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Introduction This policy describes how and why we collect, and use, your personal information when you visit the CEMS website (www.cems.org - the “website”) and use the CEMS online services, in accordance with applicable laws and regulations, and notably the European General Data Protection Regulation 2016/679 (“GDPR”, the official text is accessible via this link). ‘Personal data’ means any information relating to an identifiable living individual who can be identified from that data or from that data and other data. ‘Processing’ means anything that is done with personal data, including collection, storage, use, disclosure and deletion. This data protection policy applies to any: Use of one of the online services of CEMS: Whether this is a website, intranet (forms, cookies, etc.) or a digital work environment, On social media, Whatever the type of exchanges (email, text message, paper or electronic form, etc.), Or on mobile apps. Participation in training or an event; Response to a solicitation by CEMS by an alumnus, speaker, partner or supplier. The website contains links that may redirect the user to third party sites which have their own confidentiality and cookie management policies. The policies of such third parties should be consulted, and CEMS declines any responsibility regarding the confidentiality practices implemented by such third parties. 2. Data Controller CEMS, an association governed by the French law of July 1, 1901, having its registered office at 1 rue de la Liberation, 78350 Jouy-en-Josas and registered with the INSEE, DR de Haute-Normandie under the number SIREN 387 573 835 (hereafter, “CEMS”, “we”, “us”, “our(s)”), is the data controller as this term is defined in the GDPR. 3. Persons Concerned To meet its operational needs, CEMS has to set up and use means of processing personal data relating to its prospects, applicants, clients, alumni, faculty, partners, companies and organizations, as defined below: "Prospect" means any person who may potentially be interested in the CEMS-MIM program or the Corporate Partnership relation; "Applicant" means any person interested in a course who has started to complete an application; "Client" means any person who has confirmed their registration or had their registration confirmed by their Home School, where applicable, following an admission process, whether by making a down payment or signing a financing contract or form; "Student" means any person registered with the CEMS-MIM program; "Third-party payer" means the natural or legal person managing all or part of the funding of a Client's training; "Alumnus" means any person who has taken, and has successfully completed the CEMS-MIM program; "Academic Member" refers to any person working within one of the Academic institutions, member of the CEMS alliance, and providing teaching services whether or not they are a salaried employee of CEMS; "Providers" refers to companies or organizations with which CEMS has a purchase contract as well as the suppliers of CEMS; "Partners" refers to companies or organizations with which CEMS has a contractual partnership relationship, in particular in connection with training services. "User" may refer to all populations. 4. Personal Data Collected Non-technical types of data may include: Personal status (last name, first name, address, date and place of birth, nationality, title); Contact details (telephone number, email address, social media identifiers, mailing address); Preferred means of contact; Academic history (degrees, specialist qualifications, years obtained, language and management levels, scores in GMAT-type tests, etc.); Previous professional experience (titles of positions held, internships, role, responsibilities, companies, pay level); Reasons for applying to CEMS; Where applicable, data relating to means of payment (bank or post office account details, check number and/or credit card details, and, where applicable, transaction no., details of services subscribed to); Contract history and, where applicable, details of third-party payer; Any information relating to training courses taken (CEMS student no., modules or courses taken and, where applicable, scores, internships, assessment, exam panels, etc.); Information regarding university education mainly within the CEMS-MIM structure (Home School, Host Schools, Class-Year, Graduation Year, Terms, CEMS Mail); Any information relating to cohort tracking during and/or after the course (employer, position, salary, etc.). Important note on images and audiovisual content Images and audiovisual content (photographs, video and audio recordings) may also be collected during CEMS activities, including events, courses and community initiatives. These materials may include identifiable individuals and may be used by CEMS for internal and external communication and promotional purposes. Such content may be published across a range of media, including but not limited to CEMS websites, social media channels, digital communications, publications and other promotional materials, in edited or non-edited formats. CEMS takes care to use such content in a respectful and appropriate manner. Individuals who wish to request the removal of a specific image or recording can do so at any time by contacting [email protected]. CEMS is committed to addressing such requests promptly and with due consideration. Technical types of data may include: IP address; Connection data (login/password); Browsing data (pages visited, clickstream, length of visit, etc.); Browser-related data (type of browser, plugin, etc.); Preferences (languages used, etc.). 5. Legal Basis for Personal Data Collection Depending on your situation with respect to us, we collect and process your personal data either because: You have given consent to the processing of your personal data for a specific purpose; It is necessary for the performance of a contract to which you are a party; Such processing is necessary for the purposes of our legitimate interests. 6. Purposes of the Collection of Personal Data The purpose of the collection of this information is to enable: The setting up of prospecting and advertising operations relating to the programs, activities and events organized by CEMS or its community and subscriptions to CEMS newsletters; Access to the admission platform, and its improvement; Management of the student's application and, after admission, monitoring his/her training regarding administrative, financial and academic aspects; Client relations monitoring; Purchase management; Billing; Management of unpaid bills and disputes; Where applicable, access to CEMS network, application resources and digital documentation; Where applicable, submission of documents and academic work; Organization of surveys, in particular for CEMS, accreditation bodies, organizations publishing rankings for which CEMS has to produce statistics or answer inquiries in accordance with current legislation; Access to professional support offers developed by the Corporate Partnership Department of CEMS; Management of the risk of fraudulent use; Management of the awarding of CEMS diplomas and certificates, and in some cases, their electronic equivalents; Management of relations with companies; Transmission of data to companies (especially CVs), Partners and/or subsidiaries of CEMS; Statistics. 7. Sharing of Personal Data By providing us with your personal data through the website, you are consenting to their sharing with other CEMS-related students and alumni associations for the purpose of creating efficient alumni networks on a worldwide level. CEMS may use third party products to provide complementary services to the User. CEMS asks these third parties to follow its instructions concerning the User's personal data and only to use them in connection with the contract signed with the third parties unless the person concerned explicitly consents to such third parties using their data for their own purposes. The User acknowledges that the third party may be located outside the territory of the European Union and agrees to their data being transferred to such places. In this case, CEMS will take all the measures necessary to ensure that the provider or partner guarantees an adequate level of data protection in line with the GDPR. 8. Your Rights Under the GDPR, you have a right of access, modification, rectification and erasure of your personal data as well as a right of objection on legitimate grounds, which can be exercised by sending an email to [email protected] mentioning in the subject line "Personal rights" and attaching a copy of your proof of identity. Alternatively, you may also write to CEMS, Correspondant à la protection des données, 1 rue de la Libération, 78350 Jouy-en-Josas. You have the right to lodge a complaint with your local supervisory authority, which for France is the CNIL: COMMISSION NATIONALE DE L'INFORMATIQUE ET DES LIBERTÉS, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. A list of the different European supervisory authorities can be found here. 9. Security In order to ensure the security of personal data collected and processed, CEMS implements a level of security appropriate and proportional to the risks involved by taking all useful precautions, whether they be physical, logical, administrative or organizational, in view of the nature of the data it collects, processes or transfers. These measures include, mainly: Protection of the accesses to the premises and server rooms by our ISP; Backup data center in different location; Filtered, secure internet access; Use of a SSL-type encryption protocol for the transmission of data between the terminals and servers of CEMS or its service providers; Regular backups; Management of accreditations for accessing data, and only allowing necessary resources to access data; Separation of development/acceptance, pre-production and production environments; 10. Data Protection Officer CEMS has appointed a Data Protection Officer: Adaliance SAS, 73, rue du Château 92100 Boulogne Billancour…