PRIVACY POLICY OF PERSONAL DATA

Why this privacy policy?

SOFRASER’s ambition is to be a responsible and exemplary company. As such, it recognizes the importance of the protection of personal data and undertakes to treat them in accordance with the data protection laws applicable in all countries in which it operates and in particular with the General Regulations on the Protection of Personal Data. Data (General Data Protection Regulation) adopted by the European Parliament on April 14, 2016 and the Data Protection Act of January 6, 1978 amended.

This privacy policy is intended to inform about the processing by SOFRASER of personal data outside those related to human resources included in an internal charter.

What personal data are we dealing with?

Personal data » means all information that refers to a particular or verifiable person.

SOFRASER collects the information provided directly, or through the use of our website, our blogs or through social networks and concerning our customers, business partners, suppliers and other organizations with whom SOFRASER maintains or envisages a commercial relationship.

The information that SOFRASER deals with is particularly related to:

• The identity of the contact: name and first name
• Coordinates of the contact: e-mail address and phone number
• The professional data of the contact: name of the company, professional coordinates, position or title of the employees
• Other data provided during commercial exchanges and direct contacts: technical data, subcontractors, consultants, …

SOFRASER may also record certain details concerning the use of our website or blogs, the unique identifier of the device, the IP addresses, the operating system, the advertisements or pages consulted, the products sought and the downloaded information.

The marketing emails we send can also automatically detect whether the email is received, opened and / or the marketing content on which a click was made. We use this information for our own performance metrics, but also to provide personalized advertising and promotional messages.

Why and how do we handle personal information?

The term « processing » includes any manipulation of personal data, regardless of the means and processes used, in particular the acquisition, storage, use, review and dissemination.

In general, you are in no way obliged to transmit information to SOFRASER. In any case, you can visit the site of SOFRASER without communicating any personal information about you. However, you may not be able to benefit from certain information or services that you want.

By providing information, and according to the necessary authorizations that you grant to us, you expressly agree that they be processed by SOFRASER, for the purposes indicated below.

SOFRASER collects personal data necessary for:

• Surveys
• Transactions (from offer to billing)
• Contracts or partnerships
• Contact requests on the site www.sofraser.com
• Online context
• Technical or service-related questions
• Making contact with us
• Our satisfaction surveys
• Direct interactions with one of our employees or representatives, for example during telephone or e-mail exchanges or during a visit or a trade show

SOFRASER uses personal data acquired in order to:

• Recontact following a solicitation
• Respond to requests for information
• Conduct our business and manage contracts
• Provide requested products, services and supports
• Propose new products and services likely to interest
• Transmit newsletters, promotional messages, information about different events or updates of products or media provided you have your permission or we are authorized
• Allow us to carry out marketing studies and evaluate the satisfaction of our customers
• Collect information allowing us to improve our Site, our products and services
• Ensuring administrative compliance, defending our rights and in relation to our relationship with you
• Manage and respond to all inquiries and complaints related to our customer service team
• For security reasons, to investigate fraud and, if necessary, to protect ourselves and others
• comply with legal and regulatory requirements

or for any specific purpose that we will inform you separately when acquiring the data.

In addition, SOFRASER records the visitors to our sites (name, identification and professional contact information) and uses camera surveillance for reasons of safety and security of persons and property, as well as for regulatory purposes.

How do we store personal data?

We will retain the personal data after the explicit consent of the person and as long as the person has not expressed his wish to delete.

We retain your personal information as long as necessary for the purposes stated above, and this duration varies depending on your interactions with us. When we no longer need to keep your information, we will delete it. Please note that if you unsubscribe from our marketing communications, we will keep a record of your email address to ensure that you will not receive email marketing in the future.

Can we disclose personal data to third parties?

SOFRASER does not sell, share or rent the personal information collected about you.

SOFRASER will not transmit personal data acquired to third parties outside SOFRASER partners acting for or on behalf of SOFRASER for further processing in accordance with the purpose for which they were acquired. These objectives include the provision of products by partners, service delivery, marketing or technical support.

These partners are required to keep these data confidential and can not use them for any other purpose than to perform the services they perform for SOFRASER.

These partners are for example:

• Our distributors
• Service providers:
  • In the field of marketing, for example for:
    • statistical analyzes,
    • commercial and operational studies,
    • Website optimization
  • In the supply of products such as for the delivery chain (freight forwarders, delivery men and transport companies)
• Our professional and legal advisers
• Government authorities such as:
  • customs services
  • Police or other governmental authorities, for example to indicate fraud, or in response to a court request.
• Credit assessment organizations and with third parties engaged in the prevention and detection of fraud
• In the event that we sell commercial assets, the personal information of our customers could be communicated to the potential buyer. If this is the case, we will take the necessary precautions to compel the buyer under this privacy statement.

We also wish to draw your attention to the fact that SOFRASER may be constrained by official instructions or orders to disclose your personal data.

SOFRASER may also disclose personal information in cases where we believe this communication is necessary to protect the rights, property and personal safety of SOFRASER, our customers, our employees or the public, or if we are legally authorized to do so.

Use of cookies?

We use different cookies on the site to improve the interactivity of the site and our services.

• What is a cookie?

A « cookie » is a limited size file, generally consisting of letters and numbers, sent by the Internet server to the cookie file of the browser located on the hard disk of your computer. Some cookies are necessary for the proper functioning of the website and allow a better user experience. Others are used in audience measurement and optimization of our website and blogs. The lifetime of cookies is limited to 13 months.

• How to refuse or delete cookies?

As a user, you can decide at any time to accept or not to save the cookie files on your device (PC, tablet, Smartphone).

If you have accepted the registration of cookies on your device in your browser software (eg Microsoft Explorer, Google Chrome, Firefox, Safari …), the cookies deposited by the pages and contents you have consulted will be stored temporarily in a dedicated area of your terminal.

If you refuse the registration of cookies on your device, or if you delete those registered there, you will not be able to benefit from certain functionalities of our site. If you want to limit your tracks, it is recommended to refuse them by default.

On Google Chrome: https://support.google.com/accounts/answer/61416?hl=en

On Internet Explorer : https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

On Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

On Safari: https://support.apple.com/kb/PH17191?locale=fr_FR&viewlocale=fr_EN

To find out more about the Cookies files, you can consult the CNIL website at: http://www.cnil.fr/vos-droits/vos-traces/les-cookies/

How do we ensure the security of the data collected?

SOFRASER takes measures to ensure the security and confidentiality of the personal data it acquires. SOFRASER uses the appropriate technical and organizational resources.

SOFRASER continually strives to provide the highest level of service and security to our customers, and its website has been developed specifically with this security in mind.

What are your rights?

You have the following rights regarding the personal data concerning you:

• Right to information:

You have the faculty to access the Personal Information that concerns you. To help you in your process, especially if you wish to exercise your right of access by means of a written request you can use the mail template developed by the National Commission for Data Processing and Freedoms (the « CNIL ») : https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces.

However, due to the obligation of security and confidentiality in the processing of personal data which is the responsibility of SOFRASER, you are informed that your application will be processed provided that you provide proof of your identity, including the production of a scan of your valid ID (if requested by our dedicated electronic form) or a signed photocopy of your valid ID (in case of written request).

SOFRASER informs you that it will be entitled, if necessary, to oppose manifestly abusive requests (by their number, their repetitive or systematic nature). Right to rectification

Under this right, the law allows you to request the rectification, updating, locking or deletion of data concerning you that may be inaccurate, erroneous, incomplete or obsolete.

• Right of cancellation (« Right to be forgotten »)
• Right to restriction of treatment, and
• Right to portability of data.
• Right to set guidelines regarding the fate of your personal data after your death.

You also have the right to file a complaint with a supervisory authority regarding the processing of your personal data.

How to unsubscribe?

If you no longer wish to receive electronic communications, you can unsubscribe by clicking the « Unsubscribe » button at the top or bottom of each email sent by SOFRASER, or by following the instructions to « disable » appearing on this e-mail.

You can choose to receive information by e-mail, phone or mail about our products and services, or subscribe to subscriptions. When you visit our websites or use our services, we may provide you with personalized information. You can always refuse to receive personalized communication by sending an e-mail or unsubscribing e-mails by clicking on the link in each e-mail or by contacting us at [email protected].

How to contact us?

Questions or inquiries regarding this privacy policy should be e-mailed to:

Valérie BELLIERE, 15 rue Pierre Nobel, 45700 VILLEMANDEUR

Tel: +33 (0) 2 38 85 77 12 Fax: +33 (0) 2 38 85 99 65

[email protected]

You can also contact the CNIL if you have any questions or concerns about your personal information.

When and how is this privacy policy updated?

Please note that this privacy policy may be modified or supplemented at any time by SOFRASER, in particular to comply with any legislative, regulatory, jurisprudential or technological developments. In such a case, the date of its update will be clearly identified on the policy. These modifications engage the User as soon as they are posted online. The User should therefore consult this Privacy Policy regularly in order to be aware of any changes.

This privacy policy was last updated in May 2018.

LEGAL NOTICE