In accordance with our philosophy, we consider the protection of your personal data to be essential and we wish to inform you via this general privacy policy ("Privacy Policy") on how we gather and process your personal data.

GLOSSARY

In the privacy policy, unless provided otherwise, the following expressions and words have the meanings indicated respectively hereinafter :

Interim Archiving : means the insolating via a logical (management of access rights and of clearances limited to a specific service) and/or physical separation of Personal Data which still have an administrative interest for Weka France.

CNIL : means the la Commission Nationale de l’Informatique et des Libertés.¹

Personal data : any information relating directly or indirectly to you as a natural person.

Entity : entity of WEKA France with which you have contracted/plan to contract a Product and/or Service and which Processes your Data.

Products : documentary or information products, in particular works, des publications, sheets, updates, in paper or digital format published or distributed by WEKA France.

Regulations : means the French Data Protection Act of 6 January 1978 (la Loi n°78-17 du 6 janvier 1978 relative à l’informatique, aux fichiers et aux libertés) as amended, the (EU) Regulation 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and which repeals directive 95/46/EC (hereinafter "GDPR") as well as any current regulations relating to the protection of Personal data.

Services : occupational training, advice and support services, software solutions, any documentary service by telephone, service offering access to community spaces, content services related to jobs.

Website : means the websites published by WEKA France.

Terminal : means the physical device (computer, tablet, smartphone, telephone) that you use to consult or which shows the Website.

Processing : means the gathering, recording, organisation, structuring, retention, adaptation, or modification, extraction, consulting, use or any other form of availability, reconciliation or inter-connection, limitation, deletion and destruction.

WEKA France : means separately any Entity (Entities) of the WEKA France group which include to date, les Editions WEKA SAS, les Editions TISSOT SAS, les Editions TI. SAS, COMUNDI SAS, CMT SARL and WEKA Services SARL.

These definitions are capitalised and are understood in the singular or in the plural.

1. Scope of the Privacy Policy

The Privacy Policy applies to all Websites, Products and Services published and distributed by WEKA France.

In consequence, the use of a Website or the contracting of Products and Services published and distributed by WEKA France implies that you have accepted all of the terms of the Privacy Policy and thus the gathering, use and transfer of your Personal data.

2. Privacy players within WEKA France

The Entity is the processing officer for the Processing that it implements for Products and Services.

WEKA France has appointed a panel of GDPR referrers, the contact officer dedicated to privacy within WEKA France and with its relations with third parties. You may contact said panel by sending an e-mail to the following address: [email protected].

3. Type of Personal Data gathered by WEKA France

WEKA France takes account of the principles of reducing data, of data protection as from design and of data protection by default. In consequence, relevant and adequate information, limited with regard to what is necessary, is gathered for the processing purposes.

3.1 Personal data gathered

WEKA France gathers and processes, in particular, your last name, first name, your position within the organisation and the reporting department, your work telephone number, your work e-mail address and for community spaces and services related to jobs, your work or personal contact details depending on your choice, as well as your CV is you so wish.

WEKA France undertakes not to gather Personal data without first having informed you of the use that will be made thereof.

Moreover, cookies ("Cookies"), to wit small text files which record certain information to facilitate your browsing experience are placed on your Terminal when you browse the Website.

Subject to the setting of your Terminal, WEKA France uses the following Cookies :

• Browsing Cookies : Cookies needed to browse the Websites. These Cookies allow WEKA France to properly operate the Websites.
• Functionality Cookies : Cookies to store your chosen preferences and settings to afford you a fluid user experience. For instance, they allow you to directly access personal spaces on Websites without having to key in your login settings several times or to store your purchases in the basket.

Subject to your consent, WEKA France may place the following Cookies :

• Audience measurement Cookies : Cookies to monitor your browsing in order to draw up browsing statistics and to monitor the performances of Websites and of each of their pages. Said Cookies allow us to improve our services in order to provide a better user experience.
• Targeting/advertising Cookies : Cookies to propose content and advertising adapted to your requirements taking account, in particular, of your preferences and your last purchases.

Said Personal data is gathered in particular when :

• You fill in online forms;
• Your upload online content;
• Your create or modify your customer account in the dedicated space of one of the Websites;
• You pay for an order or a subscription;
• You browse one of the Websites;
• You contact the WEKA France customer care department;
• You download a white paper or any documentation on one of our Products and/or Services;
• You request a demonstration of a Product and/or Service or an estimate;
• You take part in an event, a conference or a webinar;
• You register with a community Website;
• You respond to a job offer.

3.2 Use of Cookies

Any setting you make is liable to modify your browsing of the Internet and your conditions of access to certain services that require the use of Cookies.

3.2.1 Consent to Cookies

You do not run any risk when you accept use of said system. Cookies do not damage your computer.

The recording of a Cookie on a Terminal is essentially subject to your consent. You may express and modify your choices in the browsing software of your Terminal at any time and free of charge.

If you accept the recording of Cookies on your browsing software, the Cookies integrated in the pages and content that you have browsed may be temporarily stored – without being longer than thirteen (13) months – in a dedicated space of your Terminal. Only the issuer thereof can read them.

3.2.2 Refusal of Cookies

If you refuse the recording of Cookies or if you delete those recorded thereon, you can no longer enjoy a certain number of functionalities which are nevertheless needed to browse certain spaces of our Website (if you try to access our content or services for which you need to be identified).

Where applicable, we disclaim any liability for the consequences of the deteriorated operating of our Services when it is impossible for us to record or browse the Cookies needed to operate them and which you have refused or deleted.

4. Processing Purposes

4.1 Based on the contract or on pre-contractual measures :

The Entity carries out operations relating to the management of pre-contractual relations and, in particular :

• Sending estimates,
• Taking appointments and
• Free tests.

The Entity carries out operations relating to the management of commercial relations and in particular :

• entering into, management, supply, delivery and billing of contracted Products and/or Services,
• monitoring of the customer relationship,
• accounting,
• management of complaints, payment incidents or unpaid accounts, and
• management of your requests for access, rectification, objection, deletion, limitation and portability of Personal data.

4.2 Based on WEKA France’s legitimate interest :

The Entity carries out the following Processing operations :

• Characterisation of customer profiles and analysis of your purchase preferences;
• Improvement of our Products and Services by inviting you to take part in satisfaction surveys;
• Training of WEKA France staff;
• Elaboration of analytical studies and of commercial statistics;
• Bringing or defending a right in court;
• Sending commercial or promotional canvassing relating to the Products and Services of the Entity. You may object at any time, without expense, to your Personal data being used for canvassing, without having to give reasons for said request, by sending your request to WEKA France via our dedicated portal. WEKA France draws your attention to the fact that the exercise of the right of objection does not prevent Entity from continuing to contact you for other purposes, in particular, under a legal obligation or to perform the contract.
• Improvement of the relevance of information sent.

Based on your express consent :

The Entity carries out the following Processing operations :

• Registering for newsletters or web conferences proposed by WEKA France,
• Registering on a community Website,
• Transfer of applications to a potential employer,
• Downloading of content,
• Requests for information on Products and Services published and distributed by WEKA France,
• Registering for competition games,
• Exchange of your Personal data with our partners and WEKA France entities with which you have not contracted any Product and Service to inform you of products and services that might be of interest to you (by letter, telephone and electronic messaging).

In this framework, you may withdraw your consent at any time; however, said withdrawal will not impair the legality of Processing by WEKA France prior to said withdrawal.
WEKA France is also liable to use your Personal data for administrative purposes or for any other goal imposed under Regulations.

You are informed of a "Bloctel" cold-calling blocking list on which you can register here: https://conso.bloctel.fr/.

5. Personal Data retention period

Your identification data is kept for commercial canvassing for a three (3) year period at most as from the date of the last performance of the service / delivery of Products or the last "active" contact with the Entity (example of active contact: opening of a link (click) from an e-mail).

In the special case of community spaces, personal data is retained during the entire term of the existence of the member’s account and for a one year period at most after the closing of said account.

In the event of litigation proceedings, regardless of the reason thereof, for instance, with regard to the authorities, your Personal Data as well as all information, documents and exhibits containing Personal Data may be retained for the duration of the proceedings, including for a period longer than that mentioned above.

Other data and, in particular, data related to your orders are the subject of Interim Archiving for the statutory or regulatory limitation periods.

WEKA France undertakes to delete Personal Data from its bases at the end of said period or to anonymise it.

Moreover, your Personal Data gathered via Cookies are retained only for a thirteen (13) month period as from the gathering of said Data.

6. Recipients of your Personal data

WEKA France never transfers your Personal Data to third parties who are liable to use it for their own purposes, in particular, for commercial and/or direct advertising purposes, without your express consent.

The Entity may have to share your Personal Data only insofar as necessary, with :

• Its employees authorised to process your Personal data;
• The other WEKA France Entities with which you have already contracted a Product and/or Service : You are informed that such Entity may contact you, in particular, for commercial canvassing, by a means of communication (email / telephone) gathered by another Entity.
• The other WEKA France Entities with which you have not contracted a Product and/or Service and their employees : The WEKA France Entity with which you have contracted a Product and/or Service may have to share in a secure way your Personal data with other WEKA France Entities for the operating of the Products and Services, in particular, for logistics purposes and, if you have agreed thereto, for commercial canvassing purposes;
• Its service providers and sub-contractors bound by contract for the performance of tasks related to the aforementioned purposes;
• Organisations responsible for carrying out surveys or polls;
• The public authorities : the Entity may be compelled to communicate your Personal data in response to a specific request made by a proper administrative or court authority as well as more generally in all situations where the law, regulations or an administrative or court decision so requires.
• Other third parties : if you have expressly consented thereto, we will provide your Personal data to carefully selected third parties, including partners for the marketing of services which may be of interest to you, or to third parties with which you have contracted or accepted a service from us.

Moreover, in the event of reorganisation, merger, sale, joint venture or other transfer or assignment of all or some of our business, we may happen to communicate or transfer your Personal data to the successor in business.

7. Storage of your Personal Data

Your Personal data is stored on WEKA France’s data bases or on those of service providers and sub-contractors bound by contract with WEKA France in the European Union.

8. Security of Personal data

WEKA France undertakes as part of its business and in accordance with Regulations to ensure the protection, the confidentiality and security of Personal data.

WEKA France takes the necessary precautions in light of the state of knowledge, implementing costs and nature, scope, context and purposes of Processing as well as of the probability of each risk in order to protect the security and confidentiality of Personal Data that you communicate to it and in particular to prevent it being distorted, damaged or communicated to third parties (unless with your consent).

Therefore, WEKA France implements all technical, software, physical and organisational measures to guarantee a level of security adapted to the risk and to avoid any loss, alteration, disclosure of Personal Data or access to unauthorised persons.

However, considering the intrinsic characteristics of the Internet, any transfer of information by Internet is not totally secure. The Personal Data that WEKA France transfers is the subject of measures which cannot avoid all risks of hijacking and/or piracy. WEKA France cannot guarantee the protection of your Personal Data from the inherent risks of the Internet.

In the event of infringement of Personal Data and in accordance with the Regulations, WEKA France undertakes to notify it to the CNIL.

9. Transfers of Personal Data

The Data gathered by WEKA France may, under the aforementioned purposes, be transferred to a country outside the European Union covered by an adequacy decision of the European Commission towards to the sole self-certified US undertakings under the Privacy Shield agreement and first entered on the register kept by the US authorities for said purpose as well as to a country outside the European Union and not covered by an adequacy decision of the European Commission, subject to suitable guarantees compliant with the GDPR have been provided for.

10. Your rights

In accordance with current Regulations, you have :

• A right of access : right to question the Entity to ascertain if it has your Personal Data and to request disclosure thereof.
• A right of rectification : right to request the Entity holding your Personal Data to rectify it in the event of errors or inaccuracies.
• A right of objection : right to refuse, for legitimate reasons, to appear on a file, apart from the commercial canvassing file where a reason is not required.
• Rights relating to digital death : right to define general or special instructions relating to the retention, deletion and communication of your Personal Data after your death, which may be recorded with a digital trusted third party certified by the CNIL. Said instructions may appoint a person responsible for exercising the rights; otherwise, your heirs will be appointed.
• A right to the limitation of the processing : right to request that certain Personal Data not be retained upon future Processing.
• A right to deletion : in the cases provided for under the Regulations, right to obtain the deletion of Personal data.
• A right to the portability of your Personal data : right to obtain, where applicable, that WEKA France transfer your Data to another processing officer.

You may exercise your rights by sending your request to WEKA France via the dedicated portal.

You may also file an application before the proper courts, without prejudice to your right to submit a claim to la Commission Nationale de l’Informatique et des Libertés if you consider that you have been the victim of a violation of the regulations relating to the protection of Personal Data.

11. Modification of our Privacy Policy

We reserve the right to modify our protection Policy. Any modification will be published on the Website. Any use of the Website after the date of modification implies your unreserved acceptance of the new Privacy Policy.

---

¹ French Data Protection Board [translator]