PERSONAL DATA PROTECTION POLICY

Consultez la version Française

 

Why a policy for protecting your personal data?

 

Your privacy is a priority for TANu Digital (hereinafter "TANu" or "we"). In this regard, we respect the personal data of our online users (hereinafter "you"), treat it with the utmost care and ensure the highest level of protection in accordance with Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR") and the amended Law of 6 January 1978 (hereinafter " French law ").

This policy informs you about:

  • The personal data we collect about you and the reasons for this collection,
  • How to use your personal data,
  • Your personal data rights and the ways to exercise them  

 

Date of last modification: 30.01.2019

 

Vocabulary of terms frequently used in this policy

 

Frequently used terms in this Policy Definition provided by the GDPR Explanation of Terms in Usual Language
Personal data Any information relating to a physically identified or identifiable person (hereinafter referred to as "the person concerned"); is deemed to be an « physically identifiable person" a physical person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to his or her physical, physiological, genetic, psychologic, economic, cultural or social identity. All types of information that relates to a physical person, that is to say, an individual, identifiable, directly or indirectly, as a person distinct from other persons. For example: a name, a photo, an imprint, an email address, a phone number, a social security number, an IP address, a voice recording, your navigation data on a website, data related to a purchase online, etc.
Processing Any transaction or set of transactions performed or not using automated processes and applied to data or sets of personal data, such as collection, registration, organization, structuring, retention , adaptation or modification, extraction, consultation, use, transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction;  Any use of personal data, whatever the process used (record, organize, keep, modify, reconcile with other data, transmit, etc. personal data). For example: the use of your data for purposes of order management, delivery, sending newsletters, etc.
Processing Manager  The person or entity, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing The person, public authority, society or body that controls your data and decides on any use of it. It is her she who decides to create or delete a treatment and determines why your data will be processed and to whom it will be transmitted. He or she is the main manager for respecting the protection of your data.
Sub-contractor The person or entity, public authority, service or other body that processes personal data on behalf of the controller; Any person or entity, who performs processing tasks on the instructions and under the responsibility of the controller.

 

Consent

By submitting personal data to www.tanu.io and www.tanu.digital, you agree that TANu Digital collects and / or processes, stores and uses such data in accordance with the rules set forth below.

 

Who has control over the use of your personal data?

 

Les données personnelles collectées sur le présent site le sont par la société TANu Digital , Société a responsabilité Limitée au capital de 10 000 euros, immatriculée au RCS de PAU sous le numéro 831 846 985 et dont le siège social est situé 12, rue du cerisier – 64400 Estos.

 

CNIL Declaration

 

TANu Digital informs its customers and prospects that automatic processing of information is declared to the CNIL under number 1407857

 

 

Why and on what basis do we collect your personal data?

 

We collect personal data about you for different reasons. TANu collects and uses your personal data to function effectively and provide you with the best experiences with its services. Please note that we may collect and use your personal data only if the use is based on a specific basis defined by the GDPR (for example, your consent or the establishment of a contract with us). The table below lists exactly why TANu uses your personal data and the corresponding legal basis.

 

Reasons for collecting your personal data Legal basis for processing your personal data

(User) TANu test run

Your data is processed by TANU in order to ensure the service runs smoothly, especially to allow users to take the TANU test at the invitation of their company or during the application process.

The execution of a contract with you (Article 6.1.b) of GDPR), namely a contract for the use of the digital culture testing service provided by TANu.

(Company) TANu Test Management

Your data are processed by TANu in order to allow you to use the service, invite people to take the test and collect the results.

The execution of a contract with you (Article 6.1.b) of the GDPR), in this case a contract to use the digital culture testing service provided by TANu.

(Entreprise) Business

Your data is used by TANu to send you promotional offers by email and keep you informed of new products

Your consent (Article 6.1.a) of the GDPR)

(Everyone) Statistics

The legitimate interest of TANu is to process personal data of users and customers to improve the services offered and to have a better understanding of target groups (Article 6.1) .f. of the GDPR)

 

Data that can be collected on the site

 

The personal data we collect depends on the nature and number of interactions you have with TANu—whether they legally contracted (eg taking the TANu test) or not (eg visiting our website ). In the chart below we explain the reasons and usage for the personal data collected during these different types of interactions and collection methods (—direct or indirect collection—information provided directly by you or by a third party).

 

- Regarding companies

 

Reason for collection Personal Data Collected Direct or Indirect Collection
Company Account Use

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

Data is collected directly from you for this purpose
Business Development

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

Data is collected directly from you for this purpose
Statistiques

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

Data is collected directly from you for this purpose

 

Other data collected on behalf of the company: business address, country, SIREN number, intra-community VAT number if applicable, order history.

 

- Regarding individual users

 

Reason for collection Personal Data Collected Direct or indirect Collection
Using the TANu service Taking the TANu test

Consulting results Access to the TANu School

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

Data is collected directly from you for these purposes.

 

The mandatory or optional data (in order to finalize your registration and to issue our services) is indicated by an asterisk*. In addition, some data is collected automatically because of your actions on the site (see the paragraph on cookies).

 

Who do you share your personal data with?

 

Your personal data collected on the site is intended for TANu and the company that invited you to take the test.

The data collection accesses your name, e-mail address, as well as your test results (scores and questions), but is in no case authorized to divulge the data in a public manner nor outside the purpose of taking the test (for example: a recruitment).

As part of our business we may share your personal information with IT providers who assist our services from a purely technical point of view. Of course, we always guarantee the best protection of your personal data.

This personal data will not be exploited by third-party applications, nor transferred to third-party applications, to other sites or other legal entities.

  • With public authorities, in response to legal demands, including to meet the requirements of national security or law enforcement.
  • In the context of a transaction, such as a merger, acquisition, consolidation or sale of assets, we may share your personal data with buyers or sellers..

TANu Digital will never sell or rent your personal data to third parties for marketing purposes. We will never do it.

 

How long do we keep your personal data?

 

 TANu has established specific rules regarding the retention period of your personal data. This duration varies according to different objectives and must take into account any legal obligations to keep some of your data.

 

Reason for collection Personal Data Collected Direct or indirect Collection
(Everyone) Company Account Use

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

60 months
(Businesses) Business Development

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

24 months
(Everyone) Statistics

Personal identification data: name, address, zip code, email address, telephone number

Identifiers: Passwords and similar security information used for authentication and account access.

Electronic identification data: IP address, cookies, connection log

60 months

 

 

What rights do you have on your personal data and how can you exercise them?

 

We want to clearly inform you of your rights regarding your personal data. We also want to enable you to exercise these rights in a simple way. Below you will find below a summary of your rights with a description of how to exercise them.

 

The right of access

You can request a copy of your personal data in our computer systems and all the following information:     -

  • 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 shared and in particular those who are outside Europe,   
  • The retention period of your personal data in our systems,
  • Your right to ask us to correct, erase, or limit the use of your personal data and the right to object to such use,
  • Your right to lodge a complaint with a European data protection agency,    
  • The right to be informed of the source of your data gathering when we do not collect your personal data directly from you,
  • How your personal data is protected when it is transferred to countries outside Europe.

 

How to exercise your right of access?

Simply contact us by email: data@tanu.io, with the subject "right of access: personal data". Unless you indicate otherwise, you will receive a free copy of your data in an electronic format. If you are unable to access your information by email, you can send us your request by post to the address below:

TANu Digital, Estos 64400, France

Your written request must be signed and accompanied by a photocopy of your identity card bearing your signature and a return address to which a response will be sent. A response will be sent within 1 month of receipt of the request (2 months in case of a request requiring extended research or if TANu is experiencing a high volume of requests). You may directly consult your personal data at any time by logging into your account with your username and password in the "My Profile" section.

 

The right to correct

You can ask TANu to correct and/or update your personal data.

 

How to exercise your right to correct?

Send us an e-mail at: data@tanu.io, indicating your last and first name, with the subject: "right of rectification: personal data". Also, do not forget to indicate in the body of your e-mail the reason: the correction of the inaccurate information and the information to be modified. Your written request must be signed and accompanied by a photocopy of your identity card bearing your signature. The request must specify the return address to which the response will be sent. A response will be sent within 1 month of receipt of the request (2 months in case of a request requiring extended research or if TANu is experiencing a high volume of requests).

You can also send us your request by postal mail to the address indicated below:

TANu Digital , Estos 64400, Fance

 

The right to be forgotten

 

You can also contact us at any time to ask us to delete the personal data we process about you, if you find yourself in one of the following cases:

  • Your personal data is no longer necessary in in regard to the reasons for which they were collected or treated in another way;
  • You have withdrawn your consent based on the processing of your personal data carried out by TANu
  • You have reason to think that the handling of your data infringes on your privacy and causes you excessive damage;
  • You no longer wish to receive commercial solicitations from us;
  • Your personal data is not processed in accordance with GDPR and French law;
  • Your personal data must be erased to comply with a legal obligation that is provided for by European Union law of the or by the national law to which TANu is subject;

 

How to exercise your right to be forgotten?

 

All you have to do is send an email to: donnees@tanu.io stating your last name, first name and in the subject : »right to be deleted: personal data". Do not forget to include the reason for your request in the body of your email (for example, the deletion of your data when you based on withdrawal of your consent on which the processing is based) .Your written request must be signed and accompanied by a photocopy of your identity card bearing your signature and a return address to which the reply shall be sent (2 months in case of a request requiring extended research or if TANu is experiencing a high volume of requests). You can also send us your request by post to the address below:

TANu Digital , Estos 64400, France

However, we may not be able to grant your right to be forgotten. Indeed, you must keep in mind that this right is not absolute. We must guarantee other rights such as freedom of expression; respect for a legal obligation to which we are subject; reasons of public interest in the field of public health; archives in the public interest, statistics, scientific or historical research. Obviously in this case we will try to give you the clearest answer 

 

The right to object

 

You have the right to ask us at any time to stop processing your personal data under serious and legitimate reasons. You can not in any way prevent us from processing your data:

  • if the processing is necessary for the conclusion or the execution of your contract. For example: your data must be processed to allow you to take the test;
  • if the processing was imposed by law or regulation. This is particularly the case when you move to another region;
  • if the processing is necessary to ascertain, exercise or defend rights in court.

 

You may object to the use of your personal data for commercial solicitation purposes, in particular, advertising.

 

How to exercise your right to object?

All you need to do is send an email to: data@tanu.io indicating in the subject: "right of opposition: personal data". It is important to indicate the reasons for your objection. You must also attach proof of identity. Your application must - in principle - be accompanied by a photocopy of an identity document bearing your signature. TANu has two months to respond to your opposition request. If your request is imprecise or incomplete, we will request that you provide the needed information to us within this period. However, we may not be able to accommodate your request. We will make sure to provide you with the clearest answer possible if this is the case. In addition, you can unsubscribe from emails or newsletters that you may receive to stop receiving promotional information.

 

The right to digital death   

 

You have the possibility to provide us with instructions regarding the storage, erasure and communication of your personal data after your death. These guidelines can also be registered with a "certified trusted digital third party". These guidelines, or some kind of "digital will", may designate a person to perform them; otherwise, your heirs will be appointed. In the absence of any directive, your heirs may contact us to:

  • Access the processing of Personal Data allowing "the organization and settlement of the estate of the deceased";
  • Receive communication of "digital goods" or "Personal Data similar to family memories, transmissible to heirs";
  • Have your Personal Account closed on the Site and oppose further processing of your Personal Data.

In any case, you have the option to tell us, at any time, that, in the event of death, you do not wish that your personal data be communicated to a third party.

 

The right to data portability

 

This right gives you the opportunity to control your personal data more easily and more specifically:

  • recover your personal data that is processed by us for your personal use, and store it on a device or a private cloud for example.
  • to transfer your personal data from TANu to another company, either by you or directly by us, provided that this direct transfer is "technically possible".

This right applies to both your actively and consciously reported data such as your data provided to create your online account (eg email address, username, age) as the information collected by TANu.

 

How to exercise your right to data portability?

All you have to do is send an email to donnes@tanu.io, indicating your last and first name and indicate the subject: "right to portability: personal data". Do not forget to specify in your email the files concerned and the type of request (return of data and / or transfer to a new provider). Your written request must be signed and accompanied by a photocopy of your identity card bearing your signature. The request must specify the return  address to which the response will be sent. A reply will be sent to you within 1 month of receipt of the request (2 months in case of a request requiring extended research or if TANu is experiencing a high volume of requests).

However, please note that TANu has the right to refuse your request for portability. Indeed, this right applies only to personal data based on your consent or the execution of a contract with you (to know precisely the personal data which may be the subject of the right of portability, click on « purposes and bases »). Likewise, this right must not infringe on the rights and freedoms of third parties, whose data may be found in the transmitted data following a request for portability.

 

Your personal data transmitted abroad

 

Data transfer within Europe.

Be assured that your personal data will benefit from the same level of protection within the European Economic Area (28 EU Member States, Iceland, Norway, Liechtenstein),

We process your personal data on computer servers located in France.

 

Testimonials

 

TANu Digital publishes a list of Customers & Testimonials on its website including information on the clients' names, their titles and the names of their companies, if applicable. TANu Digital obtains the authorization of each client before publication of any information or testimony.

 

Cookies

 

In general, TANu Digital uses cookies to improve and personalize the site and / or measure the audience. Cookies are files stored on the hard drive of your computer while browsing on the Internet and in particular on the site. A cookie is not used to collect personal data without your knowledge, but to record browsing information on the site that can be directly read by TANu Digital during your visits and subsequent requests on the site.

If you choose to refuse all cookies, your navigation to access certain pages of the site will be reduced.

The cookies used by TANu Digital are intended to allow or facilitate communication, enable the requested services, recognize users for future visits, to allow for users to customize the site, to secure payments, to record user language and other necessary preferences. Cookies also allow TANu Digital to internally conduct frequency analyzes on the site’s information pages in order to improve the content, to track the frequency of site visits, click tracking and bounce rates of individuals.

By default, cookies are not automatically installed (with the exception of cookies necessary for site and services operations of TANu Digital by which is indicated by a banner notice). In accordance with the applicable regulations, TANu Digital will require your authorization before implementing any other type of cookies. To avoid any inconvenience caused by these systematic requests for authorization, and enjoy uninterrupted browsing, you can configure your computer to accept TANu Digital cookies or we can memorize your refusal or acceptance of certain cookies. Note that without certain cookies, TANu Digital can not guarantee certain services. By default, browsers accept all cookies.

When you access by clicking on cookie banners or advertising links on third-party sites advertised on the TANu Digital website, and possibly when viewing these advertisements, cookies may be created by the companies distributing these advertisements. These third parties may use cookies as part of the TANu Digital services (partners, advertisers or other third parties providing content or services available on the TANu Digital website) and are responsible for the cookies they put in place and those cookie arrangements that apply. TANu Digital assumes no responsibility for the possible use of cookies by these third parties. For more details, you are advised to consult these site advertisers directly on their use of cookies policy.

 

Security

 

As part of its services, TANu Digital places the utmost importance on the security and integrity of the personal data of its customers.

Thus, and in accordance with Article 34 of the modified Data Protection Act, TANu Digital takes all necessary precautions to maintain data security and, in particular, to protect it against accidental or unlawful destruction, accidental loss, alteration, unauthorized dissemination or access, as well as any other form of unlawful processing or communication by unauthorized persons.

To this end, TANu Digital implements industry standard security measures to protect personal data from unauthorized disclosure. Using industry-recommended encryption methods, TANu Digital takes the necessary steps to protect regulated and credit card information.

In addition, in order to prevent unauthorized access and to ensure the accuracy and good use of data, TANu Digital has put in place appropriate electronic, physical and supervisory procedures to safeguard and preserve the data collected through the services.

Nevertheless, no one can consider themselves completely safe from pirate attacks. That is why in the event of a security breach, TANu Digital is committed to inform you as soon as possible and to take all possible measures to neutralize the intrusion and  minimize the risks and impacts. In the event that you suffer damage as a result of the exploitation of a security breach by a third party, TANu Digital is committed to providing you with all the necessary assistance so that you can assert your rights and obtain compensation. In addition, if the damage suffered was partly due to gross negligence or fault on the part of TANu Digital, you could obtain compensation from TANu Digital within the limits of the liability limits set out in the general conditions of use.

It should be kept in mind that any user, customer or hacker discovering a security breach and the exploiter is subject to criminal penalties, TANu Digital will take all measures, through a complaint and / or legal action, to preserve the data and uphold the rights of its users as well as its own to limit the impact as much as possible.

In general, if you have any questions about the security of our website, do not hesitate to contact us at support@tanu.io.

 

Contact - Complaint

 

Do you have  questions or suggestions concerning this personal data protection policy? Do not hesitate to let us know by contacting us by email at: data@tanu.io or by postal mail at:

 

TANu Digital SARL – Policy

12 rue du cerisier
64400 Estos - France

 

We will be happy to hear from you and will respond as soon as possible.

 

Do you believe that your personal data is not protected well enough?

If you consider that TANu does not process your personal data in accordance with GDPR and French law you have the right to submit a complaint with:    

  • The data protection authority of the European country in which you normally reside, or    
  • The data protection authority of the European country in which you work, or    
  • The data protection authority of the European country in which the violation of the GDPR was committed.

 

To file a complaint with the CNIL, the French data protection authority

You can submit a complaint directly on the CNIL website or by post to the following address:

Commission Nationale de l'Informatique et des Libertés
3 Place de Fontenoy -
TSA 80715
75334 PARIS CEDEX 07
FRANCE

 

To file a complaint with another European data protection authority

To submit a complaint to another data protection authority please consult the list on the European Commission’s website.

 

Privacy Policy Modification

 

This Personal Data Protection Policy may be modified at any time, in particular to take into account possible legislative or regulatory changes and the evolution of our services. Significant changes will be notified via our website or email, as soon as possible, at least thirty days before they become active. When we publish changes to this Policy, we will revise the "last updated" date at the top of the Privacy Policy and describe the changes in the « History modifications" page. We encourage you to check this Policy regularly to find out how TANu protects your personal data.