What this Policy Covers

The information about you collected on this website is subject to this privacy policy. By disclosing information to us, and validating the data privacy, you agree to the terms of the policy. “Training Orchestra”* (“Company”, “us” or “we” includes both TRAINING ORCHESTRA SA, 17 rue de Miromesnil 75008 PARIS, FRANCE and TRAINING ORCHESTRA America Corp, Newark, DELAWARE, UNITES STATES OF AMERICA) is committed to protecting the privacy of visitors to our website while permitting us to conduct legitimate business by providing services and information. Our privacy policy is stated below to demonstrate our commitment to you. This privacy policy advises our visitors and members of the types of personal and technical information that may be collected on this site and the practices that Training Orchestra follows with respect to the use and dissemination of such information. Your use of the site is subject to this privacy policy and our Terms of Use. Training Orchestra is subject to the General Data Protection Regulation 2016/679 (GDPR). Training Orchestra SA has been declaring personal data transfers to the US (prospects and clients contacts) to the French Data Protection Authority even before the effective application of the GDPR. Model clauses between the two Training Orchestra companies are in progress. Please read this privacy policy carefully to understand how we treat information collected on this site. By visiting or using any part of this Website, you agree to the terms of this Privacy Policy. If you have any questions, comments, or concerns regarding this privacy policy, please contact: gdpo@training-orchestra.com

Policy Modifications

We reserve the right to change this policy from time to time to reflect changes in our business practices. Any changes to this policy, including information collected and the use and disclosure of information, will be posted here. Following any modification, we will revise the “last updated” date at the top of this policy, so be sure to check back periodically for the most current version of our policy.

Collection of Information

When you visit our website, we may collect information regarding your visit from your computer. This information helps us determine how you found our website, the date you visited, and the search engines that may have led you to our website and helps us improve the functionality of Training Orchestra. The information that you provide can be classified into two general types which are discussed in more detail below: User-provided information and website usage information.

Personal information that you choose to provide

Depending on whether you fill out a form on our site, communicate with us by email, phone, or otherwise such as giving us your business card or contact details at trade shows, exhibitions, or other events, apply for a job opening, enter a promotion or give us feedback, the information you provide to us and that we will collect may include your name, email address, phone number, email address, company, position, company address as well as the details of your query. We may also collect additional information, such as in connection with marketing surveys or events. If you provide us with any personal information, you should inform us immediately of any changes to the information that you provided and update your personal details by sending an e-mail to: marketing@training-orchestra.com

Collection of information from third parties

Occasionally, we may receive personal information about you from third-party sources including partners with which we collaborate from time to time in joint marketing activities and publicly available sources. We may also receive analytics and advertising data about you regarding your visit or how you found our website from the sources listed below. Please visit the following websites for more information about how Google Analytics and HubSpot collect and use data when you visit their partners’ websites.

• Google Privacy Information
• HubSpot Privacy Information

Website Usage Information

Browsing & cookies

We do not collect personal information such as your name, business address, contact phone number, or email when you are browsing our site, but we use cookies on our site as detailed in the “Cookies” section below. Training Orchestra uses both session cookies, which are stored in temporary memory and not retained after the browser is closed, and persistent cookies, which store information on your hard drive so when returning to the same website at a later date, the cookie information is still available. These are readable only by Training Orchestra’s employees, and cookies cannot access, read, or modify any other data on your computer. They are used to collect information about your choices and preferences and customize our site accordingly, including integration with social media and relevant advertising tailored to you. For instance, to save the user’s preferred language and country settings, perform a statistical analysis of the number of users and of their usage habits, to improve the loading speed of the individual pages. We do not sell any data collected by these cookies or from your personal data. We also use cookies for analytical purposes particularly through Google Analytics to collect information about your use of our site and to enable us to improve our website experience. For instance, analytics cookies allow us to identify the countries of our visitors and analyze the nature of the overall traffic, as well as our most frequently visited pages on our site, and whether our advertising is effective or not. For more information about managing cookies, targeting and advertising cookies, and how you can opt-out, there are numerous resources on the Internet. One very informative not-for-profit site is: www.allaboutcookies.org You should be able to control cookie specifications via your browser settings. The relevant browser options and instructions on use can generally be found in the browser manual or help file. If you reject, block, or deactivate cookies, this may restrict the availability of the services offered via the website. In addition, parts of the website may not work correctly under certain circumstances. Some of the cookies we use and their functionality are included in the table below:

Web beacons

A Web beacon is an often invisible graphic image that is placed on a Website or in an email that is used to monitor the behavior of the user visiting the Website or sending the email – email tracking and page tagging for web analytics. We may use web beacons (or tracking pixels) alone or in conjunction with cookies to compile information about your usage of our site and interaction with emails from Training Orchestra. In the perspective of improving our website experience and customer communication, web beacons may be used by Training Orchestra’s marketing analytics in e-mail messages or newsletters to determine whether the message has been opened or to allow us to count users who have visited certain pages and to generate statistics about how our site is used. Web beacons are used solely for the purposes described in this Privacy Policy and are not intended to collect information unrelated to those purposes.

Unlike cookies, web beacons do not provide a browser-based mechanism for acceptance or refusal. However, where required by applicable law, Training Orchestra will provide appropriate mechanisms to manage email tracking preferences and withdraw consent. You may also set your browser to decline cookies, which may prevent certain Web beacons from collecting information about your activity.

Email Tracking Technologies

Training Orchestra may use email tracking technologies, sometimes referred to as tracking pixels or web beacons, within certain email communications.

These technologies may allow us to determine:

• whether an email has been opened;
• the date of the interaction with the email;
• technical information associated with the email application, browser, or device used to view the message;
• aggregated statistics regarding the effectiveness of our communications.

Training Orchestra may use such information for purposes including:

• measuring and improving the effectiveness of communications;
• understanding which content is most relevant to recipients;
• managing communication frequency;
• maintaining the quality and accuracy of distribution lists;
• identifying inactive recipients and reducing unnecessary communications.

Where required under applicable law, Training Orchestra will obtain consent before using email tracking technologies for purposes that require consent.

You may object to or withdraw consent for email tracking at any time through the preference management tools made available by Training Orchestra or by contacting us at: marketing@training-orchestra.com

Choosing not to participate in email tracking will not prevent you from receiving communications that you have requested or otherwise agreed to receive.

IP address data

Our servers automatically collect data about your Internet Protocol address when you visit us. When you request pages from our Website, our servers may log your IP address and sometimes your domain name. Our servers may also record the referring page that linked you to us (e.g. another website or a search engine); the pages you visit on this Website; the website you visit after this Website; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral website; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet service provider. Personal information (including IP addresses) is not used to facilitate contact with users who have not provided their contact details. Your IP address may be used to identify the clickstream that led you to our site; however, personal information is not shared with any third-party marketing companies.

Your Ability to Choose/Opt-Out

We provide you information that you have requested by sending us an email or entering your request through our website. We may also send you information and offers from the Company and our third-party service providers. You have the right to ask us not to process your personal data for marketing purposes. You may always choose not to receive our marketing emails / Opt-Out by following the instructions at the bottom of each email you receive from us. You may also change your preferences regarding the types of emails you receive from us by emailing us at: marketing@training-orchestra.com

Use, Disclosure, & Sharing of Personal Information

Service providers

We may use third-party providers to help us operate and maintain our Website and Activities, as well as deliver our products and services. Third-party service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.

Data may be processed in the European Union, and the United States, depending upon contractual requirements and in accordance with legal jurisdictions for the region(s) to which TRAINING ORCHESTRA is subject. All locations will either benefit from an Adequacy Decision or from alternative suitable safeguards. NS48 Declaration to the CNIL French Data Protection Authority was managed before May 25th, 2018. Declaration with EU Model Clauses is in progress.

As for clients outside the EU or the US of A., specific contractual clauses are when needed included in the written agreements between both parties.

How we use the information we collect

We use the information we collect about you in compliance with this Privacy Policy. We never sell personal information to any third party. We may use your personal information in the following ways:

• To provide you with information (via mail, email, or telephone) about our solutions and services that you may request from us or which we feel may be of interest to you, such as promotional, marketing, and events communication, if you have consented to contact for such purposes;
• To notify you about changes to our site, privacy policy, product, or services;
• To allow you to participate in interactive features of our website when you choose to do so;
• To improve our website (administration and marketing purposes) including troubleshooting, testing, and research, and as part of our efforts to keep our site safe and secure;

Our web servers automatically collect and log web usage data from you when you visit our website. This information, including your IP address, referring site, pages viewed, and length of visit, informs us about how visitors use and navigate our website. Those details are being included in our HubSpot database.

Disclosure of your information

Our general policy is not to disclose any personal data to a third party except with your prior consent or with a legal basis.

However, we may disclose personal information to comply with valid legal processes such as a search warrant, subpoena, supervisory authorities, or court order, if we find that a user’s actions violate our policies, or to protect our rights and property, or to our affiliates or successors to the relevant portions of our business.

TRAINING ORCHESTRA reserves the right to disclose Personal Data to regulatory and supervisory authorities, as well as, pursuant to this Privacy Statement, to Analysis Service Providers. In so doing, TRAINING ORCHESTRA will comply at all times with applicable regulations, laws, court orders, or official requests.

• We will not share this information with any other person, company, or organization, except with third parties providing products or services to you, pursuant to your agreement with TRAINING ORCHESTRA, and as may be required by law.
• Information concerning individuals’ usage of our sites will not be disclosed to third parties except in aggregate form /or anonymous form, such that your information will not be personally identifiable. This aggregate/anonymous information would have been collected based on web usage data or statistical information that we have compiled about our users.

Third-Party Websites

Our website contains links to third-party websites that are provided for your convenience. Training Orchestra does not endorse nor is responsible for the privacy practices or the content or services of such websites. We recommend that you review the privacy policies and terms of use that govern those websites when you visit them.

Privacy of Minors

This website is directed towards adults. Training Orchestra does not knowingly collect information from children under the age of 18. Children under the age of 18 should not use this website or submit information to us. If we happen to collect the personal data of individuals under the age of 18, we will immediately delete such personal information.

Language

The governing language of this privacy policy is French, which shall prevail over any other language used in any translated document.

Personal Data Reproduction

Employee photos and personal data have been included on this website with the expressed permission of the “Training Orchestra” employee. Customer photos and personal data have been included on this website with the expressed permission of the customer. Under no circumstances can any employee or customer photos and/or personal data be reproduced without the written permission of Training Orchestra. To obtain permission, contact us at: gdpo@training-orchestra.com.

Pictures, Logos, Trademarks & Copyrights

Pictures, Company logos, trademarks, and copyrights belong to their respective owners and have been used with the expressed permission of their owners. They cannot be copied from our site. All content on this site (image, video, sound, text …) is protected by the laws in force in France and the United States in the field of intellectual property and in particular, copyright, neighboring rights, and trademark law.

All rights of reproduction are reserved, including for downloadable documents and iconographic and photographic representations.

In the absence of express authorization from TRAINING ORCHESTRA it is strictly forbidden to exploit these contents and in particular to reproduce, represent, modify, or adapt them in whole or in part.

GDPR Information Notice & Related Provisions

Data controller & contact details

TRAINING ORCHESTRA Data Controller & Solution Representative: Stéphane Pineau
Email: contact@training-orchestra.com

TRAINING ORCHESTRA SA
RCS Paris B 438 880 957
17 rue de Miromesnil
75008 Paris – France

Data Protection Officer

Sandra MARZEC, DU DPO, CNIL #2538 (French Data Protection Authority)
Email: gdpo@training-orchestra.com

TRAINING ORCHESTRA SA
RCS Paris B 438 880 95717 rue de Miromesnil
75008 Paris – France

Purpose & Legal Basis for Processing

We collect and use your Personal Information when required for the management of the products and services we offer to you or your organization, and the associated commercial relationship, as well as to comply with legal obligations we may have.

We also may collect and use your Personal Information under the GDPR’s legitimate interest legal basis to build and maintain a network of HR-related professionals, to provide information and resources related to HR, and to promote our professional products. We will analyze your interactions with us to understand your profile and level of interest in our products and services, (e.g., to decide whether or not to include you in a given campaign).

The information may be collected directly from you, from your organization, or from other authorized third parties.

When consent is required, a consent form will be provided to you.

Sharing information

We may use third-party providers to help us operate and maintain our Website and Activities, as well as deliver our products and services. Third-party service providers are contractually restricted from using or disclosing the information, except as necessary to perform services on our behalf or to comply with legal requirements.

Consent to worldwide transfer & processing of personal information

By providing Personal Information to us through this Website, you authorize TRAINING ORCHESTRA and our Affiliated Parties for the purposes described herein.

You further understand and consent to the collection, maintenance, processing, and transfer of such information to the European Union or to the United States of America.

Any person who accesses Personal Data (either Training Orchestra’s personnel or subcontractor) is required by TRAINING ORCHESTRA to ensure compliance with all applicable data protection provisions. Any person who authorizes TRAINING ORCHESTRA to access their Personal Data as defined in this Privacy Policy will be made aware of the data security and data protection implications.

Those countries may have different privacy laws from your country of residence and may afford varying levels of protection for your Personal Information. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy.

TRAINING ORCHESTRA protects Personal Data on its own Information system environment with appropriate physical, electronic, and process-related security measures, such as firewalls, and personal passwords. Personal Data collected via a website owned by TRAINING ORCHESTRA will be encrypted during transmission using SSL Secure Sockets Layer (SSL) technology, which currently provides the best available security for data transfers.

Data retention

Generally, we will retain data for between one (1) and three (3) years after the last contact.

We retain your personal data as needed to provide you Services and as long as it remains necessary for the identified purpose(s) for which it was originally collected or such longer period as may be required for legal, audit, and compliance purposes. This includes data you or others provided to us and data generated or inferred from your use of our services. All retained information will remain subject to the terms of this Policy. If you request that your name be removed from our databases, we will do it. However, it may not be possible to completely delete all your information due to technological or legal constraints, but they will be anonymized as much as possible.

Your rights

You may exercise your rights as a data subject (access, rectification, erasure, restriction, and objection, as well as portability) by reaching out to us via: gdpo@training-orchestra.com.

When processing is based on consent, you have the right to withdraw your consent at any time.

Finally, you also have the right to lodge a complaint with a supervisory authority.

Reviewing your information/contact us

You may review and update the personally identifiable information we have collected about you by contacting us at: marketing@training-orchestra.com. To protect your privacy and security, we may take reasonable steps to verify your identity before we disclose or make any corrections to such information.

You should understand that information about you in our database might come from a number of external sources for which you might have disclosed information. Upon request, we will update produce, or erase that information from our site database or change/correct personal information that you state is erroneous.

The rights specified above may be denied or restricted if the interests, rights, and freedoms of third parties take precedence or if processing is necessary to establish, exercise, or defend legal claims of TRAINING ORCHESTRA.

Queries regarding data correction or information have to be directed to: marketing@training-orchestra.com.

Queries concerning processing Personal Data Policy are to be directed to the Data Protection Officer.

Automated decision making

We will not use the information we collect to make automated decisions that would have a legal or significant effect on you.

Site Web Host & Other 3rd-Party Vendors

Site web host

US/ENGLISH & FRENCH SITES
SiteGround
SG Hosting Inc.
901 N. Pitt St, Suite 325
Alexandria, 22314 VA USA

For more information regarding this data center, visit: https://www.siteground.com/datacenters

• Data Processing & Protection Agreement: https://www.siteground.com/term/301.htm
• Security Certificates: https://www.siteground.com/kb/how_does_siteground_protect_my_website/

The personally identifiable information we collect about you is stored in limited-access servers managed by our software service providers. While we maintain commercially reasonable safeguards to help prevent unauthorized access, maintain data security, and make proper use of the information that we collect, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us.

Data collected via forms on our website also sends information to our HubSpot instance. It is hosted and supported in the USA. All transfers are lawful transfers of personal data.

HubSpot establishes operational requirements that support the achievement of the principal service commitments, relevant laws and regulations, and other system requirements, including access control Here are links to their data processing and security measures:

• Information Security Overview
• GDPR Compliance Information
• Data Privacy and Monitoring

HubSpot is hosted on Amazon Web Services in the United States. and utilizes their Virtual Private Cloud network.

• Amazon Web Services

Voluntary Modern Slavery and Human Trafficking Statement

Training Orchestra is committed to conducting its business with integrity, transparency and respect for human rights.

This statement describes the Company’s approach to identifying and managing modern slavery and human trafficking risks in a manner proportionate to its size, activities and supply chain profile.

Training Orchestra is a SaaS company providing software solutions and related services. Given the nature of its activities, its direct exposure to modern slavery and human trafficking risks is considered limited. The Company nevertheless recognises that such risks may arise indirectly through supply chains and third-party relationships.

Training Orchestra does not tolerate slavery, servitude, forced or compulsory labour, or human trafficking in its business or supply chains.

The Company expects its employees, suppliers and business partners to comply with applicable laws and to act ethically and responsibly.

Concerns relating to unethical conduct, human rights violations or breaches of applicable laws may be reported through the Company’s internal reporting channels.

This statement may be reviewed and updated periodically. For and on behalf of Training Orchestra, Kérim SYLVESTRE, Chief People Officer.