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Privacy Policy

The website https://www.brassart.fr/ is operated by BRASSART RHONE ALPES, a simplified joint-stock company with a single shareholder, with a share capital of €369,000, registered with the Lyon Trade and Companies Register under number 524 726 817, with its registered office located at Les Jardins d'Entreprise, Avenue du Château de Gerland, 69007 Lyon, hereinafter referred to as “BRASSART”, represented by its legal representative, Mr. Amin KHIARI.

Users of the website are invited to read this privacy policy carefully.

For any questions regarding this privacy policy, users may send an email to the following address: [a]dpo@groupe-edh.com[/a].

1. Definitions

The terms defined below, whose first letter is capitalized, shall have the following meanings:

Site: refers to the website accessible at the following address https://www.brassart.fr/ operated by BRASSART.

Cookies: refer to automatic tracking technologies in the form of text files placed on a device (computer, tablet, smartphone) that record information when visiting a website or viewing an advertisement.

Personal Data/Data: refers to any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or to one or more elements specific to them. This may include, in particular, the User’s last name, first name, telephone number, email address, postal address, or gender.

Third-party platform: refers to any service, website, or application operated by an entity separate from GEDH, which may receive Personal Data in connection with the use of the Site, in particular for the purpose of content distribution, analytics, performance measurement, or advertising targeting (for example search engines, social media platforms, or advertising platforms).

Processing: refers to any operation or set of operations performed on Data, such as collection, recording, storage, consultation, communication, as well as the deletion or destruction of Data.

Data Controller: refers to the natural or legal person who determines the purposes and means of a Processing activity, i.e. its objective and how it is carried out. The Data Controller is identified in Article 2 of this policy.

Processor: refers to the natural or legal person who processes Data on behalf of the Data Controller, as part of a service or provision of services.

Recipient: refers to the natural or legal person to whom the Data is disclosed.

Data Protection Officer: refers to the natural person responsible for ensuring BRASSART’s compliance with data protection regulations.

User: refers to any natural person acting in a non-professional capacity whose Personal Data is processed by BRASSART, namely Users visiting the Site, whether they are current students, alumni, or prospective students of BRASSART.

2. Identity of the Data Controller and Data Protection Officer

The Data Controller is:

BRASSART RHONE ALPES
Single-shareholder simplified joint-stock company with a share capital of €396,000
Registered with the Lyon Trade and Companies Register under number 524 726 817
Les Jardins d'Entreprise, Avenue du Château de Gerland, 69007 Lyon

The Data Protection Officer within GEDH can be contacted:

Data Protection Officer
61 rue Pierre Charron, 75008 Paris
Email: dpo@groupe-edh.com

3. General Information

This Privacy Policy may be modified at any time by BRASSART, in particular to comply with changes in laws and regulations, case law, technology, or the requirements of authorities. In the event of a modification to the Privacy Policy, BRASSART will inform the User and/or seek their consent when necessary.

The latest version of the Privacy Policy is the one available on the Website.

Users are invited to consult the Privacy Policy before browsing the Site and to review it regularly in order to be informed of any changes and/or updates made by BRASSART.

4. Data Processed

When using the Site, the following Personal Data may be collected from the User and processed on behalf of BRASSART.

BRASSART ensures that only Data strictly necessary for the purposes for which it is processed is collected and processed.

The Processing of Data is necessary in order to provide the services requested by Users through the Site. Therefore, if the User does not wish to provide the requested information, the User understands and accepts that BRASSART may not be able to respond to their request.

BRASSART does not collect any sensitive Data within the meaning of the applicable regulations.

BRASSART may collect Data relating to minor Users wishing to obtain information and/or apply for programs offered by BRASSART. In accordance with applicable regulations, the Processing of Data relating to minors aged over 15 does not require the consent of the minor or of the holders of parental authority, but requires full information. In this context, the information provided to minor Users is deemed to be adequately covered by this Privacy Policy.

4.1. Data required to send documentation to the User

In order to receive documentation tailored to their program, the User must provide the following Data:

Other information may be requested as part of this request (choice of campus, etc.), but it cannot be considered as Data within the meaning of the applicable laws and regulations.

4.2. Data required for the User’s application

To begin the application process at a BRASSART institution, the User must provide the following Data:

Other information may be requested as part of this application (choice of program, etc.), but it cannot be considered as Data within the meaning of the applicable laws and regulations.

4.3. Data required to register the User for Open Days

To register for an Open Day at a BRASSART institution, the User must provide the following Data:

4.4. Data required to register for a personalized information appointment

To register for a personalized information appointment, the User must provide the following Data:

Other information may be requested as part of this request (choice of preferred campus, etc.), but it cannot be considered as Data within the meaning of the applicable laws and regulations.

4.5. Other Data provided

The User also has the option to contact a BRASSART institution directly, by email or by phone.

In this context, the User may provide any information they wish to bring to the attention of BRASSART. If the User provides Data on this occasion, BRASSART will process such Data in accordance with the terms set out herein and in compliance with applicable regulations.

4.6. Data required for the use of the chatbot

The chatbot used on the Site is a computer program designed to simulate a conversation through messages. It uses artificial intelligence algorithms to understand and respond to users’ questions, providing instant and interactive assistance.

The User is informed that they are interacting with an artificial intelligence system and not with a human being. The processing of Data by the Chatbot does not lead to decision-making producing legal effects or significantly affecting the User or their rights.

In order to ensure optimal use of the chatbot, the User may be required to provide the following Data depending on their request:

Other information may be requested as part of this request (partnership/collaboration, choice of program, etc.), but it cannot be considered as Data within the meaning of the applicable laws and regulations.

5. Legal basis and lawfulness of processing

Data is used by BRASSART in accordance with applicable laws and regulations.

The Processing of Data is therefore lawful insofar as it meets:

  1. The legitimate interests of BRASSART, based on:
    • On commercial and financial grounds requiring that the Data be processed;
    • On the organization of marketing and outreach activities directed at Users;
    • On requests for information and documentation submitted by Users.
  2. Where applicable, on the Users’ consent to the collection and processing of their Data. Certain processing activities, particularly those relating to the use of data for advertising targeting purposes on Third-party Platforms (such as Google or social media platforms, as listed in Article 8.1 hereof), rely on the User’s prior and explicit consent (opt-in), which may be withdrawn at any time.
  3. Where applicable, on the performance of a contract concluded between BRASSART and the User.
  4. Where applicable, on a legal obligation.

6. Purposes of data processing

BRASSART uses Data only for the purposes described in the Privacy Policy, for compatible purposes, or for the purposes disclosed to the User at the time of collection.

In particular, Data is collected for the purposes of:

7. Data retention period

Data collected on the Site is retained by BRASSART for a period of 2 (two) years from the last contact with the User.

At the end of this period, BRASSART may contact the User to ask whether they wish to continue receiving commercial communications. In the absence of a positive response, BRASSART will delete the Data in accordance with the applicable provisions, in particular those provided for by the French Commercial Code, the Civil Code, and the Consumer Code.

In the event of an unsuccessful application, the Data collected as part of the User’s application will be retained for a period of 2 (two) years from the last contact.

Data collected in relation to the management of requests to exercise rights is retained for a period of between 1 (one) and 6 (six) years, depending on the right exercised.

Data required to establish proof of a right or of a contract, or retained in order to comply with a legal obligation, may be securely archived for a period not exceeding the time necessary for the purposes for which it is retained (including but not limited to those provided for by the French Commercial Code, the Civil Code, and the Consumer Code, as well as the accounting and tax provisions applicable to BRASSART).

8. Cookies

8.1. During each of the User’s visits to the Site, BRASSART collects information relating to their connection and browsing activity.

Cookies have several functions:

Some cookies may also be used to measure the effectiveness of marketing campaigns, attribute conversions, enrich customer relationship management (CRM) tools and, subject to the User’s consent where required, enable the delivery of personalised advertising on third-party Platforms such as Google (Google Analytics 4, Google Advertising Product, Google Conversion Linker, Google conversion tracking; Google remarketing; Google Tag Manager); Facebook; LinkedIn; Snapchat; TikTok; Antvoice; Bidswitch; YouTube and Vimeo.

8.2. The Cookies used by BRASSART, as well as their retention period, are listed in Appendix 1 (Appendix 1: Cookies).

8.3. The placement and storage of Cookies on the User’s device are carried out in compliance with applicable laws and regulations and subject to the choices expressed by the User, which may be modified at any time.

BRASSART obtains the User’s explicit consent, as soon as they access the Site, for the use of Cookies, except for so-called session cookies that are necessary for the proper functioning of the Site and which do not require the User’s consent to be placed on their device. The User cannot object to the placement of these session cookies on their device due to their limited lifespan and their essential use for the Site to function properly.

The User may choose to modify the Cookie settings at any time via the Cookie settings link. They may also configure their browser to refuse all Cookies, accept all Cookies, or select only the Cookies they agree to be stored on their device.

In this respect, each browser provides different configuration options. To configure their browser settings, the User is invited to follow the links below:

The User is therefore free to refuse Cookies.

For more information about Cookies, the User is invited to consult the CNIL website: www.cnil.fr.

8.4. Cookies may also be placed on the User’s device by third-party companies when the User clicks on icons linking to third-party websites accessible on the Site, including social networks such as Facebook, Instagram and LinkedIn or the YouTube platform.

By clicking on the icon of one of these third-party websites, the User may share the Site’s content, follow BRASSART’s social media accounts and express their opinion to others.

Third-party Cookies make it possible to identify the User and track their browsing activity on the Site when the User’s account on the third-party website is already active on their device.

BRASSART does not control the collection by third-party websites of Data relating to the User’s browsing activity on the Site.

Accordingly, BRASSART recommends that Users consult the cookie policies of these third-party websites in order to understand the purposes for which their Cookies are used.

9. Access to Data

9.1. The recipients of the Data are the authorized collaborators and employees of BRASSART, its institutions, as well as all entities within its group. In particular, members of the finance, marketing, sales, and administrative departments, as well as the teams responsible for customer relationship management, logistics, and IT services, may have access to the Data.

9.2. Furthermore, BRASSART’s service providers acting as Data Processors may have access to the Data, in particular in the context of their duties related to:

In particular:

The processing carried out by BRASSART’s service providers is governed by agreements under which the Data Processors undertake to comply with applicable laws and regulations and, more generally, with all obligations incumbent upon them, particularly with regard to the protection of the security and confidentiality of the Data.

9.3. The Data may also be transmitted to judicial and regulatory authorities, as well as to legal auxiliaries and ministerial officers, in the context of their duties relating to debt recovery and the protection of BRASSART’s interests.

10. Data Transfer

The User is informed that certain Data may be transferred, for the purposes defined above, to partners located in countries outside the European Union. BRASSART takes the necessary measures to ensure the security of Personal Data.

Prior to any transfer of Data outside the European Union, and in accordance with applicable regulations, BRASSART makes its best efforts to implement the necessary safeguards to secure such transfers and to ensure that they are carried out in compliance with this Privacy Policy and the applicable regulations.

In particular, BRASSART uses the services of HUBSPOT, which may transfer and store Data in hosting centers located in the United States and in other countries outside the European Union, exclusively for the purposes mentioned above.

This service provider implements mechanisms to ensure compliance with Personal Data regulations. To meet regulatory requirements, HUBSPOT had adopted the Privacy Shield framework as a legal mechanism for the transfer of its customers’ Data. As the Privacy Shield is no longer considered a valid transfer mechanism, this provider now applies Standard Contractual Clauses (SCCs) approved by the European Commission for transfers of Data outside the European Union.

For more information, please consult HubSpot’s Data Protection Agreement, available here: https://legal.hubspot.com/fr/dpa.

In any case, the User may withdraw at any time the consent they have given regarding the transfer of their Data outside the European Union by contacting BRASSART at the following address: dpo@groupe-edh.com.

11. Data Security

Taking into account the state of knowledge, implementation costs and the nature of the Data concerned, BRASSART undertakes to implement appropriate measures to preserve the security and confidentiality of the Data. BRASSART therefore ensures that the Data is not altered or damaged and that unauthorized third parties do not gain access to it.

In particular, BRASSART ensures that:

In the event of a Data breach likely to result in a risk to the rights and freedoms of natural persons, BRASSART will notify the breach to the French Data Protection Authority (CNIL) as soon as possible and, at the latest, within the time limits provided by applicable laws and regulations. If a Data breach is likely to result in a high risk to the rights and freedoms of Users, BRASSART will inform them of the breach as soon as possible, except in cases of exemption provided for by applicable laws and regulations.

12. Users’ Rights

In accordance with applicable regulations, the User has the following rights:

Notwithstanding the above, BRASSART may retain certain Data where required to do so by the laws and regulations applicable to its activities, or where it has a legitimate reason to do so.

The User may exercise their rights by contacting the Data Protection Officer by email at the following address dpo@groupe-edh.com, or by post at the following address: 61 rue Pierre Charron, 75008 Paris.

BRASSART will respond to the request as soon as possible and, in any event, within the time limits provided by applicable laws and regulations.

The User may lodge a complaint with the French Data Protection Authority (CNIL).

13. Third-party websites

If the User uses links available on the Site to access third-party websites, BRASSART strongly recommends that the User review the privacy policies of the websites they visit.

BRASSART cannot be held liable for Data processing carried out by third-party websites.

14. Appendices

Cookies placed by BRASSART
Cookies Purposes Retention period
_hssc Session tracking 30 minutes
_hssrc Used to determine whether the visitor has reset their browser Session
_hstc User tracking 13 months
_fbp Storage of usage history 3 months
_ga Used to store and count page views. 2 years
_ga_UA-47651304-1 User tracking Session
_gid Used to distinguish users 1 day
hubspotuk User identification 13 months
brassart Necessary session cookie Session
Info.brassart.fr Necessary session cookie Session
Cookies placed by third parties
Provider Cookies Purposes Retention period
Doubleclick.net DSID Store user preferences 15 days
IDE Deliver advertisements or enable retargeting 3 weeks
RUL Personalised advertising 2 months
Facebook C_user User identification 2 years
datr Personalised advertising 2 years
dpr Performance Tracking 15 days
fr Personalised advertising 2 years
sb Browser identification 2 years
xs Store a unique identifier 1 year
Google.com et/ou Google.fr 1P_JAR Personalised advertising 1 month
AID 1 month
ANID 9 months
CONSENT 28 years
NID 6 months
_Secure-3PAPISID 3 years
_Secure-3PSID 1 year
_Secure-3PSIDCC 1 year
Hubspot.com _cf_bm Session
Linkedin.com AnalyticsSynHistory Data storage 1 month
UserMatchHistory LinkedIn Ads identifier synchronization 1 month
bcookie Identification of devices connecting to LinkedIn 2 years
Li_gc Used to store users’ consent 2 years
Li_mc Used to obtain consent data 2 years
liap Used to indicate login status 2 years
lidc Facilitates the selection of data centers 1 day
lissc Tracking the use of services 1 year
Lms_ads Identification 1 month
Lms_analytics Identification 1 month
Ads.linkedin.com lang Used to remember the language setting Session
Sc-static.net X-AB Associated with the integration of content from Snapchat 1 day
Snapchat.com Sc_at Personalised advertising 1 month
t.co muc Facilitate functionalities 2 years
Twitter.com Guest_id Identification 2 years
Perzonalization_id 2 years
Youtube.com APISID Collection of information on the use of videos hosted on YouTube 3 years
CONSENT Personalised advertising 18 years
HSID Ensure fraud prevention 3 years
LOGIN_INFO Collection of information on the use of videos hosted on YouTube 2 years
PREF 2 years
SAPISID 3 years
SID 2 years
SIDCC 1 year
SSID 3 years
VISITOR_INFO1_LIVE Provide bandwidth estimates 2 years
YSC Store and track interactions Session
_Secure-1PAPISID Personalised advertising 2 years
_Secure-1PSID
_Secure-3PAPISID
_Secure-3PSID
_Secure-3PSIDCC 1 year
_ga 2 years
_gac_UA-158850311-1 2 months
Pinterest.com _pinterest_cm Personalised advertising 12 months
_pinterest_sess
TikTok.com tt_webid Personalised advertising 12 months
tt_webid_v2
ttwid
Spotify.com To be completed Personalised advertising 6 months
Deezer.com To be completed Personalised advertising 6 months

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