Confidentiality policy

Our privacy policy

Preamble

This privacy policy informs you about how the Académie Notre Europe uses and protects any information that you provide to us when you use this website accessible from the following URL: www.academienotreeurope.eu (hereinafter referred to as the ‘Website’).

Please note that this privacy policy may be modified or supplemented at any time by the Académie Notre Europe, in particular to comply with any legal or technological developments. In such a case, the date of its update will be clearly indicated at the top of this policy. These modifications are binding on the Internet user as soon as they are posted online. It is therefore advisable for the Internet User to consult this privacy policy regularly in order to be aware of any changes.

Parties

This privacy policy is applicable between the publisher of the Site, namely the Académie Notre Europe, hereinafter referred to as ‘the Académie’, and any person connecting to the Site, hereinafter referred to as ‘the Internet User’.

Definitions

• ‘Site Content’: elements of any kind published on the Site, whether or not protected by intellectual property rights, such as text, images, designs, presentations, videos, diagrams, structures, databases or software.
• ‘Internet User’: any person connecting to the Site.
• ‘Site’: the website accessible at the URL www.academienotreeurope.eu, as well as any sub-sites, mirror sites, portals and variations of the URL relating thereto.

Scope

This privacy policy applies to all Internet Users. By connecting to and/or browsing the Site, you fully and unreservedly accept this privacy policy. Similarly, clicking on ‘I accept’ in the cookie information banner displayed on the Site confirms your acceptance of this policy and allows you to customise the cookies that will or will not be applied to you. You thereby acknowledge that you have read and accepted them without restriction.

The Internet user acknowledges the value of the Académie’s automatic recording systems as proof and, unless they can provide evidence to the contrary, waives the right to contest them in the event of a dispute.

Acceptance of this privacy policy implies that Internet users have the legal capacity to do so or are at least 16 years of age, or, failing that, that they have the authorisation of a guardian or curator if they are incapable, of their legal representative if they are under 16 years of age, or that they hold a mandate if they are acting on behalf of a legal entity.

Personal data

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016 and with the national legislation in force, the Académie provides you with the following information:

• Identity of the data controller

The data controller is the Jacques Delors Institute, Association loi 1901, 18 rue de Londres, 75009 Paris, SIREN: 410 100 184.

• Identity of the Data Protection Officer

The Data Protection Officer is Deshoulières Avocats Associés, 121 boulevard de Sébastopol 75002 Paris, tel.: +33.1.77.62.82.03, rgpd@deshoulieres-avocats.com, www.deshoulieres-avocats.com.

• Data collection by the Académie Notre Europe
• Data collected
  • Data collected during browsing

When browsing the Website, you consent to the Académie collecting information relating to:

• your use of the Website;
• the content you view and click on;
• your connection data (times, IP address, etc.).

• Data collected when using the contact email address

The use of the contact email address by the Internet user implies the collection by the Académie of the following personal data:

• email address.

Internet users who do not wish to provide the information required to send an email will not be able to send a message to the Académie.

• Data collected when using the newsletter form

When using one of the newsletter forms, the Académie may collect and process:

• email address.

• Data collected when using the donation form

When making a donation, all data provided is processed by HelloAsso. For any questions regarding the processing carried out by this service provider, please visit the following page: https://www.helloasso.com/confidentialite or contact HelloAsso.

In order to track donations, the Académie may still need to process the following data:

• first and last name;
• date of birth;
• postal address
• email address;
• bank details.

• Purposes of personal data collection

The data collected during browsing is subject to automated processing for the following purposes:

• develop, operate, improve, provide and manage the Website;
• contextualise and improve the User’s experience;
• prevent any illegal or unlawful activity;
• enforce the terms and conditions of use of the Website.

The data collected when using the contact email address is subject to automated processing for the following purposes:

• provide a detailed response to the Internet user;
• send information and contact the Internet user, including by email or telephone;
• prevent any illegal or unlawful activity;
• ensure compliance with the terms and conditions of use of the Website.

The data collected when using the donation form is subject to automated processing for the following purposes:

• ensure the management and follow-up of donations.

• Legal basis for processing

The legal basis for the data collected during browsing is the legitimate interest of the Académie, namely to analyse behaviour on the Website and to improve the security and functioning of the Website. Some of this data, such as that resulting from the installation of certain cookies, may have as its legal basis the consent of the individuals concerned.

The legal basis for data collected when sending an email to the contact address is the consent of the individuals concerned.

The legal basis for data collected when using the newsletter form is the consent of the individuals concerned.

The legal basis for data collected when making a donation is the consent of the individuals concerned.

• Recipients of the data

The data collected can only be accessed by members of the Académie’s management and by staff responsible for managing the website, and are never made freely available to third parties, except when a donation is made, in which case the data is processed by HelloAssso.

• Retention period for personal data

Personal data collected during browsing is kept for a reasonable period of time necessary for the proper administration of the Site and for a maximum of 6 months, or until the consent of the persons concerned is withdrawn.

Personal data collected when sending an email to the contact address is kept for a reasonable period of time necessary for the proper management of the Internet user’s request, and for a maximum of 12 months.

Data collected when using the newsletter form is kept until the consent of the persons concerned is withdrawn.

Data collected when making a donation is kept until the donation has been successfully completed and the tax receipt has been sent.

At the end of each of these periods, the Académie will archive this data and keep it for as long as its liability may be incurred.

After this retention period, the Académie undertakes to permanently delete the data of the persons concerned.

• Security and confidentiality of personal data

Personal data is stored in secure conditions, in accordance with current technical standards, in compliance with the provisions of the General Data Protection Regulation and applicable national legislation.

• Minimisation of personal data

The Académie may also collect and process any data voluntarily provided by an Internet user, in particular when sending an email to the contact address.

The Académie will guide Internet users as much as possible when they provide unnecessary or superfluous personal data.

The Académie undertakes to store and process only data that is strictly necessary for its activities, and will delete any data received that is not useful as soon as possible.

• Respect for rights

You have the following rights regarding your personal data, which you can exercise by writing to us at our postal address or by sending an email to the following address: info[@]academienotreeurope[.]eu

• Right to information, access and communication of data

You have the right to access your personal data.

Due to the Académie’s obligation to ensure the security and confidentiality of personal data, your request will only be processed if you provide proof of your identity, in particular by providing a scan of your valid identity document (if requesting by email) or a signed photocopy of your valid identity document (if requesting in writing), both accompanied by the statement ‘I certify that the copy of this identity document is a true copy of the original. Done at … on …’, followed by your signature.

To help you with this process, you will find a template letter prepared by the CNIL here.

• Right to rectification, erasure and the right to be forgotten

You have the right to request the rectification, updating, blocking or erasure of your personal data if it is inaccurate, incorrect, incomplete or obsolete.

You may also define general and specific guidelines regarding the fate of your personal data after your death. Where applicable, the heirs of a deceased person may request that the death of their relative be taken into account and/or that the necessary updates be made.

To help you with this process, you will find a template letter prepared by the CNIL here.

• Right to object to data processing

You have the right to object to the processing of your personal data.

To do so, please send an email to the following address: info[@]academienotreeurope[.]eu. In this email, you must specify the data you wish to have deleted and the reasons for your request, except in the case of commercial prospecting.

• Right to data portability

You have the right to receive the personal data you have provided to us in a transferable, open and readable format.

• Right to restriction of processing

You have the right to request that the processing of your personal data by the Académie be restricted. This means that your data will only be stored and no longer used by the Académie.

• Withdrawal of consent

Your consent is essential for the Académie to process your data. However, you may withdraw your consent at any time. This withdrawal will result in the deletion of your personal data.

Services requiring the processing of your data by the Académie will no longer be accessible.

• Response times

The Académie undertakes to respond to your request for access, rectification or objection or any other additional request for information within a reasonable period of time, which shall not exceed one month from receipt of your request.

• Complaint to the competent authority

If you consider that the Académie is not complying with its obligations regarding your personal information, you may lodge a complaint or request with the competent authority. In France, the competent authority is the CNIL, to which you can send a request here.

• Transfer of collected data

• Transfer to partners

The Académie informs you that we use authorised service providers to facilitate the collection and processing of the data you have provided to us. These service providers may be located outside the European Union and have access to the data collected on the Website.

The Académie has ensured in advance that its service providers implement adequate safeguards and comply with strict conditions regarding confidentiality, use and protection of data, for example via the US Privacy Shield.

The Internet user consents to the data collected being transmitted by the Académie to its partners and processed by these partners in the context of third-party services, namely:

• Transfer upon request or court order

The User also consents to the Académie disclosing the data collected to any person, upon request from a state authority or by court order.

• Transfer in the event of a merger or acquisition

If the Académie is involved in a merger, sale of assets, financing operation, liquidation or bankruptcy, or in the acquisition of all or part of its business by another company, the Internet User consents to the data collected being transferred by the Académie to that company and to that company processing the personal data referred to in this privacy policy in place of the Académie.

Policy on trackers/cookies

When you first connect to the Académie’s website, you are notified by a banner at the bottom of your screen that information relating to your browsing may be stored in files called ‘cookies’. Our cookie policy allows you to better understand the provisions we implement in relation to browsing our website. In particular, it informs you about all the cookies on our website, their purpose, and how to configure them.

• Use of trackers/cookies

The Académie, as the publisher of this website, may place a cookie and other trackers on your device’s hard drive (computer, tablet, mobile, etc.) to ensure smooth and optimal browsing on our website.

Cookies are small text files that allow us to recognise your computer, tablet or mobile device in order to personalise the services we offer you.

To provide you with more information about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the Académie’s website, their name, purpose and retention period.

• Purpose of trackers

With the help of the information contained in the trackers and cookies used, the Académie can analyse the traffic and use of the Website and, where appropriate, facilitate and improve navigation. Finally, the Académie also uses cookies to find out how Internet users use its Website.

• Trackers used

• Configuring your cookie preferences

When you first connect to the Académie’s website, a banner briefly presenting information about the use of cookies and similar technologies appears at the bottom of your screen. This banner allows you to choose which cookies you accept or refuse on your device. You will be deemed to have given your consent to the use of cookies by clicking on the ‘I accept’ icon, either globally or individually. Conversely, you will be deemed to have refused the use of cookies by clicking on the ‘I refuse’ icon. Once again, this choice may apply to all cookies or only to some of them. If you do not make a choice, you will be deemed to have refused the use of cookies. Your decision will be recorded for six months and may be changed at any time.

• Cookies exempt from consent

In accordance with the recommendations of the French Data Protection Authority (CNIL), certain cookies are exempt from the requirement to obtain your prior consent insofar as they are strictly necessary for the functioning of the website or have the sole purpose of enabling or facilitating electronic communication. These include session ID cookies, authentication cookies, load balancing cookies and cookies used to personalise your interface. These cookies are fully subject to this policy insofar as they are issued and managed by the Académie.

• Cookies requiring your prior consent

This requirement applies to cookies issued by third parties and which are described as ‘persistent’ in that they remain on your device until they are deleted or expire.

As these cookies are issued by third parties, their use and storage are subject to their own privacy policies. This family of cookies includes audience measurement cookies.

Audience measurement cookies compile statistics on the frequency and use of various elements of the website (such as the content/pages you have visited). This data helps to improve the usability of the Académie’s website.

• Maximum retention period for trackers

Trackers are intended to be stored on the Internet user’s computer for a period of up to 6 months. This data is stored under secure conditions, in accordance with current technical standards, in compliance with the provisions of the General Data Protection Regulation and national legislation in force.

• Opposition to the use of trackers

• Right to oppose the use of trackers

You can accept or refuse cookies at any time.

The Internet user may delete or disable the use of trackers at any time by changing their browser settings. It is possible to view the Website without trackers. However, some additional features of the Website may not work if the Internet user has disabled the use of trackers, such as auto-complete forms or navigation indicators.

• Settings

For more information about cookie control tools, you can consult the dedicated page on the CNIL website here.

• Browser settings

Each Internet browser offers its own cookie management settings. The User can configure their browser software so that cookies are rejected, either systematically or depending on their issuer. The User can also configure their browser software so that they are asked whether they accept or reject cookies each time before a cookie is likely to be stored on their device.

Each browser has different settings for managing cookies and user choices. These settings can be found in the browser’s help menu, which will explain how to change your cookie preferences:

• For Internet Explorer;
• For Safari;
• For Chrome;
• For Firefox;
• For Opera.

• Settings using add-ons

The Internet user may also delete or oppose the installation of cookies on their computer by installing an extension on their browser, such as Ghostery, which can be downloaded here.

Intellectual property

• Legal protection of the Site’s Content

The Content of the Website may be protected by copyright and database rights. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, carried out illegally and without the consent of the Académie or its beneficiaries or successors constitutes a violation of Books I and III of the Intellectual Property Code and may give rise to legal proceedings for infringement.

• Contractual protection of the Site Content

The Internet User contractually undertakes to the Académie not to use, reproduce or represent, in any manner whatsoever, the Site Content, whether or not protected by intellectual property rights, for any purpose other than reading by a robot or browser. This prohibition does not apply to indexing robots whose sole purpose is to scan the content of the Site for indexing purposes.

Final provisions

7.1 Modifications

This Privacy Policy may be modified at any time by the Académie. The conditions applicable to the Internet User are those in force at the time of their connection to the Site, any new connection to the Site implying acceptance of the new conditions, if any.

• Entire

The invalidity of any clause of this contract shall not invalidate the other clauses of the contract or the contract as a whole, which shall remain in full force and effect. In such a case, the parties shall, to the extent possible, replace the invalid clause with a valid clause that corresponds to the spirit and purpose of this contract.

• Non-waiver

Failure by the Académie to exercise the rights granted to it herein shall in no way be interpreted as a waiver of its right to assert such rights.

• Languages

These terms and conditions are provided in English.

• Unfair terms

The provisions of these terms and conditions apply subject to compliance with the mandatory provisions of the Consumer Code concerning unfair terms in contracts concluded between a professional and a consumer.

Disputes

• Applicable law

This Privacy Policy is subject to French law and European regulations, in particular the European Data Protection Regulation.

• Disputes

Pursuant to Order No. 2015-1033 of 20 August 2015, any disputes that may arise in connection with the performance of these terms and conditions and which cannot be resolved amicably between the parties shall be submitted to Medicys.

• Arbitration

Any dispute relating to this contract or in connection with it shall be settled by arbitration in accordance with the FastArbitre rules of the Digital Arbitration and Mediation Academy.