SYNOPSIS DATA PROCESSING (2022/01)
Categories of Personal Data Processed by hihaho:
* Processing only relates to the Personal Data of users (authors).
** Without Controller’s request/permission.
The Processor’s policy regarding the retention periods of Personal Data is bound by the instruction to that effect by the Controller.
- a1/ Name, initials and last name (users [= authors] and end users [= viewers])
- a2/ E-mail address (users and end users)
- a3/ Address data (users)
- a4/ Telephone number (optional) (users)
- a5/ IP address (users)
- a6/ Automatically recorded (learning) activities (end users)
- a7/ Automatically recorded (learning) outcomes (end users)
- a8/ Recorded communications (chat, telephone, e-mail) (users)
- a9/ Data entered by end users that may be linked (beyond Processor’s control)
- b1/ Entry into the digital system at registration / registration
- b2/ Storage in the digital system (automatic)
- b3/ Only available for inspection
- b4/ Adjustment, correction
- b5/ Deletion
- b6/ Export and shipment to client. The following table indicates the departments / categories of Processor’s employees directly or indirectly involved in the processing of personal data. An indication is also given of the purpose(s) with which and / or the condition(s) under which specific types of personal data are processed, with reference to the specifications referred to sub a) and b):
| Category of employees | Processing | Data | Purpose / Condition |
| Management | b1 to b6 | a1 to a8 | On request Controller |
| Finance | b3 | a1 to a4 | Billing* |
| Developers Team | b3 to b6 | a1 to a8 | To fix malfunction; data breach detection |
| Content & Training Team | b3 and b4 | a6 to a7 | On request Controller |
| Helpdesk | b1 to b6 | a1 to a8 | On request Controller |
| System & Security | b3 | a1 to a8 | To fix malfunction; data breach detection |
| System & Security | b3 and b5 | a1 to a9 | In case of suspected illegal or criminal activity** |
| Hostingprovider (Subprocessor) | b1 to b6 | a1 to a8 | Automated data processing |
* Processing only relates to the Personal Data of users (authors).
** Without Controller’s request/permission.
The Processor’s policy regarding the retention periods of Personal Data is bound by the instruction to that effect by the Controller.
