Privacy and cookie policy

Smartengo Privacy and cookie policy - Dated January 29th, 2019.

Introduction

The protection of your personal data is of the utmost importance to VALLOUREC OIL AND GAS FRANCE (hereinafter called “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 "Smartengo" intranet site (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 OIL AND GAS FRANCE, a company under French law entered in the Valenciennes Trade and Companies Register under No. 384 627 170, with registered address at 54 rue Anatole France 59620 Aulnoye-Aymeries, (hereinafter "the Data Controller").

Definitions

The terms defined below will have the following meanings, whether used in the singular or the 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 different means 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", "User(s)" means any person accessing the Site and whose Personal Data can be collected during their visit to the Site.
  • "Site" means the Smartengo website.


1. Conditions for collection of Personal Data

VALLOUREC collects personal data either online (through the intermediary of Your Terminal using cookies, login data, during navigation on the Site's pages or via collection forms) or offline, and this personal data protection policy applies regardless of the method in 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 the personal data protection policy.

 1.1 Cookies

1.1.1 General

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

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

These cookies are placed during Your navigation 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, etc.), enabling us to continuously improve our services;
  • store information entered in various forms.

1.1.3 Cookies sent by third parties via the Site - Your choices with regard to cookies

Storage of a cookie remains down to you. 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 "Content 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 not responsibility for the content of third-party Sites or the practices of these third parties in relation to personal data protection.

For this reason, VALLOUREC invites you to familiarize yourself with the personal data protection policies of these third parties.

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

  • 2.1 Explicit and legitimate purposes

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"):

• Properly operate and continuously improve the Site, its functionalities and the service

Our valid interest in ensuring the best experience possible on our Site and the best quality possible for our service. The scope of our efforts to properly operate and continuously improve the Site and services includes:

  • Answers to your requests and questions,
  • Help-Desk and support services,
  • Tests and satisfaction surveys on the functionalities provided,
  • Utilizing Site user statistics,

The deposit of cookies and other tracking devices, details of which can be found in this policy.

• Management of the Clients

Our valid interest is to ensure the best possible commercial relationship with You, and to ensure the best quality of our services. This implies the collection of Your consent when it is required by current regulations, but also in terms of commercial prospecting, and cookies.

Customer relations management includes:

  • The execution of orders placed on our Site,
  • Contract management,
  • Business monitoring of the relations.

• Safety and prevention of illegal activities

The valid interest we pursue is to ensure the safety of our products and services and to prevent illegal activities.

The data subject is required to provide the data if he or she wishes to benefit from our products and services. If the data subject does not provide the data, he/she will not be able to place an order on our Site.

• Manage claims to rights granted by the French Computing and Civil Liberties Act as modified

VALLOUREC is bound by a legal requirement to process data.

You have a right of access, rectification, erasure and portability for your data or you may object to VALLOUREC processing some of your data (or request it be restricted), withdraw your consent if it is the legal basis for processing, or even decide what is done with your data that VALLOUREC processed once you are deceased. For more details, please refer to section 7 of this policy.

• Using Google Analytics

The processing is necessary for the valid interests we pursue, consisting in improving and optimising our Site for the benefit of Users. This processing is used for the purposes of analysis and statistical study of the use of our Site.

Google processes the data mentioned in its privacy policy:

  • https://support.google.com/analytics/answer/6004245?hl=en
  • https://policies.google.com/privacy?hl=en-GB#infocollect)

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

The data subject is not required to provide these data and may object at any time to their processing. In order to prevent the collection of data relating to the use of the Site and the processing of this data by Google, the data subject must comply with Google's instructions: https://tools.google.com/dlpage/gaoptout?hl=en-GB

  • 2.2 Collected Data

The information collected by VALLOUREC includes in particular Your surname, first name and professional contact details: postal address, email address and telephone number, employment.

The data subject is required to provide this data if he/she wishes to establish a business relationship to benefit from our products or services. If the person concerned does not provide the data, he/she will not be able to place an order on our Site

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 Article "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 communicates your personal data to authorized and determined recipients. In particular, VALLOUREC may give access to your personal data to its potential service providers acting as subcontractors to perform services relating to VALLOUREC's IT services and applications (hosting, storage, IT maintenance services in particular).

These third party service providers act only on instructions from VALLOUREC and will be bound by the same security and confidentiality obligations as VALLOUREC.

VALLOUREC is committed to selecting subcontractors who are located within the EU/EEA.

Nevertheless, we must anticipate that in the future recipients could be installed in a country outside the EU/EEA that does not offer an appropriate level of data protection compared to the European level of data protection.

If necessary, VALLOUREC will choose service providers who accept the standard European contract clauses as authorized by the European Commission and will require them to 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 determined recipients (possible subcontractors).

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 outside of 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.

However, 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: data.protection@vallourec.com.

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 personal data protection policy and the applicable rules on the subject.

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 OIL AND GAS FRANCE

for the attention of the Privacy Champion

54 rue Anatole France

59620 Aulnoye-Aymeries

Email: data.protection@vallourec.com

Furthermore, you have the right to oppose Your Personal Data being processed for legitimate reasons.

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 made immediately enforceable for 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 data.protection@vallourec.com or send a letter to VALLOUREC.