You are an alum of IUM

Source and type of data processed

As part of our communication, we process personal data that concerns you: because you have provided it to us directly, 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.

The primary source of data that concerns you comes from your student profile and the data you have given us or that we have collected throughout your course of study. We may add to this data after you have completed your course of study as follows.

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:

• Contact us by email, telephone, messaging, post, or any other means;
• Enroll on a training program or subscribe to a service;
• Create or manage an alumni account;
• Register for events, webinars, or services;
• Subscribe to newsletters and alerts on events or information;
• Take part in surveys, competitions and any other promotional activities.

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

• Your identity;
• Your contact details (your physical or email address, your telephone number, etc.);
• Where applicable, your professional data (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, your bank account number and your billing address for the payment of your alumni membership fee);
• Information about your private life, if you have provided it to us;
• Data on family and friends for emergency contact, for example;
• 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.

When you interact with a chatbot, we naturally process all the information you provide to it, on your own initiative We draw your attention to the importance of not sharing sensitive data (concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation) unless you feel that it is absolutely essential. Some chatbots are likely to enhance your interaction with the help of artificial intelligence systems, in which case you will be informed of it.

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, by 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 come 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

From time to time, we may receive personal data concerning you from third parties, but only when the said third parties are authorized or required to disclose your personal data. The data we collect from third parties includes your contact details, professional data where applicable, data on your course of study, etc.

We may also collect data concerning you if you have made it freely accessible, for example on professional social media, for example in order to contribute to public alumni employment surveys.

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:

• Primarily, in order to enable you to join the OMNES Education group alumni network, in particular to put you in contact with all former group students, and enable you to develop a professional network;
• To provide you the information and services you require;
• To monitor your career after graduation in compliance with regulations;
• To present your profile to companies to facilitate access to the labor market or for your first position;
• To suggest alumni profiles to enable you to recruit new coworkers;
• If you have agreed to it, to inform you of future events, updates, new training programs/services, the latest services, as well as other offers, in accordance with your communication preferences and the contact methods you have given us: postal service, email, phone call, messaging, instant messaging, social media;
• If you have agreed to it, to suggest that you take part in your former institution’s activities via open days, presentations to students and as a panel member;
• To send you important notifications concerning our procedures, enrollment conditions, confidentiality policies and other legal documents;
• To carry out our activities, assess and improve the schools (including by developing new training programs, optimizing and improving our services, analyzing our training programs and services);
• 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 mainly collect personal data from you when:

• You have given us your prior express consent, for example, for any commercial prospecting via email, messaging, etc. You may withdraw your consent at any time by unsubscribing to marketing emails, by managing your communication preferences or by contacting our Data Protection Officer (dpo@omneseducation.com);
• 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. For example, this is the case for processing as part of creating and using an alumni account on our dedicated platform;
• 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 for graduate employment surveys, directories, statistical analysis, operations required for the security of our websites or events, prospection of similar products.
• We are under a legal obligation to process certain types of data to meet regulatory constraints.

For any question relating to 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. Where applicable, details of specific recipients of your data can be sent to you at the time of collection;
• Companies to facilitate your recruitment;
• 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 opt out of receiving marketing emails from us 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 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. That 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 you requested oe 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.

Data relating to your course of study has been stored during this period, then archived for a further six (6) years (as requested by the control or certification bodies) to enable us to prove the adequacy of our training programs with public benchmarks.

The data relating the management of your alumni account is stored so long as you continue to use your account and for a further three (3) years from your last login. Before we delete your data, we may contact you to inform you that deletion of your data is imminent and to allow you to reconnect to your account, if you wish to do so, and thus renew the storage duration. Failing reconnection before the end of this period, your data will be deleted except for the data required to prove your graduation status (full identity and details of training programs followed and diplomas obtained), which is stored for a period of fifty (50) years after your course of study.

The data used to provide you information and communication without commercial prospection, as well as the data used for commercial prospection, is stored for the duration of your course of study and then for a further three (3) years from the end of the agreement or your last contact.

Log files and other journals are stored for a period of three (3) years.

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 the 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 such as binding corporate rules.

You may obtain further details by making a request to:

OMNES Education – Service du DPO – Immeuble Grenelle – 43 quai de Grenelle – 75015 Paris

dpo@omneseducation.com.

Updated 18 July 2024