D ATA PRIVACY STATEMEN T

Your privacy is important to Berlitz and we are committed to using your personal data responsibly. Please read our data
protection and privacy policy carefully to understand how Berlitz and its affiliate Telelangue collect, use, disclose, transfer
and store your data.
For further information, please contact us by email at dataprotection@berlitz.fr or by writing to us at Berlitz, 9, Rue Maurice
Grandcoing, 94854, Ivry s/ Seine, France.

PERSONAL DATA COLLECTION AND USE

The personal data that we are liable to collect:
When you send a contact form, create a free trial account, buy a product, sign up for one of our promotional offers and
newsletters, or take an online survey, we collect different types of information, including your name, your mailing address,
your telephone number, your e-mail address and your language training needs.
In compliance with the principle of data minimization, we store only the information required to operate our applications,
deliver our courses, or data required by the applicable French and European regulations.
Berlitz and its affiliates may share the data to process your inquiries, respond to communications or improve the quality of
our customer service. The data can also be combined with other types of information to provide and improve our products,
services, content and advertising.
If you purchase one of our language courses as an individual, we will ask you for your credit card details for payment
purposes. This data will not be stored by Berlitz and will only be used by its secure payment partner. Telelangue uses the
Ingenico solution to secure payments. As a payment security expert, Ingenico ensures that sensitive data is transmitted and
stored in accordance with the highest standards of security and quality.

How do we use your personal data?

The personal data we collect allows Berlitz to keep you up to date with our latest news, product updates and upcoming
events. It also helps us improve our services, content and advertising. If you do not wish to appear in our mailing list, you can
ask for your name and details to be removed at any time by updating your preferences or contacting us directly.
In addition, access to the services provided by Berlitz requires you to register to obtain a username and password. We may
also use your personal data internally in the event of an audit, data analysis and research to improve Berlitz’s services and
communications with customers.

COLLECTION AND USE OF NON-PERSONAL DATA

Types of non-personal data that we are liable to collect:
We may collect information such as your occupation, age, educational background, languages, zip code, time zone, etc. This
information is sometimes required to get a better understanding of customer behavior and to improve our services.
We may also collect information about customer activity on our website and our online service platforms (CyberTeachers®,
NetPlanning, NetReporting and other language training services). This data is collected and used to help us better
understand which parts of our website, products and services are of most interest to our customers.
If we combine non-personal and personal data, the resulting data will be treated as personal data as long as it remains
combined.

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 COOKIES
Berlitz's website and online service platforms may collect anonymous information using "cookies." Cookies help us better
understand user behavior, tell us which parts of our website are the most visited, facilitate and measure the effectiveness of
our advertising and web searches. The use of cookies is common on the Internet and many important websites use them.
The data collected by cookies is considered non-personal. Your browser may allow you to delete or disable our cookies at
any time.

SHARING OF INFORMATION
With access providers:
Berlitz may make some personal data available to strategic partners in the following circumstances: (a) you have given us
your consent or (b) they are trusted partners processing data at your request (we require that such parties agree to process
the said data according to our instructions and in accordance with this privacy statement and with any other confidentiality
and security measure).
Personal data will be shared by Berlitz only to provide or improve our products, services or advertising. We may share some
non-personal data collected from you with third parties in order to improve our services. However, nobody can identify you on
the basis of that kind of data alone.

With others:
Berlitz may be required to disclose your personal data if required to do so by law, in the event of legal proceedings, litigation
and/or a request from governmental authorities in or outside of your country of residence. We may also disclose information
about you if we believe it is necessary for reasons of national security, law enforcement or any other matter of public policy.
We may also disclose information about you if we believe it is reasonably necessary to enforce our terms and conditions or
to protect our operations or users. In addition, in the event of a reorganization, merger or sale, we may transfer all or part of
your personal data to the third party concerned.
If you wish to cancel your authorization to share your personal data, you may indicate this at any time by updating your
preferences or contacting us via the contact information provided above.

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 PERSONAL DATA PROTECTION
Berlitz takes the necessary precautions to protect your personal data against loss, theft and misuse, as well as against
unauthorized access, disclosure, modification and destruction. Access to your data is restricted to only those people who
need the information to perform the services that we offer.
Your personal data may be stored in computer systems maintained by an agent or service provider of our company, both of
which are bound by an agreement protecting the confidentiality of the data. Our computer systems are located in France but
those of our service providers may be located in another country. By sending us your personal data, you consent to the
transfer and storage of your data beyond national boundaries.
When using certain Berlitz applications, such as virtual classrooms, chat rooms, or social networking services, the personal
data you share may be viewed by other participants and may be read, collected, or used by them. You are solely responsible
for the personal data that you choose to share in those cases. For example, if you enter your name and email address in a
virtual classroom, this information becomes public. Be mindful when using these features.

INTEGRITY AND RETENTION OF PERSONAL DATA

Berlitz only stores your personal data for the time required to fulfill the purposes set forth in this privacy statement, unless a
longer period of storage is required or requested by law. We are constantly reviewing our data use practices to ensure that
your personal data is accurate, complete and up-to-date, as well as to improve the services that we offer.

RIGHT OF ACCESS TO PERSONAL DATA

You have an individual right of access, rectification and opposition that is exercised with the data controller or the Data
Privacy Officer upon request by e-mail to dataprotection@berlitz.fr or by writing us at Berlitz, 9, Rue Maurice Grandcoing,
94854, Ivry s/ Seine, France.

We will act in good faith and make every effort to provide you with access to your personal data, and enable you to correct
this data if it is incorrect or to delete it at your request, providing the data does not need to be kept for legal or for other
legitimate purposes. We may refuse to process claims that might be unreasonably repetitive, require a disproportionate
technical effort, endanger the privacy of others, are extremely difficult to satisfy or for which access would not be necessary.

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 COMMISSION NATIONALE INFORMATIQUE ET LIBERTÉS
Telelangue (Berlitz subsidiary company) is registered with the Commission nationale informatique et libertés (CNIL,
registration number: 1105487). Telelangue collects and stores data as described in this privacy statement in accordance with
Article 32 of the Information Technology, Data Files and Civil Liberties Act of January 6, 1978, as amended by Law 2004-801
of August 6, 2004.
Berlitz and Telelangue undertake to comply with the very strict French and European laws on personal data protection, as
well as to guarantee an adequate level of protection to the data processing performed.

EXTERNAL LINKS
Our website or service platforms may contain hyperlinks controlled by third parties. This privacy statement does not govern
the use of such websites.

PRIVACY ISSUES
If you have any questions or concerns regarding Berlitz’s privacy statement or data processing, please contact us by e-mail
at dataprotection@berlitz.fr.
This privacy statement may be regularly updated by Berlitz. When we make substantial changes to the policy, information is
posted on our website with the updated privacy statement.

Last update: May 5, 2018