In addition, 3DS only collects personal data from children, who are considered minors under the applicable data protection law, with the prior consent of their parents or guardians. Such consent is required before a minor can create a user profile or use any 3DS products or services. If the child is a minor they must provide an email address for their parent or guardian to receive a message from 3DS instructing them on how to provide their consent. Schools should always ensure that they have received permission from parents or guardians to do so. Parents or guardians can ask 3DS to review the personal data collected about their child, to remove it and terminate the child’s account or make any other request regarding their child’s personal data by submitting a request via https://www.3ds.com/privacy-policy/contact/ whether or not they gave consent to collect their child’s personal data. If 3DS learns that it has collected personal data from a child, it will delete that information as quickly as possible unless his or her authorized representative is willing to ratify the situation.
WHAT PERSONAL DATA IS COLLECTED AND PROCESSED BY 3DS
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 natural person. Depending on the purposes detailed below, personal data processed by 3DS includes:
- Personal and Business contact information such as first and last name, postal address, email address, telephone number(s) and job title;
- Profile information such as user ID, login and password, profile picture, university, degree, certification and courses taken; type of organization (company, school, etc.), organization name, organization size, department, industry and sub-industry sectors;
- Transaction information details related to purchases you make, including through 3DS websites and apps, event registrations and billing data (such as credit card details, bank account information);
- Operation and usage data (IP and Mac Addresses, logs, etc.) on how you use 3DS websites, apps and services, including data from cookies as described below and through the 3DS marketing preferences Center as applicable.
WHY YOUR PERSONAL DATA IS PROCESSED BY 3DS
3DS will process your personal data for one or several of the following purposes:
With your Consent
- To communicate with you, including when you request information related to 3DS products and services, and more generally to manage 3DS marketing activities;
- To ascertain your requirements and interests and provide you with the most suitable products and/or services;
- To provide you with a personalized, interactive use of 3DS websites and apps and allow you to access all their features;
- To enable you to display certain of your personal information related to your profile while exchanging ideas and other information about 3DS products and services with other users of 3DS websites and apps, including the 3DEXPERIENCE Platform.
To provide you with 3DS products or services
- To enable you to
- register for an event, seminar, webinar;
- enter a contest;
- create a user profile such as the “3DEXPERIENCE ID”.
- To enable 3DS to manage its business relationships with you, (including sales opportunities, commercial offers, purchasing, contracts, orders, invoices, which may include conversational data triggered via chat functionalities on 3DS websites and apps, contact forms, emails, and voice messaging data, delivery of 3DS products, support or professional services);
- To manage your training and/or certification on 3DS products and services, which may include tracking your learning progress in order to make this information available to you.
If you attend an event organized by 3DS, you may be asked for health information for the purpose of identifying and being considerate of individuals who have disabilities, special dietary requirements as well as other additional personal data that are necessary to be processed throughout the event.
To comply with the following legitimate interests:
3DS takes into consideration and balances any potential impact on you (both positive and negative) and your rights before processing your personal data for legitimate interest purposes. Unless 3DS has your consent or is otherwise required or permitted to do so by law, 3DS will not use your personal data in situations where the impact on you outweighs its legitimate interest in processing your personal data:
- To improve your experience;
- To remember your settings;
- To provide you with information related to marketing activities for similar goods and products if you are already using 3DS products and services;
- To enable 3DS to manage its business relationships when you are acting on behalf of a 3DS prospect or customer (including sales opportunities, commercial offers, purchasing, contracts, orders, invoices, which may include conversational data triggered via chat functionalities on 3DS websites or apps, contact forms, emails, and voice messaging data, delivery of 3DS products, support or professional services);
- To manage the 3DS Anti-Piracy and Compliance program. Within this program, 3DS may combine your personal data together with additional relevant publicly available information or personal data collected through other processing activities;
- To create anonymous data for analytics and for compliance, fraud prevention and safety.
To comply with law
- To keep your financial data with a third party payment provider.
HOW LONG YOUR PERSONAL DATA IS RETAINED
3DS does not store your personal data for more time than necessary and only as long as required to fulfill the purposes set out above. Retention periods may vary depending on the data categories and the processing activities. To determine the appropriate retention period for personal data, 3DS considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which 3DS processes your personal data and whether 3DS can achieve those purposes through other means, and the applicable legal requirements:
- where 3DS is required to comply with a legal obligation, the retention period will be determined according to the applicable law;
- where you gave your consent, until you withdraw it;
- where 3DS has entered into an agreement with you or your employer, as long as the agreement is into force plus the applicable local statutes of limitations;
- where 3DS has a legitimate interest in using your personal data, for a limited period of time appropriate to ensure a fair processing of your personal data or until you object to 3DS’s use of your personal data.
Where your personal data is required to assert or defend against legal claims, 3DS will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.
WITH WHOM 3DS SHARES YOUR PERSONAL DATA
3DS does not rent or sell information but may share your necessary personal data for certain business purposes with the following categories of organizations:
- Within 3DS group: 3DS Group is a worldwide multi-tiered organization, located in the Americas, Asia and Europe to provide you with responsive and proactive services. In that globalized context, 3DS may need to share your personal data for example to provide you with support services.
- Event or marketing sponsors: 3DS may share your personal data with trusted sponsors such as 3DS resellers with which 3DS organizes events or marketing promotions. When you register for an event, 3DS may share your name, company, and email address with other participants and sponsors of the same event for the purpose of communication about the event and the exchange of ideas.
- 3DS business partners: 3DS may share your personal data with 3DS business partners such as resellers assigned to you to provide you or your employer with appropriate offers or services.
- Third parties acting on 3DS behalf: 3DS may share your personal data with third party vendors, consultants and other service providers that 3DS employs to perform tasks on its behalf (such as hosting services by a third-party or payment services to enable you to purchase from 3DS products or services) or to protect 3DS’s legal interests (such as in the event of a sale of assets to a third company, or a change of control or a total or partial liquidation of 3DS).
- Law enforcement: Under certain circumstances, 3DS may also disclose your personal data if required by law or if 3DS believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order) or protect the rights, property, or personal safety of 3DS, 3DS’s customers, or the public.
INTERNATIONAL DATA TRANSFERS
When accessing a 3DS website or app, please note that through your continued use of it, if you are located in a different country than the 3DS website or app, you consent to the transfer of your personal data to a country outside of your own.
As part of a worldwide multi-tiered organization, 3DS may transfer your personal data from Europe (or a country that is considered as offering an adequate level of protection as adopted by the European Commission on the basis of Article 45 of the General Data Protection Regulation 2016/679 (GDPR)) to another country. This can for example happen when 3DS provides you with training, support services or cloud offerings. 3DS continually monitors the circumstances surrounding any transfer in order to ensure that these transfers maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR and relies on the Standard Contractual Clauses issued by the European Commission in the absence of an adequacy designation.
WHAT ARE YOUR RIGHTS
Depending on the applicable data protection laws, you may have some or all of the following rights with regard to your personal data:
- access your personal data;
- request the rectification, completion, update or erasure of your personal data;
- restrict processing;
- obtain a copy of your personal data stored by 3DS;
- object to specific processing of your personal data if that processing is based on legitimate interests; and
- data portability.
If the processing of your personal data is based on your consent, you have a right to withdraw that consent at any time. If you have an account, you can exercise your rights by logging on to your account. Otherwise, you may exercise your rights by submitting your request here: https://www.3ds.com/privacy-policy/contact/. Parents can exercise these rights if allowed by applicable law on behalf of their minor children by this same method.
Depending on the scope of the request, and if permitted under applicable law, 3DS may charge a reasonable fee to cover costs incurred in connection with such request. 3DS may deny access to your personal data in limited circumstances in accordance with applicable laws and regulations or if 3DS’ legal grounds override your legitimate interest to privacy.
3DS maintains appropriate technical and organizational measures to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction during transmission and once in its possession. However, while 3DS strives to protect your personal data, in light of the inevitable risks linked to the Internet, 3DS cannot guarantee full protection against any leak.
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.
- Strictly necessary cookies are always used, essential for you to properly browse the 3DS website or app and cannot be switched off. For example, they allow you to save your personalization settings (choice of language, presentation of a service, saving your shopping cart).
- Functional cookies are used in order to improve the performance of the 3DS websites and apps, to provide you with optimized features and a more personal experience by collecting information when you visit a 3DS website or app. Some of them, that are solely performance cookies, collect aggregated information that are therefore anonymous.
To see the list of cookies used by Netvibes and their purpose, click here.
You can remove or reject functional cookies. However, if you do not accept certain cookies, some functionalities and features of the sites and apps may not function properly and you may experience some inconvenience in their use. You can set your cookie preferences at any time by clicking “Manage my cookies preferences” link in the footer of the website.
CONTACT – DISPUTE RESOLUTION
3DS is committed to ensuring the privacy of personal data: You can contact the 3DS Data Protection Officer via the following form: https://www.3ds.com/privacy-policy/contact/ if:
- you encounter any issue when having access to your personal data or related to your rights as described above;
- you believe that 3DS is not complying with the GDPR or the applicable local data protection laws;
- you have a reason to believe that the security of your personal data has been compromised or misused.
When you want to report a claim by lodging a complaint to the 3DS Global Data Protection Officer, you will need to send a letter to the address mentioned at the end of this Policy or submit your claim using the form referenced above containing (in addition to the information required by the form and depending on the type of rights) the name or reference of the concerned processing and any additional information as reasonably requested by the 3DS Global Data Protection Officer.
If your usual place of residence is in European Union, Lichtenstein, Norway or Iceland, you have a right to file a complaint with your local data protection authority.
DATE OF ENTRY INTO FORCE OF THE PRIVACY STATEMENT AND CHANGES TO IT
Last modification: June 8th, 2021