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HIVEBRITE Privacy Policy – end-users February 2023
Cobell Scholars – Privacy Policy - Users
This Privacy Policy is edited by Cobell Scholars. The Company offers a platform Cobell Scholars (hereafter, the “Platform”) to its users which have subscribed on the Platform and as such have a user account (hereafter, the “Users”). The Platform is available at the following url address https://community.cobellscholar.org/. The Company uses a solution called “Hivebrite”, which enables the import and export of user lists and data, the management of content and events, the organization of emailing campaigns and opportunity research and sharing as well as the management of funds and contributions of any kind. In this regard, as data controller, the Company is particularly aware and sensitive with regard to the respect of its Users privacy and personal data protection. The Company commits to ensure the compliance of the processing it carries out as data controller in accordance with the applicable provisions of the “Loi n°78-17 dated January 6, 1978, relative à l’informatique, aux fichiers et aux libertés” and the EU Regulation EU 2016/679 regarding data protection dated April 27, 2016. In order to do so, the Company has put in place an appropriate privacy policy which guarantees an optimal level of protection of its Users’ data. This privacy policy is intended for the Users of the Platform of the Company. ARTICLE 1. COLLECTED PERSONAL DATA 1.1 When subscribing on the Platform When subscribing on the Platform, the User is informed that its following personal data is collected. The User commits to only provide accurate, exhaustive, and regularly updated data regarding its identity, its content and any information in general. Under no circumstances shall the Company be liable for any data that is illegal contrary to public order provisions. In the event the User does not consent to the collection of the above-mentioned date, it shall be informed that it cannot have access to the Platform. 1.2 During the use of the Platform The User may validly publish, at its own initiative, any content on the Platform which shall be kept by the Company. The User commits not to publish any content which contains, including but not limited to, any remarks/images/pictures, contrary to application legislation and regulations, to public order and good morals, or affecting the rights of third parties, including but not limited to: - Identity fraud of a third person; - Remarks/publish pictures or images that are violent, defamatory, offensive, malicious, obscene, inciting to discrimination or hatred, racist, xenophobic, anti-Semitic, HIVEBRITE Privacy Policy – end-users February 2023 Page 2 of 7 condoning or approving war crimes, inciting to committing a crime, offense, act of terrorism, or contrary to the security of minors; - Counterfeiting the intellectual property rights of a third person; - Commercial canvassing or elements that could be qualified as unfair competition. In any event, Hivebrite shall not be liable for the content, accuracy, or up-to-date state of the information freely published by the User. The User consents that, following the publication of the content, its information will become public on the Platform and that as such, same information will be published, modified, translated, reproduced in any form and accessible, saved and reproduced by other Users and the Company. In most cases, Users post contents without previous moderation from the Company. The Company does not alter the content or information of the User, except under exceptional circumstances. The Company reserves its right to freely delete or amend the content or information of the User, without prejudice to the Users. In the case of delivery of content on the Platform which is contravenes with the present privacy policy, applicable law or the rights of third parties, any person can inform the Company of the existence of such Content at the following address: [email protected]. The User is informed that the Company does not collect any particularly sensitive data within the meaning of applicable legislation and regulations. 1.3 Cookie data The Company informs the User that Hivebrite, as well as its subcontractors, uses a tracking technology on its terminal such as cookies whenever the User navigates on the Platform. A cookie is a message that, subject to the User settings, is sent to its terminal when the User navigates on a website. The aim is to collect data regarding the internet navigation of the User to send tailor-made services to its terminal (computer, mobile phone or tablet). The cookies that are sent to the User’s terminal are detailed under Article 2 of the present privacy policy. The purpose of the process of the data collected through the cookies and the settings of such processing is detailed under article 9 of the present privacy policy. ARTICLE 2. THE PURPOSE OF THE DATA PROCESSING The Company and its subcontractors collect, process and host personal data that are freely transferred by the User when accessing the services proposed by the Platform. The Company only collects and processes the User’s personal data for the purpose for the optimal implementation and use of the Platform that is put at its disposal. ARTICLE 3. USER’S CONSENT TO THE COLLECTION OF DATA The Company informs the User that no personal data within the meaning of applicable legislation and regulations shall be collected without the prior explicit consent of the User. HIVEBRITE Privacy Policy – end-users February 2023 Page 3 of 7 The User expresses its consent upon its subscription on the Platform, and after having been able to consult the present privacy policy. The Company and its subcontractors commit to a lawful and fair collection of the User’s data, in full transparency and in compliance with the rights conferred to the User pursuant to applicable legislation and regulations. ARTICLE 4. LENGHT OF DATA RETENTION The Company informs the User that the data is retained only during the length of the User’s subscription on the Platform. In accordance with application legislation, cookie data will be automatically deleted thirteen (13) months following their placing on the User’s terminal. Finally, the data regarding the identification of the Users in case of exercise of their rights pursuant to Article 6 of the present privacy policy shall be retained for (i) one (1) year in case of exercise of their access or rectification rights and (ii) three (3) years in case of exercise of their opposition right. ARTICLE 5. OBLIGATIONS OF THE COMPANY As data controller and in accordance with applicable legislation and regulations, the Company commits to: - Only collect the Users’ data for the strict purpose as described under article 2 of the present privacy policy; - Keep a processing register; - Put in place all necessary technical and organizational appropriate measures in order to ensure the security, confidentiality, integrity, availability and the resilience of the process systems and services; - Limit the access to the Users’ data to the persons duly authorized to this effect; - Increase awareness and train staff members regarding the processing of personal data; - Guarantee to the Users their rights regarding the access, portability, erasure, rectification and opposition in relation to the collection and processing of their data; - Notify the competent supervisory authority of any security breach presenting a serious risk regarding the rights and liberties of the Users within 72 hours of the occurrence of such a breach; - proceed with the deletion of the Users’ data in the event of an absence of any contact with the Company for a period of three (3) years; - Only subcontract the processing of the Users’ data to Hivebrite which, as subcontractor, has put all necessary technical and organizational measures in order to guarantee the security, confidentiality, integrity, availability and resilience of the processing systems and services. For any additional information on Hivebrite, you can consult the webpage available at the following address: www.hivebrite.com. ARTICLE 6. EXERCISE OF THE USERS’ RIGHTS The User is duly informed that it disposes at any time, meaning prior to, during or following the processing of data, to a right to access, copy, rectify, oppose, port, limit and delete its data. In addition, in the event the User considers that its rights have not been respected, the User of which the personal data is collected can file a reclamation before the competent supervisory authority. For any additional information, you can review your rights on the websites of the competent authorities. The competent supervisory authorities are listed on the following website: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. ARTICLE 7. HOSTING OF THE USERS’ PERSONAL DATA The personal data collected by the Company is hosted by the following service providers: Host Nature of the hosting Microsoft Azure Cloud Privacy policy: https://www.microsoft.com/enus/TrustCenter/Privacy/gdpr/default.aspx Hosting of all data and content produced / provided by the User, as well as images, profile pictures and backups AmazonAWS Privacy policy: https://aws.amazon.com/compliance/gdprcenter/ ARTICLE 8. DATA BREACH In case of breach of its systems, or theft, deletion, loss, alteration, disclosure, unauthorized access, or any other malicious act, the Company commits, in the event the said breach presents a serious risk regarding the rights and freedoms of the Users, to notify the Users, within a period of seventy two (72) hours as of the occurrence of the breach, of (i) the nature of the breach, (ii) the probable consequences of the malicious act, (iii) the appropriate measures proposed to remedy the malicious act. The malicious act presenting a serious risk regarding the rights and freedoms of the Users shall be notified to the competent supervisory authority. HIVEBRITE Privacy Policy – end-users February 2023 Page 5 of 7 The User is duly informed that the Company shall not be liable in case of breach of IT security which can cause damages to computer equipment, as well as in case of breach or malicious act by a third party targeting the system or the Platform. ARTICLE 9. COOKIE MANAGEMENT CONFIGURATION AND OTHER DATA The User’s consent is requested through a banner at the bottom of the Platform homepage. In case of consent, the User’s internet navigator shall automatically transmit to the Company the data collected and detailed under Article 1.2. The User is informed that the cookies and trackers will be automatically deleted following a period of thirteen (13) months. The User may at all times configure its navigator in order to prevent the creation of cookie files. However, certain functionalities of the services proposed by the Platform may not function properly without cookies. In addition, even if most navigators are configured by default and accept the creation of cookie files, the User has the possibility to choose to accept the creation of all cookies other than the functional cookies or to systematically decline them or to choose the cookies it accepts depending on the issuer by configuring the following settings: • Internet Explorer: - Click on the settings menu, followed by “Internet Options”; - Under the “General” tab on the upper-left hand side, scroll down to “Browsing history”; - Check the "Temporary Internet files and website files," "Cookies and website data," "History," and "Download History" boxes; - Click on “Delete”; - Close out of Internet Explorer and reopen it for changes to take effect. • Firefox: - Click on your Tools bar; - Click on “Preferences”; - On the menu to the right, select "Privacy"; - Under the “history option”, there is a shortcut titled "clear your recent history", click on that; - Select only the top four options and hit clear now. • Safari: - Click on “Safari” in the top left corner of the finer bar; - Click on “Preferences”; - Click on the “Privacy” tab; - Click on “Manage Website Data”; - Click on “Remove All”; - Click “Remove Now”. • Google Chrome: - Click the Tools menu; - Click on “More tools”; - Clear browsing data; - At the top, choose a time range. - To delete everything, select “All time”; - Next to "Cookies and other site data" and "Cached images and files", check the boxes; - Click on “Clear data”. In order to configure the data settings, please find below the recommendations of the Company: Data collected for the following purposes: Settings General data enabling the proper functioning of the Platform and the improvement of the services proposed by the Platform. Data that is essential for the provision of services by the Company, non-configurable. Data regarding the management of payment services proposed by the Platform, delinquencies and litigation. Data that is essential for the provision of services by the Company, non-configurable. Data enabling the creation of User files. Management by the User in its login area. Compilation of statistics with the purpose of improving the functioning of the Platform notably by analysing the traffic of the Platform (modules which are more or less consulted, preferred routes, level of activity depending on the day of the week et hour of the day, etc.) and by adapting the Platform according to the needs and tastes of the Users (recognition of the User when it accesses the Platform). Clearance of cookie history in the navigator pursuant to the above instructions; Using the “incognito mode” whilst navigating; Request for deletion of the data base of the Company by writing to the following address [email protected] and subject to providing a proof of identity. Management of requests to access, rectify, delete, limit and oppose. Request for deletion of the data base of the Company by writing to the following address [email protected] and subject to providing a proof of identity. ARTICLE 10. PERSONS AUTHORIZED TO ACCESS THE USERS’ DATA The data of the Users are accessible only to the persons duly authorized to do so by the Company for administrative or maintenance purposes of the Platform to the exclusion of any commercial use, and if applicable, in order to enforce the rights exercised by the Users regarding their data (in particular the right to access, rectify, oppose, port and to be forgotten). The Company informs the User that, outside of hosting and payment services, it uses the following subcontractor: - The company KIT UNITED for its HIVEBRITE solution, a French société par actions simplifiée with a capital of 284.280,00 Euros, registered with the Paris Companies register under the number 75339171300017, having its registered office at 8, rue de la Grande Chaumière, 75008 – Paris. Especially in light of any future developments of the applicable legislation and regulations, the Company reserves its right to proceed with any modification of its privacy policy and commits to duly inform you if any such modification occurs. Date of privacy policy: February 2023.