transferred to and processed in countries other than the country of your school. These countries may have data protection laws that differ from this country’s laws and which, in some cases, may not be as protective.

However, we have taken appropriate precautions to require that your personal data remains protected in accordance with this Privacy Policy. When we transfer your personal data to other countries, we rely on:

• European Commission adequacy decisions, which recognize that certain non-EEA countries have national laws that protect personal data to standards substantially similar to those required by European Union law;
• The European Commission’s Standard Contractual Clauses, which require non-EEA recipients of personal data to continue to protect the personal data they receive to the standards required by European Union law;
• other legal mechanisms for transferring data or legal exemptions to restrictions on data transfer.

You can obtain more details by making your request to :
OMNES Education – DPO Service – Immeuble Greenelle – 43 quai de Grenelle – 75015 PARIS

X – UPDATE

We may update this Privacy Policy to comply with legislative, regulatory, technical or business developments. When we update our Privacy Policy, we will take appropriate steps to notify you, depending on the significance of the changes we make. We will notify you in advance of any significant changes to the Privacy Policy if and when required by applicable laws and regulations.

You can see when this Privacy Policy was last updated by checking the date at the top of this Privacy Policy.

XI – CONTACT

If you have any questions about the Privacy Policy, you can contact us at the following address
OMNES Education – DPO Service – Immeuble Greenelle – 43 quai de Grenelle – 75015 PARIS

COOKIE POLICIES

INFORMATION ABOUT COOKIES

WHAT IS A COOKIE?

Cookies are small files that are installed on your computer or device for a limited time when you visit our websites.

PURPOSE OF COOKIES

We use cookies to make your visits and registration on our sites more efficient and secure. Cookies also allow us to improve navigation on our sites and to understand your browsing preferences.

OUR USE OF COOKIES

We use cookies to :

• Remember your login information.
• Identify you when you log on to our websites.
• To collect information that may help us to provide you with advertisements that are tailored to your interests.
• Remember your browsing preferences such as your language, font size, page layout or preferred colors. All of this to make browsing our site faster and easier.
• Collect analytical information to, for example, count the number of visitors to our websites and identify the pages of our sites that you visit most often. We use the analysis data we collect for marketing and resource planning purposes.
• To determine how easily our visitors adapt to changes we may make to our websites.

INFORMATION COLLECTED THROUGH COOKIES

Cookies help us collect information about how you use our website, but we do not store any personally identifiable information in our cookie data about you. We only record a unique session ID that will help us to retrieve a user profile and your preferences the next time you visit.

TYPES OF COOKIES

• Session Cookies – Cookies of this type are temporarily stored on your computer or device during a browsing session. They are deleted from your computer or device at the end of the browsing session.
• Permanent cookies – Cookies of this type remain on your computer for a longer period of time. Persistent cookies help us recognize you when we need to know who you are for more than one browser session.

These cookies can be divided into several categories:

• Cookies that are essential for navigation (technical cookies)

These cookies are essential to enable you to browse our website and make the best use of its various features. These cookies are deposited exclusively by OMNES Education.

• Functionality cookies

These cookies are essential to your browsing experience as they allow us to optimise the operation of our site and give you access to specific functions. They also allow you to adapt the graphic rendering of the site to your terminal’s display preferences. These cookies allow you to have a fluid and customized navigation.

• Statistical cookies

These are cookies that allow us to know the performance of our site, to establish statistics on the volume of visits and use of the various elements of our site (content visited, path). These cookies allow us to improve the interest and ergonomics of our services (the pages or sections most often consulted, the most read articles, etc.). Cookies are also used to count the number of visitors to a page and to detect any anomalies in the operation of the site.

• Advertising cookies

These are cookies used to present you with offers and information tailored to your interests while you are browsing the Internet. Refusing these cookies has no impact on the use of our site. However, refusing advertising cookies will not stop advertising during your browsing. This will only result in ads being displayed that do not reflect your interests or preferences.

• Social network cookies

Our site includes elements from third parties (application buttons), which allow the user to share specific content via social networks.

This is particularly the case for the “Share”, “Like”, “g+1” and “Tweet” buttons from social networks such as “Facebook”, “Google+”, “Twitter”, etc.

If you interact with the third party elements, for example by clicking on the “Like” button or leaving a comment, the corresponding information will be transmitted to the social network and published on your profile.

If you do not want the social network to link the information collected through our site to your user account, you must first log out of the social network.

We invite you to consult the privacy protection policies of these social networks in order to learn about the purposes of use, including advertising, of the browsing information they may collect through these application buttons.

Cookie Editors : Tradelab
Type of Cookies: Advertising Cookies
Privacy Policy: http://tradelab.com/en/privacy/

Cookie Editors: TimeOne
Type of Cookies: Advertising Cookies
Privacy Policy: https://privacy.timeonegroup.com/confidentialite/

Cookies editors : Google Adwords
Type of Cookies: Advertising Cookies
Privacy Policy: https://policies.google.com/privacy?hl=fr-CA

Cookie Editors: Facebook Ads
Type of Cookies: Advertising Cookies
Privacy Policy: https://fr-fr.facebook.com/privacy/explanation

Cookies editors : Google Analytics
Type of cookies: Statistical cookies
Privacy Policy: https://policies.google.com/privacy?hl=fr

COOKIE MANAGEMENT

In accordance with the regulations, you have the right to oppose and access the data concerning you. You can therefore object to the deposit of some of our cookies by using the appropriate settings on your browser. Most browsers have options in the menu that allow you to manage your cookies by adjusting or configuring your cookie settings. Generally, the browser offers you the possibility :

• to display your cookies;
• to allow cookies;
• to disable all cookies, or only specific cookies;
• disable all cookies when you close your browser;
• to block cookies;
• to be notified when you receive a cookie.

Please note that if you choose to block our cookies, some of the functionality of our websites will be disabled (including services such as online registration, site management or customization) and your browsing experience may also be affected. If you set your browser options to delete all cookies, your browsing preferences will be erased when you close your browser. Please note that unless you have set your browser to reject cookies, our system will issue cookies whenever you visit one of our sites.

The user can deactivate the use of these cookies by adjusting the parameters of his Internet browser.

He can set his browser to refuse or delete certain cookies. The following links show how to set cookies depending on the browser you are using for :

• Internet Explorer
• Firefox
• Safari
• Google Chrome

THE DURATION OF YOUR COOKIES

In accordance with the recommendations of the CNIL, the period of validity of consent to the deposit of Cookies on our sites is extended to a maximum of 13 months after their first deposit on your equipment and is not extended by new visits to the site. At the end of this period, your consent will have to be obtained again.
So 13 months is the maximum lifetime of a cookie.

MORE INFORMATION ABOUT COOKIES

To learn more about cookies, please visit the following page.
https://www.cnil.fr/fr/cookies-traceurs-que-dit-la-loi

Updated July 17, 2020

List of cookies

A cookie is a small data file (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preferences or login information. We set these cookies called internal cookies. We also use third-party cookies, which are cookies from a different domain than the website you are visiting, for our advertising and marketing efforts. Specifically, we use cookies and other tracking technologies for the following purposes:

Strictly necessary cookies

These cookies are necessary for the operation of the website and cannot be disabled in our systems. They are generally set up as a response to actions you have taken that constitute a request for services, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block or be notified of these cookies, but some parts of the website may be affected. These cookies do not store any personally identifying information.

Subgroup of cookies	Cookies	Cookies used
www.inseec-u.com	OptanonAlertBoxClosed, _icl_current_language, OptanonConsent	Internal cookies

Performance cookies

These cookies allow us to determine the number of visits and sources of traffic, in order to measure and improve the performance of our website. They also help us to identify the most/least visited pages and to evaluate how visitors navigate the website. All information collected by these cookies is aggregated and therefore anonymized. If you do not accept these cookies, we will not be informed of your visit to our site.

Subgroup of cookies	Cookies	Cookies used
www.omneseducation.com	_ga, _gid	Internal cookies

Cookies for targeted advertising

These cookies may be set within our website by our advertising partners. They may be used by these companies to profile your interests and provide you with relevant advertisements on other websites. They do not store personal data directly, but are based on the unique identification of your browser and Internet device. If you do not allow these cookies, your advertising will be less targeted.

Subgroup of cookies	Cookies	Cookies used
www. omneseducation .com	eupubconsent-v2	Internal cookies
omneseducation .com	_gat_gtag_xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx	Internal cookies
linkedin.com	_gat, bcookie, _ga, _gid, lang, li_gc, lidc	Third-party cookies
consensu.org	init, euconsent-v2	Third-party cookies
doubleclick.net	test_cookie	Third-party cookies
scorecardresearch.com	UID, UIDR	Third-party cookies
youtube.com	YSC, CONSENT, VISITOR_INFO1_LIVE	Third-party cookies
www.linkedin.com	JSESSIONID, bscookie	Third-party cookies

Store and/or access information stored on a terminal

Cookies, terminal identifiers or other information may be stored or accessed on your terminal for the purposes presented to you.

Personalized advertising and content, ad and content performance measurement, audience data and product development

Ads and content can be personalized based on a profile. Additional data can be added to better personalize ads and content. The performance of ads and content can be measured. Information can be generated about the audiences who have seen the ads and content. The data can be used to create or improve user experience, systems and software.

• Selecting standard ads: Ads may be presented to you based on the editorial content you view, the application you use, your approximate location, or your device type
• Create a personalized ad profile: A profile can be created about you and your interests to show you personalized ads that may be of interest to you.
• Selecting Personalized Ads: Personalized ads can be presented to you based on a profile created about you.
• Create a profile to display personalized content: A profile can be created about you and your interests to show you personalized content that may be of interest to you.
• Select personalized content: Personalized content can be presented to you based on your user profile.
• Measuring the performance of ads/advertisements: The performance and effectiveness of ads you see or interact with can be measured.
• Measure content performance: The performance and effectiveness of the content you see or interact with can be measured.
• Leverage market research to generate audience data: Market research can be used to learn more about the audiences that visit sites/use apps and see ads.
• Develop and improve products: Your data can be used to improve existing systems and software and to develop new products.

Use accurate geolocation data

Your specific geolocation data may be used to support one or more purposes. This means that your location can be accurate to within several metres.

Actively analyze terminal characteristics for identification

Your terminal can be identified based on an analysis of the unique combination of characteristics of your terminal.

Ensure security, prevent fraud and debug

Your data may be used to monitor and prevent fraudulent activity, and to ensure that systems and processes are working properly and securely.

To technically distribute the advertisements or content

Your device may receive and send information that allows you to view and interact with advertisements and content.

Mapping and combining offline data sources

Data from offline data sources may be combined with your online activity to support one or more purposes.

Connecting different terminals

Different terminals may be identified as belonging to you or your household for one or more purposes

Receive and use automatically sent device identification features

Your device can be distinguished from other devices based on information it automatically sends, such as IP address or browser type.