Personal data privacy policy

At ARTFX, we are strongly committed to respecting your privacy and protecting your Personal Data.

This Personal Data Protection Policy is intended to provide transparent information about the data processing activities carried out by ARTFX. As the data controller, ARTFX undertakes to collect, use and protect your personal data with the utmost care and exclusively for the legitimate purposes for which it was collected.

When using our services, we may collect and process your personal data (hereinafter referred to as “Personal Data”), in particular through:

The use of any of ARTFX’s online services:
- Whether through the intranet website (forms, cookies, etc.) or the digital working environment;
- Through social media;
- Through all types of communication (emails, SMS, paper or electronic forms, etc.);
- Or through mobile applications, including tablet applications.
Participation in a training programme or event (workshop, etc.);
Responses to requests from ARTFX in your capacity as a former student, teaching professional, partner or supplier.

What is Personal Data?

Personal Data refers to any information in a format that makes it possible to identify a natural person, either directly through their first and last name, or indirectly through an identifier, telephone number or email address.

What is data processing?

Personal data processing may involve collecting, recording, organising, archiving, modifying, deleting, adding, exporting, consulting, processing or communicating personal data, as defined above.

ARTFX complies with all applicable French and European regulatory and legislative provisions relating to data protection. In this respect, we comply with the requirements of the French Data Protection Act of 6 January 1978, as amended, and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “Regulation”).

This document may be updated, particularly when necessary to comply with legal obligations relating to personal data protection.

The ARTFX website contains links that may redirect users to third-party websites with their own privacy and cookie management policies. Users should consult the policies of these third parties. ARTFX accepts no responsibility for the privacy practices implemented by such third parties.

WHO IS THE DATA CONTROLLER?

The data controller is ARTFX, a private international higher education institution, whose registered office is located at 95 rue de la Galera, 34090 Montpellier, France, represented by Mr Simon Vanesse, acting in his capacity as Director.

To ensure its proper operation, ARTFX is required to implement and carry out personal data processing activities relating to its prospective students, applicants, students, clients, alumni, teaching professionals, partners, companies and organisations.

ARTFX guarantees that personal data is:

Processed lawfully, fairly and transparently;
Collected for specified, explicit and legitimate purposes and not subsequently processed in a manner incompatible with those purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
Accurate and, where necessary, kept up to date;
Retained for no longer than is necessary for the purposes for which it is processed;
Processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through appropriate technical and organisational measures suited to the risks involved.

WHAT TYPES OF DATA ARE COLLECTED?

Students

Personal identification information: title, surname, first name, address, date and place of birth, nationality, telephone number, email address, social media identifiers and postal address;
Academic background: qualifications, subjects or specialisations obtained, years of completion, language proficiency levels and test scores;
Previous professional experience: job or internship titles, duties, responsibilities, companies and salary levels;
Information relating to the reasons and motivations behind an application to an ARTFX training programme;
Payment information: postal or bank account details, cheque number and/or bank card details and, where applicable, transaction number and details of the service subscribed to;
Information relating to third-party payers and their payment details;
Any information relating to the monitoring of studies at ARTFX (grades, internships, assessments, examination panels, etc.);
Any information relating to medical monitoring, particularly during a health crisis;
Any information relating to internship monitoring and professional support during or after the training programme (employer, position, salary, etc.).

The following technical data is also collected:

IP address;
Login data (username/password);
Browsing data (pages visited, browsing paths, duration, etc.);
Browser-related data (browser type, plugins, etc.);
Preferences (languages used, etc.).

Prospective Students

Surname, first name, email address, and requests for services and/or documentation.

Pre-registration, Newsletter Subscription and Information Request Forms

When you complete a pre-registration form, subscribe to our newsletter or submit an information request, ARTFX collects and processes the personal data you provide, including your contact details, for the following purposes:

To follow up on your request or application: to contact you, answer your questions, support you in choosing your course of study and provide you with the necessary information about our programmes and admissions.
To keep you informed about ARTFX: to send you news, information about our programmes, events, admissions and student life, in compliance with the regulations governing electronic communications.

The follow-up on your enquiry or application, including reminders regarding an incomplete pre-registration, is based on pre-contractual measures taken at your request and on ARTFX’s legitimate interest in responding to the enquiries it receives.

The sending of information about the school (news, events and courses) is based on your consent, obtained through an optional checkbox that you are free to leave unticked.

ARTFX processes your data on the applicable legal basis for each purpose. Where consent is required to send promotional electronic communications, it is obtained in advance. You may withdraw your consent at any time, in particular by using the unsubscribe link included in our emails.

Your data is accessible only to authorised ARTFX personnel and, where necessary, to service providers involved in managing forms and sending communications, in compliance with applicable regulations.

Prospective student data is retained for a maximum period of three years from the date of collection or from your last contact with us, unless a different retention period is justified by the purpose of the processing or by a legal obligation.

In accordance with applicable personal data protection regulations, you have the right to access, rectify and erase your data, restrict its processing and, where applicable, object to its processing and withdraw your consent. You may exercise these rights by contacting us at apply@artfx.fr.

You may also lodge a complaint with the French Data Protection Authority (Commission nationale de l’informatique et des libertés – CNIL).

Applicants and Clients

Personal identification information, contact details, payment methods, contractual relationship history, consent records where necessary, academic background, professional circumstances and experience, and motivations.

Companies, Service Providers, Partners and Subcontractors

Information relating to their organisation: name, legal form, share capital, SIRET number (French business registration number), registered office address, contractual information, payment and/or invoicing details relating to the various transactions, as well as contact details within these organisations (title, surname, first name, email address, position, role, telephone number, etc.).

Teaching Professionals

Personal identification information, contact details, preferred contact method, academic background, professional circumstances and experience, areas of expertise, payment details and contractual relationship history.

Alumni

Surname, first name, email address, position/role and telephone number.

Depending on the various purposes, ARTFX ensures that data processing is lawful and that at least one of the following conditions is met:

The individual has given consent to the processing of their personal data for one or more specific purposes;
Processing is necessary for the performance of a contract to which the individual is a party, or for the implementation of pre-contractual measures taken at their request;
Processing is necessary for compliance with a legal obligation to which ARTFX is subject;
Processing is necessary to protect the vital interests of an individual;
Processing is necessary for the purposes of the legitimate interests pursued by ARTFX, unless those interests are overridden by the fundamental rights and freedoms of the individual concerned.

ARTFX requests the individual’s consent to receive marketing communications or subscribe to its newsletters whenever such communications do not form part of the service already provided. Users are free to object to this processing by clicking the “unsubscribe” link included in ARTFX communications.

WHAT ARE THE SOURCES OF THE DATA COLLECTED?

Data is primarily collected directly through:

Browsing activity and information entered through forms or questionnaires on the ARTFX website and its various online applications;
Paper forms;
The creation of an account or personal space on the website or one of its applications;
Information provided by prospective students, applicants or clients at forums, trade fairs, through electronic or paper forms, before, during and after their studies;
Requests for information or services;
Submission of an application or enrolment in one of the educational programmes.

Data may also be collected indirectly through our academic, business and technical partners.

DATA ENRICHMENT AND DATA FLOWS

Clients are informed that data may be shared between the three ARTFX information, application and admissions websites.

Teaching professionals, employees and service providers are informed that data may be shared between our management applications, particularly order management systems, and the tools used to manage the delivery of training programmes by teaching service providers or staff members.

Once a client has completed their administrative enrolment, or once a service provider, employee or teaching professional has signed their contract, ARTFX creates all the services associated with their training programme or required to carry out their service or assignment.

These may include, for example: access to premises, accommodation, catering, network and intranet access, an email account, access to documentation loan services, access to ARTFX services, and access to online training programmes provided by partners where pedagogical prerequisites apply.

ARTFX may subsequently enrich this data through the use of tools and services by the client, teaching professional or service provider.

WHICH DATA IS MANDATORY?

Only data necessary for the purposes of the processing activities will be collected.

When personal data is collected through online or paper forms or questionnaires, mandatory fields are clearly indicated.

If mandatory fields are not completed, the associated service may not be provided, or the application or access to the service may not be fully assessed. Optional fields help us process requests more efficiently.

WHAT ARE THE PURPOSES OF DATA COLLECTION?

ARTFX acts as the Data Controller in relation to: prospective students, applicants, students, third-party payers, alumni, teaching professionals, service providers, employees, partner studios and users of web services.

In accordance with Article 5 of the GDPR, we ensure that personal data is collected for the following purposes:

Management of ARTFX personnel, recruitment and careers (reviewing and contacting applicants, etc.);
Management of client and prospective client contacts (sending marketing information about the Group’s products or news, identifying and responding to the needs of clients or prospective clients, etc.);
Management of commercial contracts (order management, invoicing, debt collection, etc.);
Creation and administration of user accounts;
Delivery and management of services subscribed to by clients (including recording support calls, etc.).

Personal Data Collected on the Website in General

Personal data collected from users is used to provide platform services, improve them and maintain a secure environment. The legal bases for processing are legitimate interest and the performance of the contract between the user and the platform.

More specifically, data is used for the following purposes:

Providing users with access to and use of the platform, registration forms and their improvement;
Managing the operation and optimisation of the platform, and verifying, identifying and authenticating data submitted by users;
Personalising services by displaying advertisements based on users’ browsing history and preferences;
Preventing and detecting fraud, malware (malicious software) and managing security incidents;
Managing any disputes with users;
Contacting you by email and telephone;
Administering competitions and promotional activities, or conducting satisfaction and interest surveys;
Implementing prospecting and advertising campaigns relating to programmes, activities or events organised by ARTFX, as well as newsletter subscriptions;
Managing and monitoring applications;
Administrative, financial and academic monitoring of clients’/students’ training programmes;
Managing client/student relationships;
Managing purchases;
Invoicing;
Managing unpaid amounts and disputes;
Medical monitoring of students, primarily during health crises;
Providing access to ARTFX resources, networks and software applications;
Enabling users to submit and retrieve documents and academic work;
Implementing firewall filtering and antivirus protection;
Video surveillance and access control for the security of people and property, and operations relating to the Vigipirate security alert system and terrorist threat alerts;
Managing requests for assistance when clients/students encounter difficulties using IT equipment or ARTFX premises;
Conducting surveys, particularly on behalf of ARTFX, the French Ministry of Higher Education, Research and Innovation, the Conférence des Grandes Écoles, accreditation bodies, ranking organisations and any third-party organisation for which ARTFX is required to produce statistics or respond to requests in accordance with applicable legislation;
Providing access to professional support services offered by ARTFX after completion of studies;
Managing the issuance of ARTFX diplomas;
Managing relationships with companies and partner studios;
Transmitting data to companies, particularly CVs;
Producing statistics.

Other Purposes

If ARTFX intends to further process personal data for a purpose other than the one for which it was originally collected, ARTFX will first provide users with information about this new purpose and any other relevant information.

INFORMING THE DATA SUBJECTS

At the time personal data is collected, ARTFX provides the individuals concerned, wherever possible, with the appropriate information, including: the contact details of the data controller and its Data Protection Officer, the purposes and legal basis of processing, the recipients of the data, any transfers outside the European Union, the data retention period, the possibility of exercising their rights and the right to lodge a complaint with the supervisory authority.

TRANSFERS OUTSIDE THE EUROPEAN UNION

Users acknowledge that third parties may be located outside the European Union and accept that their data may be transferred to such locations.

In such cases, ARTFX will take all necessary measures to ensure that the service provider or partner offers an adequate level of personal data protection in accordance with applicable personal data protection legislation and regulations.

To ensure the protection of users’ privacy and personal data, the relevant data processors are notably required to sign standard contractual clauses approved by the European Commission, or other appropriate safeguards governing such transfers pursuant to Article 46 of the GDPR, where transfers are made outside:

The European Union; or
The European Economic Area; or
Countries recognised by the European Commission as providing an adequate level of data protection.

DATA RECIPIENTS

Personal information collected or provided through this website or in connection with our services is intended for ARTFX, acting as the Data Controller within the meaning of the amended French Data Protection Act. Its registered office is located at 2 boulevard de Gabès, 13008 Marseille, France.

More specifically, such information is accessible only to authorised ARTFX departments, including: Business Support, Website Administration, Marketing and Sales, Operations, Business Development, Programme Development and Client Technology.

ARTFX ensures that personal data is accessible only to internal recipients or authorised third parties, and only under the conditions set out in this document and/or the applicable contract.

ARTFX may disclose personal data to the following recipients in particular:

ARTFX partners;
The two institutions in Enghien-les-Bains and Lille – Plaine Images;
Organisations involved in student life, such as CROUS;
Service providers;
Public authorities;
Supervisory authorities.

ARTFX Partners

ARTFX establishes partnerships with:

Studios and companies offering internships;
ARTFX alumni and professionals participating in examination panels;
Teaching professionals involved in training programmes delivered by ARTFX.

ARTFX Service Providers

ARTFX may use service providers, suppliers and subcontractors to whom it entrusts the performance of all or part of certain tasks.

These service providers may receive or access certain personal data exclusively for the purposes of carrying out their assignments on behalf of ARTFX, in accordance with the applicable procedures.

ARTFX supervises these providers and ensures that they comply with their confidentiality and security obligations regarding your information.

This may include:

Acting on behalf of ARTFX in connection with the performance of a client contract (hosting, consulting, subcontracting, etc.), under the conditions set out in that contract;
Assisting ARTFX with the financial and administrative aspects of contract performance (debt collection, invoicing, etc.);
Carrying out marketing communications on behalf of ARTFX.

Public Authorities

In certain circumstances, ARTFX may be required to disclose personal data following a request from a public authority, a court summons or any other lawful request under applicable legislation.

In such cases, ARTFX will provide the data necessary to respond to the request, particularly where ARTFX believes in good faith that such disclosure is necessary to protect your rights, ensure your safety or that of others, investigate suspected fraud or comply with a legal requirement.

PERSONAL DATA RETENTION PERIODS

The Data Controller undertakes not to retain your Personal Data beyond the period strictly necessary for the purposes for which it was collected, in accordance with applicable regulations.

The Data Controller undertakes to archive or delete your Personal Data once the purpose of processing has been fulfilled and/or the defined retention period has expired.

These maximum retention periods apply unless you request the deletion of your Personal Data or the cessation of its processing before the end of these periods, provided that its retention is no longer justified by legal or mandatory requirements.

DATA SECURITY

ARTFX implements all technical, organisational and human resources measures that are appropriate and proportionate to the risks involved, in order to ensure the security and confidentiality of the Personal Data collected and processed.

These measures are designed in particular to prevent data from being altered, damaged or disclosed to unauthorised third parties, while ensuring a level of security appropriate to the risks associated with the processing and the nature of the Personal Data to be protected, taking into account the state of the art and the cost of implementation.

These measures include:

Protection and access control for ARTFX establishments, administrative premises and server rooms;
Video surveillance;
Filtered and secure internet access through Wi-Fi;
A segmented network with filtering rules based on user profiles and access permissions;
Use of an SSL-type encryption protocol for data transmission between devices and ARTFX servers or those of its service providers;
Regular backups;
Securing equipment, servers and applications through dedicated accounts that are regularly updated;
Management of access permissions, granting access only to the resources and information required;
Control of workstations authorised to connect to the internal network;
Securing individual workstations and applications.

ARTFX employees and teaching professionals are required to comply with an IT code of conduct designed to ensure an appropriate level of security.

IN THE EVENT OF A PERSONAL DATA BREACH

In accordance with Articles 33 and 34 of the GDPR, any personal data breach must be reported as follows:

Where ARTFX acts as the Data Controller, the breach must be reported to the supervisory authority (CNIL) and, where necessary, to the individuals affected by the breach;
Where ARTFX acts as a Data Processor, the breach must be reported to the clients affected by the breach, in accordance with the conditions set out in the contract.

EXERCISING YOUR RIGHTS AT ARTFX

How can you exercise your rights regarding your personal data?

You are hereby informed that, under the conditions set out in applicable personal data protection legislation, you have the following rights with regard to ARTFX:

The right to access and obtain a copy of the personal data concerning you held by ARTFX;
The right to have your personal data rectified and updated if it is inaccurate or incomplete;
The right, subject to certain conditions, to request the deletion of all or part of your personal data;
The right to obtain information about how ARTFX uses your data;
The right to object to the processing of your data on grounds relating to your particular situation;
The right to object at any time and without justification to the continued processing of your data for direct marketing purposes (receiving commercial SMS messages and emails), even if you initially consented to such processing;
The right to withdraw your consent to the processing of your personal data (where processing is based on your consent);
The right, subject to certain conditions, to obtain the restriction (temporary suspension or freezing) of the processing of your data;
The right to data portability for the data you have provided to ARTFX;
The right to provide ARTFX with instructions regarding what should happen to your data after your death;
The right not to be subject to a decision based solely on automated processing or profiling that produces legal effects or similarly significant effects concerning you.

In accordance with Article 77 of Decree No. 2019-536 of 29 May 2019 implementing the French Data Protection Act, you must provide proof of your identity using an identity document when exercising your rights.

You may exercise your rights by contacting the ARTFX Data Protection Officer:

ARTFX
For the attention of the Data Protection Officer (DPO)
2 boulevard de Gabès
13008 MARSEILLE
FRANCE

You may also submit your request by email under the same conditions at dpo@ARTFX.fr.

Proof of identity is required in particular to ensure the confidentiality of everyone’s personal data and prevent identity theft or confusion between individuals with the same name.

If you are submitting a request on behalf of another person (acting as their authorised representative), and in accordance with the provisions of the aforementioned decree, your request must include:

Written authorisation from the data subject (the principal), specifying the duration and precise purpose of the authorisation and clearly allowing you to receive ARTFX’s response to the request to exercise their personal data rights;

+ Proof of your identity; and

+ Proof of the data subject’s identity.

If these cumulative conditions are not met, the request will be deemed inadmissible.

Subject to the admissibility of your request and compliance with the conditions laid down by law, a response will be provided within one month, or exceptionally within two months in the event of complexity or a large number of requests.

If, after contacting us, you believe that your data protection rights have not been respected, you may lodge a complaint with the CNIL online or by post.

ARTFX STAFF AWARENESS

ARTFX makes every effort to regularly inform and raise awareness among its employees and new recruits about personal data protection issues.

Specific awareness sessions and/or training may be provided to employees who regularly handle personal data.

UPDATES TO CONTRACTUAL REQUIREMENTS

ARTFX has incorporated the new mandatory contractual obligations arising from Article 28 of the GDPR into all relevant contracts.

Specific contractual clauses relating to data protection and complying with applicable regulations have therefore been introduced in particular into:

Admissions contracts;
Contracts between ARTFX and its own subcontractors.

CONTACT

For any questions relating to this policy or to contact our Data Protection Officer, please send your request to the following email address:

dpo@ARTFX.fr

USE OF COOKIES

The ARTFX website automatically collects information from users about their use of the website, as well as certain other information such as the type of browser and operating system used and IP addresses.

The website uses cookies. These are small text files sent to and stored on your computer. They enable web servers to recognise users’ browsing habits, make it easier for them to access the ARTFX website and allow the website to compile aggregated data that can be used to improve the website and its content.

Cookies do not damage computers or files. Cookies themselves cannot be used to discover a user’s identity.

The law stipulates that we may only store cookies on your device if they are strictly necessary for the operation of this website. For all other types of cookies, we require your permission.

This website uses different types of cookies. Some cookies are placed by third-party services that appear on our pages.

You can access the relevant information here: https://www.cnil.fr/fr/cookies-traceurs-que-dit-la-loi.

When you first visit this website, an explanatory banner about the use of cookies will appear. By continuing to browse the website, clients and/or prospective clients will be deemed to have been informed of and accepted the use of these cookies.

Consent given will remain valid for a period of thirteen (13) months.

Users can disable cookies through their browser settings.

All information collected will only be used to monitor the volume, type and configuration of traffic using this website, to improve its design and layout, and for other administrative and planning purposes, and more generally to improve the service we provide.

The following cookies are used on this website

Google Cookies:

Google Analytics: used to measure website traffic and audience statistics.
DoubleClick: Google’s advertising cookies used to display banner advertisements.

How can you manage cookies in your browser?

You have several options for deleting cookies.

Although most browsers are configured by default to accept cookies, you can choose to accept all cookies, systematically reject them or select which cookies you wish to accept according to their provider.

You can also configure your browser to accept or reject cookies on a case-by-case basis before they are installed.

You may also regularly delete cookies from your device through your browser.

Cookie management and preference settings vary depending on the browser you use. Instructions can be found in your browser’s Help menu, which explains how to change your cookie preferences.

FOR EXAMPLE:

Internet Explorer™: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
Safari™: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
Chrome™: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences

However, if you configure your browser to reject cookies or refuse the installation of a cookie, this deactivation may prevent certain ARTFX website features from working properly or make certain services inaccessible. ARTFX cannot be held responsible for any resulting limitations.