Praditus Data Privacy Policy

Introduction

Protecting your privacy as a Praditus user and keeping your personal data confidential are important concerns that Praditus pays close attention to in all its business processes.

This Policy for protecting personal data (referred to as the “Policy”) aims to inform you about how Praditus manages your personal information. This information includes self-reported information as well as what we have learned about you as a user. This Policy also informs you about your rights to privacy protection and the protections provided by the law.

Praditus promises to hold to these two fundamental principles:

• You are in charge of your personal data;
• Your data are always treated transparently, confidentially, and securely.

Your personal data are collected and processed by PRADITUS, a simplified joint-stock company, registration number 801 284 563 with the Paris company and trade register, headquartered at 10 rue de Penthièvre 75008 Paris.

PRADITUS is thus responsible for the processing of the personal data carried out as part of the operations of the site it publishes.

PRADITUS (also designated as “Praditus” or “we”) is committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU 2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred as: “GDPR”) as well as each applicable national Personal Data protection laws and regulations (collectively referred as “Data Protection Laws and Regulations”).

This Privacy Notice will inform you of the Personal Data we collect when you use tools like:

• Praditus self-awareness;
• Praditus 360 feedback;
• Praditus Team Dynamics;
• Praditus online courses;
• Praditus hybrid courses with a coach;
• accessing online resources on Praditus.

It also will inform you on how we use and disclose your Personal Data; how you can control the use and disclosure of your Personal Data; and how we protect your Personal Data.

What is Personal Data?

Personal Data is information that can be used to identify a person either directly or indirectly (hereinafter referred as: “Personal Data”). A “personal identifier” is a piece of information that can identify an individual. This definition covers a wide range of personal identifiers to constitute Personal Data, including name, address, email address, identification number, location data or online identifier.

There are special categories of personal data that are similar to personal data in that they could be used to identify a unique natural person: data on ethnic or racial origin, political opinions, religious or philosophical beliefs, union membership, health status, sexuality, or genetic or biometric information (hereafter designated as “special category data”).

Praditus DOES NOT COLLECT any individual information that is sensitive or belongs in a special category.

Which sources and what Personal Data do we use?

We will collect, use and process Personal Data you provide, such as:

• identity data (first and last names);
• professional data: email address, Corporate ID, Company Code;
• skills and academic background (degrees, school, skills);
• login and online data as well as data involved in the management and security of your account (IP addresses, connection logs);
• your behavioral and personality profile (for the self-awareness profile);
• your 360 report (360 Instant Insight, results summary and feedback);
• data on the business relationship: information requests and logs of interactions with Praditus departments.

We specify whether each piece of personal information is required or optional when it is collected.

What are the purposes of the processing of your Personal Data?

We use your personal data to provide an online self-awareness, courses and 360 feedback solution, available to all users, in order to gain a first level of self-awareness and development. Praditus will collect and process your personal data for the following purposes (hereinafter referred as: the “Purposes”):

• Generate self-awareness report
• Facilitate your coaching sessions
• Request feedback about your professional relationship. The request is of your free will and the feedback report is accessible only by you, the requester, and belongs only to you;
• Allow coworkers to give anonymous feedback about yourself;
• Generate anonymous statistics.
• To improve your employability
  • Performance and objectives
  • Competency management
• To develop and manage training programs
  • E-learning
  • Professional development
• Research
  • For academic publications
  • For partnership with universities or research laboratories
• To ensure security for all users
  • Authorization checks
  • User management
• To communicate with you
  • Praditus social activities
  • Event management
  • Surveys
  • Newsletters

Your Personal Data may also be used for the following purposes:

• Legal compliance: we use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request.
• To protect us and others: where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.

If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you the relevant privacy information notice.

What is the basis for processing your Personal Data?

As a responsible company, we need a lawful basis for collecting and/or processing your data. We generally rely on a number of grounds (reasons) for business processing.

We process your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data are:

• To comply with contractual obligations. We process your Personal Data as part of the performance of the employment contract to which you are a party in order to complete respective contractual obligations with your company. When you subscribe to a particular service through the Website, the purposes of processing your Personal Data are primarily determined by that service and we will process your information so that we can provide that service to you.
• Within the scope of a legitimate interest. On occasion, taking into account the minimum privacy impact for you, the processing of your personal data might be necessary for the following legitimate interests:
  • the analysis and optimization of the Website;
  • ensuring IT security and the IT operation of Praditus;
  • improving employee management;
  • the prevention and investigation of criminal acts.

Who will receive your Personal Data?

Your identity and professional data (excluding your self-awareness profile and 360 report) will be shared with:

• our authorized staff in our marketing, sales, administrative, logistics, and IT departments who are responsible for client relations and prospecting as well as site monitoring;
• our internal departments and subcontractors providing the variety of products and services needed such as IT maintenance and support, and compliance and/or security departments in case of such issue arising;
• our research team and affiliate researchers, in an aggregated and anonymized form;
• law enforcement or government authorities where necessary to comply with applicable law;
• third parties that might set cookies on your devices (computers, tablets, mobile phones) with your consent.

The following data you have entered could be made accessible to help other people find you on Praditus (for example for the 360-Feedback tool or Team Dynamics): first name, name and email address.

The self-assessment, the tests related answers, results and reports, will not be shared, transmitted, or disclosed further to your organization nor any of its employees and/or managers nor to any third party without your prior consent. Subject to the above, Praditus hereby confirms that these data will only be made available to you. However, of course, you are entitled to share these data with whomever you think appropriate.

Praditus processes your personal data only within the European Economic Area (EEA). Praditus is hosted in AWS (certified ISO 27001), Frankfurt Germany, and is headquartered in Paris, France.

Data transmission is subject to the appropriate data protection rules and occurs within the legal framework of our binding corporate rules or within a contractual framework in which a third party helps us in providing you with web services.

That being said, our binding corporate rules authorize us to transmit personal data within our company.

How long will your Personal Data be stored?

We only save your data long enough to provide the services we offer, unless the law demands that your personal data be stored in a different manner.

We thus store your account/profile data for a maximum of 3 months from the closing of your account unless the law demands that some of your data be stored for a shorter duration.

The cookies set on your browser expire within 30 days.

Notwithstanding, your data may be saved and archived for an additional period of time to manage any ongoing complaints or litigation as well as to comply with legal and/or regulatory obligations and/or to comply with requests from authorities with the right to make these requests.

The retention of your Personal Data is determined by Data Protection Laws and Regulations and by our procedures or processes adopted in accordance with Data Protection Laws and Regulations.

Data security

We implement technical and organizational security measures to protect the data entrusted to us, protecting it especially from becoming distorted, damaged, or accessed by unauthorized third parties. We take all necessary precautions given the nature of your data and the existing risks against its accidental or malicious manipulation, loss, or destruction.

Our security procedures are continuously updated as new technologies develop.

Data rights

It should be noted that as part of the processing of your data and in compliance with the provisions of the law and the GDPR, you have the following rights:

• Right of access (article 15 of the GDPR): you have the right to obtain confirmation as to whether your personal data are being processed by Praditus. If they are, you have the right to know exactly which data are being processed.
• Right to rectification (article 16 of the GDPR): you have the right to change any incorrect personal data about yourself.
• Right to erasure (article 17 of the GDPR): in some cases, for example, when your personal data are no longer needed for the purposes for which they were collected, you have the right to erase your personal data.
• Right to restriction of processing (article 18 of the GDPR): you have the right to restrict Praditus’s processing of your personal data, if, for example, this processing is unlawful, and to oppose this processing by requesting the erasure of your personal data. In these cases, your personal data will not be processed unless you provide consent or within the exercise or defense of legal claims.
• Right to data portability (article 20 of the GDPR): in some circumstances defined by the law, you have the right to receive your personal data in a structured, commonly used, and machine-readable format and/or to transmit these data to another data controller.
• Right not to be subject to a decision based solely on automated processing, including profiling (article 22 of the GDPR).
• Right to object (article 21 of the GDPR): you have the right to object to the processing of your data and to revoke your consent at any time.

To exercise these rights, please contact Praditus, either by email at dataprotection@praditus.com or by post, enclosing a copy of a proof of identity (Praditus SAS, Data Protection Manager, 10 rue de Penthièvre 75008 Paris, France).

If the answers provided do not provide satisfaction, you have the right to file a complaint with the National Commission on Informatics and Liberty (CNIL), the French regulatory body responsible for enforcing regulations related to personal data.

All the rights listed here are personal and may not be exercised by anyone other than those people who have provided their data to Praditus.

How can I contact Praditus in respect of my Personal Data?

If you want to exercise your rights, if you are unhappy with the way in which your Personal Data has been processed or should you have any questions regarding the processing of your Personal Data, you may refer in the first instance to the Praditus Data Protection Officer, who is available at the following email address: dataprotection@praditus.com. You can also write to the address below:

Praditus SAS, Data Protection Manager, 10 rue de Penthièvre 75008 Paris, France

Under certain circumstances, when some Personal Data is necessary to enter into a contract or to comply with a legal obligation, any failure to provide the requested Personal Data may result in us not being able to fulfill our contractual/legal obligations or to achieve the expected results.

Can I ask for assistance from the competent authorities?

If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the four main European countries where Praditus operates and the relevant Supervisory Authority:

• France: CNIL, Supervisory Authority France
• Germany: any competent regional German authority as the case may be
• Spain: AEPD, Supervisory Authority Spain
• United Kingdom: ICO, Supervisory Authority UK

Cookies

A cookie is a text file stored in your device through your browser.

Cookies allow their sender, and only the sender, to identify the device it was stored on. While they are active on your computer, cookies cannot be used to run programs or spread viruses.

We use cookies and other similar technologies to help you navigate through the Site, use the Site’s main features, directly access your personal spaces on the Site using login information or data that you potentially gave us previous access to, adapt the Site’s display to your device, and carry out statistical analyses. Cookies thus allow us to optimize the design of our web applications and make our Site and our applications more user-friendly, in order to provide content that meets your needs and improve our services.

You may accept or reject cookies. Most browsers automatically accept cookies, but if you prefer, you can generally change your browser settings to reject cookies. If you choose to reject cookies, you may not be able to make full use of the Site’s features.

You can configure your browser so that:

• cookies are either stored or blocked, whether for all sites or only certain sites;
• you are occasionally asked whether to accept or reject cookies before they are stored on your device;
• cookies stored on your device may be deleted at any time.

Every browser has a different configuration for managing cookies. The procedure is described in each browser’s help menu and can also be found at the following websites, provided for information purposes only:

• Manage cookies in Chrome
• Manage cookies in Firefox
• Manage cookies in Internet Explorer
• Manage cookies in Safari

Please find below a table with specific information for each cookie that we may use on our Praditus tools:

Name of the cookie	Purpose	Retention period
PRADITUS	Authentication	30 days

Modification of the privacy policy

We can occasionally and at any time make changes to this Policy, especially when we update our services and/or when the regulations in force require it; we will inform you of this change through a mention on the Site or another means.

In any case, we recommend that you regularly check the Policy in order to obtain the latest information on our privacy practices.

The most recent version of the Policy is the one released on the date indicated at the end of this document.

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Last update: February 23rd, 2026