SYNOPSIS DATA PROCESSING (2022/01)
Categories of Personal Data Processed by hihaho:
– 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)
Processing operations by hihaho in the context of services to the Controller:
– 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 t to a4 | Billing* |
| Developers Team | b3 to b6 | a1 t to a8 | To fix malfunction; data breach detection |
| Content & Training Team | b3 and b4 | a6 t to a7 | On request Controller |
| Helpdesk | b1 to b6 | a1 t to a8 | On request Controller |
| System & Security | b3 | a1 t to a8 | To fix malfunction; data breach detection |
| Hostingprovider (Subprocessor) | b1 to b6 | a1 t to a8 | Automated data processing |
* Processing only relates to the Personal Data of users (authors).
The Processor’s policy regarding the retention periods of Personal Data is bound by the instruction to that effect by the Controller.
