Privacy Policy
The purpose of this privacy policy (“Policy“) is to describe in a clear and concise manner the conditions under which the personal data (“Personal Data”) of any natural person (“USER(s)” or “YOU“), who has subscribed to the services (“Service(s)” or “Program(s)“) offered by QUANT NEXT, are processed.
The protection of your Personal Data is a priority for QUANT NEXT (hereinafter “QUANT NEXT”).
QUANT NEXT produces and distributes through the Platform training courses (hereinafter “Training“) allowing USERS to develop their skills in quantitative finance through video courses, interactive quizzes, projects and tutorials in Python language.
For this purpose, QUANT NEXT offers to its USERS an access to:
– A digital content platform integrating all resources related to the Services;
– any other Service offered by QUANT NEXT through the Platform.
Subscription to the Services is exclusively online through QUANT NEXT website available at the URL https://www.quant-next.com or any other URL that may be substituted (hereinafter the “Site” or the “Platform”).
The Site is operated by the Sole Proprietorship RAPHAEL DANDO located at 64 Rue de Montreuil 78000 Versailles (FRANCE), (hereinafter “QUANT NEXT“).
The Parties are hereinafter individually referred to as “the Party” and collectively referred to as “the Parties“.
The Services are submitted to the General Terms and Conditions of QUANT NEXT Platform.
This Privacy Policy is intended to inform USERS of any disclosures required by applicable law regarding the processing of Your Personal Data by QUANT NEXT.
When the USER entrusts his Personal Data to QUANT NEXT, the company is subject to the regulations in force concerning the protection of personal data.
Therefore, the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (“General Data Protection Regulation”, known as “GDPR”) is applicable to QUANT NEXT, as well as the French Data Protection Act of January 6, 1978, as amended, the recommendations and doctrines of the French Data Protection Authority (so called “CNIL”), the guidelines of the European Data Protection Board (EDPB) and any other legal or regulatory provisions that may be added to and/or replace them.
(hereinafter together, the “Applicable Regulations”).
For purposes of this Privacy Policy, capitalized terms used in this Privacy Policy shall have the meanings ascribed to them in this document or by the applicable Regulations.
The present Privacy Policy may be modified or completed at any time by QUANT NEXT, notably in order to comply with any legislative, regulatory, or jurisprudential evolution, interpretation by the supervisory authorities, or evolution regarding the processing of personal data implemented by QUANT NEXT. In the event of an update of the present Policy, the modifications will be applicable as soon as they are posted online.
ARTICLE 1. ARE YOUR PERSONAL DATA PROCESSED BY QUANT NEXT?
QUANT NEXT is the editor of the Platform.
In the course of providing its Services, QUANT NEXT collects and processes Your Personal Data and acts as a Data Controller.
Therefore, when YOU use the Services, YOU are transferring your Personal Data to QUANT NEXT, which operates and processes it as the Data Controller.
According to the GDPR, the Data controller is the legal person (company, etc.) or natural person who determines the purposes and means of a data processing operation, i.e. the objective and the way it is carried out.
ARTICLE 2. WHAT CATEGORIES OF PERSONAL DATA ARE PROCESSED BY QUANT NEXT?
2.1. QUANT NEXT applies, by default, the principles of minimization and protection of Personal Data in the execution of its Services (“privacy by design” and “privacy by default“). As a result, only relevant, adequate and limited Personal Data is collected in relation to the purposes for which YOUR Data is processed.
In order to benefit from our Services, WE collect and process Your Personal data. The collection of Your Personal Data can be done initially through the Website or any other useful support. The collection of Your Personal Data generally takes place when You subscribe to our Training Programs but also during any exchange (phone, email, etc). The Personal Data we collect and process may vary depending on the nature of our Services and the purpose of the Data processing.
2.2 Depending on the Service subscribed to, QUANT NEXT collects and processes the following categories of Personal Information related to YOU:
– Identification data, such as your name, first name, alias, email address, postal address, cell phone number, occupation.
– Data related to your orders, purchase history on our Platform;
– All data exchanged with QUANT NEXT before subscribing to our Services (email, contact form, telephone conversations, etc.) and after subscribing (follow-up);
– Information provided by the USER when providing the Services in order to better understand your needs:
* such as data about your expectations of our training Programs
* your level of knowledge as well as your background in quantitative finance.– The data related to your connection history on your Platform’s secure personal space;
– Data related to the follow-up of the training courses such as the results of the proposed evaluations (USER’s results, answers to the quizz, etc.), percentage of progress (progress in the training program) and all the data allowing the follow-up of the accomplished progress;
– Where applicable, when WE use cookies subject to YOUR consent: Browsing history on the Site when YOU have consented to the deposit of cookies and tracers on your browser (See our Cookies Policy where applicable).
2.3. When You provide us with these categories of Personal Data, You authorize QUANT NEXT to process them in accordance with the purposes indicated in point 3 below.
It is specified that only Personal Data that is relevant, not excessive and in adequacy with the purpose pursued by the Processing of Personal Data will be collected and processed by QUANT NEXT. Any Personal Data not related to our Services will not be collected and used by QUANT NEXT.
Except with your express prior consent and subject to the conditions set forth in the applicable Regulation, we do not collect sensitive data within the meaning of Article 9 of the GDPR (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic and biometric data or data concerning health, sex life or sexual orientation).
ARTICLE 3. WHAT ARE THE PURPOSES OF THESE PERSONAL DATA PROCESSING OPERATIONS AND THEIR LEGAL BASES?
Depending on the Services used by USERS, Your Personal Data may be processed by QUANT NEXT for the following purposes:
(a) (Prior to any subscription to our Services and in particular for any sale lead) For the purpose of processing and responding to each of Your requests for information. The legal basis for such Processing of Personal Data is your consent.
(b) (Upon subscription to our Services) For the purpose of processing and responding to each of your requests for information or queries and keeping a record of our exchanges for a better handling of your requests. The legal basis for such Processing of Personal Data is the performance of the contract binding us (following the subscription to a training Program for example).
(c) For the purpose of collecting your advice/opinions allowing us to improve and develop our offer, our Services to better satisfy YOU. The legal basis for such Personal Data Processing is in this case our legitimate interest.
(d) For the purpose of performing the Services for which YOU request us (see our list of Services or programs) and to provide, where applicable, personalized follow-up and support to our programs. In this case, the legal basis for such Processing of Personal Data is the performance of the contract between us;
(e) For the purpose of collecting your opinions on our Programs and Services in order to disseminate them on our online and offline communication media (website, social networks, newsletter, flyer, etc.) and this, in order to communicate on what our USERS think. The legal basis for such Processing of Personal Data is in this case our legitimate interest.
(f) (When We use cookies submitted to your previous consent) for the purpose of collecting information about your browsing on the Site (see, if applicable, our Cookies Policy);
(g) (When YOU subscribe to our newsletter) for the purpose of sending YOU our newsletter and informing in particular of our offers of Services, our upcoming events, our partnerships, the availability of new Programs and Services, etc.). The legal basis for such Processing of Personal Data is your consent.
(h) For the purposes of carrying out the processing imposed by our legal, accounting and fiscal obligations. The legal basis for such Processing of Personal Data is the fulfilment of our legal obligations.
(i) For the purposes of implementing the necessary processing in terms of fraud prevention under the conditions provided by the regulations in force. The legal basis for such Processing of Personal Data is our legitimate interest or a legal obligation, when such a legal obligation does exist.
(j) For the purpose of fulfilling our legal obligations in terms of archiving and storing the subscription to our Services (your Orders). The legal basis for such Processing of Personal Data is the submission to a legal obligation (French Consumer Code).
(k) For the purpose of providing the Services as set forth in the Programs and as set forth in QUANT NEXT‘s Terms and Conditions. The legal basis for such Processing of Personal Data is the execution of the contract between us (following the subscription to your Program).
(l) Where applicable, for the purpose of allowing YOU to view and monitor your progress in learning quantum finance. The legal basis for such Processing of Personal Data is the performance of the Contract.
ARTICLE 4. WHO CAN ACCESS YOUR PERSONAL DATA?
4.1. Access to your Data reserved to QUANT NEXT
In general, Your Personal Information is only accessible to QUANT NEXT staff, except for any transmission of Your Personal Data required by a mandatory legal provision or which would emanate from a duly empowered judicial or state authority.
QUANT NEXT does not disclose at any time the content of your exchanges and information that YOU may communicate during the subscription and/or execution of the Services.
Indeed, your Personal Data are confidential and secured in accordance with the applicable rules of art in force.
4.2. Access to your Data by QUANT NEXT’s subcontractors
QUANT NEXT may subcontract to third party companies the performance of certain services necessary for the provision of the Services. In such case, Your Personal Data may, strictly for the purposes above-mentioned within Article 3, be communicated to our partners for processing YOUR Personal data and strictly under the precise instructions of QUANT NEXT.
In this context, these third party companies may process Your Personal Data for a specific purpose, subject to confidentiality and security requirements.
In such situation, our partners act as subcontractors (“Subcontractor“), in the meaning of the legal provisions of the GDPR.The following companies may access Your Personal Data as Subcontractors, and act only under the specific instructions and control of QUANT NEXT:
● OVH SAS (2 rue Kellermann 59100 Roubaix – FRANCE) as host of the training Programs through the Platform.
OVH SAS has signed a Data Protection Agreement available here.
● Infomaniak SA, (Les Acacias, Geneva, Switzerland) as host of the e-commerce Platform. Infomaniak has signed an agreement on the protection of your Data available here.
● Apresta SARL (486 Rue Sadi Carnot, 59184 Sainghin-en-Weppes – FRANCE) as service provider in charge of webSite maintenance.
● Stripe Payments Europe, Ltd (SPEL) 10 Boulevard Haussmann, 75009 Paris (FRANCE) when YOU pay for the Services using STRIPE or LINK payment solution. Your bank details are only stored for the period needed to carry out this action. STRIPE has signed an agreement related to the protection of your Personal data available here.
● DOKEOS SPRL, Rue Provinciale, 264, 1301 Bierges (BELGIUM) when You use the Platform. The DOKEOS platform is used by QUANT NEXT to manage and broadcast Our online Programs, it also allows an accurate tracking of the time spent by the Users on the Platform. DOKEOS has signed an agreement on the protection of personal data available here.
Contractual warrantees with respect to our Subcontractors
In accordance with the Applicable Regulations, these partners have entered into a written agreement with QUANT NEXT to ensure the security, confidentiality, retention and processing of your Personal Data in accordance with our exclusive instructions and as set forth in the Applicable Regulations.
Thus, a Subcontractor is not entitled to:
– keep Your Personal data beyond the completion of its service;
– process Your Personal data in a different context than that defined by QUANT NEXT.
4.3. Possible transfers of Your Personal Data outside the European Economic Area (EEA)
With the exception of the following companies, QUANT NEXT does not transfer any Personal Data to a provider located outside the European Economic Area (EEA):
– Stripe Payments Europe, Ltd (SPEL), which has entered into a data processing agreement with QUANT NEXT in accordance with the European Commission’s standard contractual clauses published on June 4, 2021.
– Infomaniak SA, domiciled in Switzerland. The European Commission recognizes that Switzerland ensures an adequate level of protection to the applicable regulation (COMMISSION DECISION of July 26, 2000 on the adequacy of the protection of personal data in Switzerland pursuant to Directive 95/46/EC of the European Parliament and of the Council).
ARTICLE 5. HOW LONG WILL MY PERSONAL DATA BE STORED?
Your Personal Data is stored by QUANT NEXT only for the necessary period to the purpose for which the data is processed.
The retention periods therefore differ according to the purpose of the Processing of Personal Data.
Therefore, when QUANT NEXT:
● (For our lead sales User’s) Processes and responds to each of your inquiries or requests, we retain the necessary data for up to three (3) years after our last contact.
● (For our customer User’s) Processes and responds to each of your requests for information or queries and keeps a history of our exchanges for a better handling of your requests, we keep the necessary data for the entire legal period during which our responsibility can be engaged (under French law, 5 years from the day when the holder of a right has known or should have known the facts allowing him to exercise it, under the conditions provided for in Article 2224 of the French Civil Code).
● Processes, collects and archives your advice/notices allowing us to improve and develop our programs, our offer, our Services to always better satisfy YOU, we keep the necessary data until three (3) years after sending your notice;
● Processes, collects and archives your opinions about our Programs and Services for the purpose of collecting your opinions about our Programs and Services in order to disseminate them on our online and offline communication media (website, social networks, newsletter, flyer, etc.), we keep the necessary data up to five (5) years after the issuance of your opinion;
● (When We use cookies subject to your previous consent) for the purpose of collecting information about your navigation on the Site: please refer to our Cookies Policy on this subject (when it’s applicable);
● Sends YOU the newsletter to inform YOU of the Services and different events set up by QUANT NEXT, we keep YOUR Personal data until you effectively unsubscribe. It is however specified that QUANT NEXT deletes YOUR personal data from its database more than three (3) years after :
– the date of the last Service performed (e.g., the date you last logged into a training program) and provided that we have had no further contact from you for three (3) years);
OR
– our last contact.
● Carries out the processing imposed by the accounting and tax obligations applicable to QUANT NEXT (invoicing, etc.): we keep the necessary data for the entire legal period imposed by the legal and regulatory provisions in force;
● Implements the legal obligations in terms of archiving and conservation of your orders: we keep your Personal data for ten (10) years from the date of your last order of Services, plus a period of six (6) months (according to the legal provisions of the French Consumer Code);
● Collects and processes a USER’s Personal Data and processes it in order to deliver the Services and provide follow-up, as provided in the Services and under the conditions set forth in the QUANT NEXT General Terms and Conditions, we retain the necessary Personal data for the duration of the Service (i.e., until the end of your Program plus one (1) year in order to allow any User to keep their history if they subscribe to a new Program);
● Archive the Personal Data of a USER during the whole period during which our responsibility can be engaged by a USER (i.e. under French law: 5 years as from the day when the holder of a right knew or should have known the facts allowing him to exercise it, under the conditions provided for in Article 2224 of the French Civil Code).
ARTICLE 6. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
6.1. List of your rights
YOU have the following rights with respect to your Personal Data, which YOU may exercise by contacting us by any of the means set forth in this section.
Depending on the legal basis retained for each of the Processing of Personal Data and in accordance with the applicable Regulations, YOU do not have access to all the following Rights.
6.2. Details of Your Rights when Your Personal Data is processed
● Right to information about the processing of your personal data
QUANT NEXT strives to provide YOU with easily accessible information, in clear and simple terms, about how we process your Personal Information.
The Processing of Your Data has been brought to your attention during the provision of the Service.
YOU were thus informed about:
– The identity of the Data Controller(s);
– The nature of the Personal Data Processing implemented;
– The purpose of the Processing of Your Personal Data;
– The mandatory or optional Personal Data to be transmitted to QUANT NEXT,
– Recipients of Your Personal Information;
– Your Data Rights and how YOU can exercise them;
– Possible transfers of data to a country outside the European Union and European Economic Area (EEA).
This Privacy Policy also includes all the information required by the applicable Regulations.
● Right of access, rectification and opposition
YOU have the right to ask the Data Controller whether it processes Personal Data related to YOU and obtain a copy of that such information. You also have the right (“right of rectification”) to get Your Personal data amended, when they are inaccurate or incomplete.
Finally, YOU may object to the Processing of Your Personal Data.
● Right to erasure (“right to be forgotten”) and restriction of Processing
The right to be forgotten allows YOU to get the erasure of information concerning YOU when Your Data, subject to the exceptions provided for by the applicable Regulation (in particular when the processing is necessary to comply with a legal obligation to which the Data Controller is subject).
● Right to the portability of Your Personal Data
This right allows YOU to retrieve Your Personal Data provided to a Data Controller in a commonly used, machine-readable structured format.
Under the conditions provided by the applicable Regulation, You may also request a direct transfer of Your Data from one Controller to another, where technically possible.
● Right to Withdraw Consent and Right to Define Instructions Regarding Your Data After Your Death
YOU may also withdraw your consent to the Processing of your Data at any time and define directives relating to the retention, deletion and communication of your Personal Data after your death. These directives may be registered with a trusted third party certified by the French Data Protection Authority (the so-called “CNIL”) or directly with the relevant data Controller.
● Right to file a claim with a control authority
If, despite the efforts of QUANT NEXT to preserve the confidentiality of your data and protect your privacy, YOU are considering that your rights have not been respected, then YOU have the right to file a claim to the French Data Protection Authority (the so-called “CNIL”), www.cnil.fr.
6.3. How to exercise your rights
6.3.1. In order to exercise your rights or in case of a query relating to the Processing of Your Personal Data, YOU may contact QUANT NEXT (as Data Controller) by the following ways:
By email: [contact@quant-next.com]
By mail: ENTREPRISE INDIVIDUELLE RAPHAEL DANDO – QUANT NEXT 64 Rue de Montreuil 78000 Versailles (FRANCE)
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6.3.2. In order to be considered valid, the exercise of your rights must be completed, for each request, by proof of identity. If necessary and if the Data Controller considers that the documents communicated are not sufficient to identify you, additional information may be requested, including, when the situation requires it, a copy of an identity document bearing the holder’s signature.
The Data Controller undertakes to reply as soon as possible, and at the latest, within one month of receiving your request. If necessary, this period may be extended by two months, taking into account the complexity and number of requests addressed to the Data Controller. In such case, YOU will be informed of this extension and the reasons for this postponement.
ARTICLE 7. SECURITY AND CONFIDENTIALITY OF YOUR PERSONAL DATA
In accordance with the applicable Regulations, the Data Controller implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk. These measures are defined by each individual, taking into account the state of knowledge, the costs of implementation and the nature of the scope, context and purposes of the processing as well as the risks, which vary in probability and severity, to the rights and freedoms of natural persons.
QUANT NEXT maintains strict confidentiality measures to prevent data from being distorted, damaged, destroyed or disclosed to unauthorized third parties.
The following measures can be taken to ensure the security of Your Data:
– pseudonymization and encryption of data;
– the means to ensure the continued confidentiality, integrity, availability and resilience of processing systems and services;
– the means to restore data availability and access in a timely manner in the event of a physical or technical incident;
– a procedure to regularly test, analyze and evaluate the effectiveness of the technical and organizational measures to ensure the security of the processing;
– the use of the SSL (Secure Sockets Layer) protocol.
In practice, this can be achieved through the following measures:
– Authentication of persons having access to your Personal Information;
– Scrupulous management of authorizations (only personnel whose mission requires them to have access to the information must be authorized to access it);
– Track access and manage incidents (fraudulent or illegitimate access)
– Protect the internal computer network and servers with firewalls
– Backup the Data on a regular basis
– To secure the outsourcing of the Data, if necessary
– Encrypt, guarantee the integrity of the Data
– Etc. ; …
SECTION 8. AMENDMENT OF THIS PRIVACY POLICY
Subject to the conditions set forth in the applicable Regulations, QUANT NEXT may change the way it processes Personal Data. In such event, this Privacy Policy will be updated accordingly and posted on the Site.
ARTICLE 9. APPLICABLE LAW AND LITIGATION
This Privacy Policy is submitted to the French law.
If, despite the efforts of QUANT NEXT to preserve the confidentiality of your data and protect your privacy, YOU consider that your rights have not been respected, YOU have the right to file a claim above the French Data Protection Authority (CNIL), www.cnil.fr.
Date of publication: 31 March 2023
