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Privacy policy UP-WARD


This privacy policy sets out how we use and protect the information you provide when using the UP-WARD application. We are committed to protecting your privacy. You can find this privacy policy at any time, in your "profile" section.

Version française

Comprehensive policy

1. Personal data that may be collected

The training platform may collect and process the following data about you.
Direct identification data, some of which is mandatory and some optional (profile data that you decide whether or not to enter).

Mandatory data:

  • Username
  • First name
  • Name
  • Email address
  • Password

Data linked to the application's own use (notes, favorites, comments, etc.). Tracking data on training resources:

Detailed course information:

  • List of courses taken by the user.


  • All grades and statuses on courses for which completion tracking has been activated. All pedagogical activities for which completion tracking is activated are plotted (status seen/unseen) or for scored activities (status started/completed/successful).

Login information:

  • The platform collects the dates of 1er and last access and displays them in clear text to users. It also traces in tables, accessible to managers (if access is authorized by Admin) all user logins (date, time, duration of connection (if they log out).


  • The platform collects all the messages published in the blog, forums, etc.
  • The platform also collects the information entered in training plans, as well as related skills if these have been entered.

2. Use of your personal data

Your data will only be used for the purposes of the training platform:

  • Give you access to all the resources available to you;
  • Enable us to monitor your educational activity and, if necessary, draw up certificates of attendance, certificates, badges, diplomas, etc. linked to this educational activity;
  • Transmit the necessary data to the funding bodies if the training is to be financially supported.

3. Disclosure of your data

We will not disclose any of your data to third parties without your permission, without your consent on a form, or unless otherwise specified in this Privacy Policy. We reserve the right to disclose your personal information to third parties, without obtaining your consent, in the following cases:

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property or the safety of our employees, customers or others. This includes exchanging information with other companies and organizations for fraud protection purposes.
  • We will never sell your data to third parties.

4. Data storage

The data we collect from you may be transferred to and stored in a location outside France, but always within the European Union.

Hosting and maintenance are carried out by a provider, operating in France and subcontracting hosting to Microsoft Azure. Servers are hosted in Europe. By submitting your personal data to us, you agree to this transfer, storage or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We may keep some of the information associated with your account in our archives, in particular for statistical purposes on the platform's educational activity.

We will only retain your personal data for as long as is strictly necessary for the purposes set out in the paragraph "Use of your personal data" or to meet our legal obligations. The retention period for your personal data is 5 years from the date of your last activity. We may retain certain personal data for a longer period, including after the closure of your account, if such action is necessary to fulfill our legal obligations or to maintain security, prevent fraud and abuse and defend or enforce our rights.

5. Your rights

With regard to the use of your personal data, you may exercise your rights by contacting the Data Protection Officer of the Ecole de Management de Normandie by e-mail at this address: dpoffice@em-normandie.fr or by post addressed to : Délégué à la protection des données, Ecole de Management de Normandie 20 quai Frissard 76600 Le Havre.

6. Use of cookies

The platform uses cookies in the following cases:

  • We may collect information about your computer, including your IP address, operating system and browser type, for system administration and proper operation. Under no circumstances will the data collected by cookies be transmitted by Ingenium to a third party.
  • If links to social networks are present on the platform, and in order to make "social sharing" accessible, social network cookies are present: social network cookies vary and depend on the privacy settings specific to each social network. The "Social Sharing" buttons will only deploy cookies if you are connected to said social network at the time of your visit to our website.

Acceptance information is stored and retained in Moodle, accessible to the administrator.

How to disable cookies:

Most modern browsers allow you to control your cookie settings for all the websites you visit. You can completely disable the use of cookies by modifying your browser settings. However, you may limit the functionality displayed on our websites. To find out how to disable cookies on your preferred browser, we recommend you read the dedicated section published on the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

7. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page. By continuing to use the platform, you accept these changes.

8. Contact

Requests and comments regarding this privacy policy are welcome and should be sent to dpoffice@em-normandie.fr

Normandy School of Management privacy policy.

Updated September 2023