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Privacy policy

IQ Factory privacy policy

Preamble

This website is operated by IQ Factory, a company with share capital of 1,000 euros, registered with the Paris Trade and Companies Register under number 834 673 469, with its registered office at 19 rue Richer, 75009 Paris (hereinafter referred to as "IQ Factory"). School of Data "or IQ Factory "or we "or our ").

This confidentiality policy (hereinafter the " Privacy policy "or the Policy This Privacy Policy ("Privacy Policy") describes how we collect and process Personal Data that we collect from you or that third parties lawfully provide to us. Please read the following carefully to understand the context in which we process your Personal Data.

As the Data Controller, we process your Personal Data in accordance with this Privacy Policy and with the provisions of French law no. 78-17 of 6 January 1978 on data processing, data files and individual liberties and the General Data Protection Regulation (RGPD) (hereinafter the "Data Protection Act"). Personal Data Regulations ").

By using and visiting the "schoolofdata.artefact.com" website (hereinafter the " Website By accessing our website, you agree to be bound by the terms of this Privacy Policy ("Privacy Policy") and/or by submitting your Personal Data to us, and/or by registering as a user of the services we provide, you are invited to read and accept this Privacy Policy.

A few definitions to help you understand our Privacy Policy: 

"Intermediate Archiving: means the removal of Personal Data that are still of administrative interest to IQ Factory, (such as in case of litigation) and/or in case of legal obligation, in a separate database, logically or physically separated and whose access is restricted in any case. This archive is an intermediate step before the Personal Data concerned is deleted or made anonymous.

"Personal Data Personal data: refers to personal data collected and processed by IQ Factory in the context of your use of our Site, in particular when you complete the registration forms for our training courses offered on the Site, and/or by contacting us directly by e-mail and/or telephone.

" Trainers Trainer": refers to the natural or legal person providing one of the training courses that we offer on our Site to Trainees via the tools that we make available.

" Financing organisations Trainee": refers to the legal entities that receive Trainees' Personal Data in order to analyse their files and guarantee or refuse to finance the training chosen on our Site on the basis of the information provided.

"Person Concerned" : means the natural person whose Personal Data is processed by IQ Factory, in particular Trainees, Trainers, Funding Organisations.

"Data controller" : means the person, whether natural or legal, who determines the purposes of the Processing and the means by which it is carried out.

" Subcontractor Processor": refers to the natural or legal person, public authority, department or other body that processes Personal Data on behalf of the Data Controller.

" Trainee Registrant": refers to the natural person wishing to register for one of the courses we offer on our Site.

"Treatment: means any operation or set of operations carried out by IQ Factory in its capacity as Data Controller on the basis of Personal Data collected from the Website or directly from IQ Factory.

  1. Why do we collect your Personal Data and how long do we keep it?

We collect your Personal Data when you browse the Site and when you fill out one of the forms on our Site, and generally in the context of your relationship with IQ Factory, under the conditions indicated below.

    1. To enable you to use the Site :

When you browse the Site, we collect browsing data through cookies under the conditions set out in Article 6 of this Privacy Policy. This Processing is based on IQ Factory's legitimate interest, for which your Personal Data is kept for the duration of your browsing on the Site.

    1. To send you our newsletter :

When you subscribe to our newsletter, we collect and process the following Personal Data: your first name, your last name and your e-mail address so that we can send you our newsletter by e-mail.

This Processing is based on your consent.

We keep your Personal Data for a period of three (3) years after your registration to the newsletter or after your last interaction with IQ Factory. At the end of this period, or once you have withdrawn your consent, your Personal Data may be kept in Intermediate Archiving for evidentiary purposes during the legal limitation periods.

    1. To manage and track your requests :

When you send us a message, request or complaint via the contact form, we collect and process your first name, surname, date of birth, e-mail address, telephone number and the content of the message you send.

This Processing is based on our legitimate interest in identifying the people who contact us. If you do not provide your Personal Data, we may not be able to process your message correctly or at all.

We only keep your Personal Data for the time necessary to respond to your message. At the end of this period, your Personal Data may be kept in Intermediate Archiving for evidential purposes during the statutory limitation periods.

    1. To enable you to apply for one of the courses offered on our website:

When you apply for a course offered by the School of Data on our Site, we collect and process the following Personal Data:

  • Your identification details: first name, surname, date of birth, telephone number, e-mail address;
  • Your Personal Data relating to your professional life: LinkedIn profile address, the content of the message you send to explain your career path and professional experience, your qualifications, your Pole Emploi ID, etc.
  • Your economic and financial information: pay slips (needed to finance your training if you are eligible), your bank details, various certificates (for example: certificate of payment of Pôle emploi daily allowances, certificate of notification of entitlement to unemployment insurance mentioning payment of the Aide aux Créateurs ou Repreneurs d'Entreprise, screen copy of the CPF account, jobseeker's certificate);
  • The way you got to know us.

All of your Personal Data is necessary for the Processing relating to the management of your application with a view to concluding the contract with IQ Factory (which serves as the basis for this Processing).

  • If your application is rejected

Your Personal Data is only kept for the duration of the processing of your application and is deleted once your application has been rejected and you have been informed of this.

  • If your application is successful

Your Personal Data is kept for the duration of the training provided by IQ Factory, including in the event that your training is not financed by a Funding Organisation and that you wish to finance it yourself.

At the end of this period, your Personal Data may be kept in Intermediate Archiving for evidential purposes during the statutory limitation periods.

    1. To follow your chosen course by distance learning

Your connection data collected during remote training sessions are processed by IQ Factory as part of the execution of your training contract with us.

Your connection data is kept in the active database for a period of one (1) year, after which it is deleted.

    1. For bookkeeping

Identification data and information of an economic and financial nature are processed as part of the management of invoicing and accounting (for example to enable IQ Factory to be paid by the Trainee and/or by the Funding Organisations or to pay the Trainers).

This Processing is based on a legal obligation, for which Personal Data is kept for the duration of the current financial year and then in Interim Archiving for a period of 10 years from the end of the financial year.

    1. For commercial relationship management

All Personal Data required to conclude a contract with the Person concerned (Trainee, Trainer) are processed as part of the commercial relationship with IQ Factory.

Personal Data is kept in an active database for the duration of the commercial relationship. At the end of this period, your Personal Data may be kept in Intermediate Archiving for evidential purposes during the statutory limitation periods.

    1. To maintain our QUALIOPI certification

IQ Factory holds QUALIOPI certification as a training organisation. As such, we are required to renew it every two (2) years by transmitting certain Personal Data to the authorised certification bodies, in particular the attendance sheets and CVs of the trainers.

This Processing is based on a legal obligation, for which Personal Data is kept for a period of one (1) year in the active database, then for a period of two (2) years in the Intermediate Archive.

    1. To exercise your rights under the terms of article 7

When you make a request for rights under the terms of article 7 - Your rights, we collect and process your e-mail address, your first name and surname and the content of your message, which we keep in an active database for the duration of the processing of the request. At the end of this period, your Personal Data may be kept for evidential purposes during the statutory limitation periods.

  1. Where do we store your Personal Data?

The Site is hosted by the company whose contact details are available at the following URL address: https://schoolofdata.artefact.com/mentions-legales

Every precaution has been taken to store your Personal Data in a secure environment and prevent it from being distorted, damaged or accessed by unauthorised third parties. Personal Data transmitted by you will never be passed on to third parties for commercial purposes, nor will it be sold or exchanged.

  1. To whom is your Personal Data transmitted?

The Personal Data collected from the Site and/or directly by IQ Factory are intended :

  • for the exclusive use of authorised in-house personnel,
  • to the various funding bodies for your training;
  • certification bodies authorised to issue Qualiopi certification;
  • as well as IQ Factory's subcontractors:
    • OVH is responsible for hosting the Site and your Personal Data, which is stored in the European Union,
    • Hubspot to manage the sending of the newsletter, to manage your requests sent via the contact form and to manage applications for our training courses;
    • Artefact SA, located in France, and in particular its HR team, which can manage your applications for our training courses;
    • Google Meet for remote training sessions;
    • Trainers.

As Data Controller, IQ Factory undertakes not to transfer Personal Data outside the European Union.

In the event that Personal Data would be subject to such a transfer, IQ Factory undertakes to implement appropriate safeguards, in accordance with the GDPR, and in particular to implement standard contractual clauses adopted by the European Commission in their current version.

  1. What happens when you click on a hypertext link?

Our Site may contain hypertext links to and from the websites of our partner networks, advertisers and affiliates.

If you follow a link to one of these websites, you will leave our Site. Please note that these sites have their own privacy policies which you should read before submitting any Personal Data to them.

  1. What cookies are used?

Cookies are text files, often encrypted, stored in your browser. They are created when your browser loads a given website: the site sends information to your browser, which then creates a text file. Each time you return to the same site, your browser retrieves this file and sends it back.

For more information about the cookies we use and how you can deactivate them, please consult our Cookies policy [hyperlink to be added to the cookies policy].

  1. How we ensure the security of your Personal Data ?

We attach great importance to the protection of your Personal Data.

On our Site, where you can actively enter data, we use encryption systems, such as SSL (Secure Socket Layer), to ensure the security of your Personal Data.

We use technical and organisational measures to secure our Site and other systems against the loss, destruction, access, modification or distribution of your Personal Data by unauthorised persons.

  1. What are your rights?

In accordance with the French Data Protection Act, you have the following rights at any time:

  • Access
  • Correction ;
  • Erasure ;
  • Limitation of a Treatment ;
  • Portability ;
  • Opposition ;
  • Post-mortem instructions.
    1. Access rights

You have the right to obtain from the School of Data confirmation as to whether or not your Personal Data is being processed and, where it is being processed, access to your Personal Data and the following information:

  1. the purposes of the Processing ;
  2. categories of Personal Data ;
  3. the recipients or categories of recipients to whom the Personal Data have been or will be communicated;
  4. where possible, the period for which Personal Data is to be kept or, where this is not possible, the criteria used to determine this period;
  5. the existence of the right to ask IQ Factory for the rectification or deletion of Personal Data, or a limitation of the Processing of its Personal Data, or the right to object to such Processing;
  6. the right to lodge a complaint with the CNIL;
  7. where Personal Data is not collected from the Data Subject, any available information as to its source ;
  8. the existence of automated decision-making, including profiling, and, at least in such cases, useful information concerning the underlying logic, as well as the significance and anticipated consequences of such Processing for the Data Subject;

Where Personal Data is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards with regard to this transfer.

IQ Factory provides a copy of the Personal Data being Processed.

IQ Factory may charge a reasonable fee based on administrative costs for any additional copies requested.

When you submit your request electronically, the information will be provided in a commonly used electronic format, unless you request otherwise.

The right to obtain a copy must not infringe the rights and freedoms of others.

    1. Rights of rectification

You have the possibility to obtain from IQ Factory as soon as possible, the rectification of the Personal Data concerning you which are inaccurate. You also have the possibility to obtain that incomplete Personal Data be completed, including by providing an additional declaration.

    1. Erasure rights

You have the possibility of obtaining from IQ Factory the deletion, as soon as possible, of Personal Data concerning you when one of the following reasons applies:

  1. Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed by IQ Factory ;
  2. You have withdrawn your consent to the Processing of this Personal Data and there is no other legal basis for the Processing;
  3. You have exercised your right to object under the conditions set out below and there is no compelling legitimate reason for the Processing;
  4. The Personal Data has been processed unlawfully;
  5. Personal Data must be deleted to comply with a legal obligation;
  6. The Personal Data has been collected from a child.
    1. Limitation rights

You have the possibility to obtain from IQ Factory the limitation of the Processing of its Personal Data when one of the following reasons applies:

  1. IQ Factory verifies the accuracy of the Personal Data following your challenge as to the accuracy of the Personal Data;
  2. The Processing is unlawful and you object to the deletion of the Personal Data and instead request that their use be restricted;
  3. IQ Factory no longer needs the Personal Data for the purposes of the Processing but they are still necessary for you to establish, exercise or defend your legal rights;
  4. You have objected to the Processing under the conditions recalled below and IQ Factory verifies whether the legitimate reasons pursued prevail over the alleged reasons.
    1. Right to data portability

You have the option to receive from IQ Factory Personal Data about you in a structured, commonly used and machine-readable format when:

  1. The Processing of Personal Data is based on consent or on a contract,
  2. Processing is carried out using automated processes.

When you exercise your right to portability, you have the right to obtain that your Personal Data be transmitted directly by IQ Factory to another Controller that it will designate when this is technically possible.

The right to port Personal Data must not infringe the rights and freedoms of others.

    1. Right to object

You may object at any time, for reasons relating to your particular situation, to the Processing of your Personal Data based on the legitimate interests of IQ Factory. IQ Factory will then no longer process the Personal Data, unless it can demonstrate that there are compelling and legitimate grounds for the Processing which override your interests and rights and freedoms or may retain them for the establishment, exercise or defence of legal claims.

    1. Post-mortem instructions

You have the possibility of communicating to IQ Factory directives relating to the conservation, the erasure and the communication of your Personal Data after its death, which directives can be also recorded near "a certified third of digital confidence". These directives, or a sort of "digital will", can designate a person in charge of their execution; failing this, your heirs will be designated.

In the absence of any directive, the heirs of the Person Concerned may contact IQ Factory in order to:

  • access Personal Data Processing for the "organisation and settlement of the deceased's estate";
  • receive communication of "digital assets" or "data resembling family souvenirs, which may be passed on to heirs";
  • oppose the continued Processing of his/her Personal Data.

In any case, you have the possibility to indicate to IQ Factory, at any time, that you do not wish, in case of death, that its Personal Data be communicated to a third party.

You may exercise these rights by contacting the School of Data at the following address

  • or by mail to IQ Factory C/O Artefact, 19 rue Richer - 75009 Paris, France, accompanied by a copy of a signed identity document and specifying the postal address of return.

IQ Factory has a period of one month from receipt of your request to respond.

If necessary, IQ Factory may extend this deadline by two months, taking into account the complexity and/or number of requests.

In case of request for deletion of your Personal Data and/or in case of exercise of your right to request the deletion of your Personal Data, IQ Factory may however keep them in the form of Intermediate Archiving, and this for the time necessary to meet its legal obligations, or for evidentiary purposes during the applicable limitation period.

Finally, you have the right to lodge a complaint with the competent supervisory authority, the Commission Nationale de l'Informatique et des Libertés (CNIL) in France, if you consider that a Processing concerning you does not comply with the Personal Data Regulations at the following address:

CNIL - Complaints department

3, place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07

Tel.: 01 53 73 22 22

  1. Who is our Data Protection Officer?

If you have any further questions about this Privacy Policy, please contact our Data Protection Officer :

Ydès Avocats

12, Cours Albert 1er

75008 Paris

France

privacy.schoolofdata@artefact.com

  1. What happens if changes are made to the Confidentiality Policy?

We may change this Privacy Policy from time to time by updating this page. Please check this page from time to time to ensure that you are aware of any changes. We will notify you of any significant changes.

This Policy was last updated on xxxx 2023.