Data Privacy and cookies policy

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Introduction

The protection of your personal data is of the utmost importance to VALLOUREC (hereinafter "VALLOUREC"). VALLOUREC takes all of the necessary precautions to ensure that your personal data is handled securely and in accordance with regulations when you are on our site "www.vallourec.com" (hereinafter "the Site"). 

Therefore, VALLOUREC undertakes to collect and process your personal data in accordance with the provisions of the most recent version in force of the French Data Protection Act No. 78-17 of 6 January 1978 and with the provisions of European Regulation No 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "GDPR"). 

Your data is collected and processed by VALLOUREC (hereinafter "the Data Controller"). 

Definitions

The terms defined below will have the following meanings, whether used in the singular or plural: 

"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 elements specific to him or her. 

"Terminal" means the various media by which the Site will be accessible. Terminals include smartphones, tablets, online computers (PC or Apple) and any object that is connected or can be connected to another object or to the Internet. 

"You", "Your" and "User(s)" means any person accessing the Site and whose Personal Data can be collected during their visit to the Site. 
1. Conditions of collecting Personal Data 
VALLOUREC collects Personal Data either online (through the intermediary of Your Terminal using cookies, login data, during browsing on the Site's pages or via collection forms) or offline. This Personal Data protection policy applies regardless of the method by which Your Personal Data is collected. In the event of online collection, this personal data protection policy appears on the Site and, in the event of offline collection, You will be notified of the existence of this personal data protection policy. 

1.1 Cookies 
1.1.1 General 

When using the Site, information relating to Your browsing is likely to be recorded in "cookie" files stored on Your Terminal. 

A cookie is a file stored on Your Terminal that records information relating to browsing on a website. The data obtained in this way is used to facilitate subsequent browsing on said Site and can also be used to measure traffic. 

These cookies are placed during Your browsing on our Site, either by us directly or by our partners. (See "configuration of your cookies"). 

 1.1.2 Cookies sent via the Site 

The cookies that we send to Your Terminal enable us to recognize Your browser when You connect to the Site. 

These enable us to: 
  • produce visitor statistics (number of visits, pages visited, Your path, Your session duration, etc.), enabling us to continuously improve our services;  
  • store information entered in various forms (in particular contact, newsletter subscription and brochure request forms); 
  • obtain Your consent for the collection of Personal Data; 
  • store Your browsing preferences on the Site (preferred language). 

1.1.3 Cookies sent by third parties via the Site - Your choices with regard to cookies 
Storage of a cookie is Your choice. You therefore have the option to configure Your browsing software so that You can either completely or partially oppose the storage of "cookies" (in particular depending on the issuer). Configuration also allows You to accept or reject cookies on an ad hoc basis, before they are stored on Your Terminal. 

Therefore, given the purpose of cookies as indicated previously, any configuration intending to refuse the storage of cookies may affect Your browsing experience and/or the features and services and conditions for access to certain services that call for the use of cookies, such as, for example, ergonomic formatting of the Site suitable for Your Terminal. 

You can therefore choose to state and modify Your preferences with regard to cookies at any time as follows: 

For Chrome: click on the menu, then on "Settings" and display advanced settings. In the "Privacy and Security" section, click on "Site Settings" and under "Cookies", select the required level. 

For Mozilla Firefox: Click on the "Tools" menu, then "Options". Click on the "Privacy" icon, find the "History" menu and select "Use custom settings for history". Select the required level. 

For Microsoft Internet Explorer 11.0 and higher: choose the "Tools" menu, then "Internet Options". Click on the "Privacy" tab. Select the required level using the cursor. 

For Opera 6.0 and higher: in the main menu, select "Settings", then click on "Privacy & Security" in the side bar. Under "Cookies", select the options You require. 

For Safari: in the Safari menu, choose "Preferences" > "Security" or "Privacy" and select the options You require. 

1.2 Links to websites not controlled by VALLOUREC 
This Site may propose links to third-party Sites You may be interested in. Unless expressly authorized by you, VALLOUREC will not share any of Your Personal Data with these third parties. 

VALLOUREC has no control over the content of the third-party Sites or the practices of these third parties in relation to protection of the Personal Data they may collect, which is also out of VALLOUREC's control. As a result, VALLOUREC accepts no responsibility for the content of third-party Sites or the practices of these third parties in relation to personal data protection.  

2. Purposes of processing Personal Data – Nature of Personal Data collected 
2.1 Purposes of processing Personal Data 

In general, the legitimate interest of processing is based on the very nature of the service provided by VALLOUREC, which involves the collection of the Personal Data of Users and their consent. 

The processing of Personal Data by VALLOUREC through the Site is done for the following purposes (hereinafter the "Purposes"): 
  • The proper running and continual improvement of the Site, its functionalities and the service. 

Our legitimate interest is to ensure the best possible experience on our Site and the best possible service quality. 

Our monitoring of the proper running and improvement of the Site and Services covers: 
  • using statistics on Site usage; 
  • management of forms - subscriptions. 

The storing of cookies and other trackers, the details of which You can find in this policy and which can be configured in the Cookiebot tool. 
  • Managing requests to exercise rights resulting from GDPR and the amended French Data Protection Act. 
  • Processing is necessary in accordance with a legal obligation to which VALLOUREC is subject. 

You have a right of access to and of rectification, erasure and portability of Your data. You may object to VALLOUREC processing some of Your data (or request the restriction of processing) and withdraw Your consent when it is the lawful basis of the processing. You may define guidelines regarding the future of Your data processed by VALLOUREC after Your death. For further details, please refer to Clause 7 of this policy. 

  • Use of Google Analytics 

The processing is necessary for the purposes of our legitimate interests, consisting of improving and optimizing our Site for Users. This processing is used for the purposes of statistical analysis and study of our Site's usage. 

Google processes the data mentioned in its privacy policy: 
https://support.google.com/analytics/answer/6004245?hl=fr/ 
https://policies.google.com/privacy?hl=fr#infocollect) 

This data notably includes the IP address of devices used to visit the Site. 

Data subjects are not required to provide this data and they may object at any time to its processing. To prevent data collection related to their use of the Site and Google's processing of this data, data subjects should follow Google's instructions: http://tools.google.com/dlpage/gaoptout 

2.2 Data collected 

The information collected by VALLOUREC includes in particular Your IP address, user agent, and as appropriate, Your surname, first name and professional contact details: postal address, email address, telephone number and occupation. 

Processing of Personal Data includes in particular the use, storage, recording, transfer, adaptation, analysis, summarization, modification, declaration, sharing and destruction of the Personal Data according to what is necessary given the circumstances or legal requirements. 

3. Retention period for Personal Data 

The Personal Data collected is kept for the period required for fulfillment of the various Purposes described in the previous paragraph. 

Therefore, Your electronic identification and cookie-related Personal Data is kept for thirteen (13) months from when it was collected. 

The Personal Data collected is deleted should any of the following events arise: 
  • expiration of the retention period; 
  • exercise of Your right to delete in accordance with the French Data Protection Act, GDPR and conditions laid down in the Clause "Your rights to access Your Personal Data" of this personal data protection policy; 
  • deletion of the Site by VALLOUREC for any reason whatsoever. 

For log journals, the retention period is 1 year. 

4. Recipients and transfer of Personal Data 
In the event of access to the Site from a country outside of the European Union whose legislation or regulations relating to the collection, use and declaration of data differs from those of the European Union, please note that by continuing to use the Site, which is governed by French Law, the corresponding usage conditions and this personal data protection policy, You are agreeing to transfer Your Personal Data to the European Union. 

VALLOUREC only discloses Your Personal Data to authorized and specified recipients. In particular, VALLOUREC may allow its possible service providers acting as processors to access Your Personal Data in order to fulfill services related to VALLOUREC's services and computer applications (hosting service, storage, computer maintenance service). 

These third-party services only act upon VALLOUREC's instruction and will be bound by the same security and privacy obligations as VALLOUREC. 

VALLOUREC endeavors to select processors established within the EU/EEA. 

Nonetheless, we have to anticipate that in the future, recipients may be established in a country outside of the EU/EEA which provides no adequate level of data protection compared with the level of European data protection. 

As appropriate, VALLOUREC will choose providers that agree to the standard contractual clauses as authorized by the European Commission and require that they take all organizational and technical measures to ensure an adequate level of protection of Your Personal Data. 

5. Communication of Personal Data 
VALLOUREC is the sole recipient of the data collected. VALLOUREC will only send Your Personal Data to third parties in the following cases: 
  • You have given Your agreement for this information to be shared; 
  • VALLOUREC receives a request from a legal authority or any other administrative authority authorized by law and requesting this information in accordance with the legislative provisions in force; 
  • authorized and specified recipients (any processors, certain departments of the Controller or companies of the Vallourec group for communication purposes). 

6. Security measures 
VALLOUREC shall endeavor to protect Your Personal Data against damage, loss, misappropriation, intrusion, disclosure, alteration or destruction. 

VALLOUREC has put material, electronic and organizational measures in place to prevent any loss, misuse and unauthorized access, circulation, alteration or destruction of this Personal Data. 

Amongst these protection measures, VALLOUREC incorporates advanced technologies specially designed to protect Personal Data during transfer and to prevent transmission errors or unauthorized actions by third parties. 

Physical and electronic procedures are implemented to back up the Personal Data collected on the Site. 

VALLOUREC employees who, as a result of their position, would have access to Your Personal Data are committed to maintaining the utmost confidentiality. 

However, VALLOUREC cannot control all of the risks associated with Internet operation and draws Your attention to the existence of potential risks in terms of occasional loss of data or breach of confidentiality of the data passing through the Internet. The information provided on the Site may be interrupted in the case of force majeure events, events beyond the control of VALLOUREC or events for which VALLOUREC is not responsible. 

It is important that You exercise caution to prevent any unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and the information that appears in Your account. As a result, You must make sure that You close Your session if You are using a shared computer. 

VALLOUREC is committed to guaranteeing the protection of Personal Data. If You have reason to believe that the security of Your Personal Data has been compromised or that it has been misused, please contact VALLOUREC at the following address: [email protected] 

VALLOUREC will handle complaints concerning the use and disclosure of Personal Data and will attempt to find a solution in accordance with the principles of this policy and the relevant applicable rules. 

7. Your rights to access and correct Your Personal Data 
You have the right to access Your Personal Data. Furthermore, You have the right to ask for Your Personal Data to be corrected, completed, updated or deleted. You also have the right to obtain Your Personal Data held by VALLOUREC. You can exercise Your rights by sending Your request by email or by post to the address below, stating Your request and attaching proof of identity: 

VALLOUREC 
for the attention of privacy champion 
Legal department 
27 avenue du Général Leclerc 92100 Boulogne Billancourt 

Email: [email protected] 

Furthermore, You have the right to object, for legitimate reasons, to Your Personal Data being processed.  

8. Applicable law 
This personal data protection policy is governed by French law. 

9. Date of entry into force and Updating of the Personal Data protection policy 
Use of the Site is subject to the personal data protection policy in force at the time of use. 

VALLOUREC may modify the personal data protection policy according to its needs or if it is required to do so by the Law or regulations. These updates will be made without advance warning and will be circulated online. 

The previous personal data protection policy will then be terminated by operation of law and replaced by the new version, which will be immediately enforceable on any User from the date it is put online. 

10. Questions / Contact 
For any questions or comments relating to this personal data protection policy or about how VALLOUREC collects and uses Your Personal Data, please email us at [email protected] or send a letter to VALLOUREC. 
V.1.0 from the date of the 13/12/2019