PERSONAL DATA PROCESSING POLICY

This policy applies to all European companies in the ADDUP Group.

1. GENERAL PROVISIONS

The AddUp group attaches the utmost importance to the protection of personal data and to compliance with legal and regulatory obligations in this area.

This personal data protection policy applies to all users of the site www.addupsolutions.com (hereinafter referred to as the “Site”). It describes the processing of any personal data collected by Add4Up when the user accesses the Site and during its use.

2. DEFINITIONS AND COLLECTION OF PERSONAL DATA

By using the Site, the User is informed that personal data concerning him/her may be collected and processed in accordance with this personal data protection policy.

AddUp determines the means and purposes of the personal data processing carried out and thus acts as a data controller within the meaning of the applicable regulations on personal data and in particular EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD).

Personal data” means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a surname, a first name, an e-mail address, an IP address…

Processing of personal data” means any operation or set of operations which is performed upon personal data or sets of data, whether or not by automatic means, such as collection, recording, organization, storage, alteration, retrieval, consultation, use, dissemination, erasure or destruction…

A “purpose” is the objective pursued by the implementation of a processing operation, the reason for which data is collected.

As part of our commitment to transparency, personal data is collected and processed fairly and lawfully. Data collected is adequate, relevant and not excessive in relation to the purposes for which it is collected.

3. PROCESSING PURPOSES AND LEGAL BASIS

In the context of contact requests made by a user on the Site, the user’s personal data is collected by AddUp so that AddUp can process the user’s request and/or contact him/her. The user’s personal data may also be collected and processed for commercial prospecting purposes when the user has given his consent.

In the context of job applications made by a user on the Site, the user’s personal data is collected and processed by AddUp for the purposes of managing the application and recruitment.

Data collected by AddUp is not used for purposes other than those described above.

4. WHETHER IT IS MANDATORY OR OPTIONAL

The information presented as compulsory, in particular in the contact form or on the space dedicated to recruitment, is necessary to process your contact request or your application. Their mandatory or optional nature is indicated at the time of collection.

In the event of incomplete information, AddUp will not be able to respond to your request.

5. SHELF LIFE

Data collected by AddUp is kept for a limited period of time, determined according to the purpose of the processing, regulatory obligations or the recommendations of supervisory authorities.

Data relating to the management of job applications are deleted after a period of 2 years for applications that have not led to recruitment.

Data relating to the management of the commercial relationship is kept for a maximum of 5 years after the end of the commercial relationship for customers and 3 years from the last contact for prospects.

6. THE APPOINTMENT OF A DATA PROTECTION OFFICER

AddUp has freely chosen to appoint a Data Protection Officer (DPO) to ensure that AddUp Group companies comply with regulations on the protection of personal data.

7. USER RIGHTS

The user has a right of access, rectification, deletion, opposition, limitation, portability and not to be subject to a decision based exclusively on automated processing:

• • Access to data: the user has the possibility of requesting information directly from AddUp on the processing and data concerning him;

• • Rectification of data: if AddUp holds data that is inaccurate, incomplete, obsolete, erroneous or ambiguous, the user has the possibility of requesting their rectification;

• • Deletion (right to oblivion): the user has the right to ask AddUp to delete personal data concerning him/her if they are unnecessary or for any other reason provided for by law;

• • Opposition: the user may object, at any time and free of charge, to the processing of his or her data in accordance with the legal terms and conditions and in particular when his or her data is processed for canvassing purposes;

• • Limitation: users also have the right to limit the processing of their data, in accordance with the legal provisions;

• • Portability: users have the right to have their data ported into a digital format (this right only concerns personal data supplied by the user and data generated by the user’s activity. This right is applicable only if the processing is based on the user’s consent or the performance of a contract, and if the processing is carried out using automated processes;

• • Not to be the subject of a decision based exclusively on automated processing: the user has the option of not being the subject of a fully automated decision – based on profiling in particular – which has a legal effect or significantly affects him or her.

Finally, users have the right to decide what happens to their data post-mortem.

Subject to providing proof of identity, the user may exercise these rights by sending a written request by e-mail to the following address: dpo@addupsolutions.com or by post to the attention of the Data Protection Officer at the following address: AddUp, 13-33 rue verte – Zone Industrielle de Ladoux, 63118 Cébazat (France).

The user has the right to lodge a complaint with the supervisory authority in his country.

The list of supervisory authorities in the countries where the AddUp Group operates is available below:

Germany

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BFDI)
https://www.bfdi.bund.de/
Address: Husarenstr. 30 – 53117 Bonn
Telephone: +49 (0)228-997799-0

France

Commission Nationale de l’Informatique et des Libertés (CNIL)
https://www.cnil.fr/
Address: 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Telephone: +33 (0)1 53 73 22 22

8. RECIPIENTS OF PERSONAL DATA

The user is informed, prior to the collection of his data, that it may be transmitted to partners acting as Subcontractors (within the meaning of the RGPD) in the execution of the processing of personal data, object of the collection.

The data collected is intended for internal use by AddUp Group companies. The personal data collected will not be communicated to external third parties. AddUp does not sell personal data to third parties.

AddUp reserves the right to report to the authorities any activity on the Site by a user that may be illegal and to disclose any information concerning users of the Site in order to satisfy legal requirements.

9. DATA TRANSFERS

The data collected may be transferred to a country outside the European Economic Area (EEA). In this case, AddUp ensures that the transfer is subject to appropriate legal safeguards.

10. DATA SECURITY

The AddUp Group attaches great importance to data confidentiality and security and implements technical and organizational measures to protect the personal data it collects and/or processes against loss, destruction, alteration, unauthorized access or disclosure.

11. COOKIES

When the user visits the AddUp Site, data relating to navigation in particular is collected via cookies. These cookies are likely to be deposited on the user’s terminal (computer, tablet or smartphone) for a maximum period of 12 months from the time they are deposited.

The different types of cookies used on the AddUp website are :

– Audience measurement cookies

Google Analytics cookies are used to track the user’s browsing habits in order to establish consultation statistics and monitor the performance of the Site and each of its pages. This data enables AddUp to improve and streamline the user’s browsing experience. These cookies require your consent. During your first session on one of our websites, a banner appears on the page visited and a clickable link allows you to refuse the deposit of audience measurement cookies. Continued browsing on another page of the site or selection of an element of the site (image, link, “search” button, etc.) signifies your acceptance of the deposit of these cookies on your terminal. If you refuse to accept these cookies, they will not be installed on your terminal.

Opt-out cookie installed. Your visits to this site will NOT be recorded by our web analytics tool. Note: if you clean up your cookies and delete the exclusion cookie, or if you change your computer and/or browser, you will have to go through the exclusion procedure again.

You are not currently being monitored. Check this box if you no longer wish to be excluded.

– Cookies used to promote job offers on recruitment pages

These cookies, which have a maximum duration of 12 months, enable us to promote job offers to candidates who consult the pages of the AddUp site dedicated to recruitment.

Users may refuse to accept any type of cookie by configuring their browser (if such a function can be set in their browser). Refusal to authorize certain cookies may prevent a site from functioning properly.

12. MODIFICATION

AddUp reserves the right to update and modify the provisions of this privacy policy as required and without notice.

The user is hereby invited to regularly review the terms of this personal data processing policy.

In the event of any contradiction between the French and English versions of this policy, the French version shall prevail.