This Policy
applies between you, the User of the Web Site health.edhec.edu and the EDHEC Management in Innovative Health Chair (“EDHEC MIH
Chair”) / EDHEC Business School, Association Loi 1901, whose
head office is located at 24 Avenue Gustave Delory, 59100 ROUBAIX – FRANCE, the owner and provider of this Web Site. This Policy applies to our use
of any and all Data collected by us in relation to your use of the Web Site and
any Services or Systems therein.
Our platform is built with the Services offered by LearnWorlds (CY) Ltd, a limited company registered in Cyprus under company number HE380294, acting as Data Processor. As End User of an Online School, the LearnWorlds Privacy Policy provides the following:
If you are an End User of an Online School, please see the terms and
conditions and privacy policy of that third party, and direct your privacy
inquiries, including any requests to exercise your data protection rights, to
the Online School’s Administrator. We are not responsible for the privacy or
security practices of our Online School Administrators, which may differ from
those set forth in this privacy policy. However, we process your Personal Data
and act as data processors to the Online School Administrator that is the data
controller, with whom you have entered into an agreement with.
The Personal Data provided by the End User may include:
·
Name.
·
Email Address.
·
Other custom form fields and profile information
(occupation or other demographic information, address, job title) subject to
the Online School Administrator set-up.
·
End-user’s personal interests or preferences
(including purchase history, marketing preferences and publicly available
social media profile information subject to the Online School Administrator
set-up.
The Personal Data we collect while they use our Product and Services may
include:
·
Identifiable IT information (IP addresses, usage
data, cookies data, online navigation data, browser data).
·
Number of log-ins.
·
Webpages visited.
·
Activity on the said Online School.
If you use an Online School Account you can:
·
Control and administer your Account, including
controlling privacy-related settings.
·
Access and process your Personal Data, including
the interaction data and the contents of your communications and files
associated with your account in the Online School.
·
Access and process your End User’s Personal Data
as provided by them to offer the agreed services.
When you use an Online School, LearnWorlds processing of your Personal
Data in connection with that Online School is governed by an agreement between
LearnWorlds and the respective User, who administrates the Online School.
LearnWorlds processes your Personal Data to provide its Services to your Online
School Administrator and you.
In this
Policy the following terms shall have the following meanings:
"Account":
means collectively the personal information, Payment Information and
credentials used by Users to access Material and / or any communications System
on the Web Site;
"Content":
means any text, graphics, images, audio, video, software, data compilations and
any other form of information capable of being stored in a computer that
appears on or forms part of this Web Site;
"Cookie":
means a small text file placed on your computer by Ltd when you visit
certain parts of this Web Site. This allows us to identify recurring visitors
and to analyse their browsing habits within the Web Site.
"Data":
means collectively all information that you submit to the Web Site. This
includes, but is not limited to, Account details and information submitted
using any of our Services or Systems;
"Service":
means collectively any online facilities, tools, services or information
that makes available through the Web Site either now or in the future;
"System":
means any online communications infrastructure that makes available
through the Web Site either now or in the future. This includes, but is not
limited to, web-based email, message boards, live chat facilities and email
links;
"User"
/ "Users": means any third party that accesses the Web Site and is
not employed by and acting in the course of their employment; and
"Website":
means the website that you are currently using (health.edhec.edu)
Without
limitation, any of the following Data may be collected:
3.1 name;
3.2 date
of birth;
3.3 job
title & profession;
3.4 contact information such as email
addresses and telephone numbers;
3.5 demographic information such as post
code, preferences and interests;
3.6 financial information such as credit
/ debit card numbers;
3.7 IP
address (automatically collected);
3.8 web browser type and version
(automatically collected);
3.9 operating
system (automatically collected);
3.10 a list of URLS starting
with a referring site, your activity on this Web Site, and the site you
exit to (automatically collected); and
3.11 Cookie information (see:
Privacy | EDHEC BUSINESS SCHOOL)
4.1 Any personal Data you submit will be
retained:
- Technical
data: for up to one year as long as you use the Services and Systems provided
on the Web Site.
-
Account
data: during 5 years after your last access to your personal account
-
Financial
information: during 10 years for accounting purposes
4.2 Unless we are obliged or permitted
by law to do so, and subject to Clause 5, your Data will not be disclosed
to third parties.
4.3 Any or all of the above Data may be
required by us from time to time in order to provide you with the best
possible service and experience when using our Web Site. Specifically,
Data may be used by us for the following reasons:
4.3.1 internal
record keeping;
4.3.2 improvement of our
products / services;
4.3.3 transmission by email of
promotional materials that may be of interest to you;
4.3.4 contact for market
research purposes which may be done using email, telephone, fax or mail.
Such information may be used to customise or update the Web Site.
The EDHEC
MIH Chair may, from time to time, employ the services of other parties for
dealing with matters that may include, but are not limited to, payment
handling, delivery of purchased items, search engine facilities, advertising
and marketing. The providers of such services do not have access to certain
personal Data provided by Users of this Web Site. Any Data used by such parties
is used only to the extent required by them to perform the services that they
request. Any use for other purposes is strictly prohibited. Furthermore, any
Data that is processed by third parties must be processed within the terms of
this Policy and in accordance with the GDPR (EU) 216/679 of April 27th,
2016.
6.1 The EDHEC MIH Chair may, from time
to time, expand or reduce its business and this may involve the sale of
certain divisions or the transfer of control of certain divisions to other
parties. Data provided by Users will, where it is relevant to any division
so transferred, be transferred along with that division and the new owner
or newly controlling party will, under the terms of this Policy, be
permitted to use the Data for the purposes for which it was supplied by
you.
6.2 In the event that any Data submitted
by Users will be transferred in such a manner, you will be contacted in
advance and informed of the changes. When contacted you will be given the
choice to have your Data deleted or withheld from the new owner or
controller.
7.1 Wherever you are required to submit
Data, you will be given options to restrict our use of that Data. This may
include the following:
7.1.1 use of Data for direct
marketing purposes; and
7.1.2 sharing Data with third
parties.
8.1 You may access certain areas of the
Web Site without providing any Data at all. However, to use all Services
and Systems available on the Web Site you may be required to submit
Account information or other Data.
8.2 You may restrict your internet
browser’s use of Cookies. For more information see
Privacy | EDHEC BUSINESS SCHOOL
9.1 You may access your Account at any
time to view or amend the Data. You may need to modify or update your Data
if your circumstances change. Additional Data as to your marketing
preferences may also be stored and you may change this at any time.
9.2 You have the right to ask for a copy
of your personal Data.
Data
security is of great importance to and to protect your Data we have put in
place suitable physical, electronic and managerial procedures to safeguard and
secure Data collected online.
The EDHEC
MIH chair reserves the right to change this Privacy Policy as we may deem
necessary from time to time or as may be required by law. Any changes will be
immediately posted on the Web Site and you are deemed to have accepted the
terms of the Policy on your first use of the Web Site following the
alterations.
Your
personal data belongs to you and, as such, you possess certain rights. In
accordance with prevailing personal data protection laws and regulations, you possess
a right of:
Access: you have the right to
know what personal data we hold on you, to consult it and to obtain a
copy.
Rectification: if you notice an
error, you can ask for the incorrect data to be rectified at any moment.
Erasure: under certain
conditions, you can ask us to erase your personal data. Please note that
we are liable to retain certain data that concerns you when prevailing
laws and regulations require us to do so or when we have a legitimate
reason to do so (e.g. execution of a contract or to establish, execute or
defend legal claims).
Restriction: under certain
conditions, you can ask us to restrict the use we make of your personal
data, for example, during the period of time needed to examine a data
rectification request.
Portability: you have the right
to ask for the personal data you have provided to be sent to you or to
another data processor in a structured, commonly used and machine-readable
format.
Objection: in certain cases,
you can object to the use of your personal data for certain types of
processing (e.g. for direct marketing operations).
To respond
to your requests, we may require you to prove your identity.
At any
moment, you may also withdraw the consent you have given us to process your
data for a specific purpose.
For all
questions concerning this policy or to exercise your rights, you may contact
our Data Protection Officer at the following address:
EDHEC
Business School
Data Protection Officer
24, avenue Gustave Delory
CS 50411
59057 ROUBAIX Cedex 1
Or: DPO@edhec.edu
f you
consider that your rights have not been respected, you may make a complaint to
the competent supervisory authority:
Commission Nationale de l’Informatique et des Libertés
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Or
https://www.cnil.fr/fr/plaintesIf there are any questions regarding this privacy policy you may contact us at innovative-health@edhec.edu or dpo@edhec.edu.
13.
Contacting Us
If there
are any questions regarding this privacy policy you may contact us at innovative-health@edhec.edu or dpo@edhec.edu.
