Date of last update: June 2023
Introduction
Candriam, Société en commandite par actions (registered office: Serenity Bloc B, 19-21 route d’Arlon L-8009 Luxembourg), and its subsidiaries, branches and Candriam Switzerland (registered office: rue du 31 décembre 40-42, CH–1207 Geneva, Switzerland) (referred to collectively as “Candriam” or “we” or “our”) committed to respecting the personal data (“Personal Data”) of individuals, including individuals that visit our Webpage and/or register to Candriam Academy (“Users”).
This Privacy notice (the “Notice”) sets out the principles under which Candriam processes Personal Data. Please read the following carefully to understand our position and practices in relation to how we handle Personal Data.
For the purposes of applicable data protection law (including without limitation, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), Candriam acts as the “Data Controller” regarding the collection, the use, and the processing of your Personal Data.
Candriam Switzerland has appointed as EU representative for GDPR matters Candriam Société en commandite par actions, with registered address at Serenity Bloc B, 19-21 Route d’Arlon, L-8009 Strassen, Luxembourg registered no. R.C.S. Luxembourg B 37647.
By using Candriam’s services / site, you acknowledge that you have carefully read this Notice and have accepted it without reservation. You acknowledge that you understand the purposes and basis on which your data is processed. You acknowledge that continued use will be considered as continued consent.
You may, at any time, inform us of your withdrawal of consent by sending an email to the email address given at the end of this Notice.
Please note that as part of our services / site, we may use cookies or similar technologies. Cookies are small text files that are stored on a device’s hard drive and contain certain information and sometimes Personal Data. Candriam uses cookies according to its Cookies Policy. You can consult our Cookies Policy through the following hyperlink: Cookie Management Policy | LUMSA-Candriam Academy
For avoidance of doubt, the meaning of all the capitalized terms contained in the Notice should be understood as in compliance with the GDPR.
1. The Personal Data We collect and process
1.1 We may collect and process the following Personal Data regarding the Users provided that such data is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. These Personal Data are the following :
A. The information you provide us voluntarily including (but not limited to) while registering to Candriam Academy (e.g. first and last names, country, e-mail address, organisation, job title, preferred language…), while subscribing to any of our services and/or products, search for our Website, make enquiries on our Website, while submitting information and/or content to us, while reporting an issue you encountered on our Website, or while corresponding with us in writing, by phone, e-mail and/or by any other electronic means.
B. The information we collect automatically while you are visiting or surfing on our Webpage:
- Technical information, including for example, but not limited the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform.
- Information about your visit to our Webpage, including, but not limited the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, the percentage of achievements of educational programs available on our Website.
C. The information we receive from other sources, e.g., if you visit any other websites or webpages we operate or any the other services we provide and/or products we offer.
1.2 If you provide us information about any person other than yourself, such as other employees of your employer, you must ensure that they have granted you permission to disclose their personal information to us and for you to allow us, and our outsourced service providers, to use it.
2. Purposes of Processing
2.1 The legal bases for our data processing activities are established within the strict limits of the purposes and conditions of Articles 6, 9 and 10 of the GDPR. If your Personal Data is processed on the basis of your consent or a legitimate interest, you have the possibility to object to this processing at any time. This objection must be sent by email to the email address indicated at the end of this Notice.
2.2 Candriam processes your Personal Data for different purposes depending on the processing concerned. These purposes are as follows:
A. When this is necessary for the performance of the contract to provide services:
- To provide you the service/product you ordered.
- To offer you an appropriate/bespoke training tool depending on your profile, including managing your performance in relation to the trainings you enrolled.
By providing Personal Data to us voluntarily and/or by subscribing to our services and/or products, you consent to such processing.
B. When this is necessary for compliance with a legal obligation or with applicable laws to which Candriam is subject:
- To comply with the applicable laws and regulations.
C. For the purposes of crime prevention and fraud protection.
2.3 Where this is necessary for the purposes of the legitimate interests of Candriam and its affiliates and a third party and such interests are not overridden by the Users’ interests, fundamental rights, or freedoms (given that if Candriam cannot carry out certain processing, the impact on its business may be high and the identified risks of harm to the interests of the individual are unlikely to materialise). Should these risks materialise, Candriam has sufficient safeguards in place to mitigate their impact.
2.4 We monitor use of Candriam websites, and use your Personal Data to help Candriam to monitor, improve and protect its services and websites, both online and offline.
3. Disclosure of Your Personal Data
3.1 We may share your Personal Data with:
A. Our affiliates when it is necessary for one of the purposes above mentioned.
B. Your employer upon request (when in relation to your performance and/or completion of any educational training program provided by Candriam Academy you enrolled in). If you want to object to the sharing of such information with your employer, please contact directly your employer.
C. Trusted third-parties including:
- Legal or other advisers, consultants, and other professional experts, complainants, correspondents, enquirers, suppliers, and service providers of any of the above, and each of their associated businesses.
- For the purposes of crime prevention and fraud protection.
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce agreements; or if Candriam reasonably consider this necessary; or to protect the rights, property, or safety of Candriam, our users, our customers, or others.
- Business partners, suppliers, and sub-contractors only for the purposes of performance of any contract we enter into with them or you or your employer.
3.2 This communication of Personal Data is only carried out within the framework of the legal basis used for the data processing activity concerned, with contractual guarantees ensuring the security and confidentiality of the data.
4. Marketing Communications
4.1 We, or trusted third parties on our behalf, may contact you by email or by post with further information about the contents of this Website. Where necessary, at the time you provide your Personal Data to us, you will be given the opportunity to indicate whether or not you consent to the processing of your Personal Data and to receive further information on products, services or events offered or organised by Candriam.
4.2 You can unsubscribe from this at any time by contacting us using the email address indicated at the end of this Notice.
5. International Transfers of your Personal Data
5.1 Some of our subsidiaries and/ or affiliates and third parties to whom Candriam discloses your Personal Data (as described above) may be located in countries which are located outside of the European Union that do not provide a level of protection to Personal Data equivalent to the one provided by your home country.
5.2 To provide adequate protection for these transfers, we utilize transfer mechanisms as defined in GDPR and recognized by the European Commission which may include the execution of appropriate standard contractual clauses conforming to the EU Commission model clauses in line with the article 46 (2) of the GDPR. To obtain a copy of the transfer mechanism, please contact us using the email address indicated at the end of this Notice. We take reasonable steps to protect your Personal Data from loss or destruction.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although Candriam will do its best efforts to protect your Personal Data, Candriam cannot guarantee the security of your Personal Data transmitted to our site; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorized access.
6. How Long Candriam keeps Your Personal Data
6.1 Candriam retains your personal data only for the duration reasonably required by and proportionate to the purpose of the processing, considering all other Candriam’s regulatory or legal obligations as well as legitimate interests. For more information about the retention of your personal data, you can contact the email address indicated at the end of this Notice.
7. Your Rights
7.1 Unless otherwise provided in the GDPR or any other legal provisions, as a data subject, Users have a number of rights in relation to the use of their Personal Data:
A. Access: You have the right to obtain confirmation that Personal Data relating to you is or is not being processed and to have access to that data and to receive a range of additional information such as the purpose of the processing, the categories of data concerned. You have the right to request a copy of the Personal Data we hold about you. Please note that there are exceptions to this right. You may be denied access to your Personal Data if, for example, making it available to you involves disclosing the Personal Data of a third party, or if we are prohibited by law from disclosing such information. Please contact us at the email address at the end of this Notice.
B. Accuracy: We try to keep your Personal Data up to date and to ensure its accuracy and completeness. Please contact us at the email address listed at the end of this Privacy Policy to notify us of any inaccuracy or change in your personal information so that we may update your personal information. You can also view, correct, and update some of your Personal Data by logging into your account on our site.
C. Withdrawal: You have the right to withdraw your previous consent to the processing of your Personal Data. You may withdraw your consent at any time by sending an email to the email address at the end of this Notice.
D. Objection: In some cases, you also have the right to object to the processing of your Personal Data.
E. Limitation: In some cases, you also have the right to obtain the limitation of the processing of your Personal Data.
F. Erasure: In some cases, you also have the right to obtain the erasure of Personal Data.
G. Portability: You have the right to request the transfer of part of your Personal Data to you or to another controller in a commonly used and machine-readable format.
H. Complaint: If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority or to take legal action.
7.2 Please note that there are exemptions to these rights if, for example, we are legally required to continue processing your Personal Data.
7.3 Please note that any rectification or erasure of Personal Data or restriction of processing will be notified to you unless such notification is impossible or requires disproportionate efforts.
7.4 If you wish to submit a request to exercise one or more of the rights listed above, you may send an e-mail to the e-mail address indicated at the end of this Notice. This request must clearly indicate the right you wish to exercise and, if applicable, the reasons of this exercise.
7.5 We will inform you promptly of the receipt of this request. If the request is valid, we will honor it as soon as reasonably possible and no later than 1 month after receiving the request. Otherwise, we will inform you of the reasons for refusal no later than one month after receiving the request.
7.6 Where we ask you for Personal Data, we will endeavour to make it clear whether this is necessary or optional.
8. Questions about the processing of your Personal Data
8.1 If you have any question in relation to the Notice and/or wish to exercise any of your rights set out above and/or want to raise an issue in relation to the use of your Personal Data, please feel free to reach out to us at dpo[@]candriam.com.
8.2 While Candriam hopes to answer any questions Users may have, if you have any unresolved issues, you also have the right to complain to the data protection authorities. The competent data protection authority will be the supervisory authority in the country where Candriam operates.
8.3 A complete list of our subsidiaries and affiliates is available at https://lumsaacademy.candriam.com/en/legal-information/
9. Changes to our Privacy Notice
9.1 Candriam reserves the right to modify this Notice at any time. Any changes we may make to this Notice in the future will be posted on this page. You are invited to check on a regular basis if our Policy has been updated and/or amended. If we make material changes to this Notice, we will notify you and seek your consent where required by applicable law.