Segula Holding, a company incorporated under French law, registered in the Nanterre Trade and Companies Register under number 343 166 393, located at 19 rue d’Arras, 92000 Nanterre (hereinafter, the “Segula Technologies Group” or “we“) processes Personal Data (as defined hereinafter) in the context of its activity.

In accordance with the European Regulation 2016/679 of 26 April 2016 on the protection of personal data and the amended “Informatique et Libertés” law of 6 January 1978, the Segula Technologies Group, as the data controller, undertakes to implement adequate measures to ensure the protection, confidentiality and security of the Personal Data of any person from whom such Data is collected.

The purpose of this “Personal Data Protection Policy” (the “Policy”) is to inform all individuals browsing the https://www.segulatechnologies.com/fr/ website and/or one of its sub-domains (hereinafter the “Website”) and/or filling in the forms proposed on the said Website (hereinafter the “User(s)” or “you”) about the way in which the Segula Technologies Group uses the Personal Data collected and about the rights of the persons concerned.

“Personal Data” means any information relating to an identified or identifiable natural person. A person is “identifiable” if he or she can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors that are specific to his or her identity.

“Processing” of Personal Data means any operation, or set of operations, relating to such data, regardless of the process used (collection, recording, organisation, storage, adaptation, modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, matching or interconnection, blocking, erasure or destruction, etc.).

The Segula Technologies Group ensures that it collects and processes only Personal Data that is relevant, adequate, non-excessive and strictly necessary to achieve the previously determined purposes.

The Segula Technologies Group undertakes to obtain the consent of the persons concerned whenever this is required by the applicable legislation and to inform them of the Processing of their Personal Data and of their rights.

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

• Identification: surname, first name, title, job title, pseudonym, social network pseudo;
• Contact details: telephone, e-mail address, postal address;
• Professional life: universities, schools, degrees and courses taken ; Technical data: identification data (IP), connection data (logs in particular).

The Segula Technologies Group collects the Personal Data mentioned above in the course of the following operations:

• When Users browse the Site;
• When the User applies for jobs on the Site (Data collected via our service providers);

• When the User contacts the Segula Technologies Group via our contact

The compulsory nature of the information that you must provide is generally indicated at the time of collection of the Personal Data on the corresponding forms by an asterisk. Any failure to reply or any reply deemed abnormal by the Segula Technologies Group is likely to result in the refusal (or impossibility) of the Segula Technologies Group to take your request into account.

The Segula Technologies Group may offer you to provide certain Personal Data for prospecting/marketing communication purposes. You may explicitly and freely consent or not to the collection and Processing of your Personal Data for these purposes by means of a checkbox or by voluntarily and specifically providing your Data for this purpose.

You undertake to ensure that the Personal Data concerning you communicated to the Segula Technologies Group is up-to-date, accurate, complete and unambiguous.

The Processing implemented by the Segula Technologies Group meets explicit, legitimate and determined purposes.

Personal Data may be processed for the following purposes in particular:

• To analyse the browsing experience of Users and improve their experience;
  • In this context, the legal basis for the Processing is the legitimate interest of the Segula Technologies Group, more specifically its economic interest in constantly improving its Site and its activities, in offering you appropriate content and optimal browsing and in preserving the security of its tools.

• To answer any request from Users, made via our contact forms;
  • In this context, the legal basis for the Processing is either the execution of the contract if the request is linked to an existing contractual relationship between the Segula Technologies Group and you, or the legitimate interest of the Segula Technologies Group, more specifically its economic interest in establishing and maintaining a lasting relationship with its Users and in communicating simply and effectively with them.

• To process applications for our job vacancies via our service providers;
  • In this context, the legal basis for the Processing is the legitimate interest of the Segula Technologies Group, more specifically its HR interest in responding to your application requests and finding profiles suitable for the positions available within the Segula Technologies Group.

• To send Users information of an advertising nature concerning the Segula Technologies
  • In this context, the Processing is based on the legitimate interest of the Segula Technologies Group, more specifically its economic interest in informing you of its activities and in proposing personalised offers.

Depending on the purposes for which the Data are collected, the legal basis for the Data Processing may be :

• The consent of the data subject to the Processing ;

The Segula Technologies Group may give access to your Personal Data to any of its third-party service providers in order to carry out services relating to the Site and to the services of the Segula Technologies Group (in particular, IT service providers, providers of analytical solutions, marketing or advertising service providers, HR software providers for talent management).

The Segula Technologies Group may also be required to communicate to third parties the Personal Data collected if the law obliges it to do so or if the Group believes in good faith that such disclosure is reasonably necessary to comply with a legal procedure (for example, a warrant, a subpoena or any other legal decision) or to protect the rights, property or personal safety of the Group, our customers or the public, or as part of a restructuring of all or part of the Segula Technologies Group.

In such cases, the Group undertakes to provide only the information that the third parties need and to ensure that it complies with confidentiality and data security obligations similar to those of the Group.

The Segula Technologies Group retains Personal Data for as long as is necessary for the purposes for which it was collected.

• For Personal Data collected in the context of your requests/queries made via the Site: we retain your Data for the time necessary to process the said requests/queries and, if the latter relate to a contract between the Segula Technologies Group and you, for the duration of the contractual relationship plus 5 years (in the form of archives);

• For Personal Data collected when you consent to receive our advertising information: we retain your Data for a period of 3 years following our last contact with you;

• Candidate files are retained for 2 years from the last contact with the candidate unless you object to such a retention period and wish your Data to be deleted once the examination of your application is completed. Beyond this period, Personal Data is archived in accordance with the applicable statute of limitations;

• When cookies or other tracers are deposited on your terminal, they are kept in accordance with legal obligations and recommendations issued by the authorities (i.e. 13 months in France for cookies and tracers not essential to the operation of the Site).

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

In order to carry out its missions, the Segula Technologies Group may be required to communicate the Personal Data collected to its subsidiaries, service providers, clients or other third parties.

In the event of the transfer of Personal Data by the Segula Technologies Group outside the European Union, the Group undertakes to verify in advance that the entities outside the European Union, including the Group’s subsidiaries located outside the European Union, offer an adequate level of protection in accordance with European legislation. The location of the companies of the Segula Technologies Group is available on the website https://www.segulatechnologies.com/. The Segula Group undertakes in particular to sign with companies outside the European Union the Standard Contractual Clauses adopted by the European Commission when necessary. A copy of these clauses is available on request.

The Segula Technologies Group has put in place appropriate personal data protection measures to ensure that personal data is used in accordance with the purposes set out in Article 3 above.

In accordance with the applicable legislation on the protection of personal data, the persons concerned by the Processing of Personal Data have a number of rights concerning the collection and Processing of their Personal Data, namely:

• The right to be informed in a concise, transparent, understandable and easily accessible manner of how Personal Data is collected and processed;

• The right of access to Personal Data, which consists of the right to (i) obtain confirmation as to whether or not Personal Data has been collected and processed (ii) obtain access to and a copy of the Personal Data when it has been collected.
• The right to rectify and update incomplete or inaccurate Personal Data;
• The right to erasure of Personal Data; this right is not, however, an absolute right and the Segula Technologies Group may have legal or legitimate reasons for retaining said Data.
• The right to limit the Processing of Personal Data;
• The right to object at any time for specific reasons to the Processing of Personal Data carried out by the Segula Technologies It should be noted, however, that this objection may be refused for legitimate and compelling reasons requiring the continuation of the Processing;
• The right to portability, which consists of the possibility of receiving the Personal Data collected by the Segula Technologies Group and transmitting it to another controller; this right only applies when the Processing of your Personal Data is based on your consent or on the performance of a contract and the said Processing is carried out using automated processes.
• The right to transmit instructions concerning the use of the Personal Data after the death of the person concerned.

If you have any questions regarding the exercise of these rights, please send an e-mail to informatiqueetlibertes@segula.fr.

The Segula Technologies Group may use cookies.

When the User accesses the Site, he/she is informed of the presence of cookies. These cookies do not allow Users to be identified but are intended to record information relating to their browsing.

With regard to cookies related to social networks, they allow :

• Identify the User (login);
• Assign and identify a session number;
• Optimisation of the page rendering ;
• Counting the site’s likes on

Regarding cookies related to third-party analytics services, they allow :

• To distinguish between Users;
• To limit the rate of

When the User browses the Site, cookies are activated by default and data can be read or stored locally. The User will be informed when he/she first uses the Site and can decide whether to accept or refuse it. By continuing to browse the Site, the User expressly accepts the use by Segula Technologies of the cookies mentioned above. The User may choose to configure the browser so as to systematically refuse

cookies. However, if this is the case, certain functions and features of the sites may not function correctly.

To change your settings in relation to cookies, please click on the following addresses:

For Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer- delete-manage-cookies

For Safari: https://support.apple.com/fr-fr/HT201265

For Chrome: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en&safe=on

For                   Firefox:                  https://support.mozilla.org/fr/kb/activer-desactiver-cookies- preferences?redirectlocale=fr&redirectslug=activer-desactiver-cookies

For Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

The Segula Technologies Group takes care to protect and secure the Personal Data that has been communicated to it, in order to ensure its confidentiality and prevent it from being distorted, damaged, destroyed or disclosed to unauthorised third parties.

The Segula Technologies Group has taken physical, electronic, and organizational protective measures to prevent any loss, misuse, unauthorized access or distribution, alteration, or destruction of this Personal Data. However, despite the efforts of the Segula Technologies Group to protect Personal Data, the Group cannot guarantee the infallibility of this protection due to the unavoidable risks that may arise during the transmission of Personal Data.

As all Personal Data is confidential, access to it is limited to persons within the Segula Technologies Group who need to know it in the context of the performance of their duties. All persons having access to Personal Data are bound by an obligation of confidentiality and may be subject to disciplinary measures and/or other sanctions if they fail to comply with these obligations.

However, it is important for each User to be vigilant to prevent unauthorised access to the Personal Data in their possession.

Job postings are linked to our HR talent management and training software. Therefore, when the candidate is referred to this platform, the Personal Data processed and collected is in accordance with this Policy.

The Segula Technologies Group has no control over the content of third-party sites with regard to the protection of Personal Data that these sites may collect. Consequently, it is the responsibility of each User to find out about the Personal Data protection policies of the third-party sites concerned.

The Segula Technologies Group may update this Policy at any time to adapt it to applicable regulations and Group practices. In this case, the date of the Policy update will be updated and will indicate the day on which the modifications were made. In the event of substantial changes, we will inform you by any appropriate means.

If you have any questions about this Policy or if you have any requests concerning the Personal Data collected by the Segula Technologies Group, please send an e-mail to the following address: informatiqueetlibertes@segula.fr.