PRIVACY POLICY

1. Definition and nature of personal data

When you use our site, we may ask you to communicate personal data about yourself.

The term "personal data" refers to all data that can be used to identify an individual, which includes your name, surname, pseudonym, photograph, postal and e-mail addresses, telephone numbers, date of birth, data relating to your transactions on the site, details of your purchases and subscriptions, credit card numbers, and any other information you choose to give us about yourself

2. Purpose of this policy

The purpose of this charter is to inform you about the means we use to collect your personal data, in the strictest respect of your rights.

In this regard, we inform you that we comply, in the collection and management of your personal data, with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, in its current version and the RGPD in force since May 25, 2018.

3. Identity of the data collector

The person responsible for collecting your personal data is the company SCORPORATION, registered in the Lyon Trade and Companies Register under the number 902 583 517 with its registered office at 18 rue des roses 69730 Genay.

4. Collection of personal data

Your personal data is collected for one or more of the following purposes:

(i) To manage your access to and use of certain services accessible on the Site, (ii) To send newsletters (ii) To build up a file of registered members, users, customers and prospects, (iii) To send newsletters from Trainy, Planète Grandes Ecoles and our partner companies in the field of finance, audit, accounting and consulting, solicitations and promotional messages. In the event that you do not wish to receive such newsletters, we give you the option of expressing your refusal to do so at the time of collection of your data; (iv) To elaborate commercial statistics and of frequentation of our services, (v) To organize contests, lotteries and all promotional operations with the exception of the games of money and chance on line subjected to the approval of the Authority of Regulation of the Games on line, (vi) To manage the management of the opinions of the people on products, services or contents, (vii) To manage the possible litigations as for the use of our products and services, (viii) To respect our legal and lawful obligations

We inform you, at the time of collection of your personal data, if certain data must be filled in or if they are optional. We will also inform you of the possible consequences of failing to do so.

5. Recipients of the data collected

The staff of our company, the services in charge of control (auditor in particular), our business partners and our subcontractors will have access to your personal data, in particular via the subscription to our newsletters Trainy and Planète Grandes Ecoles. Each user may cancel his or her subscription to our newsletters at any time.

Your personal data may also be sent to public bodies, exclusively to meet our legal obligations, judicial officers, legal agents and bodies responsible for debt collection.

6. Transfer of personal data

Your personal data will not be transferred, rented or exchanged to third parties.

7. Duration of storage of personal data

(i) Concerning the data relating to the management of customers and prospects :

Your personal data will not be kept beyond the period strictly necessary to manage our commercial relationship with you. However, the data allowing to establish the proof of a right or a contract, having to be preserved under the respect of a legal obligation, will be it during the duration envisaged by the law in force.

Concerning possible canvassing operations aimed at customers, their data may be kept for a period of three years from the end of the commercial relationship.

Personal data relating to a prospect, who is not a customer, may be kept for a period of three years from the date of their collection or the last contact from the prospect.

At the end of this three-year period, we may contact you again to determine whether you wish to continue receiving commercial solicitations.

(ii) Regarding identification:

In the event of exercising the right of access or rectification, data relating to identity documents may be kept for the period provided for in Article 9 of the Code of Criminal Procedure, i.e. one year. If the right of opposition is exercised, these data may be archived for the period of limitation provided for in Article 8 of the Code of Criminal Procedure, i.e. three years.

(iii) Concerning data relating to bank cards:

The financial transactions relating to the payment of purchases and fees via the site are entrusted to a payment service provider who ensures the proper conduct and security.

For the purposes of the services, this payment service provider may be required to receive your personal data relating to your credit card numbers, which it collects and stores in our name and on our behalf.

We do not have access to this data.

In order to allow you to make regular purchases or to pay the related fees on the site, your credit card data is kept for the time of your registration on the site and at least until you make your last transaction.

By checking the box expressly provided for this purpose on the site, you give us your express consent to this storage.

The data relating to the visual cryptogram or CVV2, registered on your bank card, are not stored.

If you do not want your personal data relating to your credit card numbers to be stored under the conditions specified above, we will not store this data beyond the time necessary to complete the transaction.

In any case, the data relating to these may be kept, for the purpose of proof in the event of a possible dispute of the transaction, in intermediate archives, for the period provided for by Article L 133-24 of the Monetary and Financial Code, in this case 13 months following the date of debit. This period may be extended to 15 months to take into account the possibility of using deferred debit cards.

(iv) Concerning the management of the lists of opposition to receive prospecting:

The information allowing to take into account your right of opposition is kept at least three years from the exercise of the right of opposition.

(v) Concerning audience measurement statistics:

The information stored in the users' terminal or any other element used to identify users and allowing their traceability or frequentation will not be kept beyond 6 months.

8. Security

We inform you that we take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We also use or may use secure payment systems that comply with the state of the art and applicable regulations.

9. Cookies

Cookies are text files, often encrypted, stored in your browser. They are created when a user's browser loads a particular website: the website sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website's server.

We can distinguish two types of cookies, which do not have the same purpose: technical cookies and advertising cookies:

➢ Technical cookies are used throughout your browsing experience, in order to facilitate it and to perform certain functions. A technical cookie may, for example, be used to remember the answers entered in a form or the user's preferences regarding the language or layout of a website, when such options are available.

Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites displaying advertisements, announcements, widgets or other elements on the page displayed. These cookies can be used to carry out targeted advertising, i.e. advertising determined according to the user's navigation.

We use technical cookies. These are stored in your browser for a period that cannot exceed six months.

We do not use advertising cookies. However, if we were to use them in the future, we would inform you in advance and you would have the possibility to deactivate these cookies.

We use or may use Google Analytics which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the site, the number of pages viewed and visitor activity. Your IP address is also collected to determine the city from which you connect. The length of time this cookie is kept is mentioned in article 7 "Length of time personal data is kept" of this charter.

We remind you that you can refuse the deposit of cookies by configuring your browser. However, such a refusal could prevent the proper functioning of the site.

10. Consent

When you choose to communicate your personal data, you expressly give your consent to the collection and use of such data in accordance with the present charter and the legislation in force.

11. Access to your personal data

In accordance with the law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the right to obtain the communication and, if necessary, the correction or the suppression of the data concerning you, through an access on line to your file. You can also contact :

- e-mail address: [email protected] - postal address: 18 rue des roses 69730 GENAY

It is recalled that any person may, for legitimate reasons, object to the processing of data concerning him or her.

12. Modifications

We reserve the right, at our sole discretion, to modify at any time the present charter, in whole or in part. These changes will be effective upon publication of the new policy. Your use of the site following the entry into force of these modifications will be deemed to be recognition and acceptance of the new charter. If you do not agree with the new policy, you should no longer access the site.

13. Entry into force

This charter is effective as of January 5, 2019.