As we are aware of the importance of ensuring data confidentiality, VATEL has undertaken measures to ensure the protection of personal data.
The aim of the present data protection policy is to inform you of the undertakings and practical measures taken by VATEL to ensure that your personal data is kept confidential and protected.
The present confidentiality policy may evolve in order to comply with the legal and regulatory context as well as recommendations from the CNIL.
The present confidentiality policy applies when you visit any VATEL web site, when you access our products and services (enrollment in a school, reservation of a hotel, restaurant or spa) or when you take part in any VATEL events (hereinafter referred to as “Service(s).”
VATEL is thus responsible for your personal data as the processing party.
The present confidentiality policy could be complemented by additional elements detailed in all or a part of the Service provided.
3. TYPE OF DATA GATHERED
VATEL shall endeavor to gather and process only data that is strictly necessary in view of the purpose for which it has been processed (data minimization).
When you access one of our Services, you could be asked to provide some of your personal data while filling out our forms: the type of personal data specifically required will be indicated. You can decide not to submit the data requested, however, that could limit your access to the requested Service.
Personal data is gathered in three ways:
- data you provided;
- data supplied by third-party sources;
- and lastly, through the use of our Services that you may have.
3.1. Data you supplied
The Personal data directly provided by yourself will depend on your interaction with the Service and may include:
- contact information: the last name, first name, email address, street address, phone number and cell phone number;
- other data: the profile of a student or an alumnus, his or her profession, schooling, qualifications, the name of the school that was attended, graduation date and photo: www.vatelalumni.com;
- comments and additional information that you may submit, including requests for research, questions and information sent to the department in question.
3.2. Data supplied by third-party sources
We may also obtain your contact information and other personal information from our subsidiaries and other third-parties, including:
- Vatel Group companies with which we offer joint services; and/or
- sources available to the general public and data suppliers from whom we obtain data to verify and complete the information in our possession.
3.3. Data from using a Service, including cookies
A Service can automatically gather information from the way in which you interact with it, including:
- Information regarding the computer, the login environment, which includes the IP address, the type and browser version, the operating system and other software installed in your environment, the mobile platform, any technical data, error reports and execution data;
- Usage Data such as functions you have used, configurations you have selected, data on which you have clicked, including the date and time and pages were consulted, terms looked up, pages visited and researched related to the Service;
- Geographic information on Services based on the location of the user to give you more relevant content depending on your geographical location wherever you may be throughout the world.
We gather this data using our servers, cookies and miscellaneous technologies.
Cookies are small text files that can be read by a web server in the VATEL domain that has placed the cookie on your hard disk. We can use these cookies and other technologies to store your preferences and configurations, to help you when recording information and analyzing our site’s operations.
You can control cookies using the configurations in your browser as well as several other tools. Nonetheless, should you block certain cookies, you will no longer be able to log in, access certain parts or use all of our Services.
4. PROCESSING PURPOSES
According to relationships established with VATEL, we use your personal data to:
- Supply, activate and manage your access to the Service and your use of it;
- Process and respond to a request to enroll in a school, an order, a request for a brochure or a reservation;
- Monitor courses taken by students and their employment history as alumni;
- Supply technical support, a service or an additional product and thus ensure proper functioning of the Service and its securing.
- Improve the Service and our other products, our events and develop new ones;
- Propose personalized content to make the Service more relevant, matching your interests and your geographical location;
- Address your requests, queries, comments and concerns;
- Inform you of any modifications, updates and other announcements concerning the Service and our other products and services;
- Give you promotional messages and other information on our products, events and services, and any other updates concerning VATEL;
- Invite you to take part in our surveys on the use of the Service;
- Pinpoint user trends and develop data analysis, including for research, auditing, reporting and any other commercial operations to determine the effectiveness of our promotional campaigns and the assessment of our commercial performance;
- Comply with our legal obligations, solve any eventual litigations and respect our contracts.
If you are the manager of an entity listed in one of our Services, we will use your data to communicate with you regarding the subscription of your organization.
Should you supply us with information on users of your entity, we shall ensure to obtain their consent to use their personal data beforehand in order to supply them with our Services.
5. RECIPIENTS OF DATA
VATEL shall only communicate your personnal data to authorized and identified recipients.
The recipients of your personal data are the corresponding VATEL services.
6. PERSONAL DATA STORAGE
VATEL shall store your personal data if required to supply the Service and carry out the obligations you requested, or for other essential purposes such as complying with our legal obligations, for our commercial and financial archives, to settle any disputes, to maintain security, detect and prevent fraud and abuse and to execute the contract binding us with you.
VATEL shall only keep your data for the duration required in the operations for which it was gathered and thus in compliance with legislation in force.
8. PROCESSING LOCATIONS - TRANSFER OF PERSONAL DATA
Your personal data is stored and processed in France and in the United States for CRM data.
VATEL shall take measures, including the use of contracts, with the aim of ensuring that information continues to be protected where it is located in compliance with protection standards imposed by laws in force and thus has put in place Standard Contractual Clauses which have been approved by the European Commission and within the EU - US protection of private life framework when transferring data.
9. DATA SECURITY
VATEL shall ensure your personal data’s security by putting in place appropriate strengthened data protection using physical and logistics security measures.
10. PROTECTION OF CHILDREN’S PRIVACY
VATEL does not knowingly gather information on children under the age of 16 and VATEL’s internet sites thus do not target children under the age of 16.
11. YOUR RIGHTS
You have rights guaranteed by laws on the protection of private life and data implemented in Europe and several other countries, and according to which you can, free of charge:
- access your personal information;
- rectify or delete your personal data;
- restrict our processing of your personal data;
- object to processing;
- obtain a copy of your personal data stored by VATEL (portability).
You are the only person who can exercise these rights on your own data by contacting: VATEL Ambatoroka (Route d'Ambohipo) 101 Antananarivo - MGE-mail : firstname.lastname@example.org , with “GDPR” as the subject of your email and including a copy of your ID.
You can also file a complaint to the National Commission for Data Protection and Liberties (CNIL), the regulator for personal data in France.
The original version of this policy was written in French.
The French version shall thus be deemed to be the official version. Should there be any litigation regarding the present policy, the French version shall prevail over the English version and any other versions.
VATEL regularly updates the present confidentiality policy. All modifications will be posted on this page with the updated revision date.
Should you have any comments, questions or requests regarding the present policy or how your data is processed, please contact us at: VATEL Ambatoroka (Route d'Ambohipo) 101 Antananarivo - MGE-mail : email@example.com, with “GDPR” as the subject of your email and including a copy of your ID.
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