Introduction
Our organization Erosophia.eu, as data controller, attaches paramount importance to the protection of your personal data (hereinafter "Personal Data" or "Data"), in accordance with Regulation (EU) 2016/679 on the protection of personal data as well as Law No. 78-17 of January 6, 1978, as amended, known as "Data Protection Act" (together the "Regulations").
This Privacy Policy sets out the rules implemented by Erosophia.eu regarding the processing of personal data and the use of cookies for all activities conducted on the Erosophia.eu website and e-learning platform (hereinafter collectively referred to as the "Site").
It applies to all information you provide to us or that is collected during your navigation on the Site. This policy describes our practices regarding the collection, use, storage, sharing, and protection of your Personal Data and covers your entire use of the Site.
By providing us with your information and Personal Data, you agree that it will be processed under the conditions defined below, particularly to personalize and optimize your browsing experience and to offer you services and offers tailored to your needs.
We encourage you to carefully read this Privacy Policy as well as any specific information notices communicated to you during collection, in order to fully understand how your Personal Data is used.
1. General information
By using the Site, you may be required to provide Erosophia.eu with certain Personal Data, particularly when creating an account or subscribing to our newsletter.
Additionally, information regarding your navigation may be collected in accordance with the methods described in Article 5 "Cookies" of this Privacy Policy.
2. Your rights
In accordance with Articles 15 to 22 of the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679), you have, subject to proof of identity, the following rights:
- Access to your Personal Data
- Rectification or deletion
- Objection or restriction of processing
- Data portability
- Determination of the fate of your Data after your death
These rights can be exercised by contacting us at the following address: contact@erosophia.eu.
If you believe that the measures taken by Erosophia.eu to protect your data are insufficient, you can contact the competent supervisory authority, namely the CNIL in France, or any other data protection authority designated by the European Commission.
3. Use of data
3.1 Purposes of processing
Erosophia.eu collects and processes only the Personal Data necessary, as data controller under the GDPR, for the following purposes:
- Providing services related to your orders (see Terms and Conditions of Sale)
- Improving our services and ensuring customer follow-up
- Contacting you regarding your orders
- Carrying out commercial prospecting actions
- Offering personalized advertising
- Detecting and preventing any attempt of fraud
The legal basis for these processing operations is both the contract concluded between you and Erosophia.eu and our legitimate interest.
The collected Data is limited to what is strictly necessary: first name, email address, password, IP address, and payment details.
Optional fields (such as phone number) are clearly indicated as such. If mandatory fields are not completed, certain requests may not be processed.
Additional details are provided in Appendix 1 of this document.
3.2 Retention period
Your Personal Data is retained only for the period strictly necessary to achieve the purposes for which it was collected.
We comply with legal retention periods when these are prescribed by law. In other cases, the period is determined taking into account:
- The nature of the Data
- The sensitivity level
- Potential risks
- Applicable security requirements
Erosophia.eu may also retain certain Data related to closed accounts to comply with legal obligations, prevent fraud, or resolve potential disputes.
When retention is no longer necessary, Personal Data is anonymized.
Detailed information is also provided in Appendix 1.
3.3 Recipients of data
The collected Data is intended exclusively for Erosophia.eu.
However, it may be transmitted to third-party providers contractually bound to Erosophia.eu, when necessary for the execution of Site services. These providers have access only to the Data strictly necessary for their mission and are required to use it in accordance with the Regulations.
The list of subcontractors is provided in Appendix 2.
Under no circumstances does Erosophia.eu sell, rent, or transfer your Personal Data to third parties, whether free of charge or for a fee.
Finally, under a legal or judicial obligation (e.g., a court decision), Erosophia.eu may be required to disclose certain Data to third parties. Where possible, we commit to inform you, unless legally prohibited.
3.4 Data transfers
The Site is hosted in France, within the European Union, by O2Switch (Clermont-Ferrand). Personal Data collected by Erosophia.eu is therefore stored on secure servers located in this territory.
If certain Data is transferred to companies established in the United States or in countries not providing an adequate level of protection, Erosophia.eu undertakes to implement appropriate safeguards to ensure a level of protection compliant with the Regulations. Such transfers may in particular be governed by the standard contractual clauses adopted by the European Commission.
3.5 Security and Confidentiality of Data
Erosophia.eu implements all necessary technical and organizational measures to ensure the security and confidentiality of your Personal Data, and to prevent any alteration, destruction, loss, or unauthorized access by third parties. The deployed protection measures comply with state-of-the-art standards, particularly regarding information system security.
However, the use of the Internet carries risks that Erosophia.eu cannot completely control. We therefore draw your attention to potential risks related to its use and operation.
3.6 Institutional access by IP address
When an institution (university, school, library) subscribes to Erosophia.eu on behalf of its members, access to the relevant resources is granted, without account creation, to visitors connecting from that institution's network.
To recognize this access, your public IP address is compared, each time a restricted resource is requested, against the address ranges declared by partner institutions. This IP address is read only at the moment of the request, for the sole purpose of determining whether it belongs to a partner institution: it is neither logged, retained, nor linked to your identity as part of this processing, and no cookie or tracker is placed for this purpose.
The legal basis for this processing is the legitimate interest of Erosophia.eu and the subscribing institution in providing the institution's members with the agreed access to learning resources. This processing is distinct from the collection of connection data described in Appendix 1, which serves security and statistical purposes.
3.7 Institutional access via federated login (SAML / OpenID Connect)
When an institution (university, school) subscribes to Erosophia.eu and opens access through its members' login system ("institution" sign-in, SAML / Shibboleth or OpenID Connect), an account is created automatically on Erosophia.eu upon your first login.
In this context, we receive from your institution a stable identifier, your email address (if released and verified) and, where applicable, your first and last name; we infer your home institution. We never receive your password and request no special-category data.
This Data is processed solely to create and manage your account and to grant access to the resources covered by your institution's subscription. The legal basis is Erosophia.eu's legitimate interest (Article 6(1)(f) GDPR) in providing the service ordered by your institution for its members, applying data minimisation.
Your account is kept for the duration of the agreement between Erosophia.eu and your institution. It is deleted or anonymised after 24 months of inactivity, or at the end of the agreement (purge within 90 days). You may exercise your rights under the conditions set out in section 2 above. Further details are provided in Appendix 1.
4. External links
The Site may contain links to websites operated by third parties. These sites apply their own privacy policies, cookie policies, terms of use, and security measures, which may differ from those of Erosophia.eu.
We disclaim any responsibility for the content or practices of these sites. It is therefore recommended to carefully review their privacy policy before sharing your Personal Data with them.
6. Applicable law and jurisdiction
This Privacy Policy is governed by French law.
Any dispute relating to its interpretation or application will be submitted to the competent French courts, in accordance with the provisions of the French Code of Civil Procedure.
Appendix 1
Processing, purposes, legal bases, retention period
| Processing | Data | Purposes | Legal Bases | Retention Period |
|---|---|---|---|---|
| Information about the Client, creation of a user account, Customer service | Identifier, email address, password, phone number (not mandatory) | Ensure the execution of the Services, their improvement, and their security | Contract and legitimate interest of Erosophia.eu | Duration of the Contract + 5 years as archive to address any potential dispute |
| Payment of Services (only in the context of payment by bank card) | Type of bank card, card number, expiration date, visual cryptogram | Execute the Contract | Contract | Duration of the Contract + 5 years as archive to address any potential dispute |
| Commercial prospecting | Identifier, email address, password, phone number | Inform the Client about other services offered by Erosophia.eu | Legitimate interest of Erosophia.eu and consent of the Client | 3 years from the last active contact with the Client |
| Collection of Client connection data | With each connection: IP address, connection country. Data created by the Client when using our Services: Completed activities | Execute the Contract and ensure the security of the Services. Create site visit statistics | Contract and legitimate interest of Erosophia.eu | 1 year |
| Institutional access by IP address (partner institutions) | Visitor's public IP address | Determine whether the visitor is connecting from a partner institution's network and grant access to the subscribed resources, without account creation | Legitimate interest of Erosophia.eu and the subscribing institution | No retention: the IP address is processed in memory at the time of the request and is not stored |
| Institutional access via federated login (SAML / OpenID Connect) | Stable identifier (eppn / sub), verified email address, first and last name (optional), home institution | Create and manage the account generated automatically on first login (JIT provisioning) and grant access to the resources subscribed by the institution | Legitimate interest of Erosophia.eu (Article 6(1)(f) GDPR) | Duration of the agreement; deletion or anonymisation after 24 months of inactivity, or purge within 90 days after the end of the agreement |
Appendix 2
Suppliers
| Supplier | Function |
|---|---|
| O2Switch | Hosting of Site and data |
| Stripe | In the context of payment by the Client |
| Microsoft (Clarity) | Audience measurement and analysis of Site usage, subject to your consent |
| Google (Analytics 4) | Audience measurement for the Site, subject to your consent |