Privacy Policy

1. CONTROLLER

The controller is Innov'Educ, a French société par actions simplifiée [simplified company limited by shares] with a share capital of €9,624.00, entered on the Chartres Trade and Companies Register under number 794 926 063, located at 18 Rue de la Gare, 28240 LA LOUPE, FRANCE, represented by its CEO, Mrs Anna Stépanoff.

2. PURPOSE OF PROCESSING

2.1. GENERAL PURPOSE OF PROCESSING

Wild Code School processes candidate and student data so that it can manage, monitor and personalise the training courses that it offers.

2.2. SPECIFIC PURPOSES

The specific purposes of processing will depend on what stage each candidate or student is at in the admission or training process:

  • Admission phase:

    • Use of the Odyssey platform:
      • Enable students to register on and use the platform (learning platform used to access Wild Code School training courses).
      • Collect information to complete the student's profile on the Odyssey learning platform.
      • Save solutions posted by the student on Odyssey.
      • Register applications within Wild Code School's CRM tool: duplicate elements retrieved from Odyssey in the Hubspot CRM tool to process the application.
    • Application form and student admission to Wild Code School courses:
      • Conduct student admission interviews for selection purposes.
  • Training phase:

    • Student file:
      • Confirm admissions (collection of information to prepare admission documents, and, where applicable, professional registration on the CERES platform - for diplomas).
      • Register for training courses and follow-up.
      • Create the student's administrative record on the Odyssey learning platform.
      • Prepare candidates' funding documents.
      • Create attendance sheets, collection of each student's signature at the funder's request, in order to check course attendance.
      • Collect emails from current and former students to create mailing lists.
  • Post-training phase

    • Support with professional integration of students after their training
      • Collect students' CVs for editing and support with their professional integration
      • Collect student profiles on the JobTeaser platform so that they can apply for jobs and placement opportunities posted on the platform
      • Collect information to complete the student profile on the Job Teaser platform (not compulsory) but automatic registration

3. LEGAL BASIS FOR PROCESSING

The legal basis for the collection and processing of personal data is as follows:

  • based on the consent given by candidates and students;
  • for the performance of a contract;
  • compliance with our legal and regulatory obligations.

4. CATEGORIES OF PERSONAL DATA PROCESSED

Only personal data which is strictly necessary for the purposes described above is collected. Thus, processed data varies according to the stage that the candidate is at in the admission process, particularly if the candidate then enrols on a training course.

The mandatory nature of information is indicated by an asterisk (*) next to the relevant fields when data is collected. In the absence of an asterisk, the information requested is not mandatory.

The controller may collect and process the following personal data:

  • Identification data (surname; first name; title; personal and work email address; date of birth; place of birth; telephone number; age; city; IP address; user agent (browser, engine used); Github handle; Twitter handle; country; nationality; emergency contacts (close relatives); copy of an identity document)
  • Data concerning the educational and professional relationship (choice of campus; registration date; date of last connection; connection counter; stage in the application and testing process; session; level of training; last diploma obtained; current situation (e.g. job seeker); sector in which last job was held; exact title of last job held; type of contract (e.g.: open-ended); French Job Service (Pôle Emploi) ID; France-ioi profile/ID; SoloLearn profile; public liability insurance certificate; bank details; direct debit mandate; funder's reference number (e.g. Fongecif); days/hours of attendance; student funding documents; survey responses)
  • Data relating to professional integration (CV; biography; level of training; choice of campus; languages spoken; date of last connection; session)

5. DATA SOURCE

Data is entered either in forms or in records created at each stage of the student's admission, training and professional integration process, as applicable.

Candidates or students give their consent to the processing of their data at each stage of the course, from admission to the end of training.

6. CATEGORIES OF DATA SUBJECTS

The category of data subjects includes candidates for Wild Code School training courses and students admitted onto a training course.

7. RECIPIENTS OF PERSONAL DATA

Personal data relating to candidates and students is disclosed to different recipients depending on the stage that the data subject is at in the admission or training process.

  • Admission phase:

    • Use of the Odyssey platform:
    • Administrator of the Odyssey platform
    • Any user registered on Odyssey (for information for each user's profile)
    • Application form and student admission to Wild Code School courses:
    • Members of the Wild Code School teaching team responsible for the candidate
  • Training phase:

    • Student file:
    • Members of the Wild Code School teaching team
  • Post-training phase:

    • Wild Code School team members
    • Job teaser (not compulsory - according to the student's wishes)

8. PERSONAL DATA RETENTION PERIOD

Personal data is kept only for as long as is strictly necessary to fulfil the purposes for which it is collected and processed.

As a general rule, data is kept for the length of time necessary to manage the student's application and training.

The following specific rules apply to the following processing operations:

  • Application: If an application is rejected, documents are kept for a period of one year as from rejection.
  • Student file: Information relating to the student file is kept for a period of one year as from the end of their training. Data entered in the CRM is kept for 3 years as from the end of the students' training.
  • Support with professional integration: For students requesting the help of Wild Code School for their professional integration, data is kept for the duration of their account and for 1 year after its closure.

9. SECURITY MEASURES

All appropriate measures are taken to preserve data security and confidentiality and, in particular, to prevent damage or unauthorised access by third parties. Accordingly, technical and organisational measures are implemented by Wild Code School to ensure an adequate level of security appropriate to the risks.

10. TRANSFER OF PERSONAL DATA OUTSIDE OF THE EUROPEAN UNION

All personal data collected may be transferred to the United States insofar as Wild Code School uses the Hubspot data management solution for certain parts of its activities. Hubspot is used to process student data as part of the admission process, to manage applications, student records, communications with students and to provide assistance to students in terms of their post-training professional integration.

Hubspot is certified as being compliant with the Privacy Shield ensuring a sufficient level of personal data protection to enable data to be exported to the United States. (https://www.privacyshield.gov/participant?id=a2zt000000000TN8pAAG)

For more information about Hubspot's data privacy policy, click on the following link: https://legal.hubspot.com/data-privacy

11. YOUR PERSONAL DATA RIGHTS

Users have the following personal data rights:

  • right of access;
  • right to rectification;
  • right to erasure - this right can be exercised as long as it does not affect the performance of the contract or compliance with our legal and regulatory obligations;
  • right to restriction of processing;
  • right to modify and/or withdraw consents (to be exercised at any time) with respect to the processing of personal data based on their consent;
  • right to object to processing of personal data;
  • right to data portability.

All users also have the right to give general and/or specific instructions about what happens to their personal data and how they would like their rights to be exercised after their death.

All requests to exercise personal data rights must be sent to us as follows:

  • by email: contact@wildcodeschool.fr
  • by post: Innov'Educ, Service Protection des Données [Data Protection Department], 18 Rue de la Gare, 28240, La Loupe, France

Dissatisfied users have the right to lodge a complaint with the competent authority in France:

Commission Nationale de l'Informatique et des Libertés (CNIL)
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
Tel.: +33 (0)1 53 73 22 22

12. CHANGES TO THIS PRIVACY POLICY

This policy is designed to be dynamic and is therefore liable to change. In the case of minor changes, the new policy will be published on the website under the relevant section. In the case of substantial changes, such as changes to the purposes of processing or to the procedures for exercising your rights, you will be duly notified of those changes.