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INSEAD PRIVACY POLICIES
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Version Française
PERSONAL DATA PROTECTION CHARTER
1. Why is this Charter important?
2. Glossary of the main legal terms used in this charter
3. Who is responsible for use of your data in the framework of your
relationship with our departments?
4. Why do we collect your personal data and on what grounds?
5. What personal data do we collect?
6. Who do we share your personal data with?
1. Sharing your personal data with INSEAD affiliates
2. Sharing of your personal data with our partners
3. Other sharing
7. How long do we keep your personal data?
8. Hyperlinks to external sites
9. What are your rights over your personal data and how can you exercise them?
1. Access right
2. Correction right
3. Deletion right
4. Right to be forgotten
5. Right to restrict processing
6. Objection right
7. Right to digital death
8. Portability right
10. Is your personal data sent abroad?
1. Data transfer within Europe
2. Data transfer outside Europe
11. Data security
12. Do you wish to contact us about this Personal Data Protection Charter
and/or make a complaint to a personal data protection authority?
1. Do you have a question or suggestion concerning this Personal Data
Protection Charter?
2. Do you feel that we are not adequately protecting your personal data?
3. Submitting a complaint to CNIL, the French data protection authority
13. How do you know if this Personal Data Protection Charter has been amended?
1- WHY IS THIS CHARTER IMPORTANT?
Your privacy is a priority for INSEAD. We are committed to protecting the
personal data of our customers, prospects and online users (hereinafter “you”),
to processing it with the utmost care and ensuring it has the best level of
protection in accordance with Regulation 2016/679 of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and
on the free movement of such data (“the GDPR”) and the Law of 6 January 1978 as
amended (hereinafter “French law”).
This charter informs you about:
* The personal data we collect about you and the reasons for that collection
* The conditions for use of your personal data
* Your rights over your personal data and how to exercise them
INSEAD operates this website, accessible to the public at the URL address
https://www.insead.edu (hereinafter “the Site”). The Site is designed to make
available to web-users (i.e. any natural person or legal entity that visits or
uses the Site, hereinafter “the users” or “you”) information presenting the
training programmes and services offered by INSEAD as well as its news (events,
publications, etc.).
The Site also offers functionalities allowing users to contact INSEAD: contact
request, request for brochures, registration for an event or newsletter,
speculative application or response to a job offer, etc. The Site also offers
users the possibility of submitting an application form online for a training
programme offered by INSEAD and makes available to them a personal space on an
online platform (https://apply.insead.edu) allowing users to complete their
application and track its progress and completion.
During your browsing and interaction with the Site or with INSEAD, INSEAD may
need to collect and process personal data about you, in the capacity of data
controller.
2- GLOSSARY OF THE MAIN LEGAL TERMS USED IN THIS CHARTER
Terms frequently used in this CharterDefinitions provided by the
GDPRExplanations of terms in everyday languagePersonal data (hereinafter
“personal data”)Any information relating to an identified or identifiable
natural person (hereinafter a "data subject"); an "identifiable natural person"
is considered to be a natural person who can be identified, directly or
indirectly, by reference to an identifier such as a name, identification number,
location data, an online identifier or one or more elements specific to his/her
physical, physiological, genetic, psychic, economic, cultural or social
identity.All types of information relating to a natural person, i.e. an
individual, directly or indirectly identifiable as a person distinct from other
persons.
For example: a name, a photo, a finger print, an email address, a telephone
number, a social security number, an IP address, a voice recording, your
browsing data on a website, data linked to an online purchase, etc.Data
protection officerThe notion of data protection officer is not defined by the
GDPR.The data protection officer (DPO) is responsible within the company for
compliance with the GDPR and applicable national laws as well as our policies
and practices for managing your personal data. He/she is also responsible for
liaising with the supervisory authorities. The DPO is your first point of
contact for any request concerning your personal data.ProcessingAny operation or
group of operations whether or not they are carried out with the aid of
automated processes and applied to data or personal data sets, such as the
collection, recording, organisation, structuring, conservation, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, blocking,
erasure or destruction.
Any use of personal data, regardless of the process used (recording, organising,
conservation, modification, reconciliation with other data, transmission, etc.
of personal data).
For example, use of your data for the purposes of order management, delivery,
sending newsletters, etc.
Data controllerThe natural person or legal entity, the public authority, the
agency or other body which, alone or in conjunction with others, determines the
processing purposes and methods.The person, public authority, company or
organisation which manages your data and decides how it is used, including
deciding whether to create or delete a process and determining why your data
will be processed and to whom it will be transmitted. The data controller is the
main party responsible for compliant protection of your data.SubcontractorThe
natural person or legal entity, public authority, agency or other body which
processes personal data on behalf of the controller.Any natural person or legal
entity that carries out processing tasks on the instructions and under the
responsibility of the data controller.
3- WHO IS RESPONSIBLE FOR USE OF YOUR DATA IN THE FRAMEWORK OF YOUR RELATIONSHIP
WITH OUR DEPARTMENTS?
The data controller responsible for processing your personal data is INSEAD, an
Association Loi de 1901 (a non-profit association under French law) and a
private higher education institution whose registered office is at Boulevard de
Constance, 77305 Fontainebleau Cedex, France, declared to the prefecture of
Paris, France, under number 59/849 on 28/08/1959, tel: +33 1 60 72 40 00, email
address: legal.department@insead.edu (hereinafter “INSEAD” or “us”).
INSEAD has appointed a data protection officer in the person of Richard Rondoux,
Managing Partner BRG Avocats. He is particularly responsible for independently
ensuring internal application of the rules governing protection and management
of your data and liaison with the supervisory authorities. Here are the contact
details for Richard Rondoux:
Mr. Richard Rondoux
BRG Avocats
8 Avenue Victor Hugo
75116 Paris
4- WHY DO WE COLLECT YOUR PERSONAL DATA AND ON WHAT GROUNDS?
We collect personal data about you for various reasons.
In general terms, INSEAD collects and uses your personal data to function
effectively and optimise your experience with its departments. Generally, this
processing is necessary for:
* the management, processing and tracking of your requests for the attention of
INSEAD, with some of these operations being necessary to perform contractual
or pre-contractual measures taken at your request (as part of a job
application or a training programme or following a request to register for an
event);
* to pursue INSEAD’s legitimate interests in the framework of management and
supervision of admissions to our training programmes, the management and
organisation of its prospecting, canvassing and communication operations and
marketing generally;
You should also be aware that we can only collect and use your personal data if
that use is based on one of the legal grounds determined by the GDPR (e.g. your
consent or performance of a contract concluded with us).
The table below specifically lists the purposes for use of your personal data by
INSEAD, based on one or more of the following legal grounds:
* Your consent
* Performance of a contract concluded with you
* Compliance with a legal obligation
* Safeguarding your vital interests
* Performance of a public service mission
* Legitimate interests of INSEAD in collecting your personal data
Purposes of collecting your personal data
1. Information exchange
Management, processing and monitoring of your requests and exchanges with INSEAD
by means of or initiated via the Site (request for contact, information or
brochures, registration for an event, reservation for a training session,
recommendation of a training programme, job application, etc.) and INSEAD's
relations with its contacts (prospects, students, alumni, web-users, etc.)
generally.
2. Applications and admissions
Management, processing, study and monitoring of applications and admissions for
our training programmes, including provision of a personal space on the online
platform (https://apply.insead.edu) allowing users to complete their application
file and track its progress and completion, or assess and select applications.
3. Prospecting & Marketing
Carrying out prospecting, canvassing loyalty-building, communication and
marketing operations in a broad sense, by email, letter or telemarketing
(newsletters, invitations to events, reminders to training programme applicants,
meeting proposals, etc.), including associated technical operations (e.g.
segmentation and targeting in order to personalise exchanges, enhancement,
targeted advertising etc.).
4. Human resources
Management, processing and monitoring of applications and pre-recruitment
procedures, including assessment of professional profiles and selection of
applications, particularly using recruitment assistance methods and techniques,
as well as the creation of an application file (or CV library) in order to fill
certain positions (offers corresponding to your profile which could also be sent
to you for that purpose if you have applied on our Site).
5. Site management
Management of the Site, including:
* access to and benefit of the Site functionalities
* understanding and study of users’ use of the Site and their browsing
behaviour in order to improve our online communications
* improvement of optimisation of Site content quality and functionalities
* Site administration, particularly for the purposes of security, and for
identification and diagnostic of problems which may affect Site servers
* completion and preparation of studies, analyses, reports and statistics,
particularly concerning the Site audience or users’ browsing of the Site
* management and processing of requests from Site users and, more generally,
INSEAD's contacts, in order to exercise their personal data protection rights
6. Laws and regulations
Compliance with legal and regulatory obligations, particularly resulting from
INSEAD's activity.
7. Campus Management and Security
Collection, use and storage of data relating to campus management and security,
including:
* Campus logistics and general services
* Video surveillance
* Registration of visitors (i.e. students, staff, service providers and other
visitors)
* Physical access control, including monitoring the implementation of measures
to limit the spread of disease and ensure institutional safety
5- WHAT PERSONAL DATA DO WE COLLECT?
Your personal data is particularly collected and processed, entirely or
partially, when you browse the Site and enter information in its data collection
forms (brochure requests, registration for events, applications for our training
programmes, etc.) and, more generally, in the framework of your relations and
exchanges via the Site and subsequent (online or offline) communication with
INSEAD.
Generally, your data is therefore collected directly from you under the
circumstances mentioned below.
In addition to that information, you are informed that the data we collect and
process about you may be enhanced by us via information sources (other web
platforms provided by INSEAD, rental of files, recommendations or information
from third parties, etc.).
Furthermore, more specifically in relation to the information processed in this
respect by our recruitment operations, we use the information you send us by
email to incorporate into our file of applicants (CV library). However, we may
also contact third parties (e.g. recruitment agencies, previous employers,
internship supervisors or clients you have worked with in previous roles) to
collect information about you in order to study your application.
Within the Site, you are informed of the compulsory nature of providing your
personal data on each collection form by the presence of an asterisk alongside
the relevant field(s). Where no asterisk is present, the requested information
is optional.
If the compulsory information is not entered, the request associated with that
collection of personal data (e.g. brochure request, registration for an event,
application for a training programme, etc.) may not be able to be processed or
its processing may be delayed.
In respect of optional information requested, they are generally designed to
provide us with a better knowledge of Site users and their preferences. INSEAD
encourages users to provide this information in order to help ensure that the
contents of our Site remain relevant to your interests and needs.
6- WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In the course of our activities, we may need to share your personal data.
Obviously, whenever we do so we always ensure optimal protection of your
personal data.
6.1- SHARING YOUR PERSONAL DATA WITH INSEAD AFFILIATES
We may transmit your personal data to INSEAD affiliates. Since we wish to be as
transparent as possible, below you will find a list of INSEAD affiliates with
whom we share your data and their locations.
Recipients involved in sharing your personal dataLocation of
recipientsRepresentatives and branches of INSEAD in FranceFranceRepresentatives
and branches of INSEAD around the world
INSEAD, 1 Ayer Rajah Avenue, Singapore 138676
INSEAD Middle East Campus in Abu Dhabi
Al Khatem Tower, ADGM Square, Al Maryah Island
PO Box 48049, Abu Dhabi, United Arab Emirates
INSEAD NORTH AMERICA, c/o Bencivenga Ward & Company, CPAs, PC
420 Columbus Avenue
Suite 304, Valhalla NY 10595-1381
USA
6.2- SHARING OF YOUR PERSONAL DATA WITH OUR PARTNERS
Any of our service providers and contractual and commercial partners that may be
involved in processing the above-mentioned personal data may have access to your
personal data. We may also share your data with external institutions for the
purpose of participating in university/school rankings.
6.3- OTHER SHARING
With public authorities, in response to legal requests, including to respond to
national security requirements or application of the law.
In the context of a transaction, such as a merger, acquisition, consolidation or
sale of assets, we may need to share your personal data with buyers or sellers.
7- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
INSEAD has determined precise rules concerning how long we retain your personal
data. This length of time varies depending on the different purposes and must
take into account any legal obligations to retain some of your data.
The retention time within INSEAD has been defined to allow us to process your
requests (brochures, contacts, registration for an event, job application or
registration for a training programme, etc.), manage and monitor them and/or
complete our prospecting, canvassing loyalty-building, communication and
marketing operations, while complying with the principle of proportionality
according to which personal data must not be retained for longer than necessary
to fulfil the purpose for which it was collected.
It is nevertheless specified that all of this data may be retained for longer
than the lengths of time mentioned in this article:
* either with your consent
* or in the form of archives, to respond to any legal or regulatory obligations
applicable to INSEAD or for the legal limitation or objection periods
* or in the form of data reused for the purposes of logs, statistics or
research
8- HYPERLINKS TO EXTERNAL SITES
This Site includes links to third-party websites. Those sites are not managed or
updated by INSEAD and are therefore not covered by this charter. INSEAD does not
have any control over the content of those websites, nor over their
confidentiality policies, their use of personal data, use of cookies, or the way
in which they collect, process and store that data. You are therefore advised to
consult the terms and conditions for collecting and using personal data
established by those external sites before sending them any information.
9- WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA AND HOW CAN YOU EXERCISE THEM?
We wish to inform you as clearly as possible of your rights over your personal
data. We would also like to make it as easy as possible for you to exercise
those rights.
Below you will find a summary of your rights with a description of how to
exercise them.
9.1- ACCESS RIGHT
You can ask us to access all of the following information concerning:
* The categories of personal data we collect about you
* The reasons we use it
* The categories of persons to whom your personal data has been or will be
communicated, particularly persons located outside Europe
* The length of time we retain your personal data in our systems
* Your right to ask us to correct or delete your personal data or limit the use
we make of your personal data and your right to object to that use
* Your right to file a complaint with a European data protection authority
* Information concerning their source, when we have not collected your personal
data directly from you
* The way in which your personal data is protected when it is transferred to
non-European countries
To do this, please simply contact us via email at the address
5555-itservicedesk@insead.edu, with the subject line “access right: personal
data”, attaching a copy of your identity document showing your signature as well
as a brief description of the information you want to access. Unless you
indicate otherwise, you will receive the information requested free of charge in
electronic format within one month of receipt of the request, two months in the
case of a request requiring more in-depth research
If you are unable to access your information by email, you can send us your
request by post at the following address:
Legal Department
INSEAD
Boulevard de Constance
77305 Fontainebleau
France
In the case of a written request, it must be signed and accompanied by a copy of
your identity document bearing your signature. The request must specify the
address to which the response should be sent. A response will then be sent to
you within one month following receipt of the request, two months in the event
of a request requiring more in-depth research or in the event that INSEAD
receives an excessive number of requests.
9.2- CORRECTION RIGHT
You can ask INSEAD to correct and/or update your personal data.
You simply need to send an email to 5555-itservicedesk@insead.edu stating your
full name and with the subject line “correction right: personal data”, along
with a copy of your identity document showing your signature.
Also do not forget to indicate the reason for contacting us in the body of your
email, i.e. correction of inaccurate information and the information to modify,
with proof of the correct information where relevant and if you have it.
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a copy of your
identity document bearing your signature. The request must specify the address
to which the response should be sent. A response will then be sent to you within
one month following receipt of the request, two months in the event of a request
requiring more in-depth research or in the event that INSEAD receives an
excessive number of requests.
9.3- DELETION RIGHT
You can also contact us at any time to ask us to delete your personal data held
by us, in one of the following situations:
* Your personal data is no longer necessary in respect of the reasons for which
it was collected or otherwise processed
* You have withdrawn the consent you provided as a basis for processing your
personal data by INSEAD
* For your own reasons, you consider that one of the forms of processing
infringes your privacy and causes you excessive harm
* You no longer wish to receive marketing communications from us
* Your personal data is not processed in accordance with the GDPR and French
law
* Your personal data must be deleted to comply with a legal obligation
stipulated in European Union law or national law applicable to INSEAD
* Your personal data has been collected as the result of an offer by a website
aimed at children
You simply need to send an email to 5555-itservicedesk@insead.edu stating your
full name and with the subject line “deletion right: personal data”, attaching a
copy of your identity document showing your signature. Also do not forget to
indicate the reason for contacting us in the body of your email (e.g. deletion
of your data when you have withdrawn the consent you provided as a basis for
processing your personal data).
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a photocopy of
your identity document bearing your signature. The request must specify the
address to which the response should be sent. A response will then be sent to
you within one month following receipt of the request, two months in the event
of a request requiring more in-depth research or in the event that INSEAD
receives an excessive number of requests.
However, it may be that we are unable to accede to your request to be forgotten.
It should be remembered that this right is not absolute. We need to weigh it
against other important rights and values, such as freedom of expression,
compliance with a legal obligation applicable to us or important public interest
reasons.
9.4- RIGHT TO BE FORGOTTEN
Our Site may contain personal data concerning you. If you no longer wish for it
to be displayed, you can ask us to delete it in one of the following situations:
* Your personal data is no longer necessary in respect of the reasons for which
it was collected or otherwise processed
* You have withdrawn the consent you provided as a basis for processing your
personal data by INSEAD
* For your own reasons, you consider that one of the forms of processing
infringes your privacy and causes you excessive harm
* You no longer wish to receive marketing communications from us
* Your personal data is not processed in accordance with the GDPR and French
law
* Your personal data must be deleted to comply with a legal obligation
stipulated in European Union law or national law applicable to INSEAD
We are also obliged to take reasonable measures to inform other companies (data
controllers) that process the personal data for which you have asked for all
links and copies to be deleted.
To have information about you on our website deleted, simply send an email to
5555-itservicedesk@insead.edu stating your full name and with the subject line
“right to be forgotten: personal data”, attaching a copy of your identity
document showing your signature. Also do not forget to indicate the reason for
contacting us in the body of your email, along with the precise web address
(URL) of the page in question.
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a photocopy of
your identity document bearing your signature. The request must specify the
address to which the response should be sent. A response will then be sent to
you within one month following receipt of the request, two months in the event
of a request requiring more in-depth research or in the event that INSEAD
receives an excessive number of requests.
However, it may be that we are unable to accede to your request to be forgotten.
It should be remembered that this right is not absolute. We need to weigh it
against other important rights and values, such as freedom of expression,
compliance with a legal obligation applicable to us or important public interest
reasons.
9.5- RIGHT TO RESTRICT PROCESSING
You have the right to ask us to restrict your data, i.e. marking your personal
data held by us (e.g. b y temporarily moving your data to another processing
system or locking your data to make it inaccessible), in order to restrict its
future use.
You can exercise this right when:
* the accuracy of the data in question is disputed
* Your personal data is not processed in accordance with the GDPR and French
law
* the data is no longer necessary to fulfil the initial purposes but cannot yet
be deleted for legal reasons (e.g. official recording, the exercise or
defence of your rights in legal proceedings)
* a decision concerning your processing objection is pending
In the case of a restriction on processing, your personal data shall no longer
be subject to any processing without your prior agreement, with the exception of
its retention (storage).
Your personal data may still be processed for the purpose of official recording,
the exercise or defence of your rights in legal proceedings, or to protect the
rights of another natural person or legal entity, or else on important grounds
of public interest in the European Union or Member State.
In the case of a restriction on processing of some of your personal data, we
will keep you informed of the date when the measure will be lifted.
You simply need to send an email to 5555-itservicedesk@insead.edu stating your
full name and with the subject line “restriction right: personal data”, along
with a copy of your identity document.
Also do not forget to indicate the reason for contacting us in the body of your
email.
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a copy of your
identity document. The request must specify the address to which the response
should be sent. A response will then be sent to you within one month following
receipt of the request, two months in the event of a request requiring more
in-depth research or in the event that INSEAD receives an excessive number of
requests.
9.6- OBJECTION RIGHT
You have the right to object to us processing your personal data if, for your
own reasons, you consider that one of the forms of processing infringes your
privacy and causes you excessive harm. You cannot prevent us from processing
your data:
* if its processing is required to conclude or perform your contract. For
example, your data must be processed to validate your registration with
INSEAD
* if its processing is required by law or a regulation. That is particularly
the case when you move to another address
* if its processing is required to officially record, exercise or defend rights
in legal proceedings
You can object to the use of your personal data for the purposes of marketing
communications and particularly advertising. You can also object to profiling if
it is linked to marketing communications (e.g. when we send you personalised
content).
You simply need to send an email to 5555-itservicedesk@insead.edu with the
subject line “objection right: personal data”, attaching a copy of your identity
document showing your signature.
It is important to include the reasons for your objection request.
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a photocopy of
your identity document bearing your signature. The request must specify the
address to which the response should be sent.
INSEAD has two months to respond to your objection request. If your request is
imprecise or does not include all the information enabling us to fulfil your
request, we will contact you to ask for further information within that time.
However, it may be that we are able to accede to your request. In that case, we
will of course provide you with as clear a response as possible.
Furthermore, any emails and newsletters which may be sent to you will contain a
link you can click on to stop receiving promotional information from us.
Specifically in relation to your right to object to marketing communications, we
remind you that our marketing partners are responsible for their use of your
personal data and taking into account your rights, including to no longer
receive offers from them.
9.7- RIGHT TO DIGITAL DEATH
You have the option to send us instructions relating to the retention, deletion
and communication of your personal data after your death. Those instructions may
also be recorded with a “certified digital trusted third party”. Those
instructions, a sort of “digital will”, may appoint a person responsible for
their execution or, failing, that your heirs will be appointed.
In the absence of any instructions, your heirs may contact us to:
* Access the processing of personal data in order to “organise and settle the
deceased’s estate”
* Receive communication of the “digital goods” or “personal data containing
family memories, transferable to the heirs”
* Close your personal account on the Site and object to the continued
processing of your personal data
In any case, you have the option of informing us, at any time, that you do not
want your personal data to be communicated to a third party after your death.
9.8- PORTABILITY RIGHT
This right gives you the possibility of more easily managing your personal data
yourself, specifically:
* retrieving your personal data processed by us, for your personal use, and
storing it on a device or in a private cloud for example
* transferring your personal data from us to another company, either by you, or
directly by us, subject to that direct transfer being “technically possible”
That right covers both your actively and knowingly declared data, such as your
data supplied to create your online account (e.g. email address, username, age)
and the information collected by INSEAD.
Conversely, personal data derived, calculated or inferred from data you have
supplied, e.g. the results of a medical examination, is excluded from the
portability right since it has been created by INSEAD.
You simply need to send an email to 5555-itservicedesk@insead.edu stating your
full name and with the subject line “portability right: personal data”,
attaching a copy of your identity document showing your signature. Do not forget
to indicate in your email the files concerned and the type of request (data
retrieval and/or transfer to a new service provider).
You can also exercise this right by sending us a letter to the following
address: Legal Department, INSEAD, Boulevard de Constance, 77305 Fontainebleau,
France. Your written request must be signed and accompanied by a photocopy of
your identity document bearing your signature. The request must specify the
address to which the response should be sent. A response will then be sent to
you within one month following receipt of the request, two months in the event
of a request requiring more in-depth research or in the event that INSEAD
receives an excessive number of requests.
You should be aware, however, that INSEAD is entitled to refuse your portability
request. In fact, this right only applies to personal data based on your consent
or performance of a contract concluded with us (for more details of personal
data covered by the portability right: click on the Purposes and Grounds
section). Similarly, this right may not infringe on third-party rights and
freedoms, whose data may be contained in the data transmitted following a
portability request.
10- IS YOUR PERSONAL DATA SENT ABROAD?
10.1- DATA TRANSFER WITHIN EUROPE
Personal data benefits from the same level of protection within the European
Economic Area.
We process your personal data on IT servers located in the EEA.
10.2- DATA TRANSFER OUTSIDE EUROPE
INSEAD transfers, processes and stores your information on IT servers located in
a number of countries outside Europe as set out in section 6 above.
You should be aware that protection of privacy and rules allowing authorities to
access your personal data in those countries are not necessarily equivalent to
those in Europe.
In order to ensure standards are adhered to in terms of data and privacy
protection, we impose technical and legal guarantees on all our partners.
11- DATA SECURITY
INSEAD takes all useful and appropriate physical, logical, technical,
functional, administrative and organisational precautions and measures to
guarantee the security of your personal data, with regard to the state of the
art, implementation costs and the nature, extent, context and purposes of the
processing, as well as the risks, whose degree of likelihood and severity vary,
to the rights and freedoms of natural persons, to preserve data security and
confidentiality and guarantee a level of security appropriate to the risks, and
particularly to prevent the data being distorted, damaged or accessed by
unauthorised third parties.
Due to the difficulties inherent in exercising an activity on the internet and
the risks, of which you are aware, resulting from the electronic transmission of
data, INSEAD may not be bound by a performance obligation.
In the event that difficulties occur, INSEAD shall do its utmost to circumvent
the risks and shall take all adequate measures, in accordance with its legal and
regulatory obligations (corrective actions, informing the national authority
responsible for personal data protection and, where relevant, data subjects,
etc.).
In the event that all or part of the personal data processing is subcontracted,
INSEAD contractually imposes security guarantees on its subcontractors,
particularly in terms of confidentiality in respect of the personal data to
which they may have access (appropriate technical and organisational measures to
protect that data).
12- DO YOU WISH TO CONTACT US ABOUT THIS PERSONAL DATA PROTECTION CHARTER AND/OR
MAKE A COMPLAINT TO A PERSONAL DATA PROTECTION AUTHORITY?
12.1- DO YOU HAVE A QUESTION OR SUGGESTION CONCERNING THIS PERSONAL DATA
PROTECTION CHARTER?
Please let us know by contacting us here (legal.department@insead.edu) or by
post at:
Legal Department
INSEAD
Boulevard de Constance
77305 Fontainebleau
France
We would be delighted to hear from you and it will be a pleasure to respond as
soon as possible.
12.2- DO YOU FEEL THAT WE ARE NOT ADEQUATELY PROTECTING YOUR PERSONAL DATA?
If you believe that INSEAD does not process your personal data in accordance
with the GDPR and French law, you are entitled to complain to:
* The data protection authority in the European country in which you habitually
reside, or
* The data protection authority in the European country in which you work, or
* The data protection authority in the European country in which the GDPR
violation was committed
12.3- SUBMITTING A COMPLAINT TO CNIL, THE FRENCH DATA PROTECTION AUTHORITY
You can submit a complaint directly via the CNIL website.
Or by writing to the following address:
Commission Nationale de l'Informatique et des Libertés
3 Place de Fontenoy - TSA 80715
75334 PARIS CEDEX 07
13- HOW DO YOU KNOW IF THIS PERSONAL DATA PROTECTION CHARTER HAS BEEN AMENDED?
This Personal Data Protection Charter may be amended at any time, particularly
to take account of any changes to the law or regulations or changes to our
services.
Major changes made will be notified via our Site or by email, as soon as
possible and at least 30 days before they come into force.
When we publish changes to this Charter, we will revise the “last updated on”
date at the bottom of this Privacy Policy.
We encourage you to regularly consult this Charter to find out how INSEAD is
protecting your personal data.
Last update: 26 August 2020
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