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PRIVACY POLICY

At FABERNOVEL we are particularly sensitive to the protection of personal data and we commit to process them with respect for the privacy of the persons concerned, i.e. the data subjects.

To this end, we have drafted this policy to inform you on the nature of personal data we may collect, why we collect them, and how we process them.

What is a personal data?

Any information relating to your private or professional life through which you can be identified directly or indirectly. This may include your surname, your name, the company employing you, your job title, your personal or professional telephone number, or your email address.

What are our commitments?

Each FABERNOVEL’s company processes your personal data in accordance with the terms of this policy and the applicable law.

In particular, we commit to:

- Collect and process the personal data in a fair, lawful and transparent manner,

- Observe the purposes of their collection,

- Store them only for the period necessary to achieve those purposes,

- Ensure their security and confidentiality,

- Update your data regularly,

- Respect your rights relating to the processing carried out.

Depending on your relationship with our group, the rules under which we process your personal data may adjust. The specificities applicable to your situation are explained further in this policy.

In any case, we do not make any paid use nor sale your personal data.

What are your rights?

Because your privacy must remain yours, it is essential that you keep control of your personal data.

We ensure your right of access: you can ask us to send you a copy of all the information we hold about you in an understandable format. Under certain circumstances, you can also ask us to forward some of those information to third parties (right to data portability).

You are also entitled to object to our use of your personal data for marketing purposes or to request that we do not/no longer use them for purposes other than those which are legitimate or compelling for the FABERNOVEL group as mentioned below (right to object).

You are also entitled to ask for the restriction or the limitation of your personal data processing, if your situation allows it.

You also have the right to request the rectification or the erasure of your personal data, if they are inaccurate.

You may also define general or specific guidelines regarding the post-mortem use of your personal data.

You can exercise your various rights - or send us your questions about the processing of your personal data - by contacting us at: privacy@fabernovel.com.

We commit to deal with your request the best way we can and as soon as possible. In order to ensure the legitimate exercise of these rights, we may ask you, as permitted by law, to provide proof of your identity before processing your request.

For more information (CNIL website): Les droits pour maîtriser vos données à caractère personnel !

Who is the data controller ?

The data controller is the natural or legal person who determines the purposes and means of your personal data processing, i.e. for all the operations on such data (collection, consultation, storage, etc.): the controller is the one who decides why and how to process your personal data.

The data controller is the company (ies) you are in relation with, or which employs you or to which you have provided or transmitted your data online or in hard copy form. You can identify it by referring to the following list:

FABERNOVEL ALPHA 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL CODE (BUZZAKA) 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL DATA & MEDIA (LAGENCEMEDIA) 44-48 rue Saint-Lazare • 75009 PARIS.

FABERNOVEL GROUP 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL INNOVATE (FABERNOVEL PARIS) 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL INSTITUTE 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL TECHNOLOGIES APPLIDIUM (APPLIDIUM par FABERNOVEL) 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL TECHNOLOGIES ZENGULARITY (ZENGULARITY) 44-48 rue Saint-Lazare • 75009 PARIS

FABERNOVEL STORIES 44-48 rue Saint-Lazare • 75009 PARIS

LE SIDE CAR 44-48 rue Saint-Lazare • 75009 PARIS

May your personal data be transferred outside the European Union?

Our personal data processing is mainly carried out in Europe. Should we need to transfer your personal data to a country outside the European Union whose level of protection would not be considered adequate by the European authorities, we undertake to ensure that this transfer is made under the appropriate guarantees in accordance with the applicable legislation.

For example, we will ensure that the companies importing your personal data have signed data processing contracts based on the standard contractual clauses validated by the European Commission or have adhered to the principles of the Privacy Shield or a code of conduct or a certification mechanism.

In the event that we were to transfer your personal data to our entities located outside the European Union, the same guarantees would apply.

Claim

If you believe that we failed to comply with our obligations and commitments, or to respect your rights, you may lodge a complaint with the CNIL (the French Data Protection Authority).

We are in a business relationship

o What personal data do we collect about you?

In the context of our business relationships, we may collect the following data about you:

- Your surname and name,

- Your professional email address,

- Your business phone number,

- Your job title,

- The company employing you.

o Why do we process your personal data?

For our activities, we collect and process your personal data to achieve the following purposes:

- To manage our prospects, customers and contracts,

- To invoice and to manage accounts,

- To manage unpaid bills and litigation.

- To carry out studies and surveys on our products and services,

- To seek opinions on our products and services,

- To send newsletters and to organize public relations events,

o What are the legal grounds for processing your personal data?

Such data processing are carried out under the following legal grounds :

- to comply with our legal obligations as a commercial company ;

- to perform the commercial contract existing between you and our group ;

- to pursue our legitimate interest to promote our service offers to our customers and prospects as well as our constant objective of improving the quality of our products and services.

o To who your personal data may be transmitted?

We transmit your personal data to relevant internal services within our different entities, and, precisely to members empowered to process them (for example: account managers, accounting department).

We may also transmit your data to our subcontractors acting on our behalf in order to provide you with our products and services. In such case, we will ensure that they provide the necessary guarantees for the security and confidentiality of your personal data.

Apart from these cases, we do not share your personal data with companies or organizations outside our group, except with your prior consent or when required by law.

o How long do we keep your personal data?

We keep your personal data for a period that does not exceed what we consider necessary for the purposes of their process.

We may also need to archive your personal data over a longer period to enable us to prove a right or a contract, or to ensure compliance with a corporate obligation (legal, accounting obligations, etc.). The archiving is then carried out in accordance with the relevant applicable rules for a period that does not exceed legal requirements.

We have also drafted a data retention policy. You can receive it by sending an email to privacy@fabernovel.com.

You are an employee

o What personal data do we collect about you?

In the context of our working relationship, we may collect the following data about you:

- Your identification details (surname, birth and/or married name, gender, date and place of birth, social security number, personal and professional contact information),

- Your photo,

- Surname, name, phone number and person to contact in case of emergency,

- Surname, first name and date of birth of your children,

- Your union membership,

- Your CV,

- Information relating to your use of computer or telephone tools made available to you,

- Your HR file (trainings, interviews...),

- Your union membership,

- Our correspondence.

o Why do we process your personal data?

In the context of our working relationship, we collect and process your personal data to achieve and manage the following purposes:

- Payroll,

- Accounting,

- Recruitment,

- Following your career, training and mobility,

- Individual allocations in terms of supplies, equipment and payment cards,

- Business trips,

- Directory and organization chart,

- Staff representatives elections and the meetings of the staff representative bodies,

- Social and cultural actions we implement.

And also in order to :

- Ensure the safety of property and people.

o What are the legal grounds for processing your personal data?

Such data processing are carried out under the following legal grounds:

- to comply with our legal obligations as employer,

- to perform the employment contract existing between you and our group,

- to pursue our legitimate interest to organize the recruitment and management of human resources necessary for the proper conduct of their activities as well as to manage our internal events and the follow-up of the work tools entrusted to you.

o To who may your personal data be transmitted?

We transmit your personal data to relevant internal services within our different entities, and, precisely to members empowered to process them (for example: accounting, HR department, office managers, etc.) and to your supervisors only in the frame of the necessary management of their teams.

We may also transmit your data to our subcontractors. In such case, we will ensure that they provide the necessary guarantees for the security and confidentiality of your personal data.

We may also be required by law to transmit your personal data to an administrative or judicial authority or an authorized body (e.g. social security, tax administration, etc.). We may also communicate, with your prior express consent, your business contact details and the information strictly necessary for the representation and defense of employees, to members of the staff representatives bodies and to union representatives.

o How long do we keep your personal data?

We keep your personal data for a period that does not exceed what we consider necessary for the purposes of their process.

Some of your personal data may be retained for longer periods of time, under a temporary storage record, in order to prove the existence of a right or contract, or to ensure compliance with a corporate obligation (legal, accounting obligations, etc.). Archiving is then carried out in accordance with the recommendations of the CNIL: the archived data are selected and kept separate from the active database and limited in time, in particular according to the requirements of the French Civil Code and the French Labor Code.

We have also drafted a data retention policy. You can receive it by sending an email to privacy@fabernovel.com.

You visit our premises

o What personal data do we collect about you?

When you access the premises, we may collect the following data about you:

- Your email address,

- Your surname and name,

- The badge number that we would give you,

- The date and time of your passages to the terminals,

- Your picture or video.

o Why do we process your personal data?

In this context, we collect and process your personal data to achieve the following purposes:

- To control the access to our premises and rooms

- To ensure the safety of property and people.

- To manage problems with the terminals operation

o What are the legal grounds for processing your personal data?

Such data processing are carried out under the following legal grounds :

- to comply with our legal obligations and/or to pursue our legitimate interest to ensure the safety of property and people;

- to our interest in ensuring the confidentiality of our information, as well as that of our customers, employees and partners.

o To who your personal data may be transmitted?

We transmit your personal data to relevant internal services within our different entities, and, precisely to members empowered to process them (for example: IT department, interface management team, etc).

We may also transmit your data to our subcontractors (or to the police if necessary). In such case, we will ensure that they provide the necessary guarantees for the security and confidentiality of your personal data.

Apart from these cases, we do not share your personal data with companies or organizations outside our group, except with your prior consent or when required by law.

o How long do we keep your personal data?

We keep your personal data no longer than 3 months, except for images captured by video surveillance that we keep for 1 month maximum.

We have also drafted a data retention policy. You can receive it by sending an email to privacy@fabernovel.com

You are an Internet user

o What personal data do we collect about you?

When you our website, and if you fill in the contact form, we collect your identification details (surname, name, email address).

o Why do we process your personal data?

In this context, we collect and process your personal data to achieve the following purposes:

- To send you our newsletters, invitations,…;

- Reply to your questions.

o What are the legal grounds for processing your personal data?

Such data processing are carried out under your consent to provide your data to us for the purposes mentioned above.

o To who your personal data may be transmitted?

We transmit your personal data to relevant internal services within our different entities, and, precisely to members empowered to process them (for example: communication department).

We may also transmit your data to our subcontractors acting. In such case, we will ensure that they provide the necessary guarantees for the security and confidentiality of your personal data.

Apart from these cases, we do not share your personal data with companies or organizations outside our group, except with your prior consent or when required by law.

o How long do we keep your personal data?

We keep your personal data for a period that does not exceed what we consider necessary for the purposes of their process.

We may also need to archive your personal data over a longer period to enable us to prove a right or a contract, or to ensure compliance with a corporate obligation (legal, accounting obligations, etc.). The archiving is then carried out in accordance with the relevant applicable rules for a period that does not exceed legal requirements.

We have also drafted a data retention policy. You can receive it by sending an email to privacy@fabernovel.com.

If you are applying for a job position

o What personal data do we collect about you?

When you apply for a job position at Fabernovel, we may collect the following data about you:

- Your identification details (surname, name, gender, phone number, CV),

- Your picture if it appears on your CV,

- Your academic and/or professional background,

- Your CV.

o Why do we process your personal data?

In this context, we collect and process your personal data to achieve the following purposes:

- To review your applications,

- To reply to you,

- To transfer your application for an open position in another entity.

o What are the legal grounds for processing your personal data?

Such data processing are carried out under the following legal grounds :

- The legitimate interest we have in organizing and implementing our recruitments,

- Your consent in cases you authorize us to keep your file in order to contact you in the event that new professional opportunities corresponding to your profile arise within our group.

o To who your personal data may be transmitted?

We transmit your personal data to relevant internal services within our different entities, in particular to recommend an application for a job position in another entity.

We may also transmit your data to our subcontractors. In such case, we will ensure that they provide the necessary guarantees for the security and confidentiality of your personal data.

Apart from these cases, we do not share your personal data with companies or organizations outside our group, except with your prior consent or when required by law.

o How long do we keep your personal data?

Only if you agreed to it, our human resources department may keep your personal data and application file for a period of 24 months.

We have also drafted a data retention policy. You can receive it by sending an email to privacy@fabernovel.com.

Miscellaneous

We reserve the right to modify this policy at any time, taking into account the provisions in force regarding the protection of personal data. This policy is available online. Therefore, we invite you to consult it regularly. In case of major changes, you will be notified accordingly at the implementation.

Should you have further questions regarding the management of your personal data, please feel free to contact us at privacy@fabernovel.com.

Last update

09/12/ 2019