Last update: 3rd May 2021
As part of the website operation (hereinafter "website") and more generally of its teaching activity, the Hub School 21 association (hereinafter, "Hub School 21" or "the Association ") Is required to collect personal data (hereinafter," Data ") relating to (future) students, their parents, stakeholders, our partners and in general, users of the website (hereinafter collectively, the “Data Subjects”).
The Association undertakes to process this Data in accordance with applicable regulations, in particular "GDPR" 1 and the Data Protection Act2 (hereinafter, the "Regulations").
This confidentiality policy (hereinafter, the “Policy”) is intended to inform the Data Subjects of the conditions under which the processing of Data is carried out and of the rights they have over such processing.
1. Data Manager
The Data Manager is the Hub School 21 Association. The head office is located at 16 Boulevard St Germain 75005 Paris.
2. Data collection
The Data processed by Hub School 21 and the way in which this Data is collected are as followed :
● Via the Google Form pre-registration form on the website: The Data collected includes :
- Data related to the child (last name, first name, date of birth, languages spoken, educational level, academic or behavioral difficulties);
- Data related to the child's family (legal representative, names and addresses of each of the parents or others, email address);
- Practical information (authorization to leave the school by himself, person authorized to pick up the child from school, image rights, medical information for example: allergies, chronic diseases;
1 Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data
2 Data Protection Act n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms
● Via the newsletter subscription form : The Data collected is the email address, last name, first name.
● Through official interviews (registration or else) with the child and his parents/legal representatives, and the registration file : The Data collected includes - depending on the situation - :
- The profession of the child’s legal representatives and their social class ;
- A copy of the family record book ;
- Tax, non-taxation notices or the family quotient ;
- School insurance certificates in case of registration for optional school activities (outings and school trips);
- Data related to the compulsory vaccination status of the child ;
- If necessary, information about the child's diet ;
- If necessary, specific information concerning the child (ex: handicap) ;
- If necessary, information on the child's allergies or pathologies.
● Via the donation form : The Data collected includes: last name, first name, e-mail address, date of birth, postal address, and, the name of the company if applicable. These data are collected by Helloasso on behalf of Hub School 21. Hub School 21 does not have access to Data related to means of payment (credit card number, expiration date, security code, authorization number). These are collected directly by specialized service providers via the Hello Asso website.
Third party providers and plug-ins on the website, as well as social media on which Hub School 21 publishes editorial and promotional content (Facebook, Twitter, Instagram, YouTube and LinkedIn) may also use automated means to collect and process Data of the Data Subjects. This Data is collected directly by these service providers and / or third parties and is subject to their confidentiality policy. The Association is not responsible for the practices of these service providers and third parties.
The mandatory or optional nature of the Data collected and the possible consequences, with regard to the Data Subjects, of a failure to respond are specified at the time of their collection.
3. Use of Data
The Data collected by Hub School 21 is used to :
● manage the enrollment and education of children
● create and manage the Google For Education accounts of the Persons Concerned
● monitor and bill for school supplies and extracurricular activities
● answer to any request or need formulated by the Persons Concerned
● acknowledge donation receipt made by the Persons Concerned
● improve the website and personalize the experience of Data Subjects
● contact the Persons Concerned by e-mail or by telephone
● send school news occasionally via the newsletter
● carry out anonymized statistics
● answer to requests from Data Subjects under the Regulations.
4. Legal basis for processing
The Data is processed according to the following legal bases :
● The performance carried out by Hub School 21’ mission as a primary and middle school educational institution;
● Compliance with a legal obligation to which Hub School 21 is subject, for sending school certificates to the local authority ;
● Safeguarding the vital interests of a child in school, in serious and emergency situations ;
● The consent of the Data Subject, requested in the following situations: (i) creation of a Google For Education account for the child when registering for school, (ii) provision of information relating to allergies or pathologies of a minor, (ii) request for authorization to use the image of a minor, (iv) subscription to the newsletter and (iv) use of so-called “non-essential” cookies on the website. When the processing is carried out on an information society service and the minor is under the age of fifteen, consent must be given jointly by the minor concerned and the holder (s) of parental authority.
● The legitimate interest of Hub School 21 in (i) adapting its website according to the preferences of the Data Subjects and (ii) ensuring the security of the Site.
5. Data retention periods
With regard to the child's education, The Data collected and the supporting documents are only kept in an active database for the time necessary to achieve the purposes for which they were collected, namely :
● the pupil's education ;
● the school year for the legal obligation of education ;
● enrolling the child in an extracurricular activity, school catering, school transport ;
● examination of the file for pre-enrollment in school or for an activity in which he has not followed up.
At the end of this period, we keep the Data in an intermediate archive database when they are strictly relevant for the following purposes :
● probative, in the event of litigation, the Data is kept as long as the time limits for exercising ordinary and extraordinary remedies have not been exhausted ;
● probationary, in the event of control by authorized bodies.
Regarding the Newsletter : The Data collected is kept for three years from the last contact from the Data Subject.
6. Data Flow
Hub School 21 Data recipients may be required to communicate all or part of the Data to different recipients depending on the purpose of the processing.
The internal recipients of Hub School 21 are as follows :
● The founding team of the Association ;
● The teaching team in certain cases and for certain Data ;
● Supervisory staff ;
●The accounting department
Hub School 21 may transmit, directly or indirectly, all or part of the Data to the following third parties :
● The National Education Inspector (IEN) ;
● Health professionals where applicable ;
● IT support service, in order to detect, avoid or deal with fraudulent activities, security breaches or any technical problem ;
● IT service providers, in particular the website (Wix.com Inc), and Google, the publisher of the Google For Education suite used by Hub School 21 ;
● Auditors, statutory auditors, accountants, lawyers in order to protect against any infringement of the rights, property or security of Hub School 21, the Persons Concerned or the public, in application and in respect of the law;
● Public authorities and bodies, when required to comply with obligations legal, regulatory, judicial or administrative.
● Outsourced services such as IT maintenance or accounting service
Data Transfers outside the EU
Hub School 21 may transfer the Data of Persons Concerned to third parties located outside the European Economic Area (EEA) or the European Union (EU). When this is the case, Hub School 21 ensures that the recipient country has been the subject of an adequacy decision by the European Commission. Otherwise, Hub School 21 undertakes to supervise the transfer by the appropriate legal instruments, in particular the Standard Contractual Clauses ("SCC") of the European Commission or binding corporate rules, provided that the conditions of use of these instruments are fulfilled.
Persons Concerned are informed that Hub School 21 uses the Google For Education collaborative suite (messaging service and collaborative cloud applications). In this context, the Data may be processed according to the terms of the commitments made between Hub School 21 and Google.
If the Data Subject wishes to obtain more information on how Hub School 21 protects their Data or wishes to obtain a copy of the legal instruments implemented, they can request it at the following address :
By postal services : Hub School 21, 16 Boulevard St Germain 75005 Paris
By email : email@example.com
7. Rights of Data Subjects
Persons Concerned by Data processing can contact the Association at any time to exercise their rights over their Data at the following coordinates :
By postal services : Hub School 21, 16 Boulevard St Germain 75005 Paris
By email : firstname.lastname@example.org
The rights available to Data Subjects under the Regulations are as follows :
● Right to access information : access the Data processed by Hub School 21 (right of copy) or ask whether Data processing is actually carried out by Hub School 21 or not.
● Right of rectification : request the rectification of the Data if they are inaccurate or incomplete. ● Right to delete: ask Hub School 21 to erase the Data when they are no longer necessary, when the Data Subject has withdrawn their consent, exercised their right of objection, or the processing was unlawful.
● Right to object : to object to processing based on the performance of a mission of public interest or on the legitimate interests of Hub School 21.
● Right to portability : obtain from Hub School 21 all or part of the Data in an open and machine-readable format in order to store or reuse them or ask Hub School 21 to transfer them to another organization.
● Right to restriction of processing : ask Hub School 21 to temporarily freeze the use of certain Data.
● Right to withdraw consent : withdraw consent when it has been given. The person concerned can withdraw their consent to receive the Newsletter at any time by following the detailed unsubscribe instructions included at the bottom of each Newsletter.
● Formulate guidelines for the retention, erasure and communication of post-mortem data. The aforementioned rights may be limited in certain cases under the Regulations.
The exercise of these rights is conditional on compliance with the following rules :
● The request must come from the data subject himself or his representative.
● The person concerned must identify himself precisely if this is necessary.
● The Data Subject must state a legitimate reason when it is required by the Regulations.
If there is a reasonable doubt as to the identity of the person exercising his rights, Hub School 21 may ask him to attach any document to prove his identity.
8. Data security
The Hub School 21 Association protects the information of Data Subjects offline. Only members who need to do specific work have access to personally identifiable information. Computers and servers used to store personally identifiable information are kept in a secure environment. In accordance with the procedure provided for by the Regulations in the event of a leak or anomaly concerning the personal data in our possession, we will inform the competent authorities (CNIL), and warn the Data Subjects of the nature of the data that has leaked and the nature of the risk. which can be generated if it can affect their rights and freedoms (sensitive data) as soon as possible.
9. Changes or updates to the Policy
Hub School 21 may revise the Policy whenever necessary, in particular in order to comply with any regulatory, jurisprudential, editorial or technical changes. Any changes will be posted on this Policy page, and the date will be updated. We therefore encourage those concerned to regularly consult this Policy. In the event of material changes, we will post a notice on the website to announce these changes.
10. Contact us
For any questions, comments, complaints or requests regarding this Policy or the processing of their Data, Data Subjects can contact Hub School 21 by sending an email to email@example.com.
11. Right to lodge a complaint with the CNIL
The Data Subjects can lodge a complaint with a supervisory authority, namely the CNIL in France, if they consider, after having contacted Hub School 21, that the processing of their Data does not comply with the Regulation to the following address :
Cnil - Complaints Department 3, place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tel: 01 53 73 22 22
For any other more general information on the protection of personal data, the Data Subjects can consult the Cnil website.