Source and type of data processed
As part of our communication, we process personal data that concerns you: because you have directly provided it to us, we have collected it automatically, or because we have collected it indirectly from third parties. At each processing stage, we take care to limit the data collected to what is adequate, relevant and necessary for the purposes to be achieved.
1) PERSONAL DATA PROVIDED BY YOU
The personal data we collect is the data you provide to us voluntarily (for example, when using a chatbot or filling in forms) and the data we ask from you when you:
- Sign a contract with us;
- Accept or supervise one of our students in a work-study program or an internship agreement;
- Register to attend or contribute to events, webinars, or services;
- Subscribe to newsletters and alerts on events or information;
- Take part in surveys, competitions, or any other promotional activities.
The type of personal data we may request from you can include, but is not limited to:
- Your identity;
- Your professional data (your physical or email address, your telephone number, etc.);
- Details of your professional life (for example your position title, prior education, course preferences)
- Your login data (for example, your user name);
- Your financial data (for example, your credit or payment card, bank account number and billing address);
- Opinions on our services and products that you have expressed.
We may ask you to provide additional personal data, for example, in the case of online surveys, to understand your needs.
2) PERSONAL DATA COLLECTED AUTOMATICALLY
Our websites, and the third party web analysis service providers we use, automatically collect some types of data such as your IP address, the type of device you use, your device’s ID and other technical data, via cookies and other similar tracking tools.
Collecting personal data helps us better understand the type of users who visit our websites, where the visitors came from and the content they find useful. We use this data for internal purposes and to improve the quality and relevance of our websites for our visitors. Some of this data can be collected by using cookies and similar tracking tools if you agree to it. For further information, please read our Cookie Policy which can be found on the relevant websites.
3) PERSONAL DATA COLLECTED FROM THIRD PARTIES
We may receive personal data concerning you from third parties, but only if these third parties are authorized or required to disclose your personal data. The data we may collect from third parties includes your contact details, professional data where applicable, data on your career, etc.
We may also collect data concerning you if you have made it freely accessible, for example on professional social media.
Processing purposes
We use the personal data we collected from you for the purpose described in the present Confidentiality Policy, and those we disclosed to you at the time of collection or for compatible purposes.
In particular, we use your data:
- For the purposes of our pre-contractual, contractual and subsequent relationship, especially for the purposes of recovery or litigation;
- To present your company and the job offers it publishes to our students and to put them in contact with you;
- If you have not objected to it, to inform you of future events, updates, new training programs/services, the latest services, as well as other offers, especially those relating to our students’ course of study, in accordance with your communication preferences and the contact methods you have given us: postal service, email, phone call, messaging, instant messaging, social media;
- To provide you the information and services you require;
- To send you important notifications concerning our procedures, enrollment conditions, confidentiality policies and other legal documents;
- To meet the requirements imposed on us by administrative and financial checks and audits;
- To carry out auditing, accounting, invoicing, reconciliation and collection activities as well as other internal commercial operations;
- To undertake surveys (including market research and consumer studies, satisfaction surveys, trend analysis, financial analysis);
- To protect you and our staff against fraud and other illegal activities or unfounded accusations; to establish, exercise and defend your rights, as well as those of our staff, and to comply with the legal and regulatory obligations in force;
- To maintain the physical security of our premises (visitor logbooks, for instance) and IT and electronic security;
- To use and manage our websites.
We may also use your personal data in aggregate form, making it impossible to identify individuals in order to assess and improve our training programs and services
Legal basis for personal data processing
In the European Economic Area, the legal basis for personal data processing described above depends on the personal data in question and the specific purposes for which we process it. The legal basis for processing is usually provided to you in the information you were given at the time of collection and you can find the main processing operations here.
However, we only collect personal data from you when:
- We need your personal data to provide a service you requested as part of a contract or agreement you entered into, or for pre-contractual measures necessary for their conclusion.
- We process your data in compliance with our legitimate interests, unless your interests or fundamental freedoms and rights prevail. For instance, this is the case when we put our students in contact with one another or when we undertake satisfaction surveys, statistical analysis, operations required for the security of our websites and events, or prospection, unless you object to it at any time.
- We are under a legal obligation to process certain types of data to meet regulatory constraints. For example, we are obliged to process or transfer some of your data to prove the quality of our training programs with government agencies.
For any question on the legal basis for the collection and use of your personal data, please contact our Data Protection Officer (dpo@omneseducation.com).
Personal data recipients
We may send your personal data to the following recipients:
- All the Organisation et Développement departments, in accordance with their operational requirements for the purposes mentioned above;
- The subcontractors and service providers of Organisation et Développement and the schools, which provide us with services requiring data processing, for example our suppliers of software, data hosts, organizers of events for which you have registered with and who are tasked with welcoming you, or recovery agencies. Where applicable, details of specific recipients of your data can be sent to you at the time of collection:
- Financial service providers, regarding the payment of our invoices and yours;
- Our students and alumni, so that you can send us job offers, or invite them to contact them as part of their search for an internship or work-study program;
- Organizations involved in the control or in the certification of training provided by the IUM;
- Any relevant law enforcement agency, governmental or regulatory agency, court or other third party, for whom it is necessary to disclose personal information (i) under the laws and regulations in force, (ii) to exercise, establish and 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 acquire, merge, reorganize, transfer, wind up, 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 out in the present Confidentiality Policy;
- Any other person to whom we have given the authorization to disclose our personal data.
Your rights
In application of the Monegasque law on the protection of personal data and of the GDPR, you have the right to:
- access your personal data and obtain a copy of it;
- update or rectify the inaccuracy of this data;
- request the removal of your personal data;
- request that personal data processing be limited;
- object to the processing of your personal data, except when processing is required to execute your contract, or which is imposed on us by a regulatory constraint;
- request the portability of your personal data
- when processing is based on your consent, withdraw it at any time;
- to object to the communication of your data to third parties for prospecting purposes;
- file a complaint with the local supervisory authority – in France, the CNIL and in Monaco, the CCIN.
You also have the right to object to receiving marketing communication that we send you, at any time. You may exercise this right by clicking on the unsubscribe links in the marketing emails we send you, by replying to the message in accordance with the procedure set out, by indicating your wish to the telephone operator undertaking the prospection program or by writing to our Data Protection Officer.
In order to exercise all your rights, you may write to our Data Protection Officer at the company’s registered office:
OMNES Education – Service du DPO – Immeuble Grenelle – 43 quai de Grenelle – 75015 Paris
or by email: dpo@omneseducation.com.
If we have any reasonable doubt as to your identity, and in order to protect your private life and ensure the security of your data, we may undertake to check it.
Personal data security
We attach great importance to the protection of your personal data and private life. Which is why we have implemented the technical and organizational measures required (physical, logical and personal security, as well as regular audits and reviews) to protect your personal data against illegal or unauthorized destruction, loss, alteration, access, disclosure and accidental use.
Personal data storage
We store your personal data when we have a legitimate and ongoing need to provide you with a service which you requested or which you agreed to, for example.
When we have no legitimate commercial need to process your personal data, we delete it or we anonymize it, or if that is not possible, including because your personal data is stored in backup archives, we store your personal data securely.
The data used for commercial prospecting is stored for a period of three (3) years from the end of the business relationship or your last contact.
The data collected when students are hosted as part of an apprenticeship or professionalization agreement, or an internship is stored for a period of three (3) years from the end of our contractual relationship in order to propose that you welcome other students with a similar profile.
The data relating to invoicing is stored for a period of ten (10) years, starting from the end of the fiscal year, in compliance with Article L. 123-22 of the French Trade Code.
Documents on the rights and liberties of the persons concerned are stored for one (1) year as regards access and rectification, and six (6) years as regards the right to object. If we have reasonable doubt, identity documents requested are stored no longer than the time required to verify them.
International transfer of personal data
We host your data in Monaco or in the European Union. When we entrust the hosting of your data to service providers, in particular when it is backed up in the cloud or we use SaaS applications, we ensure that the data is hosted in the European Union and that it is not transferred outside the European Union without prior authorization.
If we have to transfer your personal data to third parties, we supervise and ensure the security of transfers with:
- European Commission adequacy decisions, which recognize that certain countries outside EEA have national laws that protect personal data in accordance with substantially similar standards to the standards required by European Union Law:
- European Commission standard contractual clauses, which require that the personal data of recipients outside the EEA continue to protect the personal data they receive, in accordance with the standards required by European Union law;
- other legal data transfer mechanisms or legal exemptions from restrictions on data transfer.
You may obtain further details by making a request to:
OMNES Education – Service du DPO – Immeuble Grenelle – 43 quai de Grenelle – 75015 Paris
Updated 18 July 2024