1. Definitions from the GDPR

PERSONAL DATA / DATA

Any information relating to an identified or identifiable natural person (also referred to as “data subject”). An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier (e.g. a name, an identification number, location data, an online identifier) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

RECIPIENT

A natural or legal person, public authority, agency or any other body, to which the Personal Data are disclosed, whether a third party or not.

CROUZET

A simplified joint-stock company with a sole shareholder (S.A.S.U.) whose registered office is located at 12, rue Jean Jullien-Davin, VALENCE (26000), registered with the ROMANS Trade and Companies Register under number 663 820 413.

CROUZET specialises in the manufacture of mechatronic components for critical applications related to Aviation, Transport, Energy, Building and Machine Construction.

FILE

Any structured set of Personal Data which is accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

REGULATIONS

All of the regulations in force applicable to the Processing of Personal Data, namely the General Data Protection Regulation (“GDPR”), which entered into force on 25 May 2018 which introduces new concepts compared to the “Concerning Information Technology, Files and Freedoms” of 6 January 1978 as amended (the so-called “French Data Protection Act”) and amends the obligations of the parties involved in the Processing of Personal Data.

CONTROLLER

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

WEBSITE

This Website published and/or operated by CROUZET and accessible via the following URL link: https://www.crouzet.fr/.

PROCESSOR

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

PROCESSING

Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. Who is the Controller of Personal Data Processing carried out through the Website?

The Controller of Processing carried out through the Website is CROUZET, whose registered office is located at 12, rue Jean Jullien-Davin, VALENCE (26000). Its legal representative is Crouzet TOP HOLDING.

CROUZET has a Data Protection Officer who can be reached at the email address DPO@crouzet.com or by post at the following address: CROUZET – For the attention of the Data Protection Officer – 12, rue Jean Jullien-Davin, VALENCE (26000).

3. What Personal Data is collected? How do we collect your Personal Data?

Through the Website, CROUZET may collect and process the following Data:

3.1. Personal Data that you disclose directly to us:

The Personal Data that is collected is that which you disclose directly to us through the contact forms available on the Website (contact with customer service and/or technical support: exchange of information relating to CROUZET products, its technical and technological innovations, and more generally in the context of marketing actions) or via the email address transmitted to exercise your rights on the Processing of your Data.

We collect Personal Data that you disclose directly to us in the following cases:

• When you contact customer service
  • Surname, first name;
  • Gender;
  • Valid email address;
  • Tel. no.;
  • Where applicable, the company.
• When you contact technical support
  • Surname, first name;
  • Gender;
  • Valid email address;
  • Tel. no.;
  • Where applicable, the company.
• When you exercise your rights regarding the Processing of your Data
  • Surname, first name;
  • Valid email address.

3.2. Personal Data that we collect automatically

When you consult the Website, so-called browsing Data is automatically saved either:

• indirectly through third-party cookies,
• directly by CROUZET’s IT system,
• indirectly by the IT service provider in charge of managing the Website.

Part of the Data is collected in order to guarantee problem-free provision of the Website, its improvement and the maintenance of a secure environment. Other Data may be used to analyse your user behaviour and the traffic generated and/or to increase the interactivity of our Website.

This may include:

• Data relating to your connection to the Website:

For example, your IP address, your search engine and its settings, the date and time of the connection, how you browse the Website and any other data tracking your use of the Website.

• Data relating to the equipment that enables you to access the Website:

Depending on the equipment you use and the settings enabled, the following Data may be collected in particular: the type of equipment (mobile phone, tablet, PC, MAC, etc.) and the operating system you use and their settings.

This information can be obtained either directly using the server event logs (the log files) or via cookies or similar tools.

4. For what purpose do we use your Personal Data?

We use your Data to carry out the Processing, the purposes of which are set out in the table below.

This Data is collected in one of the cases provided for by the Regulations, namely:

• the performance of a contract we have entered into with you, and/or
• compliance with a legal obligation, and/or
• your consent to the use of your Data, and/or
• our legitimate interest in using your Data, it being specified that the legitimate interest is a range of commercial reasons and/or security reasons that justify the use of your Data by CROUZET.

You will find all this information in the table below.

Processing Table

5. Who can have access to your Personal Data?

In general, the Personal Data that you disclose to us is intended for authorised members of the personnel of the Controller and any of its possible Processors, business partners, service providers or suppliers.

Whether in individual or aggregated form, your Personal Data may be processed by the employees of the departments concerned of CROUZET and its subsidiaries.

The subsidiaries of the CROUZET group are located within the European Union but also in third countries (outside the European Union):

• EUROPE, MIDDLE EAST & AFRICA: the United Kingdom, Switzerland, Morocco,
• AMERICAS: the United States, Canada, Mexico,
• ASIA: India, China, South Korea, South Asia Pacific.

In all cases, only the Data strictly necessary to carry out the Processing concerned is transmitted and only to employees who need to know it because of their duties. This access to your Personal Data is restricted by an individual authorisation system. All persons likely to have access to your Personal Data are subject to a contractual obligation of confidentiality.

5.2. Recipients outside the CROUZET group

Several categories of third parties referred to below may have access to your Personal Data. Only the Personal Data strictly necessary is transmitted to them for the purpose(s) of the Processing envisaged.

Third parties that may have access to your Personal Data may be classified into two categories.

1 ) Partners, Processors and/or service providers, namely:

• the IT service provider(s) (OVH which hosts the Website);
  • the suppliers of analysis and advertising tools, namely ____________;

2 ) Third-party platforms and social networks (see the article “the use of your Personal Data by third-party platforms”).

3 ) Exceptionally, the competent authorities (administrative, judicial, police) due to a legal obligation or to guarantee the rights, property or security of CROUZET.

We undertake not to transmit your Personal Data to other third parties unless:

(i) you have given your prior consent to share your Personal Data with third parties,

(ii) the sharing of your Personal Data with said third party is necessary for the provision of the products or services requested,

(iii) a competent judicial or administrative authority requires CROUZET to disclose to it the said Personal Data.

We ensure that, in terms of Personal Data, the Processors and/or partners we select undertake contractually to implement levels of protection equivalent to ours and in any event in accordance with the Regulations.

5.3. Transfer outside the EU

We strive to keep your Personal Data within the European Union. However, it is possible that your Data may sometimes be transferred outside the European Union through our subsidiaries, partners, Processors and/or service providers or third-party platforms.

Some of our subsidiaries are located in countries that have been subject to an adequacy decision (full or partial) by the European Commission which considers them to provide an adequate level of protection of Personal Data (UK, Switzerland, South Korea and Canada).

For other countries that are not considered to provide an adequate level of protection, CROUZET makes every effort to implement the necessary and sufficient guarantees to ensure the level of protection required by the Regulations (in particular, on a case-by-case basis, by the regularisation of contractual clauses based on the model of the European Commission, or any other mechanism compliant with the regulations on the protection of Personal Data).

6. How long will your Personal Data be kept for?

Your Personal Data is kept for as long as necessary for the Processing operations for which it was collected and in all cases in accordance with the legal provisions.

The period of retention of your Personal Data depends on the type of relationship you have with us and the purpose of the Processing. Detailed information can be found in the table below.

7. What rights do you have in relation to your Personal Data?

7.2. Right to rectification

You have the right to ask CROUZET to rectify your Data that is inaccurate, as soon as possible. You also have the right to ensure that incomplete Personal Data concerning you is supplemented, including by providing an additional declaration.

7.4. Right to restriction of Processing

You have the right to request the restriction of the Processing of your Personal Data when one of the following applies:

a) A verification of your Data is necessary after a challenge by you as to the accuracy of your Personal Data;

b) The Processing is unlawful and you object to the erasure of your Personal Data and instead demand the restriction of its use;

c) CROUZET no longer needs the Personal Data concerning you for the Processing, but the Data is necessary for you to establish, exercise or defend legal claims;

d) You have objected to the Processing and CROUZET checks whether the legitimate grounds pursued by it override your legitimate grounds.

7.5. Right to portability

You have the right to receive the Personal Data you have provided to CROUZET in a structured, commonly used and machine-readable format when cumulatively:

a) the Processing is based on consent or a contract;

b) the Processing is carried out by automated means.

As part of the exercise of this right, you have the right to obtain from CROUZET that your Personal Data be transmitted directly by CROUZET to another Controller where technically possible.

The right to portability must not infringe the rights and freedoms of third parties.

7.6. Right to object

Pursuant to the right to object, you have the right to object at any time, for reasons relating to your particular situation, to the Processing of Personal Data based on the legitimate interests of CROUZET.

CROUZET will no longer process your Personal Data unless it demonstrates that compelling and legitimate grounds for the Processing exist and override your interests and rights and freedoms or for the establishment, exercise or defence of your legal claims.

You have the right to object at any time to the Processing of your Personal Data for prospecting purposes.

7.7. Fate of Personal Data post-mortem

7.8. Your rights regarding your consent

If Processing of your Personal Data is subject to your consent, you may withdraw your consent at any time. Just send us an email at the following address: DPO@crouzet.com.

This withdrawal of consent does not affect the legality of any Processing of Personal Data carried out on the basis of your consent prior to its withdrawal.

Please also note that the Personal Data collected by CROUZET is collected to respond to your requests or to provide you with the services requested. Without this information, CROUZET will not be able to respond to your requests or provide the products or services requested.

8. How does one exercise one’s rights?

8.1. Terms and conditions for exercising rights

You can send your requests to the following addresses:

CROUZET

For the attention of the Data Protection Officer

12, rue Jean Jullien-Davin, VALENCE (26000)

DPO@crouzet.com

If CROUZET has reasonable doubts as to the identity of the natural person making the request, they may request additional information necessary to confirm his/her identity (e.g. a copy of their identity document).

To help you exercise your rights, you will find a template letter drawn up by the Commission Nationale de l’Informatique et des Libertés (CNIL) via the following link: https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces.

8.2. Response time

CROUZET has one (1) month to reply to you from receipt of your request. This period may be extended by (2) two months due to the complexity of your request and the number of requests made to it. CROUZET will inform you of the response within one month of your request.

You also have the right to lodge a complaint with the CNIL, the French supervisory authority (www.cnil.fr).

9. Cookies

9.1. Description

In particular, these cookies enable us:

• to draw up statistics on visits (in particular: the number of visits, page views), in order to monitor and improve the quality of our services;
• to adapt the presentation of our Website to the display preferences of your device;
• to ensure the optimised and problem-free provision of the Website;
• to improve the interactivity of the Website through social networks and to help promote through sharing;
• to enrich the website with multimedia content and increase its visibility;
• to memorise the information entered in the forms;
• to offer you targeted advertising.

When consulting our Website, cookies are placed on your computer, mobile or tablet.

Cookies are used to improve the services intended for you. Some are strictly necessary for the functioning of the Website, others are used to improve its performance, your user experience, i.e. those intended for statistics, those for social networks and finally those dedicated to advertising.

There are different types of cookies:

• Strictly necessary cookies: these are cookies essential to the use of the Website that enable you to use the main features and secure your access. These cookies may not be disabled or configured under penalty of no longer being able to access the Website and/or alter its display. Their lifetime generally does not exceed the duration of the session.
• Functional cookies: these cookies make it possible to optimise the functioning of the Website without being essential for its basic functioning. They often have a short lifespan.
• Audience and statistical cookies: analytical cookies make it possible to determine the number of visits and the sources of traffic, in order to measure and improve the performance of our Website and its use.
• Advertising cookies & social network cookies generated in particular by social network sharing buttons.

You will find the list of cookies on our Website below.

Strictly necessary and/or functional cookies

Analytical cookies: used to measure the platform audience to improve performance

Advertising cookies 

9.2. How does one manage one’s cookies?

No cookie will be installed on your device without your consent except those:

• strictly necessary for the provision of an online communication service expressly requested by you;
• the exclusive purpose of which is to enable or facilitate communication by electronic means.

The storage of a cookie by a third party is subject to your consent. We collect the latter when you connect to the Website by means of a cookie management tool which:

• presents the different types of cookies existing on the Website to you,
• requests your approval for each type of cookie installed.

When you first connect to the Website, you are informed of the use of cookies by the Website. A cookie consent screen gives you the opportunity to accept, refuse or personalise your choice.

You can change your choices at any time by accessing the “Cookies and data protection” tab at the bottom right-hand corner of the Website. Thus, you can:

• object to the use of these cookies on a general or one-off basis,
• be informed each time cookies are used,
• authorise, on a case-by-case basis, their use,
• delete them automatically or occasionally.

You will find explanations on how to configure your browser on the following websites:

https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser

https://www.aboutcookies.org

http://www.youronlinechoices.fr/.

In order to configure your browser software, you must refer to the help menu of your browser.

• Firefox™ https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Chrome™ https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=fr
• Internet explorer ™ https://support.microsoft.fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari™ https://support.apple.fr-fr/guide/safari/sfri11471/mac
• Opera™ http://help.opera.com/Windows/10.20/fr/cookies.html

Disabling cookies can reduce the quality of browsing.

10. The measures taken to ensure the security of your Personal Data

As Controller, we implement appropriate technical and organisational measures, in accordance with applicable legal provisions to protect your Personal Data against alteration, accidental or unlawful loss, unauthorised use, disclosure or access, and in particular by:

• raising awareness of the privacy requirements among our employees who have to access your Personal Data;
• securing access to our premises as well as physical and digital access to our IT systems and platforms;
• the internal implementation of a general CROUZET IT security policy;
• securing access, sharing and transfer of Data;
• a high degree of Data protection required when selecting our Processors and partners.

SSL or TLS encryption

For security reasons and in order to protect the transmission of confidential content, such as orders or requests you send to us, this Website uses SSL or TLS encryption. An encrypted connection is identifiable by the fact that the browser address line switches from “http://” to “https://” and the padlock symbol appearing on this line.

When SSL or TLS encryption is activated, the Data you transmit to us cannot be consulted by third parties.

11. Use of your Personal Data by third-party platforms

The Website may contain links to other websites. Similarly, other websites may refer to or contain a link to our Website. We have no control over these other domains and Websites. We invite you to read the privacy policies of each Website. We do not adhere to, verify, approve, nor are we responsible for the privacy practices or content of such Websites. If you visit other Websites, you do so at your own risk and are subject to their privacy policy.

You can also consult the CROUZET website using a private browsing mode.

11.1. Plug-ins/ General points about social networks

Our Website uses plug-ins (extension modules) published by third-party companies (e.g. Facebook, Youtube, Twitter, Linkedin, etc.).

If you interact using the plug-ins by clicking on the icons available on our pages, some of your Personal Data and in particular your browsing Data will be transmitted and saved on a server of the third-party company operating the social network corresponding to the icon on which you clicked. This Data will then be processed by this third-party company in accordance with its conditions and the settings of your account opened within this social network.

Your Data may in this respect be hosted outside the European Union and in particular in the United States.

If you do not want a third-party company operating a social network to link the Personal Data collected through the Website to your user account opened within the social network in question, you must log out of this social network before visiting the Website.

In any event, the use of these plug-ins is managed by third-party social network publishing companies and is exclusively governed by the conditions binding you to the social network to which you have signed up. We invite you to read the conditions applied by these third-party social network publishing companies.