Privacy Policy

Version of 28/04/2023
PREAMBLE

Welcome to the website of the École Supérieure du Parfum & de la Cosmétique, which aims to offer high-quality training programs, either in initial education or through apprenticeships, in the fields of perfumery and cosmetics.

As you browse our Site and to manage your inquiries, AD EDUCATION may collect and process personal data concerning you.

Particularly concerned about protecting users’ privacy, AD EDUCATION aims to provide you with precise information about all its data processing activities.

This Privacy Policy is therefore intended for users of the Site in accordance with the French Data Protection Act of January 6, 1978 (hereinafter “Loi IEL”), as amended, and the General Data Protection Regulation (EU) of April 27, 2016 (hereinafter “GDPR”).

ARTICLE 1. WHO COLLECTS AND MANAGES YOUR DATA?

AD EDUCATION, a simplified joint-stock company registered with the Paris Trade and Companies Register under number B 824 504 534 and headquartered at 20 rue Desbordes Valmore, 75116 PARIS (“AD EDUCATION”), is the data controller for the following processing activities:

• Managing information requests;
• Verifying eligibility;
• Managing local student accounts;
• Ensuring the proper functioning and continuous improvement of the Site;
• Handling GDPR and French Data Protection Act-related rights requests.

Legal Reminder:
The data controller, as defined by the French Data Protection Act and the GDPR, is the entity that determines the means and purposes of data processing. When two or more controllers jointly determine the purposes and means of processing, they are considered joint controllers.

A processor is an entity that processes personal data on behalf of the data controller, acting under the controller’s authority and instructions.

ARTICLE 2. DEFINITIONS

• “Student”: Refers to a person who can authenticate on the Site via the “Access My Personal Space” and “Login” sections.
• “Data” or “Personal Data”: Refers to personal data processed under this Privacy Policy as defined in Article 4(1) of the GDPR.
• “General Data Protection Regulation” or “GDPR”: Refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC.
• “Processor”: Refers to any natural or legal person, public authority, agency, or other body that processes personal data on behalf and under the instructions of AD EDUCATION, as defined in Article 4(8) of the GDPR.
• “Processing/Process”: Refers to any operation performed on personal data as outlined in Article 4(2) of the GDPR.
• “User”: Refers to any person browsing the Site operated by AD EDUCATION, whether they are a general visitor or a student.

ARTICLE 3. WHAT ARE THE PURPOSES AND LEGAL BASES OF THE DATA PROCESSING ACTIVITIES?

AD EDUCATION collects only the data necessary for the following explicit and defined purposes:

a. Managing information requests

Processing details:

• Handling requests for information about programs and advisor contacts;
• Responding to information requests about programs and advisor contacts;
• Tracking requests;
• Providing follow-up information.

Legal basis:
Performance of a contract, pre-contractual measures, or legitimate interest in responding to your inquiries.

b. Verifying eligibility

Processing details:

• Handling eligibility verification requests;
• Responding to eligibility verification requests;
• Tracking requests;
• Providing follow-up information.

Legal basis:
Performance of a contract or pre-contractual measures.

c. Managing local student accounts

Processing details:

• Student registration;
• Managing student accounts.

Legal basis:
Performance of a contract or pre-contractual measures.

d. Ensuring the proper functioning and continuous improvement of the Site

Processing details:
Ensuring the proper functioning and continuous improvement of the Site and its features.

Legal basis:

• Our legitimate interest in maintaining the best possible performance and quality of the Site, including visit statistics.
• The User’s consent where required.

e. Handling GDPR and French Data Protection Act-related rights requests

Processing details:
This processing covers all necessary operations related to handling rights requests submitted to AD EDUCATION (request qualification, investigations, technical operations, etc.). It applies only when AD EDUCATION acts as the data controller.

Legal basis:
Legal obligation under the GDPR and the French Data Protection Act.

ARTICLE 4. WHAT DATA IS COLLECTED?

The mandatory or optional nature of the collected personal data and the potential consequences of failing to provide such data are indicated during the various interactions with the concerned individuals.

• Managing information requests;
• Verifying eligibility;
• Managing local student accounts;
• Ensuring the proper functioning and continuous improvement of the Site;
• Handling GDPR and French Data Protection Act-related rights requests.

You can find details of the personal data we may have about you below.

Details of the processed data:
Note: The information provided below is not intended to be exhaustive and primarily aims to inform Users about the categories of data that AD EDUCATION may process.

• For managing information requests:
  • Last name, first name;
  • Email address;
  • Phone number;
  • Postal address.

• For managing eligibility verification:
  • Last name, first name;
  • Email address;
  • Phone number;
  • Proof of enrollment and diplomas.

• For managing student local accounts:
  • Email address.

• For ensuring proper operation and continuous improvement of the Site:
  Data collected via cookies and other trackers on our Site; for more details, please refer to Article 8 of this document.

• For managing GDPR and French Data Protection Act rights requests:
  • Last name, first name;
  • Email address;
  • Where applicable, a copy of an identity document.

ARTICLE 5. WHO RECEIVES YOUR DATA?

Only authorized and designated persons mentioned below may have access to User data.

• Authorized personnel of AD EDUCATION;
• Service providers responsible for managing and hosting the Site and AD EDUCATION’s IT system;
• Where applicable, authorized personnel of our subcontractors;
• Where applicable, relevant courts, mediators, accountants, auditors, lawyers, bailiffs, debt collection agencies, law enforcement authorities in cases of theft or judicial requisition.

Your data is not shared, exchanged, sold, or rented to any person other than those mentioned above.

ARTICLE 6. HOW LONG DO WE KEEP YOUR DATA?

AD EDUCATION ensures that the collected Data is retained in a form that allows your identification for no longer than necessary for the purposes for which these data are collected and processed.

Managing information requests:
Data is retained for as long as necessary to process the request, then archived for five (5) years for evidentiary purposes in accordance with AD EDUCATION’s legal and regulatory obligations.

Managing eligibility verification:
Data is retained for as long as necessary to process the request, then archived for five (5) years for evidentiary purposes in accordance with AD EDUCATION’s legal and regulatory obligations.

Managing student accounts:
Data is retained for the duration of the contractual relationship and then archived for five (5) years for evidentiary purposes in accordance with AD EDUCATION’s legal and regulatory obligations.

Ensuring proper operation and improvement of the Site:
Commercial cookies and other trackers may be stored on the User’s device for a maximum of thirteen (13) months. After this period, raw traffic data associated with an identifier is either deleted or anonymized.
Information collected via cookies and trackers is retained for twenty-five (25) months. After this period, these data are deleted or anonymized.

Managing GDPR and French Data Protection Act rights requests:
Data related to rights requests is retained for the time necessary to process the request. It is then archived for the applicable legal limitation period as intermediate storage.
If an identity document is provided, it may be retained for one (1) year after the request is received.

ARTICLE 7. WHAT ARE YOUR RIGHTS?

In accordance with the French Data Protection Act and GDPR, you have the following rights (learn more):

• Right of access (Article 15 GDPR), rectification (Article 16 GDPR), update;
• Right to erasure of your personal data (Article 17 GDPR), when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication, or retention is prohibited;
• Right to withdraw your consent at any time (Article 7-3 GDPR);
• Right to restrict processing of your Data (Article 18 GDPR);
• Right to data portability for the Data you have provided, when processed automatically based on your consent or a contract (Article 20 GDPR);
• Right to object to the processing of personal data (Article 21 GDPR);
• Right to file a complaint with the CNIL (Article 77 GDPR);
• Right to determine the fate of your data after your death and to choose whether we communicate (or not) your data to a third party you have previously designated (Article 85 of the French Data Protection Act). In the event of death and in the absence of instructions from you, we commit to deleting your data, except when retention is necessary for evidentiary purposes or to comply with a legal obligation.

These rights can be exercised by simple request via email at dpo@ad-education.com or by mail to AD Education – GDPR Office, 30 rue Cambronne 75015 Paris.
To learn more about your rights, you can also visit the website of the French Data Protection Authority (CNIL) at: http://cnil.fr.

ARTICLE 8. CONNECTION DATA AND COOKIES

AD EDUCATION uses connection data (date, time, IP address, pages visited) and cookies (small files stored on your computer, tablet, or phone) to identify you, remember your visits, and provide audience measurement and statistical data on the Site, particularly regarding pages visited.

You can consent, refuse, or choose the type of cookies you allow on your computer, tablet, or smartphone.

A cookie is a text file placed and read during your navigation on a website, regardless of the type of device used.

Article 8.1: Proprietary Cookies

For the sake of clarity, below is a description of the cookies used on the Website and their purpose:

• Functional and technical cookies primarily improve your browsing experience on the Website. They send information to our Website and your device, such as:
  • Storing information related to a form (ID, address)
  • Display preferences on your device (language, resolution)
  • Security measures, such as session expiration
  Example:
  • Cookie Name: Cookie-Agreed
  • Purpose: Sends information to the browser software
  • Duration: Duration of the browsing session
• Audience measurement cookies help us understand how the Website is used to improve the quality of our services.Example:
  • Cookie Name: Cookie-Analytics-Agreed
  • Purpose: Collects information and generates reports on site traffic statistics without transmitting visitor identities to Google
  • Duration: Duration of the browsing session

Cookies store certain information about your browsing activity and online behavior, helping us enhance and facilitate your user experience.

These cookies require your prior consent unless they are strictly necessary for the Website’s proper functioning.

Article 8.2: Third-Party Cookies

When visiting the Website, third-party providers may place cookies on your device.

The use of these cookies is subject to the same data protection regulations under the French Data Protection Act (Loi Informatique et Libertés) and the GDPR. You can disable these third-party cookies through your browser settings, either individually or along with our cookies.

These include:

• Advertising cookies used by advertising service providers on the Website.
• These cookies track viewed or purchased services and help personalize advertising offers.
• Cookies embedded in advertisements provide information and statistics on their effectiveness (e.g., number of clicks, number of views, etc.).Example:
  • Cookie Name: Cookie-YouTube-Agreed
  • Purpose: Set by embedded YouTube videos to collect anonymous statistics on video views and player settings. If the visitor is logged into Google/YouTube, these data are linked to their account.
  • Duration: Duration of the browsing session

ARTICLE 9. DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

By default, AD EDUCATION processes your data within the European Union.

However, due to its business nature, AD EDUCATION may transfer your data outside the EU. In such cases, appropriate safeguards are implemented in compliance with regulations. These safeguards are available upon request via email at dpo@ad-education.com or by mail at:

AD Education – GDPR Division, 30 rue Cambronne, 75015 Paris

ARTICLE 10. SECURITY

AD EDUCATION and its subcontractors commit to implementing all necessary technical and organizational measures to ensure the security and confidentiality of your personal data, in accordance with current technology and GDPR regulations.

AD EDUCATION takes necessary precautions—considering the nature of your data and the risks of processing—to protect data security, prevent data alterations or damage, and restrict unauthorized access (e.g., physical security of premises, authentication processes with secure personal access).

ARTICLE 11. UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated to reflect legislative and regulatory changes. Users can check the latest version directly on the Website.