隐私政策 - 网站和 Cookie

The Acolad Group and its affiliate companies (hereinafter “Acolad”) may collect and process information on persons visiting their website https://acolad.com), through applications, software, online services or when providing services such as support, handling enquiries about its products and services and through any other means.  

Acolad in its capacity of “data controller”, guarantees that it processes Personal data in compliance with all legal provisions related to the protection of Personal data and, in particular, with the General Data Protection Regulation (UE) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”). 

In order to inform you of the purposes of the processing of Personal data and the means implemented by Acolad, in compliance with the applicable laws and regulation, Acolad has established this Privacy Policy Website & Cookies (hereinafter the “Privacy Policy”). This Privacy Policy supplements any information you have already been given on this subject. Furthermore, Acolad may provide you with additional information to address specific circumstances (not covered by this Privacy Policy) in which your Personal data may be collected and processed.  

The word “you” shall mean anyone, wherever located, who falls within the scope of this Privacy Policy. “Personal data” shall mean any information relating to an identified or identifiable natural person. “Us/we” shall mean Acolad.  

 1. How do we collect your Personal data ? 

Your Personal data can be collected during the navigation on our website through cookies (see section bellow “Use of cookies”).  

Acolad may also collect Personal data that you provide us with through our website when:   

You submit a request for quotation,

You register to our newsletter,  
You contact us through our contact form to request information (such as on our products and services),   
You register to our online seminars through the learning store,  
You apply to a become part of our international network of expert vendors (including external translators and interpreters) (hereinafter “Vendors Network”),  
You manage and access your client portal.

 2. Processing of your Personal data  

Acolad processes only necessary data relating to the processing purposes and with respect to the data minimization principle.  

We have established the following table to provide you with an overview on which categories of data we process, for which purpose(s) and according to which legal basis. 

Purpose	Category of data	Legal basis
Manage and answer requests submitted through the “contact form”.	Data on your identity (name, surname), contact data (email address, phone number), information on your company (name of your company) and any other data you may provide.	Legitimate interest of Acolad to provide information on its business, products and services.
Manage requests for quotations.	Data on your identity (name, surname), contact data (email address, phone number) , information on your company and your request (name of your company, main sector of activities, country) and any other data you may provide.	Legitimate interest of Acolad to develop its business relationships.
Manage the subscription to our newsletter.	Email address.	Your consent.
Manage the purchase and registration to online seminars through the learning store.	Data on your identity (name, surname), contact data (email address, postal address, phone number…) and data related to your company (name of the company, tax identification number, payment information…).	Performance of a contract to which you are a party.
Analyse and manage the application you submit to join our Vendors Network.	Data on your identity (title, name, surname, age, nationality…), contact data (email address, telephone number, postal address, link to your professional network profil....) and data related to your professional skills and status (diplomas, information contained in your resume, language competences, professional status/name of your employer...).	Legitimate interest of Acolad to analyse application and develop its Vendors Network.
Manage your client portal and offer you services through the portal.	Data on your identity (name, surname), contact data (IP address, email address, postal address, phone number…), data related to your company (name of the company, payment information…) any data provided that may be necessary to the performance of services.	Legitimate interest of Acolad to provide its services to its clients.

3. Automated decision making  

The Personal data we collect does not lead to an automated decision-making within the meaning of Article 13.2 (f) of the GDPR.  

4. Personal data recipients 

The Personal data collected are for the exclusive use of Acolad and its affiliate companies which may be involved in the provision of the services, may perform data processing on Acolad’s behalf or for data centralisation purposes.   

For technical reasons, Acolad may outsource some services to providers (such as hosting providers, IT solution providers…). Acolad is informing you that the information it collects on its website is only processed by providers authorized by Acolad and that such providers cannot sell your information to third parties.   

Acolad may also be requested to communicate your information to administrative and judicial authorities to comply with its statutory obligations.  

Third parties to whom we transfer your Personal data are responsible for their compliance with the applicable data protection legislation. 

5. Transfer of Personal data outside the EEA 

Wherever possible, your Personal data is processed with the European Union (EU)/European Economic Area (EEA)/United Kingdom. Acolad may, if necessary, transfer your Personal data to a third country or to an international organization located outside these territories.  

In such case, Acolad ensures that it takes all necessary and appropriate measures to comply with the applicable law, by:  

Transferring data to countries and international organizations which are subject to an adequacy decision issued by the European Commission,   
Transferring data to recipients who have signed the Standard Contractual Clauses established by the European Commission.

6. Retention period  

Acolad does not retain your Personal data any longer than necessary for the purpose for which they were collected, unless Acolad is legally obliged to retain your Personal data for a longer period. 

Data processed 

Retention period 

Data collected as part of the subscription to our newsletter.  

3 years from the time of the last contact we had with you, unless you revoke your consent.  

Data collected via the contact form.  

Duration of the processing of the request for information or the time of the exchange. 

Data collected for a request for quotation.  

Duration of the processing of the request for quotation or the time of the exchange.  

If such quotation is accepted, the retention period will be the time necessary for the purpose of providing the related services. 

Data collected to manage the purchase and registration to online seminars through the learning store. 

5 years from the end of the provision of the services.  

Data collected to manage your application to our network of translators. 

2 years for the last contact we had with you, unless you exercise your right to object to the processing of your Personal data.  

Data collected to manage your client portal and offer you services through the portal. 

3 years following the end of the commercial relationship, except in the event of a legal archiving obligation or for evidential purposes or accounting obligations.  

7. Your rights  

Acolad will comply with the rights of the data subjects ensuing from the legislation. Under the GDPR, you have the following rights with regard to your Personal data:   

right of access to your Personal data,

right to rectification or improvement of your Personal data, 
right to be forgotten, 
right to restriction of the processing of your Personal data, 
right to data portability.

When Personal data are processed for communication and direct marketing purposes taking place because of Acolad’s legitimate interest, you have the right to object to the processing without having to justify a legitimate interest. 

In order to exercise the above-mentioned rights, you can submit a request to Acolad’s Data Protection Officer via email at the following address: dpo@acolad.com.   

If your Personal data have been processed on the basis of consent, you have the right to revoke this consent at any time. 

If you see reason to do so, you have the right, at any moment, to submit a complaint to the French data protection authority (CNIL) located at 3, Place de Fontenoy, 75007 Paris. 

8. Appropriate technical and organisational measures 

Acolad implements appropriate technical and organisational measures to ensure the integrity, availability, and security of your Personal data against any loss, destruction, damage, modification, disclosure and against any form of unlawful processing.  

Acolad has established technical measures (such as anti-virus and firewalls, etc.) and organisational measures (such as a login/password system, physical protection means, etc.) to ensure the protection of Personal data. Computer workstations are systematically locked and only accessible via a login and password system.   

We require our staff and all third parties working for Acolad to adhere to strict security and information protection standards, including contractual obligations to protect all data and to apply strict data transfer measures.  

9. Use of Cookies  

 Acolad collects Personal data through its website which uses cookies.  

A cookie is a small text file that websites place on your device as you are browsing. Cookies are processed and stored by your web browser. Every time you visit our website using your device, your device sends back data from the cookie file, which enables our website to recognize the device which is connecting to it. They are different types of cookies and they may for instance be used to memorize customer ID with a merchant site, the content of your shopping cart, to trace your navigation for statistical or advertising purposes.  

 1. Information we collect about you  

On each visit to our website or platforms we may automatically collect the following information:   

technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and version, operating system and platform; and   
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, interaction information (such as scrolling, click and mouse-overs), and methods used to browse away from the page.

We do not collect your name, address, telephone number, or email address.  The information we collect is used to build a profile of the user of the device which connects to our website and is used in connection with the use of the website only.  

 2. Types of cookies we use 

Strictly necessary cookies  

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website may not work then.  

Cookie

Description

Duration

cookies-accepted

This technical cookie stores the user’s consent to the use of cookies on the site

Session

cookie-policyDate

This technical cookie stores the date of the user’s consent to the use of cookies on the site

Session

Analytic cookies 

Acolad uses analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our online website and services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.  

Cookie

Description

Duration

gtm_auth

Google Tag Manager (GTM). Authenticate with Google Analytics OAuth2

Session

gtm_debug

Google Tag Manager (GTM). Enables the debug features that show when tag rules fire

Session

gtm-preview

Google Tag Manager (GTM). Used to test and debug the Google Tag Manager

Session

GTM-XSRF-TOKEN

Google Tag Manager (GTM) Container: These cookies collect analytical data about site usage.

Session

_ga

This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customizable by website owners.

2 years

_gat_UA-nnnnnnnn-n

A pattern type cookie set by Google Analytics

Session

_gid

This cookie name is associated with Google Universal Analytics. It appears to store and update a unique value for each page visited.

Session

_hjSessionUser

Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.

365 days

_hjSession

A cookie that holds the current session data. This ensues that subsequent requests within the session window will be attributed to the same Hotjar session.

30 minutes

_hjClosedSurveyInvites

Hotjar cookie that is set once a user interacts with an External Link Survey invitation modal. It is used to ensure that the same invite does not reappear if it has already been shown.

365 days

_hjShownFeedbackMessage

Hotjar cookie that is set when a user minimizes or completes Incoming Feedback. This is done so that the Incoming Feedback will load as minimized immediately if the user navigates to another page where it is set to show.

365 days

_hjSessionTooLarge

Causes Hotjar to stop collecting data if a session becomes too large. This is determined automatically by a signal from the WebSocket server if the session size exceeds the limit.

Session

_hjSessionRejected

If present, this cookie will be set to '1' for the duration of a user's session, if Hotjar rejected the session from connecting to our WebSocket due to server overload. This cookie is only applied in extremely rare situations to prevent severe performance issues.

Session

_hjSessionResumed

A cookie that is set when a session/recording is reconnected to Hotjar servers after a break in connection.

Session

_hstc

It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).

13 months

__hssc

This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.

30 mins

hs_opt_out

This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again.

13 months

_hjid

Hotjar cookie that is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.

365 days

__hssrc

Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser.

Session

hubspotutk

This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.

13 months

_hjRecordingLastActivity

This should be found in Session storage (as opposed to cookies). This gets updated when a user recording starts and when data is sent through the WebSocket (the user performs an action that Hotjar records).

Session

_hjTLDTest

When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.

Session

_hjUserAttributesHash

User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated.

Session

_hjCachedUserAttributes

This cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. Collected attributes will only be saved to Hotjar servers if the user interacts with a Hotjar Feedback tool, but the cookie will be used regardless of whether a Feedback tool is present.

Session

_hjLocalStorageTest

This cookie is used to check if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted almost immediately after it is created.

Under 100ms

_hjIncludedInPageviewSample

This cookie is set to let Hotjar know whether that user is included in the data sampling defined by your site's pageview limit.

30 minutes

_hjIncludedInSessionSample

This cookie is set to let Hotjar know whether that user is included in the data sampling defined by your site's daily session limit.

30 minutes

_hjAbsoluteSessionInProgress

This cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.

30 Minutes

_hjFirstSeen

This is set to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.

Session

_hjViewportId

This stores information about the user viewport such as size and dimensions.

Session

_gcl_au

It's the first party cookie for "Conversion Linker" functionality - it takes information in ad clicks and stores it in a first-party cookie so that conversions can be attributed outside the landing page.

3 months

_hjRecordingEnabled

This is added when a Recording starts and is read when the recording module is initialized to see if the user is already in a recording in a particular session.

Session

g_state

Stores the timestamp for the purpose of honoring the cool off period and dismiss count for Google's one tap prompt feature

180 days

AnalyticsSyncHistory

Used to store information about the time a sync with the lms_analytics cookie took place for users in the Designated Countries

30 days

Functional cookies  

These cookies enable the website to provide enhanced functionality and personalisation, such as videos and live chat. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, some or all of these services may not function properly. 

Cookie

Description

Duration

giosg_chat_id_2299

Giosg – Organization specific visitor identifier

2 years

giosg_gid_2299

Giosg – Personal, secret identifier of the visitor. This cookie is set only for those visitors for whom we cannot store this information to giosg.com domain in an iframe because of blocked third-party cookies.

2 years

giosg_gsessid_2299

Giosg -Identifier of the visitor’s current session

30 mins

gid

Giosg – Generic cookie identifier

2 years

csrftoken

Giosg – Helps prevent Cross-Site Request Forgery (CSRF) attacks.

2 years

Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.

3 months

GPS

Registers a unique ID on mobile devices to enable tracking based on geographical GPS location.

1 day

YSC

Registers a unique ID to keep statistics of what videos from YouTube the user has seen.

Session

yt-remote-cast-installed [x2]