Information statement for direct and indirect data collection
The personal data controller
MillionRoads, a simplified joint stock company registered in the Avignon Trade and Companies Register under number 817 446 800, with its registered office at 50bis rue Thiers in Avignon (84000), represented by its president, Mr Benoit Bonte (hereinafter “MillionRoads”), publishes an application called “humanroads” which provides its users with assistance in academic and professional orientation through an interactive mapping of educational and professional paths, statistics and dashboards (hereinafter “humanroads”).
Collected personal data
MillionRoads collects personal data from humanroads users when they create their account. These personal data include their surname, first name and e-mail address as well as information relating to their educational and professional background.
In addition, MillionRoads indexes personal data and public information of people registered on professional social networks. These personal data are their surname, first name and information concerning their academic and professional background.
The purposes of personal data processing
MillionRoads processes these personal data for the purpose of providing humanroads functionalities to users with an account, managing their account and the contractual relationship with them.
MillionRoads also processes thes personal data for the purpose of providing entities (educational institutions, companies, administrations and other institutions) that have contracted with MillionRoads (hereinafter referred to as “entities”) with statistics and dashboards concerning students or employees who have been or are part of their workforce and access to public profiles of these students or employees who are account holders.
Entities may also, using this personal data, conduct prospecting operations with their students or employees, former or current, whether or not they hold an account, subject to their express prior consent (opt-in) when such operations take place electronically or their absence of opposition (opt-out) in other cases.
Grounds for personal data processing
The processing of personal data collected from humanroads users is based on their consent obtained when creating their account and on the execution of the contract concluded with MillionRoads.
The processing of personal data indexed from public profiles of professional social networks is based on MillionRoads’ legitimate interest in having a sufficient volume of data to ensure representativeness, accuracy of predictability and relevance of the educational and professional guidance offered to users holding an account and the statistics and dashboards provided to entities.
Recipients of the processed personal data
The recipients of the personal data processed by humanroads are the corporate officers and employees of MillionRoads in charge of operating humanroads, managing users’ and entities’ accounts and contractual relations with them.
The recipients of the personal data processed by humanroads are also authorized users within the entities as well as the humanroads hosting provider, Amazon AWS.
Data retention duration
MillionRoads keeps the personal data collected from users with an account for a period of three years from the closure of their account and the end of the contract concluded with them. If these users have a public profile on one or more professional social networks, MillionRoads keeps the personal data derived solely from this or these profiles until they are closed, notwithstanding the closure of the account.
MillionRoads keeps personal data indexed from public profiles of professional social networks until the closing of these public profiles.
MillionRoads keeps in intermediate archives the personal data strictly necessary for the exercise of a right and proof of this right for the duration of the applicable limitation periods or pursuant to the legal obligations to which Millionroads is subject.
Personal data location
MillionRoads stores the above personal data on the servers of the humanroads hosting provider, Amazon AWS, whose servers are located in Germany, so that your personal data is protected according to the European Union level.
Personal processed data individuals’ rights
In accordance to the legislation in force, any user concerned by these processing of personal data may:
- obtain communication and, if necessary, rectification or deletion of personal data concerning him/her;
- object to the processing of their personal data for legitimate reasons;
- withdraw his consent to the processing of his personal data;
- obtain a copy of their personal data in a structured and current format for transmission by them or by MillionRoads to another controller;
- Inform MillionRoads of its guidelines on the fate of its personal data in the event of death; failing this, the deceased’s heirs may assert their rights under the legislation in force in accordance with the procedures below.
Any user may exercise any of these rights by contacting MillionRoads at firstname.lastname@example.org, and providing proof of identity. The costs of extracting or copying personal data will be charged by MillionRoads. However, MillionRoads will reimburse these costs in the event of justified rectification of personal data following the communication of this extraction or copy.
In addition, MillionRoads may suspend or terminate an account or terminate the contract with the user if it no longer has the personal data necessary for its performance as a result of the exercise of any of the above rights.
Any natural person who identifies himself in a profile indexed by humanroads may request that his public profile appearing on a professional social network be de-indexed by proving his/her identity and transmitting the address of the corresponding page through the contact form below.
Any user or involved person also has the right to file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL) or any other competent supervisory authority in the event of a dispute concerning the above processing of his/her data.
MillionRoads has declared the above data processing operations to the Commission Nationale de l’Informatique et des Libertés (CNIL).
Ask your question or exercise your rights.