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:
- Contact us by email, telephone, messaging, post, or any other means;
- Enroll on a training program or subscribe to a service;
- Fill in an application form;
- Create or manage a student account;
- Prove your presence in class or submit a supporting document for your absence;
- Register or activate a device (computer, mobile phone or smartphone);
- Register for events, webinars, or services;
- Subscribe to newsletters and alerts on events or information;
- Take part in studies, 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 or the data relating to your course of study (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)
- Information about your private life, if you have provided it to us;
- Data on your health status, provided that the situation justifies it, and you have agreed to providing this information;
- 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 the chatbot, 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 that 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 certain 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 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 that concerns you from third parties, but only when the said third parties are authorized or required to disclose your personal data. The data which we may collect from third parties includes your contact details, professional data where applicable, data on your course of study, etc. For instance, this is the case for data we receive directly from the Parcoursup (French national admissions) platform.
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, to provide you the service set out in your contract, in particular to manage your application, enrollment, and course of study, and to manage your student file;
- To provide you the information and services you require;
- To present your profile to companies to facilitate access to the labor market or recruitment as an intern or apprentice;
- 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);
- 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 including recovery;
- To undertake surveys (including market research and consumer studies, satisfaction surveys, trend analysis and 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;
- 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;
- 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:
- 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 implemented as part of your course of study, the management of your administrative and financial file, the management of your schedule, communication with your institution, etc.;
- 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 the improvement of our services, satisfaction surveys, statistical analysis, operations required for the security of our websites or events, the prospection of similar products.
- We are under a legal obligation to process certain types of data to meet regulatory constraints.
- In certain extreme cases, we may process your data to ensure that the vital interests of another person are protected, for example, in the case of emergency medical intervention on one of our sites.
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 and IUM departments, in accordance with their operational requirements for the purposes mentioned above;
- The subcontractors and service providers of Organisation et Développement and the school, which provide us with services that require 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, and recovery agencies. Where applicable, details of specific recipients of your data can be sent to you at the time of collection;
- Our financial services providers, linked to the payment of tuition fees;
- Other educational institutions with which OMNES Education has partnerships, provided that this data is necessary for the achievement of these partnerships, for example, when you follow a program in several institutions, or when your course of study involves international exchanges in other institutions;
- Companies, to facilitate your recruitment as part of internships and apprenticeship or professionalization agreements, and to ensure day-to-day management of these internships, apprenticeship agreements and professionalization agreements;
- Organizations involved in the control, the certification or funding 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 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 no longer have any legitimate commercial need to process your personal data, we delete it or anonymize it.
The data used to provide you with 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.
The retention period of data on the management of your student life and course of study depends on the type of data. We store all your data for a period of five (5) years, which is the duration of common law limitation period in case of dispute. We store most of the data relating to your enrollment and course of study for a further one (1) year (therefore, for a total duration of six (6) years after your graduation), in order to respond to the various surveys carried out by certification bodies. The majority of your data is then deleted, with the exception of the data required to justify your graduation (your full identity and details of the courses you have taken).
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 any 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.
Your personal data may nevertheless be transferred and processed in countries other than the country of your school, especially if you are undertaking part of your course of study abroad in a partner institution of the OMNES Education Group. These countries may have data protection laws that are different to those of the country of your original institution which may, in certain cases, not provide the same level of protection.
We take utmost precautions to ensure that your personal data remains protected in compliance with the present Confidentiality Policy.
It may be the case that the country where the host institution is located ensures a level of data protection that is adequate and appropriate, recognized by a European Commission adequacy decision, which recognizes that certain countries outside the EEA have national data protection laws that comply with standards substantially similar to those required by European Union law.
If the institution is not located in a country that ensures an equivalent level of protection, we ensure that the host institution has signed the European Commission standard contractual clauses (SCCs), which require that personal data recipients outside the EEA continue to protect the personal data they receive, in accordance with the standards required by European Union law.
If the host institution has refused to sign the standard contractual clauses, we notify you of the fact and ask your consent to transfer the data that concerns you.
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