Background
This notice is to help you understand how and why we collect your personal data and what we do with it. It also explains the decisions that you can make about your personal data.
This privacy notice applies to the personal data of our website users as well as other people whom we may contact through our staff or candidates such as references and emergency contacts. It also applies to our suppliers whether partnerships and companies (including sole traders) or atypical workers such as independent contractors and freelance workers, who provide services to Sommet Education.
If you are a member of Sommet Education’ staff you should refer to the Sommet Education group ‘s staff privacy notice which is available on the Sommet Education intranet. If you are a student of one of the schools part of the Sommet Education group, you should refer to the privacy notice available on your school platform.
What is “personal data”?
Personal data is information that Sommet Education holds about you and which identifies you or could identify you when combined with other data which Sommet Education either holds or is likely to obtain.
WEBSITE USERS
Whenever you use our Sommet Education’s website we collect a limited amount of data which we use to help us improve your experience when using our website and manage the services we provide. Indeed, our web server automatically records details about your visit, that does not, on its own, permit direct association with you including but not limited to your IP address, the website from which you visit us, the advertisements on which you have clicked, the type of browser software used, the pages that you actually visit including the date and duration of your visit, the language you choose and the way you navigate on our website – See “Cookies Policy” below for further information.
REFERENCES AND EMERGENCY CONTACTS
We may collect and process the following types of personal data about you:
- references: your contact details and confirmation of the information provided by candidates who have put your contact details down as a reference; and
- emergency contact: your contacts details where of one of our candidates or a member of staff has put you down as their emergency contact.
SUPPLIER DATA
We collect contact details of relevant individuals at your organisation as well as your bank details.
Regardless of the category you belong, the examples provided above are not all-inclusive. We also may collect similar or related information and in particular information you choose to share voluntarily about you.
Where does Sommet Education get your personal data from?
WEBSITE USERS
We collect your data automatically via cookies, in line with cookie settings in your browser – See “Cookies Policy” below for further information.
REFERENCES AND EMERGENCY CONTACTS
We obtain personal data regarding you from one of our candidates or staff member.
SUPPLIER DATA
We obtain personal data regarding you from the following sources:
- You, your employer or organisation when you contact us proactively, usually by phone or email or where we contact you, either by phone or email; or
- Third party sources such as organisations that assist us with pursuing our purposes described below including where relevant due diligence services providers, media articles, social networking posts or other public sources for example the world wide web.
Why does Sommet Education collect and use your personal data?
All such data will be processed in accordance with applicable laws and regulation and the Sommet Education Group Data Protection Policy as amended from time to time.
WEBSITE USERS
We use your data to help us improve your experience of using our website. Our website also uses re-targeting, which allows us to make our online content more interesting for you. Retargeting technology means we can advertise recently viewed and related products on our partners’ websites, meaning our adverts, even on other companies’ sites, are relevant to what you would like to see. We do this by analysing user behaviour from data collected by our cookies even without having a user profile – See “Cookies Policy” below.
REFERENCES AND EMERGENCY CONTACTS
As an emergency contact, we store (and update when necessary) the information that our students and candidates/staff members give us about you in order to put you down on our form as an emergency contact and we will contact you in the case of an accident or emergency affecting them.
As a reference, we will contact you in order to take up a reference.
SUPPLIER
We will use the personal information you provide to ensure that things run smoothly including, but not limited to the following activities:
- storing (and updating when necessary) your details on our databases, so that we can contact you in relation to our agreements;
- communicating with you in relation to our agreements including paying for the services you provide (if this is part of the contractual arrangements between us); and
- performing due diligence: please note that if your services consist in acting on behalf of Sommet Education for any reasons we may process your personal data, including information from the public domain, for due diligence purposes, in accordance with our then current policies.
Our legal grounds for using your information
WEBSITE USERS
Some cookies are necessary because otherwise the website is unable to function properly. We need your consent for using other cookies.
REFERENCES AND EMERGENCY CONTACTS
The processing of your personal data as described above is covered by our legitimate interests or the one of our staff members or candidates. For further processing, not covered by our legitimate interests, your consent will be sought.
SUPPLIER
Contractual commitment & Legal obligation
As a supplier, most of the time Sommet Education will be processing your personal data on the basis that it is necessary to enable it to meet its contractual and pre-contractual commitments or in order to comply with its legal obligations, for instance as regards to payments, taxes etc.
Legitimate interest
We may use your personal data for the above purposes if we deem this to be necessary for our legitimate interests.
Regardless of the category you belong it may also be necessary for us to process your personal data, where appropriate and in accordance with local laws and requirements, in connection with exercising or defending legal claims. This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
Sharing information with others
For operational reasons and as is necessary and proportionate for intended purposes, we may share your information with other entities in the Sommet Education Group.
For the purposes referred to in this privacy notice and relying on the bases for processing as set out above, we may also share your personal data with certain third parties:
- government departments and agencies and local authorities where we have a statutory obligation to provide information;
- crime prevention or detection agencies (e.g. the police); We may also need to share information with or our legal advisers;
- contractors, suppliers, agencies, or any other parties acting on Sommet Education’s behalf (collectively, “External Parties”) where there is a legitimate reason for their receiving the information, including, including but not limited to third parties contracted to provide IT services for us including cloud-based storage providers.
Sommet Education contractually requires External Parties processing personal data on behalf of Sommet Education to follow this policy, whether they are utilizing Sommet Education’s and/or their own electronic systems and data management tools. Sommet Education employees are responsible for ensuring that any External Parties they work with in support of Sommet Education operations comply with this policy.
The website may contain advertising of third parties and links to other sites or frames of other sites where Sommet Education does not control how your data is processed. In those situations, please ensure you read and understand the privacy policies and practices of such websites and be aware that we are not responsible for the privacy practices or content of those third parties or other sites.
Sending information to other countries
Some of the personal data we process about you will be transferred to, and stored at, a destination outside Switzerland or the European Economic Area (“EEA”), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers who is based outside the EEA or who uses storage facilities outside the EEA.
In these circumstances, your personal data will only be transferred on one of the following bases:
- a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection;
- where the transfer is subject to one or more of the “appropriate safeguards” for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission); or
- there exists another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).
How Do We Secure you Personal Data?
We implement appropriate physical, administrative and technical measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.
Sommet Education contractually requires that External Parties provide equivalent levels of protection when handling your personal data and only process the data in accordance with our instructions.
For how long do we keep your personal data?
We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.
What decisions can you make about your personal data?
Sommet Education makes reasonable efforts to ensure that your personal data is reliable for its intended use. However, you are equally responsible for updating and checking the accuracy of the information provided to Sommet Education.
Moreover, you are able to make various decisions about your personal data. Your rights are as follows:
- to obtain access to, and copies of, the personal data that we hold about you;
- to require that we cease processing your personal data if the processing is causing you damage or distress;
- to require us not to send you marketing communications.
- to require us to correct the personal data we hold about you if it is incorrect;
- to require us to erase your personal data;
- to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
- to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that:
- the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply;
- information request will be fulfilled free of charge unless in case of repetitive, manifestly unfounded or excessive requests or for further copies; and
- where our processing of your personal data relies on your consent and where you then withdraw that consent, it may affect the provision of the services.
Further information and guidance
Sommet Education reserves the right to modify this notice as needed, for example, to comply with changes in laws, regulations, Sommet Educations practices and procedures, or to respond to new threats or new requirements imposed by data protection authorities. Please just visit this page if you want to stay up to date, as we will post any change here.
If you have questions about your personal data, email our Data Protection Officer at: dpo@sommet-education.com
If you are not satisfied with how we are processing your personal data, you can make a complaint to the relevant data protection authorities.
Last update: May 2018
The sommet-education-preview.elca-services.com website is operated under the Sommet Education name by Sommet Education Sàrl, a company registered in Switzerland at Chemin du Pierrier 1, 1815 Clarens.
COOKIES POLICY
WHAT ARE COOKIES?
Our websites, email messages and advertisements may use “cookies” and other technologies.
A cookie is a small text file that is stored on your computer, smartphone or any other device optimized for the Internet when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date being understood that can be distinguished:
Session cookies: only stored on your computer during your web session and automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
Persistent cookies: stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. For instance we use persistent cookies such as Google Analytics and for personalisation (see below).
Some of these cookies are necessary because otherwise the website is unable to function properly. Cookies are also used to optimise the performance of the website.
Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Sommet Education uses such cookies to help us provide you with a better user experience tailored to your personal preferences. By using cookies we make sure that you do not receive or need to enter the same information every single time you visit the website.
Information collected by cookies and other technologies are most of the time non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by certain laws, we also treat these identifiers as personal data. Similarly, to the extent that non-personal information is combined with personal data, we treat the combined information as personal data for the purposes of this privacy notice
PREVENT COOKIES FROM BEING STORED ON YOUR COMPUTER
For certain cookies, your consent will be required. More generally, you can manage the settings in your browser. Usually, your browser’s help section will provide information on how to change your cookie settings. You can find detailed information on how to change your browser settings by clicking here.
When you save your cookies settings, they should also apply to your future visits to the Site. However, for technical reason beyond our control, this cannot be guaranteed.
Your attention is drawn to the fact that our cookies improve your browsing experience on the website and allow you to access to certain secure areas where necessary. Where this is the case, certain website functions may be altered or blocked. If you would like to accept Sommet Education’s cookies but block our partners’ cookies, you can set your browser to block third party cookies.
SPECIFIC COOKIES WE USE
Cookies may be set either by our website or by a third-party website. The tables below identify the cookies we use and explain the purposes for which they are used. However, we continue to collect information about third-party cookies and the tables below are based on the work completed to date. Accordingly, we may update the information contained in this section from time to time.
Cookie Name
Cookie Purpose
Cookie Provider privacy policy
AppNexus
This cookie contains a unique randomly-generated value that enables AppNexus to distinguish browsers and devices. It is matched against information – such as advertising interest segments and histories of ads shown in your browser or on your device – provided by us or other third parties and stored on the AppNexus technology platform. This information is used to select advertisements for delivery by AppNexus, and to measure the performance of, and attribute payment for, those advertisements. In addition, this cookie is sometimes matched to other cookies that contain non-personally identifying information.
Google Adwords User Lists
This cookie enables us to create, transact and manage digital advertising.
Google Analytics
Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyse how visitors use our site. Google will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage.
GA Audiences
Google Audiences helps us to organise and analyse your data. The cookies help us to understand more about the type of people who visit our website and the optimal frequency with which to send advertising messages to our Website Users.
https://www.google.com/intl/en%20/policies/privacy/
Google Tag Manager
This cookie is associated with sites using Google Tag Manager to load other scripts and code into a page. The cookie helps us to classify information on our website and label it in a way which makes it easier to be found in future searches.
Google Dynamic Remarketing
This cookie enables us to create, transact and manage digital advertising.
Google Adwords Conversion
This cookie enables us to create, transact and manage digital advertising.
Facebook Connect
Facebook Connect is a single sign-on application which allows you to login to and interact with our website through your Facebook account to avoid having to take the basic registration steps on our website.
Facebook custom audience
This cookie enables us to create custom lists of existing customers. We can then send relevant advertising to the customers on different lists depending on the specific interests of the custom audience on each list.
Marketo
These cookies allow our website to link visitor behaviour to the recipient of an email marketing campaign, to measure campaign effectiveness.
Crazy Egg
We use Crazy Egg’s Analysis Service to obtain information about how you interact with our website.
This cookie helps us to see what people are doing on our website, such as showing us where people are clicking (and where they aren’t). Or how many people scroll down our pages (and where most people stop). Also, it allows us to see where those people are coming from to begin with, and who clicks on what the most.
Kenshoo
Kenshoo allow us to manage, optimize and analyse our digital marketing activities. The information collected by Kenshoo is typically used to identify trends and optimize our overall advertising activities. As such, this information is un-identifiable, and we do not know, nor will we attempt to know the identity of users.
Bing
This cookie enables us to create, transact and manage digital advertising.
Yandex
This cookie enables us to create, transact and manage digital advertising.
Baidu Analytics
Baidu Analytics (Baidu Tongji) is a web analytics service provided by Baidu Inc., the largest search engine in China. Similar to Google Analytics, Baidu Analytics also uses cookies to help us analyse how visitors use our site. Baidu will use this information for the purpose of assessing your use of the website, compiling reports on website activity for us and providing other services to us relating to website activity and internet usage. This cookie is only placed on the Chinese websites.
Baidu SEM Analytics
Baidu SEM Analytics works exactly like regular web analytics. It is used to track paid search campaigns on Baidu. This cookie is only placed on the Chinese websites.
