Privacy Policy

Last updated: November 3, 2026

Key points at a glance

This summary gives you a simple overview of how Elite uses your data. It does not replace the full policy, which is set out below.

01. Who are we?
Elite is an orientation media outlet belonging to the Thotis group. We publish the website https://elitehighered.com/ and the orientation platform https://app.elitehighered.com/. Elite is the controller of your data, where applicable jointly with certain partner schools.

02. What data?
Your name, your contact details, your academic background and your orientation plans, your answers to tests, your exchanges with the orientation assistant and information about your browsing, collected by means of cookies subject to your consent where required.

03. Why?
To run your account and our services (tests, admission chance estimation, orientation assistant), answer your questions, organize our events, improve our services and, if you agree, send you information.

04. What about artificial intelligence?
When you use the orientation assistant, you are interacting with an artificial intelligence. Its answers, like the test results, are for guidance only: no decision is made on your behalf. Do not share sensitive information in it (health, religion, opinions, etc.).

05. Do schools receive my data?
Your data is only passed on to a school, so that it can send you its own information, with your consent. The list of schools concerned is provided to you at the time this consent is obtained.

06. For how long?
We keep your data for periods that vary depending on its nature, the use we make of it and our legal obligations. These periods are set out in sections 4 and 12.

07. Cookies?
You choose which ones to accept. Refusing is as easy as accepting, and you can change your choice at any time using the “Manage consent” link at the bottom of the page.

08. Where is your data?
It may be processed within the European Economic Area (EEA) or outside it. Any such transfers are governed in accordance with applicable regulations.

09. Your rights:
you can access your data, correct it, delete it, object to its use or withdraw your consent. You can delete your account directly from the platform. For any questions: contact@thotismedia.com. In the event of a disagreement, you can lodge a complaint with the Cnil (www.cnil.fr).

This policy is issued for Elite Higher Education (hereinafter “Elite”), an orientation media outlet operated by Thotis, a simplified joint-stock company (société par actions simplifiée) with a share capital of €6,000, registered with the Pontoise Trade and Companies Register under number 840 091 664 (SIRET: 840 091 664 00010). In this policy, “Elite” refers to Thotis acting through its Elite Higher Education brand.

Your privacy is important to us and we pay particular attention to it. We strive to protect the personal data collected about you. This personal data protection policy (hereinafter the “data protection policy”) describes the information that Elite (hereinafter “Elite” or “we”) collects about you, in particular by means of or through, in whole or in part, the website https://elitehighered.com/ and the orientation platform available at https://app.elitehighered.com/ (hereinafter, together, the “site”) or one of Elite’s social media pages, but also in the course of your dealings with Elite, and how Elite processes it (i.e. information on the methods of collection, processing and use of your personal data).

The processing of personal data presented and described in this data protection policy concerns processing carried out by Elite as controller, on its own behalf or, for certain purposes, jointly with certain of its clients (i.e. advertisers, mainly schools). The list of Elite clients that may qualify as joint controllers with Elite, for certain purposes, in accordance with the details set out in this policy, is as follows:

List of advertisers

3iL
Audencia
BUILDERS
Clermont SB
Concours Puissance Alpha
Cours du Parnasse
CPCM
De Vinci Higher Education (EMLV + IIM)
Diploma Education (Diploma Santé + Médibox)
EBI
EF Education
EPF
ESA
ESA Assurance
ESIEA
ESIEE
ESIGELEC
ESSCA
ESSEC
ETS
Excelia
FMMS
GEM
Groupe CJC (CPCM + Juridicas)
Groupe EDH (EFAP + BRASSART)
Groupe Formapriv (Antémed + Sup Exam)
Groupe IGENSIA (ISB + IGENSIA Tech + IGENSIA Alternance + IGENSIA RH + ISCPA)
IFEC
Institut Lyfe
ISC Paris
ISCOM
ISEP
Isfogep
ISIT
ISO
Juridicas
MBS
Médisup
NEOMA
Rennes SB

The essence of the arrangements concluded between Elite and these clients, in accordance with Article 26 of the GDPR, may be obtained on request from Elite’s Data Protection Officer (see section 6.2).

Where Elite passes your personal data to one of its clients so that the client can use it on its own behalf, in particular for direct marketing purposes, that client acts as a separate controller, and not as a joint controller.

Processing of personal data carried out by other entities, where those entities act as controllers, is not covered by this data protection policy. To find out more about such processing of your personal data by those entities, please contact them directly.

Definitions
What is our role in the processing of personal data?
How is your personal data collected?
What data is collected, for what processing purposes, on what legal bases and for how long?
Who are the recipients of your personal data? How do we share your data?
What are your rights and how can you exercise them?
How is your personal data secured?
Is your personal data transferred outside the European Economic Area?
How are the site and the social media pages linked to third-party sites?
Can this data protection policy be amended?
What is the cookie management policy of the site?
Additional information about the Elite orientation platform

1. Definitions

In addition to the terms defined elsewhere in this policy, the following terms, whether used in the singular or plural in this policy, have the following meanings:

“recipient”: means the natural or legal person, public authority, agency or other body to which personal data is disclosed, whether or not a third party.
“personal data”: means any information relating to an identified or identifiable natural person (the “data subject”); an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“controller”: means the natural or legal person, public authority, agency or other body which determines the purposes and means of the processing. Where the controller determines the purposes and means of the processing jointly with others, it is referred to as a “joint controller”.
“processor”: means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
“processing”: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. What is our role in the processing of personal data?

2.1 Elite is an orientation media outlet operated by Thotis, a simplified joint-stock company (société par actions simplifiée) with a share capital of €6,000, registered with the Pontoise Trade and Companies Register under number 840 091 664, whose registered office is located at 14K – PARC TECHNOLOGIQUE DE MONTMAGNY, 26 RUE DES SABLONS, 95360 MONTMAGNY (France), intra-community VAT number FR52840091664, SIRET: 840 091 664 00010, telephone: 06 40 14 07 62, email address: contact@thotismedia.com.

2.2 Elite is a media outlet designed to help young people with their orientation choices. It publishes the website https://elitehighered.com/ and the orientation platform available at https://app.elitehighered.com/ (together, the “site”). The site is intended to provide any internet user who uses or visits it with content providing information on study paths, schools, degrees or programs offered to students, as well as news (events, publications, etc.).

It also offers features and/or information allowing users to contact students (i.e. contact / information request), download information brochures or guides (orientation guide, careers guide, etc.), register for events organized by Elite, interact with artificial intelligence tools, and ask questions or obtain information.

Accessible after creating a user account, the orientation platform notably offers orientation tests, tools for estimating the chances of admission to programs, a database of programs and an orientation assistant based in particular on the information published on our site and on artificial intelligence.

Elite also manages pages presenting its activity, allowing it to publish content on social media and to interact with internet users through these networks (i.e. Instagram, Facebook, TikTok, YouTube, X (formerly Twitter) and LinkedIn).

When you browse and interact with the site, the pages managed by Elite on social media or, more generally, when you interact or communicate with Elite, Elite may collect and process personal data about you, whether you are a pupil, student, client / advertiser, prospect, contact, internet user / user, job applicant, influencer, speaker, political / public figure, supplier, service provider or partner, potential or current (also referred to as “you” or the “data subject(s)”), in particular for the management of its activities.

In this context, Elite applies the principles defined by the legal and regulatory provisions applicable to it regarding the protection of personal data, in particular Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (the “GDPR”) and French Law No. 78-17 of January 6, 1978 on information technology, data files and civil liberties (the “French Data Protection Act”) and its implementing decrees.

3. How is your personal data collected?

3.1 Your personal data is collected by Elite, either directly from you or indirectly from third parties.

3.1.1. Your personal data is notably collected or processed, in whole or in part, when you browse the site (for example through redirection plug-ins or social media features linked to / integrated into the site, or to which the site may be linked), when you interact with the site, and when you enter information in any data collection forms they may contain, but also more generally in the context of requests you may send to Elite by any means of your choosing, your relationship and exchanges with Elite, when you access social media pages via redirection “buttons” from the site, or when you browse one of the pages managed by Elite on social media.

Your personal data is therefore collected by Elite from you in the situations described above.

3.1.2. In addition, your personal data is notably collected or processed in the context of requests you may send to students through the site, and of your relationship and exchanges with those students.

In these situations, your personal data is therefore collected from you by the students to whom you have sent a contact request. These students receive the data necessary to handle your request.

3.1.3. Your personal data may also be collected through third parties.

The personal data we collect and process about you may be obtained or enriched by us, in particular for commercial, communication, solicitation, direct marketing or marketing operations, by means of other sources of information (“public” information, social media, third-party / partner websites, file rental operations / provision of files by third parties / partners, etc.).

In addition, your personal data may be collected by Elite and then passed on or made accessible to its clients.

Likewise, your personal data may be passed on to Elite by other staff members / contacts within your company or through third parties in certain situations.

Furthermore, with regard more specifically to personal data processed in the context of Elite’s recruitment operations, Elite may use the information you provide (e.g. a form completed for this purpose or, more generally, information included in your CV), which may, under certain conditions, be added to a candidate database (CV database). However, Elite may also contact third parties (for example, recruitment agencies, previous employers, internship supervisors or clients for whom you have worked on previous assignments) or use other sources of information (in particular professional social networks, recruitment firms or specialized recruitment websites) in order to gather information about you for the purpose of assessing your application or your profile. In addition, even if you have not applied, Elite may, in particular in the context of monitoring and actively searching for professional profiles that may match its job openings, collect personal data from third parties (for example, recruitment agencies or headhunters) or use other sources of information (in particular professional social networks or specialized recruitment websites) in order to gather information about you with a view to inviting you to apply for one of its job openings.

3.2 In addition, and in general, you are informed that as a matter of principle:

if the processing of your personal data is necessary for compliance with Elite’s legal or regulatory obligations, the collection of that data is mandatory;
if the processing of your personal data is subject to your consent, providing that data is entirely optional (it being specified that failure to provide it may, at a minimum, prevent Elite in certain cases from carrying out the processing concerned);
if the processing of your personal data is necessary for the performance of a contract or of pre-contractual measures taken at your request, providing that data is necessary for this purpose and, if it is not provided, Elite may be prevented from performing its contractual obligations or the aforementioned pre-contractual measures;
if the processing of your personal data is based on the pursuit of Elite’s legitimate interests, providing that data is necessary for this purpose, and failure to provide your data may prevent or hinder the processing concerned. For example, if the information needed to respond to a request from you (request for information, etc.) is not provided, your request relating to that collection of personal data may not be processed or its processing may be delayed.

Special case: if personal data collection forms (for example, forms integrated into the site or Elite’s social media pages, or any collection form in any format that Elite may make available to you to gather information about you) require the entry of mandatory personal data for the associated processing, the fields concerned will be marked with an asterisk and you will be informed of the possible consequences of not providing this information. Where there is no asterisk, the information requested is optional.

3.3 Except in specific situations, or unless otherwise stated in this policy, we do not collect so-called “sensitive” or “special category” personal data, i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, nor genetic or biometric data for the purpose of uniquely identifying a natural person, nor data concerning health or data concerning a natural person’s sex life or sexual orientation. In this respect, you are informed that, as a matter of principle, Elite asks you not to provide such “sensitive” or “special category” data in your exchanges through the site or the pages managed by Elite on social media.

However, in certain situations, Elite may process so-called “sensitive” or “special category” personal data, subject to obtaining your prior explicit consent or where such information has manifestly been made public by you.

3.4 Personal data of minors: given its activity, which is dedicated to academic and university orientation, Elite processes personal data of minors, in particular when they use the site or Elite’s social media pages, register for an event or apply to Elite for a job or internship.

In accordance with Article 45 of the French Data Protection Act, where processing is based on consent, a minor may consent alone from the age of fifteen. Below that age, processing is only lawful if consent is given jointly by the minor and the holder(s) of parental authority. The latter may exercise the rights of a minor under fifteen under the conditions set out in section 6.

With regard to minor users, Elite ensures in particular that it:

limits collection to the data necessary for the purposes pursued;
does not send them targeted advertising based on profiling;
does not pass their data on to its clients for direct marketing purposes without having obtained the required consent under the aforementioned conditions;
provides them with clear information adapted to their age.

4. What data is collected, for what processing purposes, on what legal bases and for how long?

Your personal data is processed for the following purposes:

4.1 Management and follow-up of information requests and exchanges with users, initiated via or by means of the site or Elite’s social media pages or by any other means, and more generally of relationships with contacts in the broad sense

Purpose of processing: Elite and, where applicable, its clients, each for their own part, may process your personal data in order to handle, manage and follow up any request you send to Elite (for example, a request to receive the orientation guide, the careers guide, etc.) by any means, in particular via the site or through interactions on Elite’s social media pages (including in particular the management, handling, follow-up and possible moderation of your messages or comments) and the responses to be given, the management and follow-up of the features offered on or via the site, the collection and technical transmission of your contact requests to former students listed, where applicable, on the site, and more generally for the purpose of managing its relationships with its contacts in the broad sense, including carrying out and preparing studies / surveys or polls where applicable.
Controller: Elite.
Data processed: identity (title, last name, first name), username or pseudonym / alias, contact details (in particular postal address or, at a minimum, place of residence, telephone number or email address), level of education, contact or information request, correspondence exchanged, history of exchanges (information requests, solicitations, etc.): existence, traceability and content.
Legal basis for processing: the processing of your personal data in this context is necessary for the pursuit of Elite’s legitimate interests in responding to your requests and, more generally, in managing and following up its relationships with you.
Data retention period: personal data is kept in the active database for the time necessary to respond to your request or to manage the relationship and then, at the end of the active retention period, kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.2 Management of Elite’s relationships with current or potential clients (i.e. advertisers)

Purpose of processing: in order to manage relationships with its current or potential clients, Elite collects the personal data of its contacts at its current or potential clients (e.g. staff members, service provider / consultant at the client, etc.) to manage and follow up its pre-contractual, contractual and post-contractual relationships with its current or potential clients in the broad sense, including the search for new clients, the management and follow-up of the conclusion and performance of contracts, services provided, payments and transactions, related invoicing / accounting, client / prospect / contact relationships in the broad sense, and in particular the management and follow-up of client accounts and, where applicable, complaints.
Controller: Elite.
Data processed: identity (title, first name, last name), contact details (email address, postal address, telephone number, etc.), professional data, economic and financial information, details of transactions / services provided / contracts, data relating to these transactions / services provided / contracts, data relating to the follow-up of transactions / services provided / contracts, and more generally of relationships between Elite and its clients, data relating to complaints.
Legal basis for processing: such processing of your personal data is, as a matter of principle, necessary for the pursuit of Elite’s legitimate interests in properly managing its relationships with its current or potential clients, and more generally with contacts at those clients in the broad sense, in particular in the context of searching for new clients, monitoring the proper performance of contracts concluded with clients, or organizing and properly carrying out assignments or services entrusted by clients. With regard in particular to invoice management and the related accounting, such processing may result from Elite’s legal obligations.
Data retention period:
- for current clients (or contacts linked to a current client) of Elite: your personal data is kept in the active database for the duration of Elite’s contractual or commercial relationship with the client concerned;
- for potential clients (or contacts linked to a potential client) of Elite: your personal data is kept in the active database for the duration of Elite’s pre-contractual relationship with the potential client concerned;

then, at the end of the active retention period, kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.3 Management of Elite’s relationships with its service providers and suppliers, and more generally its partners, current or potential

Purpose of processing: Elite may process personal data relating to its current or potential partners and/or contacts at those partners (e.g. staff members, service provider / consultant at the partner, etc.). The purpose of this processing is the search for new partners, the management, follow-up and response to requests, quotes or service proposals, as well as the management of partners and/or of Elite’s relationships with them, including in particular the management and follow-up of the performance of contracts, orders / services entrusted, deliveries, invoices, payments and transactions, related accounting, and in particular the management and follow-up of partner accounts, of the relationship with them in the broad sense and, where applicable, of complaints.
Controller: Elite.
Data processed: identity (title, last name, first name), pseudonym / alias, contact details (email address, postal address, telephone number, etc.), social media profile information, employer and position, information relating to your education (studies, degrees, etc.), your experience and career path, your professional skills / references, and any information that may be contained in your CV where applicable, information on requests, quotes and service proposals, details of orders / services / contracts, data relating to payments and payment methods, data relating to transactions, data relating to the follow-up of contracts and of the relationship, data relating to invoices, data relating to complaints.
Legal basis for processing: such processing of your personal data is, as a matter of principle, necessary for the pursuit of Elite’s legitimate interests in properly managing its relationships with its current or potential partners (and more generally with contacts at those partners in the broad sense), in particular in the context of searching for new partners, monitoring the proper performance of contracts concluded with them, or organizing and properly carrying out the assignments or services entrusted to them. With regard in particular to invoice management and the related accounting, such processing may result from Elite’s legal obligations.
Data retention period: kept in the active database for the duration of the pre-contractual relationship (for potential partners) or contractual or commercial relationship (for current partners) with Elite, then kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.4 Elite’s external communication operations

Purpose of processing: Elite and, where applicable, its clients, each for their own part, may process personal data about you for the purpose of carrying out external communication operations, including in particular the presentation of Elite and/or its clients and their activity (testimonials, promotion and communication relating to events, programs or applications to higher education, news relating to student life, etc.) on the site and/or Elite’s social media pages, and more generally on any communication medium managed / distributed by Elite.
Controller: Elite, possibly jointly with one of its clients (i.e. where applicable, the Elite client referred to in the communication operations concerned).
Data processed: identity (title, last name, first name), pseudonym / alias, photograph / video / voice, status (e.g. client, prospect, contact, influencer, student, political / public figure, speaker, internet user / user, partner, supplier or service provider, and any details on this status), testimonial.
Legal basis for processing: such processing is based on your consent (to be obtained by Elite by means of a dedicated document that will be submitted to you), which means that you have the option of not consenting or, if you do consent, of subsequently withdrawing your consent at any time, without having to give any reason or explanation.
Data retention period: kept in the active database for 3 years from the date your consent is obtained, then kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.5 Carrying out and preparing studies, analyses, reports and statistics

Purpose of processing: Elite and, where applicable, its clients, each for their own part, may process personal data about you for the purpose of carrying out and preparing studies, analyses, reports and statistics. Wherever possible, this processing is carried out using pseudonymized or anonymized data.
Controller: Elite, possibly jointly with one of its clients.
Data processed: identity (title, last name, first name), username or pseudonym / alias, position and employer where applicable, possibly professional data, contact details (telephone number, email address or postal address), economic and financial information where applicable, details and data relating to the follow-up of ongoing transactions / services / contracts / disputes, etc., and more generally data relating to the relationships between Elite (and, where applicable, its clients, each for their own part) and the data subjects.
Legal basis for processing: such processing is, as a matter of principle, necessary for the pursuit of the legitimate interests of Elite and/or one of its clients in ensuring their development, or in assessing the performance of the communication operations carried out.
Data retention period: kept in the active database for 3 years, then kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.6 Compliance with legal and regulatory obligations (including accounting, tax and administrative obligations) relating to the performance of contracts concluded by Elite, and more generally to Elite’s activity, and monitoring of Elite’s accounts and financial position

Purpose of processing: in order to comply with the various legal or regulatory obligations incumbent on Elite (in particular accounting, tax or administrative obligations arising from the performance of commercial contracts to which Elite is a party and more generally from Elite’s activity), Elite processes the personal data of its contacts (for example influencers, or contacts at its current or potential partners or clients) for this purpose, but also for the purpose of monitoring its accounts and its financial and budgetary position (including in particular general and analytical accounting, the representation and monitoring of changes in its assets, and the assessment of its financial and budgetary position, etc.).
Controller: Elite.
Data processed: identity (title, last name, first name), contact details (postal address, telephone number, email address, etc.), data relating to payments and payment methods, data relating to transactions, data relating to the follow-up of contracts / services provided and of relationships with contacts, data relating to invoices, accounting, financial, budgetary and tax information.
Legal basis for processing: such processing is, as a matter of principle, necessary for compliance with the legal or regulatory obligations incumbent on Elite (in particular financial, tax and accounting documents). In addition, the sub-purposes of this processing relating to the monitoring of Elite’s accounts and financial and budgetary position are necessary for the pursuit of its legitimate interests in properly managing its accounts and financial position.
Data retention period: kept in the active database for the duration of the current financial or tax year, then kept in archived form for up to 10 years (except for data kept solely to take account of the tax limitation period, which is therefore kept in archived form for a period limited to 6 years).

4.7 Organization, management and follow-up of events

Purpose of processing: Elite may process personal data about you in the context of the management and follow-up of the events it offers, online or in person (e.g. fairs, conferences, live sessions, etc.), for example for the purpose of promoting or communicating about a program or a school (organization of talks, management, handling and follow-up of registrations, responses to information requests, etc.).
Controller: Elite.
Data processed: identity (title, last name, first name), age, postcode, areas of interest, contact details, position and employer of speakers, information on registrations and attendance at events.
Legal basis for processing: in general, the processing of your personal data in this case is necessary for the organization and management of events, and is therefore based on the performance of pre-contractual measures taken at your request or of a contract to which you are a party (i.e. registration for the event). With regard in particular to the management of relationships with speakers, such processing is necessary for the pursuit of Elite’s legitimate interests in organizing the talks.
Data retention period: kept in the active database for the time necessary to organize and follow up the event, then kept in archived form for 5 years for administrative and/or evidentiary purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the conditions and terms set out below in this section 4.

4.8 Direct marketing / solicitation by post or telephone

Purpose of processing: Elite and, where applicable, its clients, each for their own part, may process personal data about you for the purpose of carrying out commercial, communication, solicitation, direct marketing or marketing operations (including technical segmentation, targeting, personalization of communications, etc.) by post or telephone, in particular in order to send you certain information for this purpose by these means: offers of products and services or information on services or programs that may interest you, information on the news and/or activities of Elite, or even of Elite’s clients, and more generally relating to study paths, schools, degrees or programs, other marketing information or documents (e.g. brochure / leaflet), or studies, polls or satisfaction surveys.
Controller: Elite. Where your data is used by a Elite client for its own direct marketing operations, that client acts as a separate controller.
Data processed: identity (title, first name, last name), contact details (postal address, telephone number), position and employer where applicable, answers to studies / surveys / polls, place of residence, profile / segment (in particular level of education, postcode, age, preferences / areas of interest, types of programs sought, etc.), acceptance / refusal of commercial communications where applicable depending on the communication channel (yes/no), and more generally data relating to the relationships between Elite and the data subjects.
Legal basis for processing:
- direct marketing by post, as well as telephone marketing to professionals relating to their professional activity, is carried out on the basis of the pursuit of Elite’s legitimate interests in making itself known, ensuring its development, in particular its commercial development, and carrying out direct marketing and solicitation operations in the broad sense, it being specified that the recipient of such direct marketing has in any event the right to object to it at any time without having to give any reason or explanation.
- Telephone marketing to consumers is subject to their prior consent; this consent may be withdrawn at any time.
Data retention period: as a matter of principle, kept in the active database for three years from the collection of the personal data or from the end of the relationship with Elite and/or the relevant Elite client where applicable, or from your last contact with Elite and/or the relevant Elite client (for example, from the last contact initiated by the data subject (online request, email or letter, telephone call, etc.)). With regard in particular to data processed in the context of satisfaction surveys, kept in the active database for 3 years. At the end of the active retention period, the data is deleted or anonymized, with the exception of the elements needed to prove consent, which are kept in archived form for 5 years.

4.9 Direct marketing / solicitation by electronic communication

Purpose of processing: Elite and, where applicable, its clients, each for their own part, may process personal data about you for the purpose of carrying out commercial, communication, solicitation, direct marketing or marketing operations (including technical segmentation, targeting, personalization of communications, etc.) by electronic communication, in particular in order to send you certain information for this purpose by this means (i.e. email, SMS, MMS, private online messages): offers of products and services or information on services that may interest you, information / announcements (including in particular their distribution, reminders, management of responses, etc.) on the news and/or activities (e.g. newsletter) of Elite, which may also concern Elite’s clients, other marketing information or documents, or studies, polls, promotions or satisfaction surveys. Your data may also be passed on to Elite clients for the purpose of their own direct marketing operations by electronic communication.
Controller: Elite, possibly jointly with one of its clients.
Data processed: identity (title, first name, last name), contact details (email address, mobile telephone number, messaging ID), position and employer where applicable, answers to studies / surveys / polls, place of residence, profile / segment (in particular level of education, preferences / areas of interest, types of programs sought, etc.), acceptance / refusal of commercial communications where applicable depending on the communication channel (yes/no), and more generally data relating to the relationships between Elite and the data subjects.
Legal basis for processing:
- where messages are sent to professionals, at their professional email address, and relate to their professional activity, they are not subject to the prior consent of the data subjects; the processing is then carried out on the basis of the pursuit of the legitimate interests of Elite and/or one of its clients in making itself known, ensuring its development, in particular its commercial development, and/or carrying out direct marketing and solicitation operations in the broad sense, it being specified that the recipient of such direct marketing has in any event the right to object to it at any time without having to give any reason or explanation;
- in other cases, in particular when you subscribe to the newsletter on the site, such processing is based on your consent, which means that you have the option of not consenting or, if you do consent, of subsequently withdrawing your consent at any time, without having to give any reason or explanation. Your prior consent is also required for your personal data to be passed on to Elite clients for the purpose of their own direct marketing operations by electronic communication (it being specified that, failing such consent, your personal data will not be passed on). This consent is obtained separately at the time of collection, and the list of recipient clients is provided to you at that time.
Data retention period: kept in the active database for three years from the collection of the personal data or from the end of the relationship with Elite and/or the relevant Elite client where applicable, or from your last contact with Elite and/or the relevant Elite client where applicable (for example, from the last contact initiated by the data subject (online request, email or letter, telephone call, etc.)). With regard in particular to data processed in the context of satisfaction surveys, kept in the active database for 3 years. At the end of the active retention period, the data is deleted or anonymized, with the exception of the elements needed to prove consent, which are kept in archived form for 5 years.

4.10 Use of cookies or other similar technologies for the purpose of tracking browsing, including carrying out and preparing studies, analyses, reports and statistics, managing and monitoring the proper functioning of the site, improving the user experience, making certain services or features available on the site, monitoring and measuring the audience and performance of the site, and displaying advertising, possibly targeted (excluding social media and social media features)

Purpose of processing: in the context of your use of the site and more generally Elite’s digital media (excluding social media and social media features), Elite processes personal data about you, in particular for the purpose of tracking browsing, including carrying out and preparing studies, analyses, reports and statistics, managing and monitoring the proper functioning and in particular the security of the site, improving the user experience, making certain services or features available on the site, and monitoring and measuring the audience and performance of the site. Personal data about you may also be collected and processed in order to display to you, on the site or on third-party websites, advertising that may be targeted (or behavioral or programmatic advertising) based on your profile, your browsing, your location (i.e. geolocated advertising) and your interactions with the websites you visit. This personal data is collected by means of cookies or other similar technologies.
Data processed: session, connection and internet browsing data, including in particular information about your browser or device and their configuration (e.g. device fingerprinting), unique device identifier, display resolution, operating system, IP address, web browser, device type, etc.), history and more generally traffic and browsing information on the site, information relating to the traceability of actions on and interactions with the site, and on the number of visitors, where users come from and the pages visited, “identifier” type information linked to your device, hardware or operating system, “scoring” type information (e.g. bot score intended to ensure that the user is not a robot), information relating to your browsing and usage preferences on the site or even on third-party websites, location data (IP address and geographical area, for example), information relating to the network, your language, or non-nominative personal data (age, gender, areas of interest, etc.) (i.e. specific to the internet user’s identifier).
Controller: Elite.
Legal basis for processing: where the processing of your data either has the sole purpose of enabling or facilitating communication by electronic means, or is strictly necessary for the provision of an online communication service at your express request, i.e. in general if this processing is strictly necessary to enable you to browse the site and use the features offered, it is based on Elite’s legitimate interest in facilitating your browsing on the site. In other cases, such processing is subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, which means that you have the option of not consenting or, if you do consent, of subsequently withdrawing your consent at any time, without having to give any reason or explanation. The use of device fingerprinting techniques is, in any event, subject to your prior consent.
Maximum lifespan of cookies and retention period of personal data collected by this means: kept in the active database for the lifespan of the cookies and other similar trackers by which the personal data is collected, up to a maximum of 13 months, the data collected by this means being kept for a maximum of 25 months.
To find out more about the cookies, trackers and other similar technologies used by Elite and its partners on the site, how to configure them and their lifespan, please refer to Elite’s “cookie policy”.

4.11 Use of cookies or other similar technologies for the purpose of tracking and measuring browsing, traffic and performance of the site (in connection with social media features) and of Elite’s social media pages, including carrying out and preparing tests, studies, analyses, reports and statistics, or assessing and analyzing how you use and interact with the site (in connection with social media features) and those social media pages, making available and monitoring interactive features with social media, adapting the site and Elite’s social media pages in order to improve their performance and the user experience, and displaying advertising, possibly targeted (social media and social media features)

Purpose of processing: for the purpose of making available interactive features between the site and social media, and of monitoring, understanding and studying the use of the site (in connection with social media features) and of Elite’s social media pages and the interactions between the site and social media, Elite may offer you, on the site, links or “buttons” to its social media pages, integrate / link social media features to the site or link the site to such features, configure those social media pages as administrator, or offer you the use on those networks of tools created / offered by those social networks. In this case, Elite processes personal data about you, in particular for the purpose of tracking and measuring browsing, traffic and performance of the site (in connection with social media features) and of Elite’s social media pages, including carrying out and preparing tests, studies (for example positioning studies), analyses, reports and statistics, or assessing and analyzing how you use and interact with the site (in connection with social media features) and those social media pages, in order to make available to you and monitor the interactive features offered on social media (in particular “buttons” giving access to social media pages), but also to adapt the site and/or Elite’s social media pages in order to improve the performance of the site and those pages, as well as your user experience. Personal data about you may also be collected and processed in order to display to you, on the site, on third-party websites or on social media, advertising that may be targeted (or behavioral or programmatic advertising) based on your profile, your browsing, your location (i.e. geolocated advertising) and your interactions with social media, but also with the site or with the other websites you visit. This personal data is collected by means of cookies or other similar technologies.

Please note: the use of these cookies may allow the social networks concerned to track users’ browsing on the site, whether or not they are otherwise users of these third-party social networks (i.e. whether or not they have created an account on these social networks).

Controller: where Elite’s configuration of a social media tool has an impact on the nature of the personal data processed or on the characteristics of that processing, and more specifically where Elite can be considered to contribute to jointly determining the purposes and means of the processing of personal data, Elite may be a joint controller of your personal data with the social network concerned. In this case, the social network, which primarily determines the purpose and means of the processing, as well as the nature and terms of the placing of cookies, bears primary responsibility for the processing, and you are advised to consult the privacy policies and cookie policies of these third parties for detailed information on their practices for collecting and processing your personal data. The social networks concerned are Facebook, Instagram, YouTube, X (formerly Twitter), TikTok and LinkedIn (see below).
Data processed: session, connection and internet browsing data, including in particular information about your browser or device and their configuration (e.g. device fingerprinting, unique device identifier, display resolution, operating system, IP address, web browser, device type, etc.), history and more generally traffic and browsing information on the site and our social media pages, information relating to the traceability of actions on and interactions with the site or Elite’s social media pages, or between the site and social media, “identifier” type information linked to your device, hardware, social media or operating system, “scoring” type information (e.g. bot score intended to ensure that the user is not a robot), information relating to your browsing and usage preferences on the site and Elite’s social media pages, or even on third-party websites, location data (IP address and geographical area, for example), information relating to the network, your language, or non-nominative personal data (age, gender, areas of interest, demographic data, family / marital status, professional activity / status, etc.) (i.e. specific to the internet user’s identifier).
Legal basis for processing: such processing is subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, which means that you have the option of not consenting or, if you do consent, of subsequently withdrawing your consent at any time, without having to give any reason or explanation.
Maximum lifespan of cookies and retention period of personal data collected by this means: kept in the active database for the lifespan of the cookies and other similar trackers by which the personal data is collected, up to a maximum of 13 months, the data collected by this means being kept for a maximum of 25 months. With regard to the retention of personal data by LinkedIn, Instagram, X (formerly Twitter), TikTok, YouTube and Facebook, see their Privacy Policy and Cookie Policy (see below).
To find out more about the cookies, trackers and other similar technologies used by Elite and its partners on the site, how to configure them and their lifespan, please refer to Elite’s “cookie policy”.
To find out more about the cookies, trackers and other similar technologies linked to social media:
- Facebook and Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland. For more information on how Meta Platforms Ireland Limited processes your personal data, please refer to the Meta Platforms Ireland Limited Data Policy, as well as the cookie policies of Facebook and Instagram;
- YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For more information on how Google processes your personal data, please refer to Google’s Privacy Policy and to the information on Google’s use of cookies;
- X (formerly Twitter): Twitter International Unlimited Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland. For more information on how Twitter processes your personal data, please refer to Twitter’s Privacy Policy and Cookie Policy;
- TikTok: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, 6th Floor, One London Wall, London, EC2Y 5EB, United Kingdom. For more information on how the aforementioned TikTok entities process your personal data, please refer to TikTok’s Privacy Policy and the TikTok Websites Cookie Policy;
- LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For more information on how LinkedIn processes your personal data, please refer to LinkedIn’s Privacy Policy and Cookie Policy.

4.12 Management of applications and the recruitment process

Purpose of processing: Elite may process your personal data for the purpose of managing and following up applications, whether in response to job or internship offers or sent on a speculative basis, and operations relating to Elite’s recruitment process, including in particular monitoring and actively searching for professional profiles matching the positions to be filled, receiving and reviewing applications, assessing and selecting applications and professional profiles, building a candidate database (or CV database), using recruitment assistance methods and techniques (in particular psychometric tests or work simulations, whose relevance to the position and terms are communicated to you in advance in accordance with Articles L. 1221-6 and L. 1221-8 of the French Labour Code), inviting candidates and conducting recruitment interviews, and the resulting decision (rejection of the application or recruitment of the candidate).
Controller: Elite.
Data processed: identity (title, first name, last name), contact details (email address, telephone number, postal address, etc.), professional data, information relating to your education (studies, degrees, etc.), your experience and career path, your professional skills / references and your current job, and any information contained in your CV (in particular your interests where applicable), and more generally in your application (in particular cover letter, portfolio of creations / content where applicable, etc.).
Legal basis for processing: such processing is necessary for the performance of pre-contractual measures taken at your request and, with regard to the active search for profiles, for the pursuit of Elite’s legitimate interests in recruiting new employees. However, keeping your data, once the position has been filled, in Elite’s candidate database (or CV database) in order to offer you other positions that may interest you at a later date is subject to your prior consent.
Data retention period: your personal data is kept for the time necessary to process your application and may, subject to obtaining your prior consent, be kept for up to two years from the last contact, for example to allow Elite to contact you again during this period if a position matching your profile becomes available. At the end of this period, your personal data is kept in archived form for 5 years for evidentiary purposes (limitation period for discrimination claims provided for in Article L. 1134-5 of the French Labour Code).

4.13 Management of requests from data subjects to exercise their rights

Purpose of processing: in order to enable Elite and, where applicable, its clients, each for their own part, to comply with their various legal and regulatory obligations regarding personal data protection (e.g. responding to requests from data subjects to exercise their rights, taking account of the resulting consequences, in particular managing objections to direct marketing, etc.), Elite and, where applicable, its clients, each for their own part, may process personal data about you in connection with this purpose.
Controllers: Elite, possibly jointly with one of its clients.
Data processed: identity (title, first name, last name), contact details (email address, telephone number, postal address, etc. and more generally all data collected / processed concerning the requester), nature and content of the request, the exchanges and the response, additional information or a copy of an identity document, but only where the situation requires it (i.e. in the event of reasonable doubts as to the identity of the requester).
Legal basis for processing: such processing is, as a matter of principle, necessary for compliance with the aforementioned legal and regulatory obligations incumbent on Elite and its clients where applicable as (possibly joint) controllers.
Data retention period: kept in the active database until the controller(s) respond(s) to the request*, then kept in archived form for a maximum of 6 years from the time the controller(s) respond(s) to the request (depending on the type of request), it being specified, however, that where a copy of an identity document is collected in this context, it is:
- deleted immediately where you have provided it but the request does not require such an identity document;
- deleted as soon as the identity of the requester has been verified where the situation requires such verification, or kept in archived form for 6 years for evidentiary purposes in exceptional cases where the controller(s) identify(ies) a high risk of litigation.
If you object to receiving direct marketing, your identity and/or contact details may be kept by the controller(s) in the active database for 3 years in order to take account of your request (i.e. maintaining a direct marketing opt-out list).

4.14 Management and follow-up of pre-litigation and litigation

Purpose of processing: such processing of personal data about you is carried out by Elite for the purpose of managing and following up pre-litigation and litigation (in particular commercial disputes / disputes with its clients, with its partners / service providers / suppliers, with its contacts in the broad sense, etc.), including in particular the preparation, conduct and follow-up of litigation and the enforcement of decisions rendered, as well as the management and follow-up of actions aimed at establishing, exercising or defending legal claims (including, where applicable, the enforcement of the decision rendered). However, in the case of litigation and pre-litigation relating to processing carried out jointly by Elite and one of its clients, they may jointly process data for the purpose of managing and following up such litigation and pre-litigation.
Controllers: Elite, possibly jointly with one of its clients.
Data processed: identity (title, first name, last name), civil status, economic and financial information, history / information relating to exchanges and relationships with Elite and/or one of its clients, and more generally any information where necessary in view of the subject matter of the dispute, disputed facts giving rise to the proceedings, information / documents / evidence gathered with a view to establishing or refuting facts that may be alleged, characteristics and details of the pre-litigation / litigation / proceedings, decision, information necessary for the enforcement of the decision, etc., including, where applicable, data relating to (in particular criminal) convictions, offenses or security measures, or so-called “special category” data as defined above.
Legal basis for processing: such processing of your personal data is based on the legitimate interests pursued by Elite and/or the relevant Elite client in preserving / asserting their interests and rights in court, in particular in connection with relationships with the data subjects, etc. In addition, in the context of this processing, so-called “special category” personal data may be processed for the aforementioned purposes if strictly necessary for those purposes and for the establishment, exercise or defense of legal claims. Likewise, data relating to offenses, convictions or security measures may be processed in order to enable Elite and/or the relevant Elite client to prepare and, where applicable, bring and follow up legal action as victim(s), defendant(s), or on behalf of a victim or a defendant, and to enforce the decision rendered.
Data retention period: as stated above, the data processed in connection with the various purposes presented above is kept in archived form for the statutory limitation periods, in particular for evidentiary purposes in the event of litigation. In the event of pre-litigation initiated before the end of the above periods and requiring the retention of personal data, in particular for the establishment, exercise or defense of the rights of Elite and/or the relevant Elite client, such data will be kept until the dispute is settled amicably (including its enforcement where applicable) or, failing that, will be deleted once the corresponding legal action becomes time-barred. In the event of litigation / proceedings, in particular judicial proceedings, initiated before the end of the above periods and requiring the retention of personal data, in particular for the establishment, exercise or defense of the rights of Elite and/or the relevant Elite client, such data will be kept for the duration of those proceedings and until ordinary and extraordinary means of appeal against the decision rendered are no longer available. Decisions rendered may be kept by Elite and/or the relevant Elite client until the decision has been fully enforced, or even as permanent archives.

N.B.: with regard to all the active retention periods referred to above in section 4, you are informed that these are the periods applied “as a matter of principle” by the controller(s), unless you exercise your right to erasure, your right to object or your right to withdraw your consent, in the situations and in accordance with the details set out in section 6 below. In that case, once such rights have been exercised, your data will only be kept in archived form for the archiving periods provided for each of the purposes described in this section 4, under the conditions set out in 4.14. These periods may be adjusted, in accordance with applicable regulations, depending on the nature of the data, the purposes pursued and Elite’s legal or litigation-related obligations.

5. Who are the recipients of your personal data? How do we share your data?

5.1 As a matter of principle, only authorized persons within Elite may access your personal data where such access is necessary for the performance of their duties and/or assignments, namely in particular authorized Elite staff (including, in the broad sense, employees, interns, temporary staff, etc.), in particular those in charge of marketing, communication, sales management, recruitment and human resources, client and prospect relations, administration, finance and legal matters, development, IT, projects, etc.

5.2 Recipients outside Elite may also, where applicable, receive your personal data, namely:

Elite’s clients (i.e. advertisers), for certain personal data and in certain situations;
students and former students listed on the site, solely for the data necessary to handle the contact requests you send them;
the providers of the artificial intelligence tools integrated into the site;
the departments or entities responsible for auditing Elite and/or Elite’s clients where applicable (statutory auditor, departments or entities responsible for internal or external audit procedures, bodies authorized to carry out inspections, etc.);
the advisers of Elite and/or Elite’s clients where applicable (legal, financial, accounting, etc.);
the partners of Elite and/or Elite’s clients where applicable, including in particular their current or potential service providers and suppliers;
social media publishers, third-party website publishers or the publishers of cookies used on the site, or third-party companies involved, for example, in carrying out direct marketing or communication operations, etc., in managing our marketing, or in the operation of the site in the broad sense (e.g. provision and proper functioning of the features offered, performance, security, etc.). In this respect, it is also noted for the record that if you post content disclosing your personal data on the internet, and in particular on the site or Elite’s social media pages, this content may of course be accessible to any internet user. Likewise, if you have consented to our use of your personal data for internal and/or external communication purposes, it may be accessible to / viewed by the audiences for whom these communications are intended, depending on the uses to which you have consented;
technical or other service providers involved in activities or assignments for which access to personal data is necessary and/or justified. This category of recipients may also include any publisher of an application, software program or tool used in the course of our activities, or any IT or maintenance service provider for the applications, software programs and/or tools used by Elite and/or Elite’s clients where applicable and in which your personal data may be processed;
social security and tax bodies authorized to receive personal data in certain situations;
bodies, court officers and public officials, in particular in the context of their debt collection duties;
where applicable, the body responsible for managing the telephone marketing opt-out list;
court officers, public officials and, where applicable, the competent administrative or judicial courts or authorities, to enable the sale or transfer of all or part of the activities or assets of Elite and/or Elite’s clients where applicable, or in the context of the management and follow-up of pre-litigation and/or litigation;
the opposing party(ies) and their advisers where applicable in the context of pre-litigation and/or litigation;
the insurers of Elite and/or Elite’s clients where applicable.

5.3 The controller(s) may also be required to disclose your personal data in response to legitimate requests from public or authorized authorities, on the basis of legal or regulatory provisions applicable to them. Your personal data may therefore be disclosed to any authority entitled to receive it, in particular in the event of a requisition from judicial, police or administrative authorities.

5.4 It is specified that the recipients referred to above do not necessarily receive all of your personal data, depending on the purpose requiring such disclosure.

6. What are your rights and how can you exercise them?

6.1 Subject to the conditions, terms and limits defined by the legal and regulatory provisions on personal data protection, you have the following rights with regard to your data:

Right of access: you can obtain confirmation as to whether or not personal data concerning you is being processed by Elite and/or Elite’s clients where applicable and, where that is the case, access to that personal data, as well as certain information relating to the processing of your personal data and the characteristics of such processing;
Right to rectification: you can request the correction of personal data that you consider incomplete or inaccurate;
Right to erasure: you can, in certain cases provided for by the applicable provisions, request the erasure of your personal data (except, for example, where it is necessary for the performance of your contractual relationship with Elite and/or a Elite client where applicable, or where it is necessary for Elite and/or a Elite client where applicable to comply with their legal or regulatory obligations or to establish or exercise their rights);
Right to restriction of processing: you can request the restriction of the processing of your personal data, i.e. request in certain cases that your personal data be marked in order to restrict its future processing;
Right to data portability: you have the right, in certain cases and under certain conditions provided for by the applicable provisions, to request to receive the personal data concerning you that you have provided to us or, where technically feasible, to have it transmitted to a third party, in a machine-readable format (it being specified that this right to data portability only applies to processing based on the consent of the data subjects or on the performance of a contractual relationship, and provided that the processing is carried out by automated means);
Right to withdraw your consent: you can withdraw your consent where the processing is based on your consent, without the withdrawal of such consent affecting the lawfulness of processing based on consent before its withdrawal;
Right to give instructions regarding the retention, erasure or disclosure of your personal data after your death. In this respect, in the event of a death brought to the attention of the controller(s), please note that your personal data will be deleted (unless it needs to be kept for a specific period for reasons relating to our legal and regulatory obligations and/or the statutory limitation and/or mandatory retention periods referred to above in section 4 in the details of the characteristics of the processing), after being disclosed, where applicable, to a third party you may have designated.
Right to object: you have, in certain cases and under certain conditions provided for by the applicable provisions, a right to object that allows you to object to the processing of your personal data on grounds relating to your particular situation, it being specified that with regard to direct marketing operations, including any profiling related to such direct marketing, you have an absolute right to object, which may be exercised at any time, without having to give any reason or justification.
Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Article 22 of the GDPR). In this respect, the results of the orientation tests, the admission chance estimation and the answers of the orientation assistant are provided for guidance only and do not give rise to any decision of this nature.

6.2 With regard to the processing of your personal data carried out by Elite as controller (whether or not jointly with its clients), these rights may be exercised with Elite (i) by email at the following address: contact@thotismedia.com or (ii) by post at the following address: Elite (Thotis), 14K – PARC TECHNOLOGIQUE DE MONTMAGNY, 26 RUE DES SABLONS, 95360 MONTMAGNY (France).

Upon receipt of such a request, a response will be provided as soon as possible and in any event within a maximum of one month from receipt of the request. If necessary, this period may be extended by two months, taking into account the complexity and number of requests received, in which case the requester will be informed.

In the event of reasonable doubt as to the identity of the data subject making such a request to exercise the aforementioned rights, they may be asked to provide additional information necessary to confirm their identity and, for this purpose, where the situation requires it, they may be asked for a photocopy of a signed identity document. In such a case, the aforementioned response periods will be suspended pending receipt of the additional information needed to identify the data subject.

The request may be made by the data subject or by a person specifically authorized for this purpose by the data subject, provided that the authorized person proves their identity and the identity of the principal, their authorization and the duration and precise purpose of that authorization. The authorization must also specify whether the authorized person may receive the response.

Elite has appointed a Data Protection Officer who can be contacted at the following email address: contact@thotismedia.com.

6.3 In addition, where your personal data is processed by another entity acting as controller, either jointly with Elite or on its own behalf, you should contact the entity concerned directly to exercise your rights with regard to such processing.

For example, with regard to the processing of personal data carried out by a Elite client as controller, on its own behalf and not jointly with Elite, you should contact the client concerned directly to exercise your rights with regard to such processing.

6.4 Furthermore, and for the record, Elite may in certain cases be considered a joint controller of your personal data with the social networks on which Elite has dedicated pages or with which Elite offers you interactions (see details of the purposes in section 4 above). Depending on the social network concerned, the joint controller may be:

Facebook and Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland. For more information on how Meta Platforms Ireland Limited processes your personal data, please refer to the Meta Platforms Ireland Limited Data Policy, as well as the cookie policies of Facebook and Instagram where applicable in order to configure the cookies used on the pages of these social networks;
YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For more information on how Google processes your personal data, please refer to Google’s Privacy Policy and to the information on Google’s use of cookies;
X (formerly Twitter): Twitter International Unlimited Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland. For more information on how Twitter processes your personal data, please refer to Twitter’s Privacy Policy and Cookie Policy where applicable in order to configure the cookies used on the pages of this social network;
TikTok: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, 6th Floor, One London Wall, London, EC2Y 5EB, United Kingdom. For more information on how the aforementioned TikTok entities process your personal data as joint controllers, please refer to TikTok’s Privacy Policy and the TikTok Websites Cookie Policy where applicable in order to configure the cookies used on the pages of this social network;
LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For more information on how LinkedIn processes your personal data, please refer to LinkedIn’s Privacy Policy and Cookie Policy where applicable in order to configure the cookies used on the pages of this social network.

In these cases, in order to exercise the aforementioned rights, you may also check your account settings on the above social networks and/or contact:

for Facebook and Instagram: the Data Protection Officer of Meta Platforms Ireland Limited by email, in particular using the dedicated contact form;
for YouTube: the Data Protection Officer of Google Ireland Limited by email, in particular using the dedicated contact form;
for X (formerly Twitter): X’s Data Protection Officer by email, in particular using the dedicated contact form;
for TikTok: TikTok’s Data Protection Officer by email, in particular using the dedicated contact form;
for LinkedIn: LinkedIn’s Data Protection Officer by email, in particular using the dedicated contact form.

6.5 Finally, you have in any event the right to lodge a complaint with the competent Supervisory Authority (in France, the Commission Nationale de l’Informatique et des Libertés, or “Cnil”: 3 place de Fontenoy, TSA 80715, 75334 Paris cedex 07; tel.: 01 53 73 22 22) if you consider that the processing of your personal data is not carried out in accordance with the legal and regulatory provisions on personal data protection.

To understand your rights, you can also refer to the explanations provided by the Cnil here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles.

6.6 You are also informed that, in accordance with Article L. 223-1 of the French Consumer Code, as amended by Law No. 2025-594 of June 30, 2025, if you are a consumer, you may only be the subject of telephone marketing if you have given your prior consent. This consent may be withdrawn at any time.

7. How is your personal data secured?

7.1 Elite implements appropriate organizational and technical security measures, taking into account in particular the categories of personal data processed, the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, to protect your personal data against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties, and more generally to preserve the security and confidentiality of that personal data and ensure a level of security appropriate to the risk.

In the event of difficulties, Elite will make its best efforts to contain the risks and will take all appropriate measures in accordance with its legal and regulatory obligations (corrective actions, notification of the breach to the Cnil without undue delay and, where feasible, no later than 72 hours after becoming aware of it and, where applicable, communication to the data subjects, etc.).

7.2 When developing, designing, selecting and using our services offered on the site that rely on the processing of personal data, Elite takes into account the right to data protection by design and by default (“Privacy by design and by default” principles).

7.3 Access to your personal data is limited to our employees or partners, and more generally to the recipients referred to above, who are authorized and need to know it in the performance of their assignments and/or activities.

7.4 Where part or all of a personal data processing operation is subcontracted, Elite contractually requires its processors to provide security guarantees, in particular confidentiality guarantees, regarding the personal data to which they may have access (appropriate technical and organizational measures to protect this data).

8. Is your personal data transferred outside the European Economic Area?

8.1 Your personal data is preferably processed within the European Economic Area (EEA).

8.2 In connection with the aforementioned purposes, some of your personal data may, however, be transferred to third-party entities established in countries outside the EEA (e.g. processors involved in the aforementioned processing, etc.).

Some of these entities are considered to provide an adequate level of personal data protection because they are established in a country whose personal data protection legislation has been recognized as providing an adequate level of protection (see the European Commission’s adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) or because they have committed to complying with a data protection framework called the “Data Privacy Framework” (the list of entities concerned is available here: https://www.dataprivacyframework.gov/s/participant-search, it being specified that this data protection framework only concerns US entities).

In addition, if the country of the entity concerned or the entity itself does not offer an adequate level of protection of that data, we ensure that appropriate security and confidentiality measures are taken to guarantee that your data remains protected.

Accordingly, in these cases, you are informed that transfers of your personal data to other entities outside the EEA are governed by the conclusion, with the recipients of that data, of standard contractual clauses adopted by the European Commission, allowing us to ensure that appropriate safeguards are in place for the protection of that data, supplemented where applicable by additional measures to protect your personal data.

Exceptionally, in the absence of an adequacy decision and appropriate safeguards, an occasional transfer may also take place on the basis of Article 49 of the GDPR if the transfer is necessary for the performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures taken at the data subject’s request, if the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person, or if the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for them due to the absence of an adequacy decision and appropriate safeguards.

A copy of the reference documents referred to in this section may be obtained (free of any commercial information considered sensitive or confidential or covered by trade secrecy) from the contact mentioned in the section above “What are your rights and how can you exercise them?”.

9. How are the site and the social media pages linked to third-party sites?

9.1 You are informed that Elite’s digital media (in particular the site and Elite’s social media pages) may provide or contain links to third-party sites, including the sites of Elite’s clients (i.e. advertisers) or social networks. Elite has no control over the activity of these sites or over the policies they apply regarding the protection of your personal data and your rights. You are advised to review the safeguards offered by these sites before interacting with them. In this respect, your attention is drawn to the fact that the personal data protection policy of these sites may differ from this data protection policy of the site, and that it is your responsibility to read it.

9.2 If you post content disclosing your personal data on the internet, and in particular on social media, including Elite’s social media pages, this content may be accessible to any internet user, and collected or used by third parties, in particular on websites or social networks, for purposes and in ways for which Elite is not responsible. This processing is the responsibility of the publishers of those websites or social networks, subject to the cases of joint controllership referred to in section 6.4.

10. Can this data protection policy be amended?

10.1 This data protection policy may be amended at any time, with amendments taking effect on the date of publication of the corresponding update. The date of the last update appears at the top of this policy.

10.2 In the event of an amendment, the new data protection policy will be published on the site in the dedicated section. In addition, all personal data collection forms that may appear on the site provide a link to this policy.

10.3 We therefore invite you to consult it regularly.

11. What is the cookie management policy of the site?

11.1 Cookies and other trackers or similar technologies may be installed and/or read in your browser or device when you visit the site.

11.2 You can access Elite’s “cookie policy” via the link in the footer of every page of the site.

12. Additional information about the Elite orientation platform

In the context of the use of the orientation platform, Elite may process certain personal data specific to its operation. This processing supplements the processing described for the use of the website elitehighered.com and the processing referred to above, and meets the same confidentiality and security requirements.

The categories of data that may be collected via the orientation platform include in particular:

Identification data (last name, first name, email address, user ID, etc.);
Authentication data (encrypted password);
Data relating to academic background and orientation plans (level of education, specializations, academic results, programs and choices under consideration) and answers to orientation tests;
Technical data relating to the device used (model, operating system, version, unique identifier, connection data and usage logs);
Location data, where the user has enabled the geolocation function on their device (search for nearby institutions, personalization of the service);
Data exchanged with automated assistance features integrating artificial intelligence tools (“bots”).

The platform may, with the user’s prior authorization, access their geographical location in order to provide certain personalized services (for example: display of content adapted to the location, optimization of the user journey, etc.). This location data:

is only collected and processed with the user’s explicit consent;
is used only during the usage session and is not kept beyond it;
can be disabled at any time in the browser or device settings, where applicable, without affecting the other features.

With regard to the use of artificial intelligence tools and bots, the site and the platform include features based on artificial intelligence (“AI”) technologies that provide automated assistance, answer users’ questions or facilitate access to certain information.

In this context, Elite may process, via these tools, the data that the user voluntarily enters or communicates (free text, messages, queries, etc.). This processing:

is intended to generate automated responses and improve the quality of the service offered to the user;
may only be used for commercial purposes or kept beyond the period indicated below with the user’s prior, separate consent, which may be withdrawn at any time (obtained jointly from the holder of parental authority for users under fifteen);
does not relieve the user of the need for vigilance: insofar as the user enters information in the text or chat fields themselves, it is their responsibility not to share sensitive data or data that is not necessary to handle their request.

The characteristics of this processing are as follows:

Orientation tests and admission chance estimation: processing necessary for the provision of the service requested by the user (Article 6.1.b of the GDPR); results provided for guidance only, with no decision being made regarding the user on that basis; data kept for the lifetime of the account;
User account management: processing necessary for the performance of the terms of use of the orientation platform (Article 6.1.b of the GDPR); data kept for as long as the account is used, then deleted after a period of two years of inactivity or at the user’s request, it being possible to delete the account directly from the orientation platform;
Geolocation: processing based on the user’s consent (Article 6.1.a of the GDPR); data used only during the usage session and not kept beyond it;
AI-powered automated assistance: processing necessary for the provision of the service requested by the user (Article 6.1.b of the GDPR), with the improvement of the quality of the service based on Elite’s legitimate interest (Article 6.1.f of the GDPR); conversations kept for 30 days from the last exchange, unless separate consent is given to longer retention; tools provided by Chatbase Inc., established in the United States, with any transfers outside the EEA governed under the conditions set out in section 8; Elite ensuring, in its contractual relationship with the provider, that this data is not used to train its models;
Transparency: the user is clearly informed, in the interface, that they are interacting with an artificial intelligence system.