Effective Date: March 25, 2019

The purpose of this “Privacy Policy” (the “Policy”) is to inform all concerned data subjects (“You” or “Your”) about how and why NOVELTIS, as the data controller, collects and uses such Personal Data and about how you may control such use.

By “Personal Data” (the singular includes the plural and vice-versa) is understood all information that permits identifying a person, either directly (ex: by his or her name, first name or date of birth, ….), or indirectly by reference, as the case may be, to an identification number, or to one or more factors that are specific to that person, or else by cross-referencing data.

When Personal Data is “processed” this includes the use, storage, recording, transfer, adaptation, analysis, modification, notification, sharing and destruction of Personal Data as appropriate under the circumstances or as required by law.

1. INTRODUCTION

We want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about your privacy, and we want to maintain your trust.

This privacy policy describes our practices in connection with information we collect through this website, electronic newsletter or other online service operated by us from which you are accessing this Privacy Policy.

If there is a conflict between this Privacy Policy and your company’s subscription agreement, the services corporate subscription agreement will take precedence.

As described more fully below, we may share your personal data or other information with our Institutional and business partners, for the purposes described in this privacy policy.

The list of institutional and business partners displays on the homepage.

By using this website, you acknowledge you have read and accept this privacy policy.

This website is professional and general audience sites, and are not targeted to, and do not knowingly collect Personal Data from, minors under 16 years of age.

2. WHAT WE COLLECT

We collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent.

We may collect the following information from and about you :

a. Personal data

“Personal Data” for purposes of this privacy policy is the information that identifies you as an individual or relates to an identifiable person.

b. Personal data you submit

We collect Personal Data when you submit it to us, such as when you register for or subscribe to this website, create a profile, take a survey.

The Personal Data you submit may include your name, postal address, telephone number, mobile number, gender, username, and email address.

c. Personal data we receive from third parties

To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as Institutional and business partners. The personal data we receive from third parties may include your name, postal address, telephone number, mobile number, gender, username, and email address.

d. Other information

“Other Information” is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent are required by applicable law, and aggregated information.

e. Other information you submit

We collect other information when you submit it to us. This may include your occupation, and interests.

We also collect the content you create, upload, or receive from others when using our services.

This includes things like photos, videos, documents and data you upload on this website, and comments you make on this website.

Other information We receive from third parties.

We may receive other information about you from third parties, including, for example, demographic data, information about your interests, and information about your activities on other websites.

Other information collected automatically our services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, please refer to our Cookie Policy.

3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION

We may use the Personal Data we collect from and about you for the purposes set forth below.

We may use and disclose other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine other information with your Personal Data, we treat the combined information as Personal Data.

To improve the quality of our products and services and to present products and offers tailored to you, we may also combine the Personal Data and Other Information we collect with information relating to your use of other NOVELTIS products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from Institutional and business partners.

a. To provide, measure and improve our products and services

We use the information we collect from and about you to provide our products and services and features to you, including :

  • to process your applications for our job offers,
  • to measure and improve those services and features,
  • to provide you with customer support and to respond to inquiries.
b. To contact you

We may periodically send promotional information, with your permission are required, or notifications related to our services.

To help make this promotional information more relevant to you, we may use and combine any of the Personal Data and Other Information we collect.

If you want to stop receiving these promotional informational, you can unsubscribe it. We may also use your Personal Data and Other Information we collect, to respond to inquiries or requests you make to us.

We may use your Personal Data as we believe to be necessary or appropriate in order to :

  • protect, enforce, or defend the legal rights, privacy, safety, or property of NOVELTIS, our Institutional and business partners ;
  • protect the safety, privacy, and security of users of our services ;
  • comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policy; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION

We may share your Personal Data with one another, as well as with affiliates for the purposes described in this Privacy Policy, including for each company’s marketing purposes if you have consented to such use.

Users who visit affiliates services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. We are the party responsible for the management of the jointly used Personal Data. In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorised by this Privacy Policy, as follows :

  • To manage corporate and third-party subscriptions If your subscription is provided in whole or in part by your employer or other third party, we may share with them information about your access to and use of your subscription. When providing this information, we may reveal limited amounts of your Personal Data such as your name or email address.
  • To allow third-party service providers, to assist us in providing and managing our services. We may make your personal data available to certain third-party service providers, such as contractors, affiliates, who help us manage or provide our products and services by, for example developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; and processing data or statistics. These third-party service providers are required to protect personal data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
  • To protect the rights of NOVELTIS and others. There may be instances when we may disclose your personal data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of NOVELTIS, our affiliates and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activities or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or to respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
  • To complete a merger or sale of assets if NOVELTIS sells all or part of its business or assets or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction NOVELTIS may transfer your information to the party or parties and their advisors involved in the transaction.

5. HOW WE PROTECT AND RETAIN PERSONAL DATA

We use a combination of technical, administrative, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorised loss, use, access, disclosure or modification.

We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information.

If you have reason to believe that your interaction with us is no longer secure, please contact us.

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

For Personal Data communicated via the contact or request for demo forms, such data is only kept for the time necessary for the processing and proper handling of your request and no longer than six (6) months after the date of collection, unless you have given your express consent that such data be used for the purpose of receiving email communications on NOVELTIS, its solutions, products, services and events, and being contacted for surveys, for sales prospections and/or solicitations.

More generally, for clients who are individuals or individuals acting as legal representatives of legal persons having dealings with our website, Personal Data is erased no later than five (5) years from the date of the end of the business relationship between the client and NOVELTIS, subject to any shorter periods provided by applicable legislation depending on the type of data and purposes of collection.

Similarly, Personal Data of individuals who have agreed to receive commercial solicitation is erased no later than three (3) years after the date of Your latest business interest in NOVELTIS’ product, services or events, subject to any shorter periods provided by applicable legislation depending on the type of data involved.

You may, at any time, unsubscribe from all NOVELTIS communications, on the website, accessible directly or through a link provided in each email communication.

6. YOUR RIGHTS AND CHOICES

a. Your Choices Regarding Our Use and Disclosure of Your Personal Data

Your principal rights are :

  • the right to access ;
  • the right to rectification ;
  • the right to erasure ;
  • the right to restrict processing ;
  • the right to object to processing ;
  • the right to data portability (European Economic Area (“EEA”) only) ;
  • the right to complain to a supervisory authority ; and
  • the right to withdraw consent.
b. How to access, correct, erase or update Your Personal Data

You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting our Customer Support (contact information provided below).

For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion.

7. OTHER IMPORTANT INFORMATION

a. Privacy Policy Updates

We may periodically update this Privacy Policy without prior notice to reflect changes in our practices.

Please look at the effective date at the top of this Privacy Policy to see when it was last revised.

Any changes to this Privacy Policy will become effective when we post in this website.

We will notify you by posting a notice indicating we have updated this Privacy Policy.

Your use of this website and services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Policy.

b. Transfers

Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in your country.

If you are located in the European-Union, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside of the European-Union.

c. Linked Services

We may be linked to sites operated by third parties, and may offer content, functionality, applications developed and maintained by third parties. We are not responsible for the privacy practices of any such third parties, and once you leave this website, you should check the applicable privacy policy of the other service.

8. CONTACT US

This website is owned and operated by NOVELTIS.

We are registered France under registration 420 805 152, and our registered office is at 153, rue du Lac 31670 LABEGE FRANCE.

If you have questions about this Privacy Policy or how we or our service providers handle your personal data, please contact our customer support at privacy@noveltis.fr

Or you may write to : NOVELTIS – Confidentialité – 153, rue du Lac – 31670 LABEGE – FRANCE

Please do not disclose any sensitive Personal Data when contacting us (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, …).

If you are located in the European-Union, the entity responsible for the collection and processing of Personal Data is NOVELTIS (contact information provided above).

NOVELTIS is subject to applicable European legislation on personal data protection, and in particular General Data Protection Regulation No. 2016/679 of April 27th, 2016 (“GDPR”), and to any national legislation adopted in application thereof, on a subsidiary basis, and which might apply depending on the circumstances.

We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, you can contact a supervisory authority.

NOVELTIS operational headquarters being located in France, the lead supervisory authority for its activities within the European Union is the French Data Protection Authority (la Commission Nationale de l’Informatique et des Libertés (CNIL)).