Do you speak Jeun'Est personal data management policy
The Do you speak Jeun'Est platform wishes to develop a relationship of trust with its users, both adults and minors.
We remind you that the law sets the age of numerical consent at 15 years of age. In accordance with Article 7-1 of Law No. 18-17 of 6 January 1978 on computers, files and freedoms, a minor from the age of 15 may independently consent to the treatment of his or her personal data.
The personal information you share with us is kept secure to provide you with the best possible service.
The purpose of this personal data protection policy is to inform you about how we process your data.
1. Name and address of the entity responsible for data processing
The entity responsible for the processing of your data, within the meaning of the data protection regulations, is the Ile-de-France Region, whose head office is located at 2 rue Simone Veil, in Saint-Ouen (93400), available for the purposes of this document at the following email address:
2. Name and address of the data protection officer
The Ile-de-France Region has appointed Lexing Alain Bensoussan Avocats as an outsourced personal data protection officer, who can be contacted at the following postal address:
A l’attention du Délégué à la protection des données, Région Ile-de-France, Pôle Transformation Numérique, 2 rue Simone Veil, 93400 Saint Ouen
Or
At the following email address: dpo@iledefrance.fr
3. Purposes of the data processing
The collected data are used to follow the learning experience of the learners, that is to say all Ile-de-Paris residents aged 15 and above, and evaluate this service.
No data is used for commercial, advertising or marketing purposes.
The treatment of data also pursues the following secondary objectives:
- To make sure that the User is in the Ile-de-France Region during the registration thanks to the recognition of his or her IP address at the first connection;
- To Identify the user's department of residence by the entering of his or her postal code;
- To ensure the pedagogical follow-up of learners via the creation of a user profile by means of a username identification, and to enable reminders snet by email;
- To adapt the content and ensure that the User is at least 15 years old, by collecting data on the age group;
- To adapt the content to users by collecting their professional category, activity sector and learning motivations;
- To follow the progress of the learners through the transmission of an anonymous satisfaction survey.
4. Legal basis of the processing of data
We use your data only on the basis of your consent regarding the monitoring of users' learning experience, the collection of your emails via the Citizen Relationship Management (CRM) system, the receipt of the newsletter, and the reception an anonymous satisfaction survey.
We use your data only for the execution of a contract regarding the free availability of a foreign language learning platform for people over 15 years of age.
5. Procedures for processing of personal data
Only representatives of the Ile-de-France Region and the service providers it uses - listed below - have access to your data in order to send you the newsletter, to reply to the messages sent via the contact form of our Site, to transmit to you the anonymous satisfaction survey, to take into account your complaints, to follow up on your learning, and to contribute to the creation of a Unique Contact Reference System (RCU) within the framework of the Citizen Relationship Management (CRM) and to offer you the best possible service.
Access to your data is shared solely with the following entities:
HUMENSIS SA, in charge of pedagogy.
170 bis boulevard Montparnasse - 75014 Paris, France
Telephone: 01 55 42 84 00
ENTERTAINMENT LEARNING SAS, Technical Team Leader
75 rue de Lourmel - 75015 Paris, France
GLOBAL EXAM SAS, which prepares for language certifications.
53 rue Fénelon - 92120 Montrouge, France
Phone: 07 71 77 40 45
PANISERO SAS - Testapic, in charge of the functional audit of the platform.
100 rue de la Folie Mericourt - 75011 Paris, France
Telephone 01 47 00 92 86
ACCESS42, in charge of the accessibility audit of the platform.
102, rue des Poissonniers - 75018 Paris, France
Telephone: 09 72 45 06 14
LinkedIn, which enabled users to register on the platform.
37 rue du Rocher - 75008 Paris, France
MATOMO, which allows the analysis of the Site audience.
Personal data is stored by the Ile-de-France Region on its servers for the purpose of processing it for the provision of the Services. It is kept only for the duration necessary for the purposes of its collection, ie for three (3) years, before deletion.
When we collect additional personal data, you will be notified by email. The General Terms and Conditions of Use, Legal notices, as well as the Personal Data Management Policy will be modified and adapted accordingly.
6. Data processing hypotheses
6.1 Your user account
By creating a user account on the Do you speak Jeun'Est Site, the User accepts the terms of the contract as provided for in the General Terms and Conditions of Use for the processing of his or her data. These are used to allow the User to take full advantage of the services and features offered by the Website.
When you create a user account on our Site, the following data is recorded in order to perform the requested service (ie, learning one or more foreign languages):
- Gender,
- Postal code,
- The age group (15-25 years old, 26-59 years old, over 60 years old),
- The professional category,
- The area of the activity,
- Login data (username, password, e-mail, IP address at the first connection),
- Data from third-party applications at first connection
(LinkedIn)
- The language proficiency level,
- Learning motivations,
- Online dashboards to analyze the performance of the service.
We use the data collected as part of the creation of a user account, solely on the basis of the execution of a contract.
6.2 Receipt of our satisfaction survey
An anonymous satisfaction questionnaire will be sent by e-mail every 6 months to any active learner during the period of the previous 6 months.
This questionnaire will focus on the user's feeling of progress towards achieving mastery of the language in real life situations.
Your personal data is collected to analyze the performance of the service. It is kept for three (3) years from its collection, then permanently deleted.
The data collected as part of the satisfaction survey is used only on the basis of your consent.
6.3 The receipt of our newsletter
In order to receive our newsletter, you must indicate your email address. The processing of this data is based on your consent and is only intended to keep you informed of our news.
For the processing of these data, your consent is requested when you register, and is followed by a confirmation procedure. A reference to this data protection policy is also made.
We send our newsletter via HUMENSIS SA, located at 170 bis boulevard Montparnasse - 75014 Paris, France, with an appropriate level of data protection. You will find further information on the processing of data by HUMENSIS by writing to the following e-mail address: dpo@iledefrance.fr
You can unsubscribe from our newsletter at any time by clicking on the "unsubscribe" link at the bottom of each email that we send you, or by sending an email to info@qioz.fr
We keep your personal data only for the duration necessary for the purposes of their collection, ie for three (3) years, before their definitive deletion.
We use the data collected in our newsletter only on the basis of your consent.
6.4 Communication via the contact form
A contact form is placed on our website, enabling you to communicate with us.
To this end, you must indicate your title, last name, first name and email address and the subject of your request. The accuracy of your address and phone number, or any other data in the body of the message, is optional.
We draw your attention to our privacy policy when entering your message on our Site.
The data processed in this context is done with your consent and so that we can answer any questions you may have.
Your personal data is deleted as soon as it is no longer essential for the purposes of its collection, or when the circumstances allow a conclusion with certainty that the subject of our exchange is definitely clarified.
The data collected as part of the contact form is used only on the basis of the execution of a contract.
6.5 Complaints
For the processing of user requests, we use the company HUMENSIS SA, located at 170 bis boulevard Montparnasse - 75014 Paris, France, which manages e-mails and organizes their processing.
HUMENSIS processes the names, content and technical information of the communication. This takes place as part of an on-demand data processing with an appropriate level of data protection. You will find further information on the processing of data by HUMENSIS by writing to the following e-mail address: dpo@iledefrance.fr
Any complaints may be sent to us by sending an email to info@qioz.fr
To this end, you must indicate your title, surname, first name and email, as well as the subject of your request. The accuracy of your address and phone number, or any other data in the body of the message, is optional.
The data processed in this context is done so with your consent and so that we can answer any questions you may have.
Your personal data is deleted as soon as it is no longer essential for the purposes of its collection, or when the circumstances allow the conclusion with certainty that the subject of our exchange is definitely clarified.
We use the data collected as part of your claims only on the basis of the performance of a contract.
6.6 Follow-up of your learning
We also send you e-mails related to your activity on our platform (confirmation and follow-up e-mails), through the service provider HUMENSIS SA, located at 170 bis boulevard Montparnasse - 75014 Paris, France.
HUMENSIS manages the emails of the users and organizes their processing.
HUMENSIS executes, on our behalf, the content and technical aspects of this communication. This takes place as part of an on-demand data processing with an appropriate level of data protection.
You will find more information about data processing
by HUMENSIS by writing to the following email address: dpo@iledefrance.fr
We keep your personal data only for the duration necessary for the purposes of its collection, ie for three (3) years, before its definitive deletion.
The data collected as part of the learning follow-up is used only on the basis of your consent.
6.7 Collecting your emails as part of Citizen Relationship Management (CRM)
Your e-mails are sent to the controller of the CRM system put in place by the Ile-de-France Region.
The Ile-de-France Regional Council's CRM project, implemented on 23 January 2019, has as its main purpose the creation of a Unique Contact Reference System (RCU).
It also pursues the following sub-goals:
- Unification in a repository of personal data held by the Region
- The definition of a single data format for the Region
- The possibility for any future internal or external data source to feed into and enrich the RCU based on the single data format;
- Obtaining the consent of Ile-de-France residents for the use of their personal data with the establishment of a preference center, allowing them to manage their data and their subscriptions to the proposed topics, or even to completely unsubscribe;
- The use of RCU data via a multichannel campaign manager to optimize communication with Ile-de-France residents according to the needs of the service (marketing fatigue, costs, relevant targeting ...);
- The production of dashboards to monitor the effectiveness of communication actions and better understand the data;
- The updating of the source databases with the RCU data by feedback flows to be implemented according to data governance to be defined by management.
We keep your personal data only for the duration necessary for the purposes of its collection, ie for three (3) years, before its definitive deletion.
We use the data collected as part of the CRM only on the basis of your consent.
7. Data security
We implement technical and organizational measures to protect your data, such as setting up physical security and access control procedures.
We require our agents and all third parties working for the Region to adhere to strict work practices in the areas of security and information protection, including contractual obligations under which they undertake to maintain confidentiality of data. and apply rigorous data transfer measures.
The data collected as part of the Do you speak Jeun'Est learning platform are not transferred outside the European Union.
8. Confidentiality
Your personal data is used by our representatives for the proper performance of the services you have requested and to strengthen and personalize the communication between our services and you.
We do not share your personal information with third parties, except for service providers specifically described in this policy. The communication of the data to our service providers occurs only for the specified purposes, if necessary.
We do not transfer or sell your information. We do not disclose any of your information unless we have your consent, or if it is required by law or regulation.
9. Your rights concerning the processing of your data
In accordance with the regulations on the protection of personal data, persons identified or identifiable by means of the data transmitted by the platform Do you speak Jeun'Est have the following rights:
- For the follow-up of users' learning, the right to access, rectify and erase their data, as well as the right to oppose or request the limitation of the treatment of said data
- For the provision of a foreign language learning platform for all Ile-de-France residents over the age of 15 years, a right of data access, rectification, opposition, limitation of treatment and portability.
To act upon these rights it is sufficient to make the request to the email address indicated in article 1 or to dpo@iledefrance.fr , by specifying your last name, first name and address and to accompany your request with proof of identity .
An answer to your request will be sent as soon as possible and within a maximum of thirty (30) days following receipt of the request.
In addition, persons identified or identifiable by means of the data transmitted by the Do you speak Jeun'Est platform have the right to lodge a complaint with a supervisory authority if they consider that the processing of their personal data constitutes a violation of the regulations on data protection, in accordance with Article 77 of the European Data Protection Regulation. You can file a complaint directly with the Commission Nationale Informatique et Libertés at the following address: https://www.cnil.fr/fr/plaintes/ .