DATA PROTECTION POLICY

Scope

Takoma grants the utmost importance and care to the protection of privacy and personal data, and with this in mind is committed to respecting the relevant legal requirements.
European Regulations on the subject of personal data protection state that any processing of personal data must be lawful, fair, and transparent. This Data Protection Policy (hereinafter the “Policy”) is destined to provide simple, clear information on how and why we process personal data relating to you, collected in the context of navigating and performing actions on our website.

1. Controller

In order for you to use our website https://www.takoma.fr, we collect and process personal data relevant to you, natural persons (hereinafter “concerned persons”).
Takoma SAS, headquarters at 14 boulevard Raymond Poincaré FR – 92380 Garches, will act as Controller of all data processing for which TAKOMA determines the means and purposes, as defined by current regulations regarding personal data, specifically Regulation UE 2016/679 relating to the protection of natural persons with regard to the processing of personal data and the free transmission of data.
For certain data processing, notably that specified in article 4 of the present policy, Takoma can also act as a subcontractor on behalf of its customers, in accordance with articles 28 and according to the RGPD.

2. What data do we collect and how?

In the course of our activities, you communicate to us specific data relating to you, some of which could be used to identify you (“personal data”). This occurs when you browse our website, when you fill out online forms, or when you register for our training courses.
Each online form on the site limits the collection of personal data to only that which is necessary and will always indicate the purpose(s) of the data collection and the recipient(s) of said data. Data required to process your requests will always be indicated with the term “required”.  If you do not fill in these fields, Takoma will not be able to respond to your request.

The nature and quality of collected personal data relevant to you will vary depending on the nature of the relationship between you and Takoma, the foremost being:

  • Identification data: this includes any information that would allow us to identify you, such as your first name, last name, telephone number, email address, or postal address.
  • Professional life data: skills, position, occupation, references, diplomas
  • Personal life data: family status, non-professional activities.
  • Navigation data: anonymous IP address and certain browsing related information

As a training organization, we may need to collect certain sensitive data, such as health data, data relating to disabilities; dietary habits and allergies in order to organize meals or prepare premises.

3. Why do we collect your personal data and how?

We collect your personal data for specific purposes and on different legal grounds.
In all the situations below, TAKOMA acts as “Data Controller“.

With regards to our website management, TAKOMA uses personal data as follows:

Purpose Personal data collected Legal basis for processing Storage period
We collect your data when you fill in the contact form Identification data, professional life data Legitimate interest The data collected via the form is kept for 3 years from its collection or the last contact date
We carry out audience analytics via functional cookies that do not require your consent Navigation data Legitimate interest

Navigation data is kept for a maximum of 13 months

 

With regards to recruitment management, TAKOMA uses personal data as follows:

Aims Personal data collected Legal basis for processing Storage period

We manage the reception of applications for job and internship offers

We organize the interviews and set up a recruitment process

Identification data, professional life data, personal life data Legitimate interest 2 years maximum after the last contact with the candidate

We search for candidates and contact them via dedicated recruitment websites

We build a CV database

Identification data, professional life data, personal life data Legitimate interest 2 years maximum after the last contact with the candidate

With regards to the management of business relations, TAKOMA uses personal data as follows:

Aims Personal data collected Legal basis for processing Storage period
Management of the business and contractual relations with customers Identification data, professional life data Contract For 5 years starting from the end of the contractual relationship
The conclusion and execution of contracts with customers Identification data, professional life data Contract For 5 years starting from the end of the contractual relationship
Drafting of quotations and proposal customisation Identification data, professional life data Execution of pre-contractual measures For 5 years starting from the end of the contractual relationship in the case of a signature, and 3 years from the last contact with the prospect in case of no signature
Prospect and business relations management Identification data, professional life data Legitimate interest 3 years maximum after the last contact with the prospect
Invoicing and payment management Identification data Legal requirement 10 years

With regards to our activity as a training organization, TAKOMA uses personal data as follows:

Aims Personal data collected Legal basis for processing Storage period

o    Collect learner needs,

o    Manage positioning assessments,

o    Manage the training agreements, invitation notifications, internal training regulations, enrolments, and the delivery of certificates,

o    Manage online registrations and the administrative part of an LMS platform,

o    Manage the recruitment of consultants (trainers)

o    Organize and manage contributors and training session planning and logistics,

o    Manage training session consultants

o    Manage learner satisfaction surveys of learners, trainers, customers and financiers,

o    Manage learner achievement assessments,

o    Manage payments, invoices, etc…

o    Answer Customer and learner enquiries and interact with them in other ways,

o    Monitor our contractual relationship,

o    Complete and carry out our mission as a training organization.

Identification data, professional life data, personal life data

(health data: disability, dietary habits and allergies,…)

 

Contract

5 years starting from the end of the contractual relationship in the case of a signature, and 3 years from the last contact with the prospect in case of no signature

Retention of invoices for 10 years.

 

Communication or satisfaction survey mailings Identification data, professional life data Legitimate interest 3 years maximum after the last contact with the customer

With regards to secondment of our employees to our customers, TAKOMA uses personal data as follows:

Aims Personal data collected Legal basis for processing Storage period

With regards to our employee assignments with our customers

·         Access to the customer’s information system

·         Use or handling of the customer’s information (documents, contact list, confidential information…)

Identification data, professional life data Contract For the duration of the assignment

 

In all the situations below, TAKOMA acts as “subcontractor”:

With regards to our IT services, TAKOMA uses personal data as follows:

Aims Personal data collected Legal basis for processing Storage period
Software development Identification data, professional life data Contract End of the contract or upon request by the customer 5 years from the end of the contractual relationship
Software hosting and maintenance Identification data, professional life data Contract End of the contract or upon request by the customer 5 years from the end of the contractual relationship

With regards to our activity as a training organization, TAKOMA may sometimes act as a “subcontractor” for its customers and use their personal data as follows:

Aims Personal data collected Legal basis for processing Storage period

o    Manage positioning assessments,

o    Manage training agreements and enrolments

o    Manage the training agreements, invitation notifications, internal training regulations, enrolments, and the delivery of certificates,

o    Organize and manage contributors and training session planning and logistics,

o    Manage learner satisfaction surveys

o    Manage learner achievement assessments,

o    Answer Customer and learner enquiries and interact with them in other ways,

 

Identification data, professional life data, personal life data

(health data: disability, dietary habits and allergies,…)

 

Contract 5 years starting from the end of the contractual relationship

 

4. Do we share your personal data?

Your data which is communicated to TAKOMA’s internal services, is that which is strictly necessary for us to carry out our mission.
We may also, for certain processing purposes, share your data with our subcontractors whom we call upon to carry out a range of operations and tasks on our behalf, in particular software publishers and hosts, our website host or our IT provider.  We only authorize these subcontractors to use your personal data in situations where it is necessary in order to provide services to you in your name, or to abide by legal requirements, and we work to ensure that your personal data is protected at all times.
In addition, they are only given the information they need to perform the service. They are also asked not to use the data for purposes other than those originally intended. We make every effort to ensure that these third parties maintain the confidentiality and security of your data.
Finally, your data may also be communicated to legal or regulatory authorities in order to comply with our legal obligations.
In these last two cases, as with subcontractors, only the necessary data is provided. And we make every effort to keep it confidential and secure.
We do not sell your data.

5. Is your data transferred to other countries?

Takoma works to ensure your personal data remains within the European Union. However, the data we collect when you use our platform or services can be transferred to other countries, for example if a subcontractor is located outside the European Union.
In this type of transfer, we guarantee that:

  • The transfer will be made to a country with adequate protection levels, that is to say a level of protection equal to those required by European regulations;
  • The transfer is governed by standard contractual provisions.

6. How long do we keep your data?

Your personal data is stored only as long as strictly necessary in order to fulfil the purpose for which the data was collected, in order to meet your needs or our own legal obligations.
The storage duration of this data will vary depending on various factors, including:

  • The requirements of Takoma’s activities;
  • Contractual requirements;
  • Legal obligations;
  • The recommendations of supervisory authorities.

7. How do we guarantee data security?

Takoma is committed to protecting all personal data we collect or process against loss, destruction, alteration, and unauthorized access or transmission.
With this in mind, to protect your data we implement all technical and organisational measures necessary based on the nature of the data and the risks inherent to the processing method. These measures ensure we can maintain the security and confidentiality of your personal data.  These measures can include actions such as limiting data access to only authorized persons based on their function.
Furthermore, our practices and policies and/or physical/logistical security measures (secured access, authentication procedures, back-up copies, software, etc.) are regularly verified and updated as necessary.

8. What are your rights?

Based on the private nature of the data that we collect/process, you can exercise the following rights:

  • The right of access: you have the right to request access to the personal data regarding you that we possess, and you can request a copy;
  • The right to rectification: you have the right to ask us to rectify information you think is inaccurate;
  • The right to erasure: you have the right to ask us to erase your personal information in certain circumstances;
  • The right to data portability: you have the right to ask that we transfer any personal data you have communicated to us in a structured format. You also have the right to ask that we transfer your personal data to another controller in certain circumstances;
  • The right to restriction of processing: you have the right to ask us to restrict the processing of your information if:
    • You contest the accuracy of the data concerning you, which we will verify;
    • The processing is illegal but you do not want us to delete your data;
    • We no longer need your personal data for processing requirements, but you need the data to pursue or defend yourself from any legal action;
    • You are opposed to the processing of your data based on your own reasons pending an evaluation of our own legitimate and compelling justifications to determine which take precedent;

If this personal data is subject to limitations of this kind, we will only process your data with your consent, or with the objective to pursue or defend ourselves from any legal action;

  • The right to object to processing for legitimate reasons;
  • The right to revoke consent at any time.

You can exercise your rights by contacting our Data Protection Officer at the following address:

DPO consulting
Service DPO Externalisé
18 rue Pasquier
FR – 75008 Paris
dpo@takoma.fr

When you communicate a request to exercise your rights, you will be asked to specify as much as possible the scope of the request, the type of right you wish to exercise, the personal data processing method concerned, and any other useful information to facilitate the processing of your request.  Furthermore, with this in mind you will have to provide proof of identity.

9. How should you contact us?

You can contact us using the following postal address:
Takoma SAS
14 Bd Raymond Poincaré
FR – 92380 Garches

10. Cookie management

10.1 What is a cookie?

Cookies are computer files that are automatically deposited on the hard drive of your computer, tablet or smartphone when you browse our Website. They are managed by your Internet browser (Internet Explorer, Firefox, Safari or Google Chrome).

10.2 Are cookies stored when you browse TAKOMA’s website?

We do not collect personal data through cookies.
We use an audience measurement service which allows us to generate statistics on the number of visitors which is useful for the improvement of the site. This service can be activated or deactivated with your consent.  The memorization of your consent requires the use of a functional cookie described on our cookies page.

11. Update of this policy

This policy may regularly be updated to account for evolutions in regulations relating to personal data.
The last update is dated 10/10/2022.