PERSONAL DATA PROTECTION POLICY

Segula Holding, a limited liability company, incorporated under the laws of France, registered under the number 343 166 393 R.C.S. Nanterre, with a registered Office located at 19 rue d’Arras, 92000 Nanterre (hereinafter referred to as the “Segula Technologies Group”) collects and processes personal data (as defined below) as part of its activities

This “Personal Data Protection Policy” (the “Policy”) is intended to inform all the individuals affected by the processing, of the way in which the Segula Technologies Group collects and uses their Personal Data and of the means that enable them to control this use.

By this policy, the Segula Technologies Group, responsible for the processing, undertakes to process your personal data with all necessary care and exclusively for the legitimate purposes for which they were collected, in accordance with applicable regulations.
This policy applies to the segulatechnologies.com website and its subdomains.

1. DEFINITIONS

“Personal Data” refers to information relating to an identified or identifiable natural person. A person is “identifiable” when they can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to their identity.

“Personal Data Processing” refers to any operation or set of operations that is carried out using personal data, regardless of the method used (collection, recording, organisation, storage, adaptation, modification, extraction, consultation, use, disclosure by transmission, dissemination or any other form of provision, alignment or combination, blocking, deletion or destruction, etc.).

2. THE DATA COLLECTED BY THE SEGULA TECHNOLOGIES GROU

The Segula Technologies Group makes sure to collect and process only relevant Personal Data, that is sufficient, not excessive and strictly necessary in order to achieve previously specified purposes.

The Segula Technologies Group is committed to obtain the consent of those concerned as required and to inform them of the processing of their Personal Data and of their rights.

In this context, the Segula Technologies Group may collect and process the following Personal Data:

• Identification: surname, first name, title, function, alias, social network name,
• Contact Information: telephone N°, email and postal address,
• Professional life: universities, schools, degrees and courses
• Technical data: identification data (IP), connection data (including logins).

The Segula Technologies Group collects the aforementioned Personal Data:

• During users’ navigation on the Website
• When the user applies for job opportunities (data collected through our service providers)
• When the user contacts the Segula Technologies Group via our contact forms.

3. PURPOSE OF THE PROCESSING CARRIED OUT BY THE SEGULA TECHNOLOGIES GROUP

The Processing carried out by the Segula Technologies Group meets explicit, legitimate and particular purposes.

Personal Data may be processed for the following purposes:

• To analyse user navigation and to enhance their experience
• To respond to any queries they may raise via our contact forms
• To process applications for our employment opportunities via our service providers
• To send users commercial information regarding the Segula Technologies Group

Depending on the purpose for which the data is collected, the legal basis for the data processing may be:
• The consent of the subject of the data Processing,
• The Segula Technologies Group’s legitimate interest, which may include:

Establishing and maintaining a lasting relationship with suppliers, customers and any other person interested by the Group’s activities,

The improvement of the Group’s websites,

Securing the Group’s tools in order to ensure the protection and security of the tools used.

4. RECIPIENTS OF THE COLLECTED DATA

The Segula Technologies Group may communicate the Personal Data collected to a third party if the law requires it or if the Group believes in good faith that disclosure is reasonably necessary in order to comply with a legal process (e.g. a warrant, subpoena or other court order) or to protect the rights, property or personal safety of the Group, our customers or the public.

The Personal Data may also be disclosed to a third party after obtaining the consent of the subject of the Processing.

The Segula Technologies Group may also share the Personal Data collected with a third party in order to provide website users targeted marketing or advertising offers. The Group also works with third party businesses that may have access to your Personal Data:

• Subcontractors used by the Segula Technologies Group for technical services and analytics providers
• Providers of HR software for talent and training management

En estos casos, el Grupo se compromete a facilitar únicamente la información requerida por los terceros y a cumplir con obligaciones de confidencialidad y seguridad de los Datos similares a las del Grupo.

5. DATA RETENTION PERIOD

The Segula Technologies Group stores the Personal Data for as long as is necessary in order to achieve the purposes for which they were collected.
The Segula Technologies Group may however store Personal Data for a longer period in order to comply with legal or regulatory obligations or even for statistical or historical purposes, including cookies and other tracers stored on your device in accordance with the legal obligations and recommendations issued by the authorities.

6. STORAGE AND TRANSFERS OF PERSONAL DATA

The Personal Data collected by the Segula Technologies Group is stored in France

In order to accomplish its missions, the Segula Technologies Group may be required to disclose the Personal Data collected to its subsidiaries, service providers, customers or other third parties.

Where Personal Data is disclosed by the Segula Technologies Group outside of the European Union, the Group undertakes to first verify that the entities outside of the European Union, including the Group’s subsidiaries located outside of the European Union, offer an adequate level of protection under EU law. The location of the Segula Technologies Group companies is available on the website https://www.segulatechnologies.com/.

7. THE RIGHTS OF PERSONAL DATA SUBJECTS

The Segula Technologies Group has introduced appropriate Personal Data safeguards to ensure that the Personal Data is used in accordance with the purposes set out in section 3 above.

In accordance with the legislation regarding the protection of personal data, the subjects of Personal Data processing have a number of rights with regard to the collection and processing of their Personal Data.

Personal Data, namely:
• The right to be informed about how the Personal Data is collected and processed in a concise, clear, understandable and easily accessible manner
• The right of access to Personal Data, which means having the right (i) to obtain confirmation that Personal Data has or has not been collected and processed (ii) to obtain access to this Data and a copy of the Data once it has been collected.
• The right to rectify, update or delete incomplete or inaccurate Personal Data,
• The right to restrict processing of Personal Data,
• The right to object at any time for specific reasons to the processing of Personal Data by the Segula Technologies Group. However, it should be noted that such objections may be refused for legitimate and compelling reasons requiring further processing,
• The right to portability, which is the right to retrieve the Personal Data collected by the Segula Technologies Group and to transfer it to another processing body.
• The right to give instructions concerning the use of Personal Data after the death of the subject.
For any questions relating to the exercise of these rights, please send an email to the following address: informatiqueetlibertes@segula.fr.         

8. COOKIES

The Segula Technologies Group may use cookies to collect or store Personal Data.

When the user accesses the website, they are informed of the presence of cookies. These cookies do not identify users but are designed to record information regarding their navigation.

The social network cookies make it possible:
• To identify the user (connection),
• To assign and identify a session number,
• To optimise the effect of the page,
• To count the number of likes on Facebook.
The analytics cookies make it possible:
• To distinguish between users,
• To limit the rate of demand

When the user navigates on the Group’s website, the cookies are enabled by default and the data may be read or stored locally. The user will be notified on their initial use and will therefore be able to decide whether to accept or refuse.

By continuing to use the websites, the user expressly accepts the use by Segula Technologies of the aforementioned cookies. The user may choose to configure their browser to automatically refuse cookies. If so, some features and characteristics of the websites may not function properly.

9. SAFETY / PRIVACY

The Segula Technologies Group work to protect and secure the Personal Data that has been disclosed to them, in order to ensure its confidentiality and that it may not be distorted, damaged, destroyed or disclosed to unauthorised third parties.

The Segula Technologies Group has taken measures of physical, electronic and organisational protection to prevent any loss, improper use, unauthorised access or diffusion, alteration or destruction of the Personal Data. However, despite the efforts of the Segula Technologies Group to protect the Personal Data, the Group cannot guarantee the infallibility of this protection because of unavoidable risks that may occur during the transmission of Personal Data.

As all Personal Data is confidential, its access is limited to Segula Technologies Group employees who require access in order to perform their mission. All individuals with access to Personal Data are bound by a confidentiality obligation and expose themselves to disciplinary action and/or other sanctions if they fail to meet these obligations.
Nevertheless, it is important for each user to show vigilance to prevent any unauthorised access to the Personal Data in their possession.

10. LINKS TO THIRD PARTY WEBSITES

Job postings are linked to our HR software for talent and training management. Hence, when a candidate is referred to this platform, the processed and collected data conforms to our Personal Data Protection Policy

The Segula Technologies Group exercises no control over the content of third party websites in terms of protection of the Personal Data that these websites may collect. It is therefore the responsibility of each user to inform themselves of the Personal Data protection policies.

11. POLICY CHANGES

The Segula Technologies Group may update this Policy at any time in order to adapt it to applicable regulations. In such an event, the date of the Policy update will be updated and will indicate the date on which the changes were made.

12. CONTACT

For any question regarding this Policy or for any request concerning the Personal Data collected by the Segula Technologies Group, please send an email to the following address: informatiqueetlibertes@segula.fr.

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