WISE – Legal Information and Privacy Policy

Last update: November 15, 2023

1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we explain how we collect, use and protect your personal data.

We also explain what rights you have with regard to your personal data and how you can exercise those rights.

2. Who we are

WISE is an international, multi-sectoral platform for creative thinking, debate and purposeful action. WISE has established itself as a global reference in new approaches to education. Through both the biennial Summit and a range of ongoing programs WISE is promoting innovation and building the future of education through collaboration.

The thrust for constant innovation has long prevailed in sectors such as technology and healthcare, but education has generally lacked this approach in both policymaking and in the classroom. Moreover, education is key to addressing the toughest challenges facing communities around the world today – poverty, conflict, inequality, unemployment, environmental sustainability and future challenges. But there is a widening gap between the education systems currently in place and those required to meet the needs of future generations.

WISE is a response to the necessity of revitalizing education and providing a global platform for the development of new ideas and solutions. Since 2009, WISE has evolved into a thriving global, multi-sectoral community, which continues to generate fruitful dialogue and productive partnerships. The WISE community is a network of education stakeholders – from students to decision-makers – from about 200 countries who share ideas and collaborate to seek creative solutions to solve challenges facing education.

Our registered office address is:

WISE – ThinkBay
Qatar Foundation – Education City
P.O. Box 5825
Doha, Qatar

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at: 
wise-community@wise.org.qa

3. Companies and websites within scope

Auditoire
44 rue Copernic,
75116, Paris
France

Systonic
2 rue Eugène Chevreul,
33600, Pessac
France

DataTherapy
One Pancras Square, Kings Cross,
London N1C 4AG
United Kingdom

Netkin
8 rue de Milan,
75009, Paris

Smartsheet
500 108th Ave NE #200,
Bellevue, WA 98004,
United States

Swapcard
6 rue de Paradis,
75010, Paris
France

The following websites are within the scope for this privacy notice:

WISE website: www.wise-qatar.org
WISE database: www.wise.org.qa
WISE Programs: programs.wise.org.qa
WISE registration website wise-summit2023.org
WISE Speakers registration app.smartsheet.com
WISE Summit webapp events.wise.org.qa

It includes personal data that is collected through our website, by telephone and through any related social media applications.

4. Collection of personal data

We collect personal data from you for one or more of the following purposes:

1. To provide you with information that you have requested or that we think may be relevant to a subject in which you have demonstrated an interest.
2. To initiate and complete commercial transactions with you, or the entity that you represent, for the purchase of services.
3. To enable your participation to any event organised by our organisation, be it online or physical
4. To ensure the security and safe operation of our websites and underlying business infrastructure.
5. To manage any communication between you and us.

The table in section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
• Your login information, browser type and version, time zone setting, browser plugin types and versions.
• Operating system and platform.
• Information about your visit, including the URL (Uniform Resource Locator) clickstream to, through and from our site.

From time to time we may use technologies, such as tracking pixels (also called 1×1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing to your needs, leading to more relevant emails to our subscribers. It also helps us to identify subscribers that are not engaged with our marketing emails, enabling us to remove them from our send lists.

Our cookies policy, which can be viewed from the homepage of each of our websites, describes in detail how we use cookies.

In section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

5. Lawful basis for the processing of personal data

The table below describes the forms of personal data we collect and the lawful basis for processing this data. The organisation of our business architecture, accounting and systems infrastructure and compliance means that all personal data is processed on common, group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties; where this happens, this is also identified below.

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

The purpose test – is there a legitimate interest behind the processing?

Necessity test – is the processing necessary for that purpose?

Balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights or freedoms?

Lawful basis for data processing chart

6. Storage of personal data

WISE website: Systonic is a France-domiciled organisation whose offices are in Pessac, France. All servers are domiciled in France. Learn more in Systonic’s Privacy Policy (French).

WISE database and WISE Programs: DataTherapy is an UK-domiciled organisation whose offices are in London, UK. All servers are domiciled in Ireland.

• Our websites and web applications are hosted in the EU and are accessed only by our UK & EU-based staff.
• Our customer relationship management, marketing and accounting systems are either EU-based or, in cases transfers of personal data outside the European Economic Area (“EEA”) are necessary, data transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”) and may be based on the use of the European Commission’s Standard Contract Clauses for transfers of personal data outside the EEA.
• We use a wide range of CSPs (Cloud service providers) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all these CSPs, the data controller.
• Unless we specifically state otherwise, all the CSPs that we use utilise EU processing facilities.
• Our payment processors and banking arrangements are based in the UK & EU.
• We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are contained in the table in section 5 above.

Learn more in Datatherapy’s Privacy Policy.

WISE registration website: Netkin is a France based organization whose offices are in Paris (all servers are domiciled in France by the company OVH) SAS with a capital of €10,174,560, whose registered office is located in ROUBAIX : 2 rue Kellermann, 59100 Roubaix, France.

Appropriate security measures are implemented to prevent personal data from being accidentally lost, used, altered, disclosed or accessed without authorization. In addition, access to personal data is limited to employees, agents, contractors and other third parties on a need-to-know basis. They will process personal data in accordance with our instructions and are subject to the obligation of confidentiality. Procedures are in place to deal with any suspected breach of personal data. Any relevant regulator will be notified of such a breach where required by law. Learn more in Netkin’s Privacy Policy.

WISE Speakers registration website: Smartsheet is a US based company whose offices are in Bellevue. Smartsheet work with industry-recognized hosting partners. They have multi-site data redundancy, hosting at AWS facilities, and facilities are SOC 1, SOC 2, ISO 27001, and FISMA examined and certified. Monitoring includes biometric scanning protocols, continuous surveillance, and 24×7 production environment management. Smartsheet maintains internal processes and plans in order to address business continuity events and disaster recovery scenarios. These plans are reviewed and tested on an annual basis and are distributed to applicable staff throughout the organization. Data centers are geographically isolated (approx. 600 mi) from each other to prevent the data centers from being impacted simultaneously in the event of a large-scale natural disaster. Learn more in Smartsheet’s Privacy Notice.

WISE Summit webapp: Swapcard is a France based company whose offices are in Paris. All the data and servers are hosted by Amazon Web Services, Inc. (“AWS”), in AWS Ireland datacenter (main data hosting and data processing). Emails sent via Mailgun are also processed in EU. Learn more in Swapcard’s Legal Center.

7. Security measures

Systonic:

Our France-based web platform is certified to ISO27001, and our web services provider is certified to ISO9001.

Datatherapy:

Our other web platform is based on Amazon Web Services and so the ISMS (information security management system) is certified to ISO/IEC 27001. Our associated UK business is also certified to Claris Platinum Partner status and all our payment card processing is in compliance with the PCI DSS.

We have what we believe are appropriate security controls in place to protect personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects is carried out in line with the General Data Protection Legislation. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

Netkin:

Data is hosted exclusively on dedicated OVH servers in France, located in OVH’s main data centers in Roubaix (France), Gravelines (France) and Strasbourg (France).

• Physical security measures for OVH datacenters: https://www.ovh.com/fr/protection-donnees-personnelles/securite.xml
• Front-end servers (Apache 2.4, php 7.4): CloudLinux 7.x (hardened version of CentOS 7.x, specifically designed for instance-isolated web hosting), WHM / CPanel with CPHulk (brute force protection) and built-in firewall. No client database on this server.
  • Using CageFS technology (provided by CloudLinux), each instance runs in its own “caged” file system and cannot see files, data, processes of other instances, nor sensitive files of the server configuration. More information on https://cloudlinux.com/index.php/cagefs;
  • None of our customers have administrative or technical access to the server (no FTP or MariaDB, CPanel, or shell access, etc.) ;
  • Fully automated updates and patches for CPanel and CloudLinux/CentOS, with a summary sent by email to CSO, and a monthly human check;
  • ClamAV antivirus with automated daily scanning;
  • DDOS protection by OVH;
  • Apache 2.4 / PHP 7.4;
  • Sqreen solution is integrated in PHP and provides:
    • Runtime App Self-Protection,
    • In-App WAF (Web Application Firewall),
    • Request monitoring, with detection of attack attempts or automated vulnerability discovery,
    • The severity of the rules is pushed to the maximum possible, with immediate blocking of suspicious requests, then temporary IP blocking (1 hour) for any IP repeatedly triggering rules.

Other security measures and information: https://sqreen.com/product

• Administrative access to the server is all filtered via IP, only connection through our secure VPN is possible. (OpenVPN Access Cluster managed by us on dedicated OVH servers, with individual accounts, password rotation every night, daily mandatory 2FA OTP, and audit of all connections in OpenVPN) ;
• Brute force protection on all server authentication mechanisms, and on the authentication mechanisms of each instance ;
• Apache logs are analyzed daily in an automated way via Datadog, and weekly in a human way, in order to detect any security or performance anomaly.
• Cluster of database servers (mariadb 10.6.x):
• CentOS 7.x, only port 3306 is allowed through the firewall, on private LAN (VRack by OVH), with data encryption on disk.
• This cluster is not accessible from the Internet.
• On the database servers, each instance has its own database, with credentials known only to that instance. Our instance management solution itself does not know these credentials.
• The default credentials and accounts are either disabled or changed automatically during the provisioning of each server.

Smartsheet:

The following security and privacy-related audits and certifications are applicable to core application services within Smartsheet.

• SOC 2/SOC 3: Smartsheet undergoes annual examination and testing as part of the SOC auditing process. The resulting external audit reports attest to the design and operating effectiveness of internal controls across our business, including security, availability, and confidentiality.
• EU-U.S. and Swiss-U.S. Privacy Shield Certification: Customer data submitted to the Covered Services is within the scope of an annual certification to the EU-U.S. Privacy Shield Framework and the SwissU.S. Privacy Shield Framework as administered by the U.S. Department of Commerce. The current certification is available at gov/list by searching under “Smartsheet.”
• FedRAMP (moderate): Smartsheet was selected for the FedRAMP Connect program by the Joint Authorization Board (JAB), which prioritized Smartsheet Gov for certification based on demand from federal government agencies. Smartsheet Gov is a separate Smartsheet environment with FedRAMP authorized status, making it easier for the U.S. government to use Smartsheet for managing their work while helping them meet their security and compliance requirements.
• Sarbanes-Oxley Act of 2002: Smartsheet is a public company and is required to be compliant with Sarbanes-Oxley (SOX). SOX compliance helps build a cohesive internal team and improves communication between teams involved with the audits.

Smartsheet uses infrastructure provided by Amazon Web Services, Inc. (“AWS”) to host customer data. Information about security and privacy-related audits and certifications received by AWS, including ISO 27001 certification and SOC reports, is available from the AWS Security website and the AWS Compliance website. For a full list of our certifications and additional white papers and data sheets, visit the Compliance page on the Smartsheet Trust Center.

Swapcard:

8. Your rights as a data subject

wise-community@wise.org.qa or use the information supplied in the ‘Contact us’ section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

• The right to be informed
  As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.

• The right of access
  You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
  1. The purposes of the processing
  2. The categories of personal data concerned
  3. The recipients to whom the personal data has been disclosed
  4. The retention period or envisioned retention period for that personal data
  5. When personal data has been collected from a third party, the source of the personal data

• If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasions unreasonable expense (which you may have to meet), we will inform you.

• The right to rectification
  When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

• The right to erasure (the ‘right to be forgotten’)
  Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

• The right to restrict processing
  You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
  1. The accuracy of the personal data is contested.
  2. Processing of the personal data is unlawful.
  3. We no longer need the personal data for processing but the personal data is required for part of a legal process.
  4. The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

• The right to data portability
  You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

• The right to object
  You have the right to object to our processing of your data where:
  1. Processing is based on legitimate interest
  2. Processing is for the purpose of direct marketing
  3. Processing is for the purposes of scientific or historic research; or
  4. Processing involves automated decision-making and profiling.

9. Contact us

Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed to 
wise-community@wise.org.qa

Alternatively, you can contact us using the following postal address or telephone number:

Auditoire
44 rue Copernic,
75116, Paris
France

Telephone: +33 1 56 03 57 03

Our telephone switchboard is open 9:00 am – 5:30 pm CET, Monday to Friday. Our switchboard team will take a message and ensure the appropriate person responds as soon as possible.

10. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to:

CNIL: https://www.cnil.fr/fr/adresser-une-plainte