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Institut de Francais Privacy Notice (october 2019)
The Institut de Francais “we”, “us” and “our”) takes the
issue of
safeguarding your privacy seriously. Our Privacy Notice describes what information we collect
from our
students and the way in which we use this information to better serve your needs.
What is Personal Information?
Personal information is any information about you as an identifiable individual. The personal
information
that we process includes:
Basic information – such as name, age, gender, passport information and
publicly
available photograph;
Contact information – such as your home address, zip/postal code, email
address and
phone number;
Financial information – such as transaction history;
Health information where disclosed and relevant to the provision of services;
Preferences – such as special requests, service issues and other
preferences for
your stay;
Technical information – such as information about the device you use to
interact
with us (including the unique device identifier, hardware model, operating system and version,
and
Correspondence – when you contact us, such as to send an enquiry or make
a request,
any correspondence or application may be kept and added to your personal information.
How do we use your personal information?
We use your personal information for the following purposes:
to enable you to use our website
to help us identify you and any accounts you hold with us;
to assist us in making your reservation.
to confirm prior transactions and reconcile statements or invoices;
to contact you in relation to matters that arise from your stay with us;
On what basis do we use your personal information?
We use your personal information on the following basis:
to comply with legal and regulatory obligations, including financial reporting
requirements imposed by government regulators and our auditors;
to enter into agreements with you, and to perform our agreement to provide
services to you
when you stay with us;
for legitimate business purposes – using your personal information helps
us to
operate and improve our business and minimise any disruption to the services that we may offer
to you. It
also allows us to make our communications with you more relevant and personalised to you, and to
make your
experience of our services more efficient and effective;
because you have given your consent – at times we may ask for your
consent to allow
us to use your personal information for one or more purposes. See the Your Rights section for
more
information about the rights that you have if we process your information on the basis of your
consent; or
for the establishment, exercise or defence of legal claims or proceedings.
How is personal information collected?
We collect your personal information while monitoring our technology tools and services,
including email
communications sent to and from Institut de Francais.
Otherwise, we gather information when you provide it to us, or interact with us directly, for
example:
when you fill our online application form.
We also receive information about you from other sources, such as our business partners. We
combine
information that we have about you from various sources, including the information that you have
provided to
us.
We may also collect information from you through the use of cookies, when you visit our website.
For more
information about our use of cookies, please see our Cookie Notice.
How do we protect personal information?
We use a variety of security measures and technologies to help protect your personal information
from
unauthorised access, use, disclosure, alteration or destruction, consistent with applicable data
protection
and privacy laws. For example, we allow only encrypted communications from all of our web forms.
What information is not secure?
We endeavor to protect the privacy of your account and other personal information that we hold in
our
records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use,
hardware or
software failure, and other factors, may compromise the security of user information.
Also, while we
endeavor to put adequate contractual protections in place, we cannot guarantee the security of
any personal
information in databases hosted by third parties.
It is important to note that any e-mail communication is not secure. This is a risk inherent in
the use of
e-mail. Please be aware of this when requesting information or sending forms to us by e-mail
(for example,
from the “Contact Us” section of our website). For your protection, our e-mail
responses to you
will not include any confidential information.
Finally, to be prudent, please be sure to always close your browsers when you are done using a
form or the
reservation site. Although the session will terminate after a short period of inactivity, it is
best to
close your browsers immediately upon completion, especially when using a public computer.
What personal information may be provided to third parties?
We may share certain of your personal information with:
our professional advisors and auditors; and
local or foreign regulators, governments, courts, law enforcement and national
security
authorities.
You may advise the Institut de Francais if you do not want personal preferences shared.
Where a third party is engaged by the Institut de Francais to provide services on our behalf, we
ensure these
parties protect your Personal Information in a manner consistent with the principles articulated
in this
Privacy Notice.
If the Institut de Francais suspects any unlawful activity is taking place, it may investigate
and/or report
its findings or suspicions to the police or other relevant law enforcement agency.
Transfers of your personal information outside your home country
Accessing your personal information
We understand that you may like to know what personal information we hold about you. We are happy
to assist
you with your request. To protect your personal information, however, we require that you prove
your
identity to us at the time your request is made.
When you make a request in person, we will require you to produce some form of photo
identification such as a
passport or a driver's license and you will be asked to sign a request form.
Where you make a request by other means, we request you contact us in writing via email, fax or
letter
including a copy of a government issued identification and signature. We require home and
business addresses
and phone numbers so we can check them with our files and satisfy ourselves as to your identity.
The above information is required to create an audit trail of how the request has been handled.
The Institut de Francais reserves the right to decline access to your personal information under
certain
circumstances as permitted by law. If your personal information is not disclosed to you, you
will be
provided with the reasons for this non-disclosure.
Other rights
You may also be entitled to:
request the correction and/or deletion of your personal information;
request the restriction of the processing of your personal information, or
object to that
processing;
opt out from processing of your personal information for direct marketing
purposes;
withdraw your consent to the processing of your personal information (where
the Institut
de Francais is processing your personal information based on your consent); and
request the receipt or transmission to another organisation, in
machine-readable form, of
the personal information you have provided to the Institut de Francais.
Where you are given the option to share personal information with the Institut de Francais, you
can always
choose not to do so.
If you object to the processing of your personal information, or if you have provided your
consent to
processing and you later choose to withdraw it, we will respect that choice in accordance with
our legal
obligations.
This could mean that we are unable to perform the actions necessary to achieve the purposes of
processing
described above (see ‘How do we use your personal information?’) or that you are
unable to make
use of the services offered by us.
After you have chosen to withdraw your consent the Institut de Francais may be able to continue
to process
your personal information to the extent required or otherwise permitted by law.
If at any time you wish to exercise any of these rights, you can do so by:
via e-mail at rgpd@institutdefrancais.com
Alternatively, you can contact our Chief Privacy Officer via the details in the ‘Contact
us’
section.
How long is my Personal Information retained?
Your personal information will be stored for the period of time required by law in the French
jurisdiction,
i.e. 5 years. This may involve retaining information following your stay. We will delete your
personal
information once it is no longer required for any of the purposes described above.
We will also keep your personal information where we need to do so in connection with a legal
action or an
investigation involving 5 years
Any financial information the Institut de Francais retains will be protected under the terms of
this Privacy
Notice.
If you have additional questions regarding the law or if you feel we have not treated your
personal
information appropriately, you may contact The Privacy Commissioner of France at the following
address:
CNIL - 3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
You may also have the right to complain to the local data privacy supervisory authority in your
home country.
Contact Us
If you have any questions or concerns regarding this Privacy Notice, please contact our Chief
Privacy Officer
by writing to the following address:
Chief Privacy Officer
Institut de Francais
23 avenue Général Leclerc
06230 Villefranche sur Mer