Personal Data Protection Policy
Last update: April 2021
1. Scope of application of the present personal data protection policy
The present personal data protection policy applies to all contents, provision of services and advice (information services, seminars, congresses, conferences, events, webinars) proposed via all the websites, social media accounts and paper media belonging to the company ALIXIO (hereinafter « ALIXIO ») and its subsidiaries performing personal data collection (hereinafter collectively the « Services »). Consequently, this policy does not apply to the websites/mobile applications/social media accounts/paper media of third parties nor to the Services proposed by the latter.
ALIXIO complies with the French regulations on personal data protection (including the Act of 6 January 1978, as amended, on “Informatique, Fichiers et Libertés”) and Regulation 2016/679 of 27 April 2016 (hereinafter, the « GDPR »).
The present personal data protection policy shall apply as a supplement to the General Conditions of Use of the ALIXIO Services, where applicable.
2. Collection of the data you submit to Alixio
As a Data Processing Manager within the meaning of the GDPR, ALIXIO is responsible for the personal data that it collects.
The personal data that you provide when filling in electronic and printed forms, subscribing to online services, uploading contents online, or sending to ALIXIO directly emails, posted letters, etc. :
- First name;
- Family name;
- Email addresses;
- Telephone numbers;
- Postal addresses (including the “département”);
- Date of birth;
- Photographs; videos;
- Your opinion concerning the Services;
- Any specific request that you might send to ALIXIO (mainly for purposes of archiving and handling your request);
- Job titles;
- Curriculum Vitae;
- Letter of motivation;
- IP address;
- Type of organisation (company, school, university, etc.), name of the organisation, size of the organisation, department and job title;
- Level of education
- ALIXIO could also ask you to reply to opinion polls that it uses in order to improve its Services.
Data not collected from you directly: ALIXIO may decide to collect personal data concerning you from third parties. These sources are public and non-public. ALIXIO will not fail to provide you, during the first communication, with all information on the processing and source of the data, and all useful information regarding the exercise of your right to object to, erase, limit, access and correct data, and the right to portability and to decide the fate of the data after death.
3. Cookies and other trackers
General provisions regarding cookies and the automated collection of your personal data
During your visits to the ALIXIO websites, and more generally during use of the Services, ALIXIO may collect, in accordance with the applicable legislation and with your prior agreement where required, information concerning the terminals on which you use its Services or the networks from which you access its Services, such as, in particular: your IP addresses, connection data, types and versions of web browsers used, types and versions of your browser’s plugins, operating systems and platforms, data concerning your clickstream on its websites, and in particular your clickstream on the various pages of its websites, the contents that you consult, search terms used, the length of time consulting certain pages, interactions with the page and any telephone number used to contact ALIXIO.
Among the technologies used to collect this information, ALIXIO employs cookies in particular.
Overview of the cookies used
Cookies are small files of characters and numbers downloaded onto your terminal when you access ALIXIO’s websites and social media accounts.
These cookies may be of various kinds:
Functionality cookies and cookies required for functioning of the Services
These cookies are inserted exclusively by ALIXIO and are necessary for proper functioning of the Services that you use and to access the website functionalities designed to ensure your browsing comfort. They may also allow adaptation of the view of ALIXIO websites to the preferences of your terminal and the viewing software installed on your terminal.
The ALIXIO websites and social media accounts contain analytic cookies in order to know their number of visits, their use and their performances, and to improve their functioning and their ergonomics (e.g., pages most commonly consulted, visitors’ searches, etc.).
The Services use website statistical analysis tools such as Google Analytics.
Sharing cookies (social links)
To enable you to share articles and contents with your friends, or to comment on them, the ALIXIO websites contain sharing links to social media (YouTube, Twitter, LinkedIn). When you use these share buttons, a third-party cookie is installed. If you are connected to the social media when you are browsing on the ALIXIO websites and social media accounts, the share buttons can link the consulted contents to your user account.
However, ALIXIO informs you that disabling functionality cookies could prevent the use of its websites in full or in part.
4. Purposes of collection and processing of your personal data
Use of your personal data that you submit to ALIXIO, with your prior consent where required, takes place within the following framework:
- For provision of the Services on a non-paying basis;
- To enable you to ask for and obtain information concerning the company and its Services;
- To enable you to open and manage an account/profile in order to obtain the materials (pdf, video, etc.) necessary for use of the Services and for technical support;
- To enable you to subscribe to the Services;
- To enable you to register for seminars, conferences, webinars and other events;
- To allow you to enjoy interactive, personalised use of the ALIXIO websites and third-party applications;
- To craft the ALIXIO websites so that they may be better suited to your use and your terminal;
- To identify your needs and centres of interest and offer you the most suitable Services;
- To enable ALIXIO to manage surveys and opinion polls aimed at improving the Services and their contents;
- To protect you against fraudulent activities;
- To send you regularly news and information on the Services, marks, operations and/or websites and social media accounts of ALIXIO that could attract your interest, and to send you reports on ALIXIO events;
- To reply to any request by government and/or judicial authorities, and in particular to communicate usage data at the request of a judicial authority in accordance with legal provisions.
- To enable us to manage recruitments following candidacies that have been submitted to us by you.
Marketing emails: In accordance with the applicable legislation and with your consent where required (which the company collects by means of an opt-in), ALIXIO may use the data you provide it with on its websites and paper media for purposes of commercial prospecting under the conditions of Article L.34-5 of the Post and Electronic Communications Code (Code des Postes et des Communications Electroniques), e.g. to send you its newsletters, send you invitations to its events, and propose to you offers from its partners or any other notice that could interest you. You can withdraw your consent at any time by clicking on the desubscription link provided in each of ALIXIO’s notices or by contacting it using the contact data provided below.
5. Retention period for your personal data
The retention period for your personal data may vary depending on the purpose of the collection. The retention period for your personal data will be four years after the termination of the commercial relationship with ALIXIO (or the last contact on your part if you are merely a potential client). At the end of this four-year period, ALIXIO may resume contact with you to know whether you wish to continue receiving commercial solicitations. If there is no explicit positive reply from you, the personal data will be deleted or archived in accordance with the provisions in force.
Please note that ALIXIO could retain certain personal data concerning you when the law requires it to do so or when ALIXIO has a legitimate reason to do so. This is the case, for example, if ALIXIO considers that you have committed fraud or infringed the General Conditions of Use of the Services and Sale.
The information stored in your terminal (e.g. cookies), and any other element used to identify you and allowing its traceability, as well as the raw data on numbers of visits linked with an identifier, will not be stored for more than thirteen months.
The data of a candidate who is not recruited is stored for a period of two years from the last contact, unless said candidate requests the destruction of their dossier or if ALIXIO is authorised by the candidate to store it for a longer time.
6. Recipients of your personal data
The personal data collected are intended for ALIXIO.
Your personal data are disclosed to no third party, except in the following cases:
- When you have given your prior agreement for the sharing and/or disclosure of your personal data, including via the functionalities proposed as part of the Services;
- When ALIXIO has to share your personal data with business partners (as authorised beforehand by you), suppliers, service providers and in particular technical service providers for the purpose of provision of the Services, resolution of operating problems concerning the Services, or else in order to provide promotional information related to the Services proposed by ALIXIO;
- ALIXIO may decide to pass your personal data on to subcontractors, in particular for payment processing, data analysis, handling mailing campaigns, management of subscription and subscription renewal information flows, hosting of the Services, or treatment of certain marketing aspects of the Services;
- ALIXIO may have to disclose your personal data to third parties pursuant to a law or regulation, or by virtue of a decision of a competent regulatory or judicial authority, or else, if it proves necessary, in order to protect its rights and interests;
- In the event of a change of control of ALIXIO or the disposal of all or part of its assets, ALIXIO will be authorised to transfer your personal data.
ALIXIO does not pass your personal data on to third-party advertisers for targeted marketing purposes unless you have consented beforehand. ALIXIO may use and share with third parties certain technical data or non-personal aggregated data relating to your browsing on the ALIXIO websites. The collection, processing and disclosure of such anonymised data may not be subject to the restrictions set out in the presents.
7. Storage/hosting of your personal data
Your personal data are stored/hosted either on ALIXIO’s servers or on the servers of its service providers located in the European Union.
8. Security of your data
ALIXIO implements security measures to protect the security of your personal data. ALIXIO uses encryption to protect sensitive information transmitted online (HTTPS browsing, etc.). Only employees who need to perform a specific job (e.g., invoicing or customer service and the subscription service) have access to personal data. Personal data storage is performed in secure environments.
9. CNIL and GDPR: Right to access, correct, remove and object to data, the right to data portability and the right to limit processing and to decide the fate of the data after death
In accordance with the French law on personal data protection and the GDPR, you have rights to access, correct, remove and object to data, the right to portability of your personal data and the right to limit processing and to decide the fate of said data after death. These various rights can be exercised with the Data Processing Manager, ALIXIO.
You can exercise your rights of access, modification (if you detect an error in the entry of your data or if you consider them incomplete or ambiguous) and objection.
You also have the right to portability of your data, i.e. the right to receive personal data that you have provided to ALIXIO in a structured, commonly used format (Excel spreadsheet file, for example) that is machine-readable, and to have the data transmitted to another Data Processing Manager, for processing operations performed by automated processes for which you have given your consent.
You can give ALIXIO instructions concerning the procedures for storage, removal and communication of your personal data to be employed after your death.
You can ask ALIXIO to delete all the personal data concerning you that is held by ALIXIO. However, please note that ALIXIO may keep a trace of your data for archiving purposes (especially when required to do so by law).
Lastly, in accordance with Article 18 of the GDPR, you may also ask to limit access to processing, for example:
- when the accuracy of your personal data is disputed by you – this during a period allowing ALIXIO to verify the accuracy of your personal data;
- when ALIXIO no longer needs your personal data for processing purposes but they are still needed by you for the recognition, exercise or defence of your rights in court.
You may exercise all the aforementioned rights at the following address:
137 rue de l’université, 75007 PARIS
For the attention of the DPO.
email@example.com / 01 53 10 79 73
For your full information, you are entitled to refer the matter to the French data protection agency CNIL (Commission Nationale de l’Informatique et des Libertés, whose contact data are shown at the address https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) if ALIXIO has not responded to your request within a period of one month after receiving it. If necessary, this period may be extended by two months, taking into account the complexity and quantity of requests.
10. Contact data of the Data Protection Officer
ALIXIO has appointed a Data Protection Officer (hereabove and hereinafter, « DPO ») tasked with ensuring the correct application of the regulations in force, and in particular compliance with the rights referred to in the preceding article.
For any other questions relating to the present personal data protection policy and for any request concerning your personal data, you may contact the DPO using the contact data shown above.
11. Amendment of our personal data protection policy
ALIXIO may occasionally decide to amend the present personal data protection policy. When this occurs, ALIXIO will inform you or solicit your agreement if necessary by virtue of the legal provisions. In any case, ALIXIO invites you to go regularly to the page dedicated to the present personal data protection policy to learn of any amendments made.