Privacy Policy of La Fondation Dassault Systèmes

The purpose of this “Privacy Policy” is to inform all individuals ("You" or "Your") from whom Personal Data is collected by 3DS Foundations (as defined hereinafter) how Your Personal Data (as defined below) are processed i.e. collected and used such in the course of their activities, including the Personal Data of people browsing their website (the “Site”) and how You can control its use.

Depending on where You are located, please be aware that there are three foundations (individually or collectively identified as “3DS Foundation”) that are respectively located in Europe, USA and India. Each of them declares hereby that this Privacy Policy will govern its use of Your Personal Data.

In Europe, Le Fonds de dotation Dassault Systèmes, an endowment fund located 10, Rue Marcel Dassault, 78140 Vélizy-Villacoublay, FRANCE, (hereinafter “La Fondation Dassault Systèmes”), processes Personal Data collected in the context of all projects submitted to the 3DS Foundations mentioned below.

In USA, the Dassault Systèmes Foundation, located in Boston Campus, 175 Wyman Street, 02451 WLATHAM MA 02451, UNITED-STATES, processes Your Personal Data collected in the context of the projects submitted to it by an organization located in USA.

In India, the Dassault Systèmes Foundation located Plot No. 15B, Pune Infotech Park M.I.D.C, phase I Taluka Mulshi, Hinjawadi, Pune, Maharashtra 411057, INDIA, processes Your Personal Data collected in the context of the projects submitted to it by an organization located in India.

 

1. SCOPE OF THIS PRIVACY POLICY

 

This Privacy Policy sets forth the principles and guidelines governing the protection of Your Personal Data including the Personal Data collected on or through the Site.

3DS Foundation collects Personal Data either online (including via email) or offline and this Privacy Policy is applicable regardless of the means of collection or processing.

Personal data ("Personal Data") means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.

Non-Personal Data means any information that does not result in the identification of a person.

The Site is subject to Terms of Use that can be found here and are incorporated into this Privacy Policy. Your use of the Site and any Personal Data You provide on the Site are subject to the terms of this Privacy Policy and the applicable Terms of Use.

 

2. DATA COLLECTED

 

Visitors

Visitors are individuals who visit the Site without submitting a project. Personal Data likely include:

  • IP address;
  • Cookies (as described in section 10);
  • And any Personal Data as may be relevant for the purposes listed below.

 

Users

Users are individuals who submit a project to a 3DS Foundation. Users’ Personal Data likely includes:

  • title ;
  • first and last name;
  • postal address ;
  • email address ;
  • telephone number(s) ;
  • university ; degree and courses taken ;
  • type of organization (company, school, university, etc.),
  • organization name, organization size ;
  • department and job title;
  • industry and industry sub-industry sectors;
  • financial data ;
  • IP or MAC address ;
  • cookies (as described in section 10)
  • and any other Personal Data as may be relevant for the purposes listed below.

 

In all cases, however, the Personal Data gathered is limited to data necessary for the purposes described in Article 4 below.

In order to submit a project, 3DS Foundation requires that You provide certain Personal Data. You are free to decide whether or not to provide all or part of Your Personal Data. However, if You choose not to provide all or part of this Personal Data, the purposes as described in Article 4 hereafter might not be achieved or not properly achieved, some areas and functions of the Site may not function properly and/or You may be refused access to certain pages on the Site.

 

3. PROTECTION OF PERSONAL DATA CONCERNING CHILDREN

 

The activities performed by 3DS Foundation are not designed to be addressed to children who are considered as minor under the applicable data protection law and 3DS Foundation does not knowingly collect or store Personal Data from children under such age. For children whose usual place of residence is in the European Union, Lichtenstein, Norway or Iceland, the default age at which a person is no longer considered a child is 16 subject to local law to adjust that limit between 13 and 16.

However, certain activities performed by 3DS Foundation may be appropriate for use by children, and in that case children below the age of consent under local data protection laws, must seek consent from their parents or guardians prior to register a project on the Site. Teachers and school administrators may act in the place of parents or guardians and provide consent for the collection of Personal Data from children (schools should always ensure that they have received permission from parents or guardians to do so).

If parents or guardians become aware that their child has provided 3DS Foundation with Personal Data without their consent or without a teacher’s or school administrator’s consent, they can ask 3DS Foundation to remove such Personal Data and deleted the child’s Personal Data by sending an email to: info@lafondation3ds.com.

If 3DS Foundation becomes aware that it has collected Personal Data from a child below the age of consent under local data protection laws without consent from a parent or a guardian, 3DS Foundation will take steps to seek the parent’s or guardian’s consent for that processing or to remove such Personal Data and terminate the child’s Personal Data.

 

4. PURPOSES AND LEGAL GROUNDS OF PROCESSINGS OF PERSONAL DATA

 

Whether You are a visitor or a user, 3DS Foundation collects and processes Your Personal Data based on its legitimate interest for the following purposes: to improve Your user experience and to recognize that You have given a Personal Data so You don’t need to do it for every web page requested.

In addition, when a user submits a project, Your Personal data will be processed by 3DS Foundation based on Your consent.

In addition, 3DS Foundation might also use the user’s email address for administrative or other non-marketing purposes (for example, to notify You significant changes to the Site or to ask You more details about the submitted project).

 

5. PERSONAL DATA RETENTION PERIOD

 

3DS Foundation does not store Your Personal Data for more than necessary.

Retention periods may vary depending on the data categories and the processing activities.

Where 3DS Foundation is processing and using Your Personal Data as permitted by law or under your consent, 3DS Foundation will store them (i) only as long as required to fulfil the purposes set out above or (ii) until You object to 3DS Foundation’ use of your Personal Data  (where 3DS Foundation has a legitimate interest in using them) or (iii) where you gave Your consent, until you withdraw it. However, where 3DS Foundation is required by applicable law to retain your Personal Data longer or where your Personal Data is required to assert or defend against legal claims, 3DS Foundation will retain them until the end of the relevant retention period or until the claims in question have been settled.

 

6. TRANSFER OF PERSONAL DATA

 

If You are accessing the Site from a location outside of the European Union, with laws or regulations governing data collection, use, and disclosure that differ from those of the European Union, please note that through Your continued use of the Site, which is governed by French law, the corresponding Terms of Use and this Privacy Policy, You are transferring Your Personal Data to the European Union and You consent to that transfer.

Please note that 3DS Foundation may transfer Your Personal Data outside of the European Union to the two other 3DS Foundations, that offer an adequate level of protection in accordance with European legislation

 

7. RIGHT TO ACCESS, TO RECTIFICATION AND OTHER RIGHTS

 

3DS Foundation will take reasonable steps to ensure that the Personal Data collected is used for the purposes stated in this Privacy Policy and that such Personal Data is correct and up to date.

You have a right to access Your Personal Data. In addition, You have a right to request the rectification, completion, update or erasure of Your Personal Data. You have a right to restriction of processing. You also have a right to obtain a copy of the Personal Data stored by 3DS Foundation. You have a right to object, in relation to your particular situation. You may have a right to data portability.

You may exercise Your rights by sending an email to: info@lafondation3ds.com.

Depending on the scope of the request, 3DS Foundation reserves the right to charge a reasonable fee to cover any out-of-pocket costs incurred in connection with such access, modification and deletion of Personal Data. 3DS Foundation may deny access to Personal Data in limited circumstances, defined by applicable laws and regulations.

 

8. DATA RECIPIENTS

 

Where 3DS Foundation has knowledge that a third party to which 3DS Foundation has provided Personal Data for the purposes listed in Article 4 above, is using or disclosing Personal Data contrary to this Privacy Policy or to applicable laws, 3DS Foundation will take reasonable steps to prevent or stop such use or disclosure.

3DS Foundation will also disclose Your Personal Data to third parties if 3DS Foundation determines that such disclosure is necessary for technical reasons (such as hosting services by a third party) or to protect 3DS Foundation’ legal interests, 3DS Foundation may also disclose Your Personal Data if required by law or if 3DS Foundation believes in good faith that such disclosure is reasonably necessary to comply with legal process or protect the rights, property, or personal safety of 3DS Foundation or the public.

 

9. DATA SECURITY

 

3DS Foundation undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties.

3DS Foundation maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alternation and destruction. As part of those safeguards, 3DS Foundation employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third parties. However, while 3DS Foundation strives to protect Your Personal Data, in light of the inevitable risks of data transmission over the internet, 3DS Foundation cannot guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond 3DS Foundation' reasonable control.

Since all Personal Data is confidential, access is limited to employees, contractors and agents of 3DS Foundation who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.

However, it is important for You to exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and information appearing on Your account. Consequently, You must ensure that You log out of Your session in the event of shared use of a computer.

 

10. COOKIES

 

The Site may use cookies -or other technologies-, which may collect or store Personal Data. Cookies are text files stored and used to record Non-Personal and Personal Data concerning Your browsing of the Site. Cookies can be either permanent (and remain after You logoff from the Site in order to be used on Your subsequent visits to the Site) or temporary (and disappear as soon as You log off from the Site).

Cookies will be kept for a maximum period of 13 (thirteen) months after your last visit from the Site.

To view the list of cookies 3DS Foundation and their purpose, click here.

3DS Foundation uses cookies in order to:

  • improve Your user experience ;
  • analyze traffic and data on the Site to measure how many people are visiting the Site, so the Site can be made easier to use and navigate and to make sure there is enough capacity to ensure the Site have adequate response times, and to help 3DS Foundation to understand how visitors interact with the site so 3DS Foundation can improve its functionality and performance.

When you browse the Site, cookies are enabled by default and data may be read or stored locally on your device. You will be notified the first time You access the Site with a different device; 3DS Foundation will not install any cookies before obtaining your explicit consent. You can decide whether to accept or refuse some or all cookies. You can configure Your browser software to refuse all cookies (including cookies used for web analytics services); if You do so, however, some areas and features of the Site may not function properly and/or You may not be able to access some parts or services of the Site.

You can set your preferences here

 

 

11. DISPUTE RESOLUTION

 

Although 3DS Foundation has put in place reasonable safeguards to protect Personal Data, 3DS Foundation recognizes that there is no method of transmitting or storing Personal Data that is completely secure.

However, 3DS Foundation is committed to ensure the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact 3DS Foundation via the following address: info@lafondation3ds.com.

3DS Foundation will investigate and attempt to resolve complaints regarding use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy. Unauthorized access to Personal Data or the improper use of Personal Data may constitute offenses under local law.

If Your usual place of residence is in European Union, Lichtenstein, Norway or Iceland, You have a right to file a complaint with Your competent data protection authority.

 

12. CONTACT

 

For any additional question concerning this Privacy Policy, to opt out of receiving information from 3DS Foundation or any request regarding Your rights on Your Personal Data You may send an email to: info@lafondation3ds.com.

 

13. DATE OF ENTRY INTO FORCE OF THE PRIVACY POLICY AND CHANGES TO IT

 

This Privacy Policy may be updated according to 3DS Foundation' requirements and circumstances, or where required by applicable laws and regulations so please check back periodically for updates.

 

If major changes occur to this Privacy Policy, 3DS Foundation may inform you via email or via display of a notice.

 

PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS

 

This PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS (“Addendum”) supplements and amends the information contained in the above Privacy Policy of the 3DS Foundation and applies solely to individuals who reside in the State of California (“You”). The 3DS Foundation adopts this Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Addendum. In the event of a conflict between the 3DS Foundation Privacy Policy and this Addendum, this Addendum shall prevail but only with respect to personal information California residents. Where the Privacy Policy refers to “Personal Data” it shall be interpreted to mean “Personal Information” as defined in this Addendum but only for California residents.

 

1. Information the 3DS Foundation  Collects

 

The 3DS Foundation collects information both online and offline that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a person or device (“Personal Information”). In particular, the 3DS Foundation has collected the types of Personal Information set forth above in Section 2 of the Privacy Policy from You within the last twelve (12) months and possibly prior to that. The type of information specified in Section 2 of the Privacy Policy falls under category of “Identifiers” ,”Internet or other similar activity” both as defined under the CCPA or Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

The categories of Personal Information are obtained directly and indirectly from activity on our Site. For example, from submissions through our Site or website usage details collected automatically.

 

2. Use of Personal Information

 

The purposes for which the 3DS Foundation uses Your Personal Information are set forth above in Section 4 of the Privacy Policy. The 3DS Foundation will not collect additional categories of Personal Information or use the Personal Information the 3DS Foundation collected for materially different, unrelated, or incompatible purposes without providing You notice.

 

3. Sharing Personal Information

 

In the preceding twelve (12) months, the 3DS Foundation may have disclosed Your Personal Information for a business purpose as further specified in Sections 4, 6 and 7 of the Privacy Policy. The 3DS Foundation discloses Your Identifiers for a business purpose to the following categories of third parties:

  • 3DS Group Companies.
  • The Foundation 3DS Service providers.
  • Third parties to whom You or Your agents authorize the 3DS Foundation  to disclose

The 3DS Foundation will also disclose Your Personal Information to the others 3DS Foundations mentioned in the preamble of the Privacy Policy. .

The 3DS Foundation does not sell Personal Information.

 

4. Your Rights and Choices

The CCPA provides You with specific rights regarding Your Personal Information. This section describes Your CCPA rights and explains how to exercise those rights.

- Access to Specific Information and Data Portability Rights

You have the right to request that the 3DS Foundation discloses to You certain information about the 3DS Foundation’s collection and use of Your Personal Information over the past 12 months. Once the 3DS Foundation receives and confirms Your verifiable request, as defined by the CCPA, the 3DS Foundation will disclose to You:

  • The categories of Personal Information the 3DS Foundation collected about You;
  • The categories of sources for Your collected Personal Information;
  • Our business purpose for collecting, or sharing Your Personal Information;
  • The categories of third parties with whom the 3DS Foundation  shares Your Personal information, if any;
  • The specific pieces of Personal Information the 3DS Foundation collected about You.

 

- Deletion Request Rights

You have the right to request that the 3DS Foundation deletes any of Your Personal Information that the 3DS Foundation collected from You and retained, subject to certain exceptions. Once the 3DS Foundation receives and confirms Your verifiable request, the 3DS Foundation will delete (and direct the 3DS Foundation service providers to delete) Your Personal Information from the 3DS Foundation records, unless an exception applies.

The 3DS Foundation may deny Your deletion request if retaining Your Personal Information is necessary for it or its service providers to:

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  •  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

 

- Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to the Foundation 3DS by either:

  • Calling the 3DS Foundation toll free within the US only at (888) 337-0030
  • Sending an email to info@lafondation3ds.com.

Only You or a person or a business entity registered with the California Secretary of State to conduct business in California that You authorize to act on Your behalf, may make a verifiable request related to Your Personal Information.

You may also make a verifiable request on behalf of Your minor child. You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows the 3DS Foundation to reasonably verify You are the person about whom the 3DS Foundation collected Personal Information or an authorized representative.
  • Describe Your request with sufficient detail that allows the 3DS Foundation to properly understand, evaluate, and respond to it.

The 3DS Foundation cannot respond to Your request if the 3DS Foundation cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You. Making a verifiable request does not require You to create an account with us. The 3DS Foundation will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.

 

- Response Timing and Format

The 3DS Foundation endeavors to respond to a verifiable request within 45 days of its receipt. If the 3DS Foundation requires more time (up to 90 days), the 3DS Foundation will inform You of the reason and extension period in writing. The 3DS Foundation will deliver its written response by mail or electronically, at Your option. Any disclosures the 3DS Foundation provides will only cover the 12-month period preceding the verifiable request's receipt and/or explain the reasons the 3DS Foundation cannot comply with a request, if applicable. For data portability requests, the 3DS Foundation will select a format to provide Your personal information that is readily useable and should allow You to transmit Your Personal Information from the 3DS Foundation to another entity without hindrance.

The 3DS Foundation does not charge a fee to process or respond to Your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If the 3DS Foundation determines that the request warrants a fee, the 3DS Foundation will tell You why the 3DS Foundation made that decision and provides You with a cost estimate before completing Your request.

 

5. Non-Discrimination

The 3DS Foundation will not discriminate against You for exercising any of Your CCPA rights.

 

6. Contact Information

If You have any questions or comments about this Addendum, our Privacy Policy, the ways in which the 3DS Foundation collects and processes Your personal information, Your choices and rights regarding Your use, or wish to exercise Your rights under California law, please do not hesitate to contact the 3DS Foundation at:

Phone: (888) 337-0030 (toll free within the US only)

Postal Address: Dassault Systèmes Foundation

Attn: Americas Data Protection Officer

175 Wyman Street Waltham,

MA 02451

Or by sending an email to: info@lafondation3ds.com.

 

Last modification: This Privacy Policy was modified in October 20th, 2020.