Privacy and Data Protection Policy (GDPR)

Last updated: 02/10/2025

1) Who are we? (Data Controller)

The platform EducTime is published by MON CERVEAU IT, SASU with share capital of 1 000,00 €, registered with the Avignon Trade and Companies Register under 833 197 288 R.C.S. Avignon (SIREN 833 197 288), VAT FR40833197288, with its registered office at 230 CR 37 NORD, BAS ABRIAN NORD, 84100 ORANGE, France.
Contact: [email protected]. Legal representative: Yohan LEONI. EducTime is a registered trademark.

Unless otherwise stated, MON CERVEAU IT acts as the Data Controller for data processed via the platform (accounts, payments via provider, security, support, etc.).
Teachers act separately as Data Controllers for their own students/clients (teaching, after-sales, marketing). They must provide their own privacy policy.

2) What data do we collect?

3) Purposes and legal bases (Art. 6 GDPR)

4) Who receives your data?

Data is never sold.

5) Data transfers outside the EU

Some providers may operate outside the EU. In such cases, we rely on the European Commission’s Standard Contractual Clauses (SCCs) or another recognized equivalent mechanism, and limit transfers to what is strictly necessary.

6) Data retention periods

We retain data for the strictly necessary period. For example:

| Category | Retention | |---|---| | User account (student/teacher) | Duration of use, then 3 years after inactivity | | Accounting/financial records | 10 years (French Commercial Code L123-22) | | Messages/reviews/tickets | Duration of relationship + up to 3 years after closure | | Technical/security logs | From a few days up to 12 months, depending on criticality | | Cookies | See § 9 |

Training access: unless otherwise stated in the offer, access is granted without time limit as long as the service and your account remain active. This does not imply unlimited retention of all your personal data.

7) Your rights (Art. 12 to 22 GDPR)

You have the rights of access, rectification, erasure (where applicable), restriction, objection (notably to marketing and recommendations based on legitimate interest), and data portability for data you have provided.
You may withdraw your consent at any time for processing based on consent (e.g., newsletters, non-essential cookies), without retroactive effect.
To exercise your rights: [email protected] (proof of identity may be requested).
You can also contact the CNIL (www.cnil.fr).

8) Security

We implement appropriate technical and organizational measures: encryption in transit, access controls, logging of sensitive actions, backups, environment separation, internal policies and awareness.
As no measure offers absolute security, we apply the principles of minimization and defense in depth.

9) Cookies & trackers

You can manage your preferences anytime via the banner or your account settings, and configure your browser (block, delete). Refusal of non-essential cookies does not affect basic access.

10) Marketplace specifics (Teachers’ role)

For their own clients, Teachers are separate Data Controllers (service delivery, pedagogical follow-up, accounting obligations, marketing).
They commit to complying with the GDPR (legal basis, information, security, retention, rights) and must provide a compliant notice to their students/clients.
In case of a complaint relating to processing by a Teacher, we may redirect the request to the appropriate controller while remaining available at [email protected].

11) Children/minors

The platform is not intended for children under 15 years old without parental consent. If such a case is detected, the account may be suspended until proof is provided.

12) LCEN: reporting content

EducTime acts as a hosting provider under the French LCEN: any manifestly unlawful content can be reported to [email protected]. After review, it will be promptly removed in accordance with the law.

13) Changes

We may update this Policy for legal, technical or operational reasons. In case of a substantial change, we will notify you appropriately (in-app notice, email, or banner). The update date is shown at the top.

14) Contact us

For any questions or to exercise your rights: MON CERVEAU IT – EducTime, [email protected].


Annex — Typical sub-processors (examples)

Cloud hosting; payment provider (e.g., Stripe); transactional email; video conferencing; support/ticketing; analytics.
Sub-processors are contractually bound (Art. 28 GDPR): processing under instruction, confidentiality, security, assistance with rights, transfer safeguards.