Privacy statement
Updated:
Our company (hereafter “GlobalExam”), as data controller, attaches particular importance to the protection of your personal data (hereafter “Personal Data” or “Data”), as defined by EU Regulation 2016/679 related to the protection of Personal Data and by French Act no. 78-17 of 6th January 1978 amended, so-called “IT and Freedom Act” (hereafter referred to together as the “Regulations”).
The Privacy Statement below details GlobalExam’s policy in terms of personal data and cookies for all activities taking place on the www.global-exam.com website and on the GlobalExam e-learning platform (hereafter referred to together as the “Website”).
This Privacy Statement applies to all information provided by you to GlobalExam or collected by the latter when you browse the Website. It sets forth our methods of collection, use, conservation, disclosure and protection of the Personal Data. It applies to all browsing on the Website.
By providing us with your information and personal data, you give us your consent to process them in accordance with the terms and conditions defined below and in particular to personalise and optimise your browsing on the Website and to provide you with offers that meet your requirements.
You are asked to read through this Privacy Statement very carefully along with the various notifications that may be communicated to you when collecting the Data, in order to be fully informed about the collection and uses of your Personal Data.
1. General information
When using the Website, you may be required to provide your Personal Data to GlobalExam in particular when creating an account on the Website, placing an order or signing up to receive our newsletter.
Furthermore, GlobalExam may be required to collect certain information related to your browsing on the Website. This collection is performed in accordance with the terms and conditions set forth in article 5 “Cookies” of this Privacy Statement.
2. Right to access, rectify, erase and object to processing
In accordance with articles 15 to 22 of the General Data Protection Regulation of 27th April 2016, related to the protection of private individuals with a view to the processing of personal data and the free movement of these Data (2016/679) (“GDPR”), you have a right, subject to proving your identity, to access, rectify, erase, object to the processing, request the portability of the Personal Data about you and request the limited processing of them, and the right to decide on the outcome of these same Data after death. These rights may be used by contacting: [email protected].
If you consider that GlobalExam’s efforts to protect the confidentiality of your personal data are insufficient, you may make a claim to the relevant controlling authority (CNIL or any other authority indicated on the list available from the European Commission).
3. Use of Personal Data by GlobalExam
3.1 Purpose of processing
Through the Website, GlobalExam only collects and processes, as data controller (as specified by the GDPR), the Personal Data required for the following purposes: providing you with the services related to the orders (as defined in the General Terms of Sale), improving these services, contacting you about your orders and ensuring customer services, contacting you as part of commercial canvassing, providing you with personalised advertisements, detecting and preventing attempts at fraud. The legal base for this processing is the agreement entered into between you and GlobalExam, and the latter’s legitimate interest.
For more information regarding the processing of your Data by GlobalExam, please consult appendix 1 of this document.
When collecting the personal data, only the information that is essential for these purposes and necessary for meeting with your requests is required (mainly, first name, email address, password, IP address and bank details). If you do not complete the compulsory fields, we will not be able to answer your requests.
Optional fields, such as telephone number, may be left empty. They are then clearly labelled as “optional”.
3.2 Conservation of Data
The Data are kept for a period which may not exceed the period required for the purposes for which they are processed. We keep your personal data for at least the legal period stipulated by the texts when this is specified. When a different conservation period is required for our legitimate interests, the sensitive nature of the data, the potential risk and the requirements in terms of security for these data will be taken into consideration, in order to establish the conservation period.
Furthermore, GlobalExam may be required to keep data related to closed accounts in order to respect legal obligations, in relation to fraud prevention or as part of dispute settlement procedures, for example.
When keeping your Data is no longer required for the performance of the purposes for which they were kept, GlobalExam will ensure the anonymisation of the said Personal Data about you.
For more information regarding the conservation of Data, please consult appendix 1 of this document.
3.3 Recipients of the Data
The Data collected are only destined for GlobalExam.
The Personal Data collected may however be communicated to third parties bound by agreement to GlobalExam for the performance of subcontracted services and/or as required for the performance of the services available on the Website. Before any transfer of information, we will check the compliance of the purpose of each request and guarantee the transfer of the elements that are strictly necessary for the performance of the services by the service provider.
It is specified that these third parties will only have limited access to the Personal Data that are strictly necessary for performing their services and will be required to use them in compliance with the provisions of the Regulations.
For more information regarding the subcontractors of GlobalExam, please consult appendix 2
GlobalExam will not, in any event, transfer, sell or rent the Personal Data collected to third parties, whether free of charge or in return for payment.
Furthermore, GlobalExam may be required to disclose these Personal Data to third parties, in cases in which it is required or authorised by law to do so, in particular due to a court decision or any other legal requirement or request. In this case, GlobalExam undertakes, where possible, to inform you of this (unless we consider reasonably that we are not authorised to do so, in particular due to the legal or judicial obligations incumbent on us).
3.4 Transfer of Data
The Website is hosted on servers located in the territory of the European Union.
GlobalExam keeps the Personal Data on secured servers, located in the territory of the European Union.
In the event that the Data collected are transferred to companies located in the USA or in countries that do not guarantee a sufficient level of protection, GlobalExam undertakes to enter into agreements with the recipients in question, ensuring sufficient protection of the Personal Data transferred. In particular, these transfers may be regulated by the standard contractual clauses validated by the European Commission in accordance with the Regulations in force.
3.5 Safety and confidentiality of Data
GlobalExam has ensured the implementation of all useful precautions for guaranteeing the safety and confidentiality of the Personal Data processed and for preventing them from being distorted, damaged, destroyed or accessed by an unauthorised third party. All of the security means implemented comply with the professional rules, in particular as regards the IT systems.
As GlobalExam cannot control all risks related to the Internet, it draws the visitors’ attention to the existence of possible risks related to its use and functioning.
4. Links to third-party websites
The Website may contain links to third-party websites, which are governed by their own privacy statements and cookies policies, conditions of use and safety measures, which may differ from those of GlobalExam. GlobalExam may not be held liable for the content and methods of these websites. This is why you are advised to consult their privacy statement before communicating any information or Personal Data to them about you.
5. Cookies
5.1 What is a cookie?
A “cookie” refers to a text file that may be saved in a specific part of the hard drive of your device (computer, tablet, smartphone) through the browsing software that you use to consult our Website and subject to your preferences recorded in your browser as regards cookies. This cookie file enables its issuer to identify the device in which it is saved during the period of validity or safeguard of the cookie.
When consulting the Website, information related to the browsing of your device on our Website may be saved in the “cookie” files installed on your device.
When you visit the Website for the first time and GlobalExam intends to place a cookie on your device, you are informed of this through an information banner at the bottom of the page. You will then be able to give your consent on the installation of cookies.
You may amend the settings related to cookies, at any time. You will find more information below about cookies and the way in which you can manage the settings related to cookies.
5.2 Cookies and the Website
Subject to your preferences and the settings saved on your browser, your browsing on the Website may give rise to cookies, web tags, your IP address, the geolocation via IP address, connection and browsing information (referring URL, publicity data, visit statistics, connection identifiers) being saved in your device, enabling GlobalExam to recognise the browser of your device during the conservation period of this information. GlobalExam therefore collects information on the pages that you visit, the links on which you click and other actions in relation to your browsing on the Website. Some anonymous Cookies are saved upon connecting to the Website and are used by GlobalExam for statistical analysis purposes.
The cookies that we save enable:
- to draw up statistics and traffic and usage volumes of the various elements comprising the Website (sections and content visited, routes) enabling GlobalExam to improve the interest and ergonomics of its services;
- to adapt the presentation of our Website to the display settings of your device (language used, display resolution, operating system used, etc) when you visit the Website, depending on the display or presentation equipment and software included in your device;
- to memorise information related to a form that you have completed on the Website (registration or access to your account) or services or information that you have chosen on the Website;
- to provide you with access to reserved and personal areas of the Website, such as your account, through identifiers or data that you may have communicated to us;
- to fight against fraud on the internet (prevention of fraud on means of payment, usurpation of identity, etc.).
5.3 Your preferences regarding the cookies
There are several possibilities enabling you to manage cookies. Any change in settings may amend your browsing and the conditions for accessing the Website. You may amend these settings at any time by using the procedures described below.
It is possible for you to set up your browsing software so that, depending on your choice, cookies are either saved on your device or, on the contrary, are refused. You may also set up your browsing software so that the acceptance of cookies is proposed to you, when necessary, before a cookie is saved on your device.
- Allowing cookies
Except in the cases where Cookies are absolutely necessary for our service or are completely anonymous, any saving of cookies on your device is subject to obtaining your consent, that you can put forth and amend at any time by clicking on the link at the bottom of the Website and/or by amending the settings of your browser.
- Refusing cookies
If you refuse to allow cookies to be saved or if you delete those already saved, you will no longer be able to benefit from a certain number of functions that are required for easy browsing on the Website. This would be the case if you wanted to have access to areas or services for which it is necessary to identify yourself. This would also be the case if GlobalExam or its service providers are unable to recognise, for technical compatibility purposes, the type of browser used by your device, its language and display settings or the country/region from which your device seems to be connected to the internet. Where necessary, we decline all responsibility regarding the consequences related to the reduced operation of our services due to settings that you have chosen.
- How to make your choices depending on your browser?
For managing cookies, each browsing software offers different methods of configuration. They are described in the help menu of each browser. As an example:
For Internet Explorer 8.0 and later:
- Select the “Tools” menu, then “Internet Options”
- Click on the “Privacy” tab
- Select the level of privacy chosen using the cursor.
For Mozilla Firefox:
- Choose the “Tools” menu, then “Options”
- Click on the “Privacy” button
- Go to the “Cookies” menu and select the appropriate options.
For Chrome:
- Choose the “Settings” menu
- Click on “Show advanced settings” and go to the “Privacy” section
- Click on “Content settings”
For Safari on iOS:
- Go to “Settings” and choose “Safari”
- Go to “Accept cookies” in the “Privacy” section
- Define the privacy settings
For more information about cookies and their use, you may consult the file of the French Data Protection Agency (“Commission Nationale de l’Informatique et des Libertés”) at the following address: www.cnil.fr.
6. Amendment of the terms of the Privacy Statement
We may amend this Privacy Statement. The new terms and conditions will apply in the month following the publication. Where applicable, any major amendment may be notified to you by email.
GlobalExam recommends that you consult the Privacy Statement each time you use the Website in order to keep informed of the methods implemented in terms of information and means that you can use to protect your privacy.
7. Applicable Law and Jurisdiction
This Privacy Statement is governed by French law and any dispute about it will be referred to the jurisdiction of the Courts with territorial jurisdiction in accordance with the rules set forth by the French Code of Civil Procedure.
Appendix 1
Processing, purposes, legal bases, conservation period
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Processing :
Information about the Customer, creation of a user account, Customer Service
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Data :
Username, email address, password, telephone number (optional)
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Purposes :
Ensure the performance of the Services, their improvement and their safety
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Legal bases :
Agreement and GlobalExam’s legitimate interest
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Conservation period :
Term of the Agreement + 5 years of archiving in order to respond in the event of a dispute
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Processing :
AI Assistant regarding the follow-up of the contractual relationship
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Data :
Surname, first name, email address of the Customer Data shared with AI during conversations with the Customer
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Purposes :
Perform the terms of the Agreement
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Legal bases :
Agreement
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Conservation period :
Term of the Agreement + 5 years of archiving in order to respond in the event of a dispute
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Processing :
Payment of the Services (only for payments by card, as chosen by the customer, and in the event of an additional order placed during the agreement)
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Data :
Type of card, card number, expiry date, visual cryptogram
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Purposes :
Perform the terms of the Agreement
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Legal bases :
Agreement
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Conservation period :
Term of the Agreement + 5 years of archiving in order to respond in the event of a dispute
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Processing :
Commercial canvassing
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Data :
Username, email address, password, telephone number.
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Purposes :
Inform the Customer about other services provided by GlobalExam
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Legal bases :
GlobalExam’s legitimate interest and Customer’s consent
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Conservation period :
3 years as from the last active contact with the Customer
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Processing :
Collection of Customer’s connection data
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Data :
Upon each connection: IP address, connection country.
Data created by the Customer when using our Services: Activities completed
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Purposes :
Perform the terms of the Agreement and ensure the safety of the Services. Perform statistics of visits of the Website
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Legal bases :
Agreement and GlobalExam’s legitimate interest
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Conservation period :
1 year
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Appendix 2
Subcontractors
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Subcontractor :
Singlestore
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Position :
Website and data host
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Subcontractor :
AWS (Europe)
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Position :
Website and data host
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Subcontractor :
Agora
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Position :
Video-conference platform
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Subcontractor :
G-suite
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Position :
Mailbox and storage management
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Subcontractor :
Hubspot
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Position :
CRM
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Subcontractor :
Sentry
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Position :
Application error management
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Subcontractor :
Brevo (Sendinblue)
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Position :
Email campaigns
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Subcontractor :
Mandrill
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Position :
Email campaigns
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Subcontractor :
Stripe
Only for card payments, as chosen by the Customer, and in the event of an additional order placed during the agreement
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Position :
Online payment
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