360Learning edits several online spaces – some of those being freely accessible, others being accessible via a subscription or during a limited trial period:
In the context of its commercial activity and while browsing these web spaces (the “Website(s)”), 360Learning is required to process personal data concerning you. This policy allows you to be aware of the way your personal data are used, why we use them and what we do with them.
Your Personal Data are processed by the 360Learning company in its capacity as controller when you have the following status: prospect; contact/administrative referral in order to allow for the management of the commercial relationship.
Your personal data are processed by the 360Learning company in its capacity as processor in any other instances, i.e. when you have the following status: final user of the 360Learning Platform.
For more information on 360Learning and its terms and conditions.
We only use your personal data in the cases provided for in the applicable legislation, which are the following:
|Management of the 360Learning Platform||Performance of contracts for the provision of services|
|Management of your orders placed via the Platform and via Universities||Performance of contracts for the provision of services|
|Analysis of your browsing on the Platform for the purpose of improving our services||Legitimate interest of 360Learning|
|Conduct of satisfaction surveys for the purpose of improving our services||Legitimate interest of 360Learning|
|Performance of statistical studies on the use of our Platform and of our services||Legitimate interest of 360Learning|
|Direct commercial marketing (sending promotional offers, newsletter)||Legitimate interest of 360Learning|
|Behavioral advertising||Consent obtained|
|Audience measurement||Consent obtained|
You can provide us with information that concern you during the various contacts that we have with you, including in the context of the:
These data include your name, first name, email address, occupational category, password. It can also include your phone number, profile picture, link to your LinkedIn/Twitter account if you fill in these information on the Platform or information that you provide when you write a review on the Platform or a comment on the Blog.
These are the data that you provide to us:
These data include the name, first name, email address, occupational category of the commercial contact, HR or any person that might enter into a relationship with 360Learning for the satisfactory performance of the services entrusted to 360Learning, as well as any information that you would wish to provide to us.
As regards orders, the data are information related to your means of payment (credit card number, expiration date of the credit card, visual cryptogram) through a secured payment service provider, which is the only one to have access to these data.
Every time you visit our websites and apps, we collect information related to your connection and browsing via the cookies’ technology (for more information on cookies, see Title II below).
The “sensitive” data are those revealing racial or ethnic origin, political, religious or philosophical beliefs, trade union membership, data related to health or sexual orientation. 360Learning does not collect any of those data that concern you.
Your personal data are retained for a duration that complies with applicable regulations or that is proportionate to the purposes for which they have been saved. Some durations of retention reflect 360Learning’s legitimate interest as specified above in the introduction. Please find below the main durations of retention of your data.
|Category of data||Purposes||Durations of retention|
|Data related to a prospect||All of the data of the prospect(name, first name, email, occupational category, etc)||Management of a file of prospects||3 years as from the collection of the data or of the last contact initiated by the prospect|
|Data related to a Final User of the Platform||All of the data of your own clients, whether internal or external, so long as they have been authorized (staff, partners, external providers)||Performance of a contractual obligation||Duration of the contractual relationship, from the free trial up until 4 months and 30 days (backup) as from the end of said relationship.|
|Data related to an active client||All of the client data that have been filled in the Subscription Warrant, at the time of the subscription(name, first name, email, occupational category)||Management of the client's account||Unless a request for deletion is made, at the expiration of a period of 3 years after the end of your contract and subject to applicable legal rules|
|Data related to an inactive client||Identification and contact data of persons who subscribed to the newsletters||Information sent on the evolution of our publications and our offers||Maximum period of 3 years as from the unsubscription or of the last contact initiated by the client|
|Data generated by cookies||Data related to your browsing on our online services||Functioning, optimization of the services, audience measurement, personalization of the contents, ads.||Maximum period of 13 months|
|Data collected when you enforce rights related to the GPDR||Copy of the ID card||Management of the file of persons enforcing their right of access, rectification, erasure, limitation and objection||12 months|
When the retention of data is no more justified by requirements of a legal or commercial nature or requirements that relate to the management of your client account, or if you have exercised your right to modify or erase these data, we shall erase these in a secured manner.
Your data are accessible to certain teams of 360Learning. These teams only have access to the data that are necessary for the purpose of the performance of their duties and are not authorized to process data for other uses. Besides, they are subject to a confidentiality undertaking for this purpose.
Your data, depending on your role (Learner or Author, for example) on the Platform are accessible to your employer, and by the Extended Roles that are allowed to administer the Platform (“Owner” and “Administrator”).
Your data are accessible to the service providers to which we subcontract all or part of the processing that we perform on your data (hosting of the Platform and of the data, maintenance, sending emails confirming orders, mailing, secured payment, etc.).
The processors on which we rely comply with the guarantees required by the legislation which governs the protection of personal data. They only have access to the data that are necessary for the purpose of the performance of their services and are not allowed to process your data for other uses.
The list of the processors with which 360Learning works is available here, and in the last pages of our legal documentation. This list may be amended in the future.
Our processors’ access to your data relies on legal acts which incorporate the obligations to which they are subject as regards protection of the security and confidentiality of the data.
Your personal data may be divulgated to the authorities by virtue of a law, a regulation or a decision of a competent regulatory or judicial authority.
In general, we undertake to comply with all legal rules which may prevent, limit or govern the dissemination of information or data and notably to comply with the applicable regulations governing the protection of data.
If your interact by way of elements emanating from third parties, for example if you click on the “like” button or if you post a comment, the related information shall be transmitted to the social network and published on your profile.
If you do not wish that the social network liaises the information that have been collected via our Website to your user account, you shall log out of the social network beforehand.
We invite you to go through the personal data protection policies of these social networks.
You have the right to obtain from our services:
You can also, at any time, oppose the processing of your data for direct commercial marketing purposes and withdraw your consent to the processing of your data by our services for the purpose of behavioral advertising, browsing analysis and audience measurement.
We also remind you that you have the right to file a complaint with the CNIL if you are of the opinion that your rights have been violated. For more information on the rights that you have with regard to your data, please visit the CNIL’s website: www.cnil.fr/en/home
For any request of access, opposition, rectification, portability, limitation and fate of your data in case of death: You can send an email to the following address: firstname.lastname@example.org and:
To oppose the processing of your data for direct commercial marketing purposes: You can send us an email at email@example.com, liaise with your Account Manager or your Success Partner (should you have one) or click on the unsubscribe link that appears in all our promotional emails and in our newsletter. Our services undertake to remove your address from our mailing list as soon as practicable.
To withdraw your consent to the processing of your data by our services for behavioral advertising purposes, browsing analysis and audience measurement: You can send us an email to firstname.lastname@example.org or configure your cookies.
Some processing operations that we subcontract to processors are performed outside of the European Union. Transfers of your data are performed safely and in compliance with the applicable legislation on data protection.
In our capacity as data controller, we implement appropriate technical and organizational measures which comply with applicable legal rules, in order to protect your personal data from alteration, accidental or illicit loss, use, divulgation or unauthorized access, including:
For more information, please see our Technical Documentation which can be accessed here.
We reserve our right to amend this policy in order to comply with the legal rules and regulations but also because our website and our services continuously evolve. Please visit this page from time to time in order to be aware of any new information which may be added.
This policy is governed by French law. Any dispute related to the interpretation or the performance of this policy shall be governed by French law.
A “cookie” is a small alphanumeric file which is placed in the terminal of your computer (or your smartphone/tablet/mobile, etc.) when you browse a website.
A cookie does not necessarily contain your name or your email address, it is rather the ID of your browser, which records your use of a website.
Depending on the entity that manages the website from which the cookies emanate and processes the data that are so obtained, it can be:
Depending on the time period during which the cookies are stored in the terminal of the user, there exists some:
Depending on the function of the cookies and the purposes of the data so obtained, there is a distinction between:
360Learning uses several types of cookies which address different needs:
|Internal cookies||Type||If you browse...|
|360Learning (personalization_id)||Required||The cover website|
|360Learning (Token)||Required||Universities or a private training space|
|360Learning (rememberMe)||Required||A private training space|
|360Learning (TrafficSource)||Functional/Personalization||The cover website or the Blog or a private training space|
|360Learning (mail; telephone)||Functional/Personalization||The cover website|
|Third party cookies||Type||If you browse...|
|Zendesk (__cfduid)||Functional||A private training space|
|Amplitude (amplitude_id)||Analysis and performance||The cover website or Universities or a private training space|
|Errorception/CloudFare (__cfduid)||Analysis and performance||The Blog or a private training space|
|Marketo (_mkto_trk)||Targeting||The cover website or the Blog|
|Google Analytics (_ga _gat _gid)||Anaysis and performance||The cover website or the Blog or Universities|
|Adroll (__adroll ; __adroll_fpc ; __ar_v4)||Targeting||The Blog or Universities|
|Facebook (fr, pl, presence, sb, spin, act, wd, xs)||Social networks||The cover website or the Blog or Universities|
|Twitter (personalization_id)||Social networks||Universities|
|Linkedin (BizoID; UserMatchHistory; Bcookie; Lang; Lidc)||Social networks||The cover website or Universities or The Blog|
|Bing (MUID ; MUIDB)||Advertisement||The cover website or the Blog or Universities|
|Drift (Dftt_end_user_prev_Bootstrapped; driftt_aid; driftt_sid)||Targeting||The cover website|
|Crazy Egg (_ceg.s ;_ceg.u ;_ceir)||Advertisement||The cover website or the Blog or Universities|
|Google/Doubleclick (1P_JAR; DSID; DV; HSID; IDE; NID; SAPISID; SID; SIDCC; SSID||Advertisement||The cover website or the Blog or Universities|
|WordPress (pum_alm_first_activity)||Functional||The Blog|
The installation of certain cookies is subject to your consent, when their exclusive purpose is not to allow or facilitate browsing or when they are not strictly necessary for the provision of services or the management of your orders.
It follows that, when you first visit the website, you are informed by a banner that if you pursue the browsing, you agree to the installation of these cookies on your equipment. A cookie will be installed in order to memorize your choice. Please note, however, that if you delete this cookie, you will be asked to agree again.
You can reconsider your choice at any time:
You can configure your browser in order for:
The configuration of each browser is different:
If you oppose the saving of cookies in your terminal, or if you delete those that are saved in it, certain functionalities that are required for browsing the Platform may be impaired as a result of the settings that you would have chosen (difficulties to save or display…). We shall, in any case, not be held responsible for the deficiencies that may be observed.
With regard to advertisement cookies placed by third parties, you can also log in to the Youronlinechoices website, which is offered by the digital advertisement professionals which are gathered within the European EDAA association (European Digital Advertising Alliance).
You would then be able to refuse or accept cookies used by advertisement professionals that are members of the association.
For Google Analytics, you can visit this page directly.
This will save a cookie within your terminal, the sole purpose of which is to deactivate the audience measurement services that are performed.
Notice: the implementation of your choice requires the issuance of a cookie. If you delete all of the cookies that are saved in your terminal (via your browser), we will not know that you had chosen this option anymore.
By configuring the social networks’ cookies