Exclusive Networks Privacy Policy

Scope

The Privacy Policy applies to Exclusive Networks S.A. and all its affiliates, in all its activities and to all its employees. In this document, “Exclusive Networks” represents this entire scope.

Exclusive Networks S.A., a company registered in France with registration number 839082450, located at 20, Quai du Point du Jour, 92100 Boulogne-Billancourt, France, together with its subsidiary undertakings (“Exclusive Networks”, “we”, “us”, “our”), are the data controllers of your Personal Data.

About this Privacy Policy

The purpose of this privacy policy (“Privacy Policy”) is to explain the types of personal information Exclusive Networks collect for the use of the services we provide via our websites, and any other means (our “Services”), how we use it and with whom it is shared.

This Privacy Policy applies to all users of our Services across the world as required by local laws. If you are accessing the Services in the European Economic Area, Switzerland and the United Kingdom, then you will have additional rights which we explain in this Privacy Policy.

This Privacy Policy is divided into the following sections:

• What is Personal Data;
• What Personal Data do we collect about you;
• How do we use the Personal Data we collect;
• With whom do we share your Personal Data;
• What is our legal basis for using your Personal Data;
• For how long we keep your Personal Data;
• Possible transfer of your Personal Data outside the European Economic Area;
• Security;
• Responsibility for Personal Data you provide to other websites;
• How to exercise your rights regarding the use of your Personal Data;
• How to contact us;
• Changes to this Privacy Policy.

What is Personal Data?

As used in this Privacy Policy, the term “Personal Data” means any information that specifically identifies an individual, (such as a name, username, e-mail address, postal address, phone number, etc) or information about that individual that is directly linked to information that specifically identifies an individual. Personal Data may also include additional data that could identify you or be indirectly linked to you, such as some aggregated data, your location, device ID and the way that you use the Services.

What Personal Data do we collect?

From websites visitors, we may collect the following Personal Data:

• Information that you have provided to us, such as your name, email address, phone number, etc;
• Information we get from your use of our website. When you visit our website, we may collect certain information automatically from your device. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked. Some of this information is collected using cookies and similar tracking technology, as explained further in our Cookie Policy.

From our customers, suppliers, and business partners, we may collect the following Personal Data:

• If you are a current or prospective vendor, service provider, customer or end user of ours (or if you are an employee, contractor, agent or other representative of any of these), we may collect Personal Data about you: name and professional contact details (email address, business or delivery address, phone number), etc.

How do we use the Personal Data we collect?

We use Personal Data we collect for our business purposes including:

In addition, we may use your Personal Data for additional specific purposes made clear at the point of collection of your Personal Data.

With whom do we share your Personal Data?

We share your Personal Data with the following third parties, which may vary from time to time and may be different according to where you are located when you access the Services:

We will enter into data processing agreements with all the third parties that process Personal Data on our behalf.

For how long do we keep your Personal Data?

Exclusive Networks retains Personal Data to the extent necessary to reasonably serve customer relations, to meet our compliance and legal obligations, to enhance security and fraud prevention, and for audit purposes.

We may also retain your information during the period of time needed for us to pursue our legitimate interest, respect our legal obligations, resolve disputes and enforce our agreements. We determine the appropriate retention period for the Personal Data on the basis of applicable legal requirements or data protection authorities’ requirements (such as applicable statutes of limitation).

If you would like to find out how long we keep your Personal Data for a particular purpose, you can contact us at dpo@exclusive-networks.com.

We may transfer your personal data outside the European Economic Area

To run our global operations, we may transfer and access your Personal Data from around the world, including from other countries in which we have operations to affiliates, service providers and other recipients for the purposes mentioned above.

If we provide any Personal Data about you to any such non-European Economic Area (“EEA”) member of our group (The list of our affiliates is available in the annual Group Universal Registration Document updated yearly (see our website, investors page) of third-party data processor, we will take appropriate measures to ensure that the recipient protects your Personal Data adequately in accordance with this Privacy Policy. These measures may include the following:

a) ensure that there is an adequacy decision by the European Commission in case of transfers out of the EEA which means that the recipient country is deemed to provide adequate protection for such personal data;

b) enter into an intra-group data transfer agreement within our group compliant with the European Union Standard Contractual Clauses; or

c) enter into the standard contractual clauses as issued by the European Commission. These standard contractual clauses include certain safeguards to protect the personal data.

You may at any time request a copy of the relevant safeguards in place, using the contact details set out in this Privacy Policy.

How do we keep your Personal Data secure?

We take appropriate technical and organisational measures to safeguard your Personal Data that you provide to us against unauthorized or unlawful processing and against accidental destruction, loss or damage, including through use of appropriate organisational and technical measures.

In the course of provision of your Personal Data to us, your Personal Data may be transferred over the internet. Although we make every effort to protect the Personal Data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your Personal Data transmitted to our website and that any such transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to prevent unauthorised access to it.

We are not responsible for Personal Data you provide to other websites

Our Services may contain links to other websites. Any Personal Data you provide on the linked pages is provided directly to that third party and is subject to that third party’s Privacy Policy. We are not responsible for the content or privacy and security practices and policies of these websites or any other websites that are linked to/from our Services. We encourage you to learn about their privacy and security practices and policies before providing them with any Personal Data.

How to exercise your rights regarding the use of your Personal Data?

You have the following rights:

• The right of access. You have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, and about how it is used. You also have the right to access your Personal Data, by requesting a copy.
• The right to rectification. You can ask us to take measures to correct your Personal Data if it is inaccurate or incomplete.
• The right of restriction of processing. You have the right to ‘block’ or suppress the further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Data, but may not use it further.
• The right of erasure. This is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Data where, for example, there is no compelling reason for us to keep using it or its use is unlawful. This is however not a general right to erasure and there are some exceptions, e.g., where we need to use the information in defence of a legal claim or to be able to comply with a legal obligation.
• The right to data portability. You have the right to obtain and reuse Personal Data for your own purposes across different organisations. This only applies to your Personal Data that you have provided to us that we are processing with your consent and for the purposes of contract fulfilment, which is being processed by automated means. In such a case we will provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format.
• The right to object. You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us, any of the affiliates, or by a data recipient. We will be allowed to continue to process the Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or we need this for the establishment, exercise or defence of legal claims.
• The right to withdraw consent, where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred prior to such withdrawal.
• The right to opt-out to direct marketing. You have the right to opt-out at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, or by contacting us. Please note that we reserve the right to send you other communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt-out of receiving them.
• Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your Personal Data in our website or in our Services.
• The right to lodge a complaint with a data protection authority. If you consider that the processing of your Personal Data infringes your data protection rights according to the privacy law you are subject to , you have the right to lodge a complaint with a data protection authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
• When French law is applicable, you have the right to provide instructions on the use of your Personal Data after your death.

These rights can only be exercised by the natural person directly concerned. To exercise your rights, please contact us by using the information in Section below (“How to contact us”). We will respond to all legitimate requests as soon as possible.

How to contact us?

If you have any questions about this Privacy Policy, or about how we use your Personal Data, you may contact our Data Protection Officer (DPO) at dpo@exclusive-networks.com or by mail us at: Exclusive Networks, 20, quai du Point du Jour – CS40099 92659 Boulogne Billancourt Cedex, France.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Please review this Privacy Policy periodically so that you understand how your Personal Data will be used. In the event of a substantial change, we will inform you by a pop-up on our website.