Privacy Policy

HE NOVATION, SAS, the writer of the present document, implements the processing of personal data.

The personal data that is collected varies depending on how the services are used. The personal data collected or held is either directly provided by the individual him/herself or from third parties, or is collected from the activity on the website and the use of the services.

The manner in which data is collected and the details of how it is used are set out in this Privacy Policy

The Publisher: HE NOVATION, SAS.

The Site: All websites, web pages and online services offered by the Publisher on www.heraw.com.

The User: The person using the Site and/or the services.

Any person whose personal data has been collected and processed in the context of the implementation of this privacy policy has the following rights

⦁ the right to access their personal data;

⦁ the right to correct any errors in the files;

⦁ the right to have personal data erased, to limit their processing or to object to them;

⦁ the right to withdraw consent;

⦁ the right to object to receiving future marketing materials;

⦁ in certain circumstances, the right to ensure that such information is transferred to a third party;

⦁ the right to define general and specific directives defining the manner in which he/she intends the above-mentioned rights to be exercised after his/her death by e-mail to the following address contact@heraw.com by post to the following address HE NOVATION, 55 rue de la Boétie, 75008 PARIS, accompanied by a copy of a signed identity document.

In the course of using the Sites, the Publisher may collect the following categories of data about its Users:

⦁ Civil status and identity data: last name and first name(s)

⦁ Identification data: telephone number, e-mail address, IP address

On the basis of legal obligations, your personal data may be disclosed in application of a law, a regulation or by virtue of a decision of a competent regulatory or judicial authority. In general, we undertake to comply with all legal rules that could prevent, limit or regulate the dissemination of information or data and in particular to comply with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms.

The personal data that you communicate to us at the time of your order are transmitted to our suppliers and subsidiaries for the treatment of this one. This information is considered by our suppliers and subsidiaries to be strictly confidential.

If your personal data is disclosed to a third party, the third party's privacy terms and conditions apply.

In the event that we become involved in a merger, acquisition or other form of asset transfer, we are committed to maintaining the confidentiality of your personal data and to informing you before your personal data is transferred or subjected to new privacy rules.

If you connect your account to another service's account for the purpose of cross-mailing, that service may share your profile information, login information, and any other information you have authorized to be shared. We may aggregate information about all of our other Users, groups, and accounts with the personal data available about the User.

⦁ Sales and marketing prospecting

The following information is collected and processed: contact information, such as name, surname, telephone number, e-mail address.

The use of this information constituting personal data has the following purpose:

⦁ To send communications about products and services for commercial prospecting purposes.

These communications may take the form of an e-mail. This data is kept for canvassing purposes for a maximum of 3 years.

Where data has been collected in connection with the provision of a service or inquiry, information on similar or targeted services or inquiries based on previous requests may be sent, unless the data subject requests to stop or opts out of receiving such marketing communications. This data is kept for marketing purposes for up to 3 years after the data is collected.

Each time an electronic communication for commercial prospecting purposes is sent, the recipient has the possibility of choosing not to receive it in the future by means of an unsubscribe link. In addition, it is possible, at any time, to send an e-mail to the following address: contact@heraw.com, in order to ask to stop receiving these commercial communications.

The use of data and information as described above is permitted by the applicable regulations on the protection of personal data. In most cases, this processing of personal data for commercial prospecting purposes is based on the legitimate interest of the Publisher.

⦁ Online Questionnaire/Appointment

The following information is collected and processed: last name, first name, email, company name, and, if applicable, the elements provided in the online questionnaire.

The use of this information is made only in order to establish a contact with the person having filled in the online questionnaire and to propose him an appointment with an authorized person of the Editor to establish a personalized estimate without engagement and to ensure the follow-up after the contact. This contact will be made by e-mail.

The data collected when the completed online questionnaire is sent is kept for a maximum of 3 years.

The use of this information as described above is permitted under the applicable regulations for the protection of personal data. The processing of this personal data is based on the consent of the person concerned.

⦁ Within the framework of the services provided

The following information is collected and processed: name, first name, telephone number, e-mail address, position and company.

This information is collected for the execution of pre-contractual measures or of the contract with the Publisher, and, if necessary, for the implementation of a treatment having for finality: the canvassing, the production, the management, the follow-up of the requests and the files of its customers, the drafting of acts on behalf of its customers, the prevention of the laundering and the financing of terrorism and the fight against corruption, the invoicing and the accounting. All the elements necessary for these purposes are collected and processed.

This information is used to fulfill the purposes related to the requested services.

Such processing is authorized by the applicable regulations on the protection of personal data, and in all cases is based on the legal basis of the contract between the data subjects and the Publisher or on legitimate interest. Unless otherwise provided, the above information is necessary to fulfill our contractual obligations.

We use your electronic identifiers only for and during the execution of the contract.

Some of your device's technical data is automatically collected by the Site. This information includes your IP address, Internet service provider, hardware configuration, software configuration, browser type and language... The collection of this data is necessary for the provision of the services.

⦁ Cookie retention time

In accordance with the recommendations of the CNIL, the maximum duration of conservation of cookies is 13 months after their first deposit in the terminal of the User, as well as the duration of the validity of the consent of the User to the use of these cookies.

The lifetime of cookies is not extended with each visit. The User's consent must therefore be renewed at the end of this period.

⦁ Purpose of cookies

The Site uses cookie technology to improve the navigation and experience of users of the Site.

During the consultation of this one, these cookies can be recorded on the navigators of the support used, whatever the terminal (computer, tablet, Smartphone). They are used in particular at the time of the identification for analyses of the frequentation and the use of the elements of the site.

The information is used for statistical purposes, in particular to optimize the services provided to the User, based on the processing of information concerning the frequency of access, the personalization of the pages, the operations carried out and the information consulted.

You are informed that the Editor may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of consultation, etc.) which we can read during your subsequent visits.

⦁ User's right to refuse cookies

You acknowledge that you have been informed that the Publisher may use cookies. Visitors can decide to accept or refuse cookies when browsing the site. To this end, the Editor displays a banner on the Site inviting the visitor to accept cookies. As long as the visitor has not given his consent to the collection of cookies, no cookie can be deposited on his terminal, with the exception of cookies exempted from the collection of consent insofar as they are strictly necessary to provide a service expressly requested by the user.

The technical data are kept for the time strictly necessary to achieve the purposes mentioned above.

⦁ Retention of data for the duration of the contractual relationship

In accordance with article 6-5° of the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, the personal data being the subject of a treatment are not preserved beyond the time necessary to the execution of the obligations defined at the time of the conclusion of the contract or of the predefined duration of the contractual relation.

⦁ Retention of anonymized data beyond the contractual relationship / after account deletion

We keep personal data for the time strictly necessary to achieve the purposes described in this Privacy Policy. After this period, the data will be anonymized and kept exclusively for statistical purposes and will not be used in any way whatsoever.

⦁ Deleting data after account deletion

Means of data purging are set up in order to provide for the effective deletion of data as soon as the period of conservation or archiving necessary for the achievement of the determined or imposed purposes is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, the files and freedoms, you have moreover a right of suppression on your data which you can exert constantly by taking contact with the Editor.

⦁ Data deletion after 3 years of inactivity

For security reasons, if you have not logged in to the Site for a period of three years, you will receive an e-mail inviting you to log in as soon as possible, otherwise your data will be deleted from our databases.

User may delete his or her Account at any time by simply requesting the Publisher OR by using the Account deletion menu in the Account settings if applicable.

If you violate any provision(s) of the Privacy Policy or any other document incorporated herein by reference, Publisher reserves the right to terminate or restrict, without prior notice and in its sole discretion, your use of and access to the Services, your account and all Sites.

We undertake to implement all appropriate technical and organisational measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorised or illegal access, disclosure, alteration, loss or destruction of personal data concerning you. In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the risks identified above, we undertake to

⦁ Notify you of the incident as soon as possible;

⦁ Examine the causes of the incident and inform you;

⦁ Take reasonable steps to mitigate any adverse effects and damages that may result from such incident.

Under no circumstances may the commitments defined in the above point concerning notification in the event of a security breach be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

The Publisher undertakes not to transfer the personal data of its Users outside the European Union.

https://www.cnil.fr/fr/la-protection-des-donnees-dans-le-mondehttps://www.cnil.fr/fr/la-protection- data-in-the-world

The Publisher undertakes to offer you the possibility of having all your data returned to you on request. The User is thus guaranteed a better control of his data, and keeps the possibility of reusing them. This data must be provided in an open and easily reusable format.

This Privacy Policy was last updated on April 20, 2022. We reserve the right to change it at any time in order to provide updated information on how we collect and process data.

We will inform you of any material changes to this Privacy Policy, and will not lower the level of confidentiality of your data substantially without informing you and obtaining your consent.

Any person has the right to file a complaint with the CNIL.

All issues raised in this Policy and requests to exercise the rights of the person concerned are handled by the Data Protection Officer who can be contacted as follows: by e-mail at the following address contact@heraw.com by post at the following address 55 rue de la Boétie, 75008 PARIS.

Any request to exercise the rights of access, rectification, deletion or limitation of processing must be accompanied by a copy of the applicant's identity document.

This Privacy Policy and your use of the Site shall be governed by and construed in accordance with the laws of France, and in particular with Law No. 78-17 of January 6, 1978 relating to data processing, files and liberties. Your choice of law does not affect your rights as a consumer under the applicable law of your place of residence.

If you are a consumer, you and we agree to submit to the non-exclusive jurisdiction of the French courts, which means that you may bring an action relating to this Privacy Policy in France or in the EU country in which you live.

If you are a professional, all actions against us must be brought before the Commercial Court of Paris.

In the event of a dispute, the parties will seek an amicable solution before any legal action. In case of failure of these attempts, all disputes concerning the validity, interpretation and/or execution of the Privacy Policy shall be brought before the courts of the jurisdiction of the Paris CA, even in the case of multiple defendants or third party claims.