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    Privacy Policy

    Trace Academia Privacy Policy

    As part of its “Trace Academia” service, which is an e-learning platform providing users with access to free distance education and learning solutions based on the concept of “Edutainment” combining education and entertainment, TRACE GLOBAL is required to process information about the User. Indeed, by using the “Trace Academia” service, the User transmits information, some of which is of a nature to identify him/her (“personal data”).

    This Privacy Policy informs the User of the manner in which TRACE GLOBAL collects and processes personal data. We invite the User to read this Privacy Policy carefully.

    Data controller

    The person responsible for the processing mentioned in this document is TRACE GLOBAL, a simplified joint stock company with a share capital of €1,204,000.00, registered with the Nanterre Trade and Companies Registry under number 411 205 628, whose registered office is located at 73, rue Henri Barbusse – 92110 Clichy.

    The data protection representative is Mr Sven Balisson.

    Purpose of data processing

    TRACE GLOBAL uses the data it collects to:

    – Communicate with the User about the Trace Academia Service and its evolutions (new content available, new features, satisfaction survey…) or to help the User in case of technical problems,

    – Determine the general geographical location of the User, where the User has consented to this and thereby provide localised content,

    – Communicate with the User (by e-mail, push notifications or instant messages) in the event that he has ticked the box “I wish to receive Trace news”,

    – Communicate with the User (by e-mail, push notifications or instant messages) in the event that he or she has checked the box “I wish to receive commercial offers from Trace” in order to send him or her any special offers, promotional announcements, contests from the Trace group,

    – Prevent, detect and investigate potentially prohibited or illegal activities, such as fraud, and enforce Trace Academia’s Terms and Conditions of use,

    – Analyse, improve and personalise its services and marketing activities in order to enable the User to benefit from the best possible customer experience in the event that the User has accepted all or part of the cookies.

    Legal basis for the processing of your data

    TRACE GLOBAL only collects and processes the User’s personal data in the cases provided for by the regulations in force:

    – The consent given by the User to the use of his/her data (article 6.1, a) of the General Regulations on Data Protection of 27 April 2016,

    – The existence of a legitimate interest for TRACE GLOBAL to use the User’s data. The legitimate interest is a set of commercial or business reasons that justifies the use of the User’s personal data by TRACE GLOBAL (Article 6.1, f) of the General Regulations on Data Protection of 27 April 2016.

    Data processed :

    First of all, TRACE GLOBAL processes personal data that the User communicates to it such as:

    – Surname, first name, title,

    – E-mail address, postal address, telephone number,

    – Encrypted username and password used to identify you on our site or application,

    – Encrypted information relating to your means of payment,

    – Geolocation

    Secondly, TRACE GLOBAL processes the User’s personal data which it collects automatically when the User uses the Trace Academia service, such as:

    – Activity on the Trace Academia service, in particular the Contents followed, the history of the training courses followed;

    – Details about the User’s interactions with customer service, such as the date, time and content of your e-mails;

    – The User’s IP address

    – The User’s computer connection identifiers

    – The iD or unique identifiers of the User’s devices, their characteristics as well as those of the software they are equipped with (such as their type and configuration),

    – Connection data,

    – Statistics on the pages displayed,

    – Forwarding URLs,

    – Standard information on Internet connection logs.

    Thirdly, TRACE GLOBAL processes the data it collects via cookies and other tracers:

    What are cookies and other tracers?

    Cookies or other similar trackers are files deposited during the consultation of a site, a mobile application or an online advertisement and stored in a specific space on the hard disk of the User’s computer or mobile device.

    Cookies allow status information to be sent when a User consults a site. Status information can be, for example, a session ID, language, expiration date, response area, etc. Cookies are managed by the User’s web browser or the mobile application they use and only the sender of a cookie can decide whether to read or modify the information contained therein.

    Cookies have several functions, such as enabling the User to navigate efficiently on a site or mobile application and/or to optimise its operation, to remember his choices, to offer him relevant advertising content according to his centres of interest expressed during navigation.

    There are different types of cookies:

    – Functioning cookies,

    – Cookies related to targeted advertising operations,

    – Some audience measurement cookies,

    – Cookies from social networks generated in particular by their share buttons when they collect personal data without the consent of the persons concerned.

    The installation of cookies is subject to the User’s consent. During his first visit to the site or application, an information banner is displayed indicating that by continuing his navigation on the site, he will be able to choose which cookies will be installed on his equipment. The User must necessarily consent to the installation of certain cookies in order to continue browsing on the site, these are called operating cookies. If the User consents in accordance with the Terms and Conditions brought to the attention of TRACE GLOBAL, he may however at any time reconsider his choices in accordance with the terms and conditions described in the paragraph below “How to deactivate cookies”.

    SDKs (Software Development Kit) are programming assistance tools offered to editors and developers of mobile applications. SDKs may have various functionalities. Some allow you to debug or debug mobile applications. Others, to detect and analyse application crashes. Finally, some are used to analyse the audience and user behaviour on applications in order to measure the popularity of the application, or to broadcast advertisements.

    What cookies does TRACE GLOBAL use?

    Provided that the User is not opposed to it, the cookies and tracers used on the Site are:

    • lang (language)
    • facebook.com;
    • twitter.com;
    • LinkedIn
    • Didomi (consent management)
    • Google Analytics (Google)
    • Firebase (database management)
    • Google Tag Manager (Google)

    Provided that the User is not opposed to it, the cookies and tracers used on the Application are:

    • Sessionid (system)
    • Csrftoken (system)
    • completedAssessmemt (user flow management)
    • assessmentData (pedagogical follow-up)
    • language
    • preassessment-seen (user flow management)
    • username (system)
    • accessToken (system)
    • loggedIn (system)

    Why does TRACE GLOBAL use cookies and other tracers?

    TRACE GLOBAL and its Service Providers use, if the User has consented, cookies and other technologies for various reasons. Cookies and other technologies enable TRACE GLOBAL among other things to authenticate the User, in particular when he is connected to the website and/or the application in order to provide him with the Trace Academia service, to facilitate his access to the said service (TRACE GLOBAL offers the User to remember him each time he connects), to measure the audience of these advertisements and the frequency of the Site or the Application (number of pages viewed, number and frequency of visits), to enable TRACE GLOBAL to provide and analyse its services, to identify its users more precisely, to better define their interests, and to target its advertisements and marketing campaigns.

    How to deactivate cookies?

    The User has several options for deleting cookies and other tracers:

    Set up his browser settings:

    The recording of a cookie in the User’s terminal is subject to his will, which he can express and modify at any time and free of charge through the choices offered by his browser software.

    The User has the possibility of choosing to accept all cookies or to reject them systematically, or to choose which ones he wishes to accept depending on their originators. The User may also set their browser to accept or reject cookies on a case-by-case basis prior to their installation. The User can also regularly delete cookies from his terminal via his browser. The User must not forget to set the parameters of all the browsers of his different terminals (tablets, smartphones, computers, etc.). The configuration of each browser is different for the management of cookies and its choices. It is described in the help menu of his browser, which will allow him to know how to modify his wishes in terms of cookies.

    Cookies or tracers enable you to take full advantage of the Site’s functionalities. If the User’s browser is configured to refuse all cookies or tracers, this may prevent the use of some of Trace Academia’s services, for which the Publisher cannot be held responsible.

    In order to manage cookies and trackers as closely as possible to the User’s expectations, the User is advised to set up his or her browser taking into account their purpose.

    Deactivate cookies and other tracers deposited by third party publishers:

    The User may choose to deactivate cookies and other tracers deposited by third party publishers by going directly to their sites. Cookies or trackers deposited by social networking sites are their sole responsibility. The User can consult the confidentiality conditions of each of these sites on their own page.

    How long do cookies last?

    The lifetime of cookies is 13 months maximum. At the end of this period, TRACE GLOBAL must again obtain the consent of the User.

    Persons concerned

    The data processing only concerns persons who wish to benefit from the Trace Academia service and/or Trace Group’s commercial offers and/or Trace Group’s newsletters.

    Recipients of the data

    Recipient categories

    TRACE GLOBAL shares the User’s data for various purposes with third parties as described below:

    – To the Trace Ecosystem: TRACE GLOBAL shares User’s data with Trace Ecosystem companies for the purposes of processing and storing User’s data, providing User access to services, providing customer support, making decisions regarding service improvements and content development, and for other purposes as described in the Use of Data section of this Privacy Statement,

    – Trace Service Providers: TRACE GLOBAL uses other companies, agents or subcontractors (“Service Providers”) who perform certain services on behalf of TRACE GLOBAL or who assist TRACE GLOBAL in providing the services to the User. For example, TRACE GLOBAL works with Service Providers in the area of IT services, to personalise and improve the service and to process and administer consumer surveys. In the course of providing these services, these Service Providers may access the User’s personal data or other data concerning the User. TRACE GLOBAL will not allow them to use or disclose the User’s personal data, except when such use is in the context of providing their services,

    – As part of the protection of TRACE GLOBAL and its Service Providers : TRACE GLOBAL and its Service Providers reserve the right to disclose and otherwise use your personal and other data when they believe in good faith that it is necessary to (a) comply with any law, regulation, legal process or government request, (b) enforce applicable terms of use, including for the purpose of determining possible violations of these conditions, (c) to detect, prevent or deal with illegal or suspected illegal activities (including payment fraud), security breaches or any technical problems, or (d) to guard against any infringement of the rights, property or safety of TRACE GLOBAL, its users or the public, where required or permitted by law,

    – As part of a business transfer: whether as part of a reorganisation, restructuring, merger, sale or any other type of asset transfer, TRACE GLOBAL shall transfer all its data, including your personal data, provided that the receiving party agrees to respect such personal data in accordance with the TRACE GLOBAL Privacy Policy,

    – In the context of information sharing, when TRACE GLOBAL transfers personal data to countries outside the European Economic Area and other regions with data protection legislation, TRACE GLOBAL ensures that such transfers are made in accordance with this Privacy Policy and in compliance with applicable data protection legislation.

    Transfer of data outside the European Union

    Personal data may be transferred to partners of TRACE GLOBAL outside the European Union who provide sufficient and appropriate guarantees regarding the protection of the User’s personal data.

    Access to your account and profiles

    In order to make it easier for the User to access his account and to simplify the management of the Trace Academia service, we use technologies that allow him to identify himself as the account holder and provide him with direct and simplified access to his account without having to enter a new password or other means of identification when he returns to the service. Whenever possible, users of public or shared devices are strongly encouraged to disconnect and deactivate their device systematically at the end of each visit. If the User sells or makes a computer or device compatible with the Trace Academia service, it is imperative that the User disconnects and deactivates the device beforehand. Otherwise, if he does not keep his password or device secure, or if he does not disconnect and deactivate your device, other users may have access to your account, including your personal data.

    If the User shares his or her account or allows others to access it, these people will be able to see your information, including in some cases the User’s personal data, such as account information (your email address, among others).

    Legal age to use the service

    Access to the Trace Academia service is reserved for people above 14 years. Minors under 15 years old may use the service, but only with the agreement and under the supervision of a parent or a legal representative.

    Data retention period

    TRACE GLOBAL retains your personal data for a period of three years from the last use of the Trace Academia service.

    If you have also consented to receive our commercial offers we retain your data for a period of three years after the last commercial solicitation that we sent you and which remained unanswered by you.

    If you have also consented to receive our newsletters, we will keep your data for as long as you do not unsubscribe (via the unsubscribe link in the newsletter).

    Security

    .Site belonging to Trace

    In order to guarantee the security of the User’s data, TRACE GLOBAL has in particular adopted the following measures to prevent personal data from being distorted, damaged or accessed by unauthorised third parties:

    – The protection of physical access to the premises in which the data is stored (secure building);

    – The implementation of a user authentication process using individual passwords;

    – Processing is carried out on a dedicated internal network not connected to the Internet.

    .Sites belonging to third parties

    Links on the Site or the Application may take you to external sites.

    The personal data protection policies of these sites may differ from this policy.

    Consequently, it is recommended that you read the personal data protection policy of each of the sites concerned.

    In any event, we cannot be held liable in the event that the content of one of the sites concerned contravenes the legal and regulatory provisions in force.

    Changes to this Privacy Policy

    This Privacy Policy may be modified or amended at any time.

    You are invited to consult it regularly.

    User’s choice

    If the User no longer wishes to receive certain types of messages and communications (commercial offers, newsletter, events) from TRACE GLOBAL, simply click on the “Unsubscribe” link in the e-mail or reply STOP (or the indication received in the message) to the SMS. Please note that you cannot unsubscribe from some of our communications, including messages regarding transactions related to your account.

    You may opt to receive Push Notifications from TRACE GLOBAL. If you later decide that you no longer wish to receive these notifications, you can disable this feature at any time through your mobile device settings.

    To make your choices regarding the cookies used on our website as well as other types of tracking and online advertising, see the section “Cookies and Online Advertising” (below).

    User Rights

    The User may request access to his or her personal data, modify or update them when they are incorrect or out of date. The easiest way to do this is through the “My Account” section, from which the User will be able to view and edit a wide range of account information, including contact details and payment information. He or she will be asked to identify himself or herself in order to access this “My Account” section. The User will also be able to refer to the “Your choices” section in this Privacy Policy for additional options regarding his or her personal data.

    The User will also have the possibility to ask TRACE GLOBAL to delete his/her personal data if it is no longer necessary for the service or for other legitimate reasons. To do so, or if the User has any other questions regarding the privacy practices of the Trace Academia service, the User may write to dpo-trace@trace.tv.

    If the User considers, after contacting TRACE GLOBAL, that the rights to his/her data are not respected, he/she may address a complaint to the CNIL on the CNIL website or by post by writing to : CNIL – 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.

    Last modification :02/23/2021

    In case of translation, the French version shall prevail.