PRADITUS PRIVACY POLICY


Introduction


As a Praditus user protection of your privacy and Personal Data is an important concern to which Praditus pays special attention throughout our business processes. This privacy notice is to let you know how Praditus looks after your personal information. This includes what you tell us about yourself, what we learn by having you as a user. This notice also tells you about your privacy rights and how the law protects you.

Praditus SAS (also known as, “Praditus”, or “we” or “us”) is committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU2016/679) 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”).


What is Personal Data?


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.

Special Category Personal Data Special category is any Personal Data which relate to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or sexuality and includes genetic data, and biometric data where processed to uniquely identify an individual (hereinafter referred as : ‘Special Category Personal Data’)


Which sources and what Personal Data do we use?


When you join Praditus as a user, we will collect, use and process any Personal Data you provide, such as the following categories of data:

  • Data of the civil register (_Name, First name, Year of birth... _)
  • Professional life (_Job profile, Position name, Company, Management position... _)
  • Qualifications and education data (degree, school, skills)
  • Data connection (logs activities)
  • IT identifiable data (Corporate ID, IP address, user account, login, browsing activity …)
  • Psychometrics data (personality, interests, motivation,...)

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


To provide efficient management of Praditus experience, we use your Personal Data for the following purposes such as:

1. Professional career management and Mobility

  • Performance and goals
  • Global mobility
  • Recruiting
  • Competence management
  • Qualifications and education

2. Development and Training management

  • Leadership University
  • E-Learning (MOOC, Rich Media, Virtual Classroom ,…)
  • Professional development

3. Security

  • Authorization monitoring
  • User management

4. Communication

  • Praditus social activities
  • Event management
  • Surveys
  • Newsletters

What is the basis for processing of 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 our 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:

  1. To comply with contractual obligations.

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.

  1. As a result of your consent.

When you have consented to the processing of your Personal Data by us for certain services through the Website, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at dataprotection@praditus.com. For further information on the right of withdrawal, please see below Section “Am I obliged to provide my Personal Data?”

  1. Within the scope of a legitimate interest.

On occasion we may not need your consent to use your data, given our legitimate interest to do so but we must inform you that we do this; examples of this are:

  • For the analysis and optimisation of the Website.
  • For ensuring IT security and the IT operation of Praditus.
  • For prevention and investigation of criminal acts.
  1. On the basis of Praditus' legal obligations or in the public interest.

Praditus, as any other company, is subject to legal obligations and regulations. In some cases the processing of your Personal Data will be necessary for Praditus in other to fulfil these obligations.


Who will receive your Personal Data?


  • Authorised persons working for or on behalf of Praditus;
  • Praditus SAS on a need-to-know basis for the purposes as outlined in this Privacy Notice;
  • Our agents, service providers and advisers (e.g. Third party service providers and advisers providing the variety of products and services we need such as IT maintenance and support, procurement services, compliance and security services, etc.);
  • Other authorised third parties in connection with a reorganisation or sale of Praditus businesses and/or assets;
  • Law enforcement or government authorities where necessary to comply with applicable law.

Will your Personal Data be transferred to a third country outside the European Economic Area (EEA)?


Praditus processes your Personal Data mostly in the EEA. On occasion Personal Data could be transferred to affiliates of Praditus, on a need-to-know basis, including entities outside the EEA. This transfer is subject to appropriate safeguards, and through the legal framework of our Binding Corporate Rules or through alternative contractual frameworks where a third party is engaged to help us providing web-services to you.


Which countries will Praditus transfer Personal Data to?


Our Binding Corporate Rules allow us to transfer Personal Data within our organisation, and they include a list of countries (below) which are structured to allow us to transfer Personal Datato the countries where we have a presence. For Praditus, France and Germany are where most of our processing of personal information takes place and below is a list of countries where Praditus could operate,

United Kingdom, United States of America.


How long will your Personal Data be stored?


We process and store your Personal Data for as long as is required to meet our contractual and statutory obligations. The retention of your Personal Data is determined by Data Protection Laws and Regulation and by our procedures or processes adopted in accordance with Data Protection Laws and Regulation.


Security


We use technical and organizational security measures in order to protect the data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorized persons. Our security procedures are continually enhanced as new technology becomes available.


What are your rights and how to exercise them?


You may at any time exercise your data protection rights:

  • Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by Praditus and if so, what specific data is being processed.

  • Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you.

  • Right to be forgotten: In some cases, for instance, when the Personal Data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your Personal Data to be erased.

  • Right to stop the processing of your data: You have the right to restrict the processing of your Personal Data by Praditus, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defense of legal claims.

  • Right to data portability: Under some circumstances provided by law, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller.

  • Right to object and to withdraw consent: please see below section “Am I obliged to provide my Personal Data?

To this effect, please contact Praditus in writing either by e-mail at the following address: dataprotection@praditus.com or by writing to the addresses below, enclosing a copy of a document evidencing your identity.

Praditus SAS, Head of Data Protection, 33 Rue Raffet, 75016, Paris. France


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


If you are unhappy with the way in which your Personal Data has been processed or should you have questions regarding the processing of your Personal Data, you may refer in the first instance to the Praditus Data Protection Officer, who is available for enquiries or complaints, at the following email address:

dataprotection@praditus.com or you can write to the address below:

Praditus SAS, Head of Data Protection, 33 Rue Raffet, 75016, Paris. France


Can I ask for assistance to the competent authorities?


If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority.

FRANCE: CNIL: Supervisory Authority France


Cookies


Certain Praditus portals and apps contain cookies. Cookies are small files that may be downloaded on your device when you access and use some of our web applications. They allow to recognise your device and store information about your preferences or past actions. We use cookies to record the preferences of our users, to enable us to optimise the design of our web applications. They ease navigation, and increase the user-friendliness of websites and applications. Cookies also help us to identify the most popular sections of our IT solutions. This enables us to provide content that is more accurately suited to your needs, and in so doing improve our service. You can prevent cookies from being stored on your device by setting your browser to not accept cookies. The exact instructions for this can be found in the manual for your browser. You can delete cookies already on your device at any time. However, if you choose not to accept cookies that are strictly necessary for the provision of our services provided by our Website, it may result in a reduced availability of such services.


Modification of the Privacy Notice


Praditus will update this Privacy Notice from time to time in order to reflect the changes in our practices and services and also to remain compliant to Data Protection Laws and Regulations. We will inform you of any substantial modification in how we process your Personal Data.


Last Update


June, 26th 2018