The personal data protection is governed in Europe by the General Data Protection Regulation of April 27, 2016, better known under the name of GDPR.
The company dthinking network (hereinafter “us” or “dthinking network”), is a company headquartered in Pantin, France.
As data controller, we are committed to the protection of the data of our customers and prospects (hereinafter “you”), which we process for the needs of our activity. This is why we are committed to respecting the essential principles applicable to the protection of personal data.
As such, we set out in this policy how we collect, process and use your personal data (hereinafter your “Data”) to provide you with new services on a daily basis while respecting your rights.
This policy will be updated as necessary.
Your Data is only used for the purposes mentioned below in a relevant and proportionate manner.
Your Data may be processed when:
· You subscribe to our newsletter and receive our commercial offers. Thelegal basis for this processing is your consent.
· You contact us for a request for information. The legal basis for this processing is your consent.
· You follow training with our partners. The legal basis for this processing is the execution of the pre-contractual and contractual measures of the general training conditions.
· We carry out statistical studies, work to improve our services and have to defend our interests (litigation). The legal basis is our legitimate interest.
· You exercise your rights over your Data or to enable us to meet our legal obligations.
We ensure that our only authorized services can access your Personal Data for the purposes set out above.
Personal data is processed, within the limits of their powers, by:
· The authorized staff of our administrative and commercial department
· Subcontractors in charge of implementing personal data processing, in particular IT
· Partners including training organizations and trainers
We may also be required to communicate your Data in the event of legitimate requests from public authorities, in particular to meet national security, anti-fraud or law enforcement requirements. In such a case, we are not responsible for the conditions under which the staff of these authorities process your Data.
No data processing by a partner will give rise to a transfer outside the European Union if the country of transfer is not recognized as having an adequate level of protection or if appropriate guarantees are not implemented. These guarantees may be the conclusion of a transfer agreement based on the standard contractual clauses adopted by the European Commission and / or any other mechanism approved by supervisory authorities.
In general, we store your Data within the European Union. However, since some of our service providers are located in countries outside the European Union (“Third Countries”), we transfer some of your Data to Third Countries, such as the United States of America. . These transfers are made in accordance with applicable regulations and guarantee an adequate level of protection of your privacy and your fundamental rights (in particular through the use of standard contractual clauses from the European Commission). On simple request, we can provide you with more information about these transfers.
We collect your Data for the time necessary to achieve the purposes defined in this policy.
Categories of personal data Retention period
Data relating to the sending of the newsletter and marketing data of your customer account
· 3 years from the last contact
Training data:
· 10 years from the date of issue of the invoice
The last contact can be:
- The date of participation in a competition
- A click on a hypertext link contained in an email (Newsletters, cart abandonment emails, download link)
- The consultation of a product sheet (identification thanks to cookies)
- Entry into the site's search engine (identification using cookies)
- The last authentication in his customer account
- The last purchase
At the end of these periods, your data is then either deleted oranonymized.
In order to allow you to control our use of your Data, you have the right:
· To be informed about our use of your Data. This is the purpose of this policy;
· To obtain confirmation that data concerning you is being processed, access this data and request a copy;
· To have any data concerning you corrected that is inaccurate, erroneous or obsolete;
· To request the right to restriction of processing. This right only applies under certain conditions (contestation of the accuracy of your Data, doubt about the lawfulness of the processing, exercise of your legal rights);
· To obtain the deletion of your Data. This right only applies under certain conditions (withdrawal of consent on which the processing is based, your Data is no longer necessary for the initial processing purposes, opposition to the processing of your Data, doubt about the lawfulness of the processing);
· To oppose the processing of your Data for reasons relating to your particular situation and when this processing is based on our legitimate interest or on your consent (withdrawal of consent);
· Your right to portability. This right only applies under certain cumulative conditions (you yourself have communicated your Data to us on our online services and for purposes based solely on the consent of persons or the execution of a contract).
· To formulate specific and general post-mortem guidelines on the conservation and communication of your Data. Without a directive, your heirs can send us any request.
If you wish to exercise any of your rights described below, you can:
· Contact us at the following address:
· By email : academy@dthinking.co
· By mail: dthinking network, 89 avenue Jean Lolive, 93500 Pantin
To ensure that your request is handled as quickly as possible, please give us your precise contact details and indicate the right (s) you wish to exercise. Supporting documents may be requested if there is any doubt as to the identity of the applicant.
We will provide you with the answers to your requests as soon as possible and in compliance with our legal obligations.
You have the right to lodge a complaint with a supervisory authority: in France, the CNIL.
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