I. Personal data" section

Definitions:

• Customer: Any professional or capable natural person as defined in the French Civil Code, or legal entity, who visits the Site which is the subject of the present declarations.
• Content: All the elements making up the information on the Site, in particular text, images and videos.
• User: Internet user connecting to and using this Site.
• Site: This website is available at https://www.velum.biz/.

The terms "personal data", "data subject", "processor" and "sensitive data" have the meaning defined by the General Data Protection Regulation (GDPR: no. 2016-679).

2. General terms and conditions of use of the site and the services offered

The Site constitutes an intellectual work protected by the provisions of the French Intellectual Property Code and applicable international regulations. The Customer may not in any way reuse, transfer or exploit for his own account all or part of the elements or works on the Site.

Use of the https://www.velum.biz/ website implies full acceptance of the general conditions of use described below. These conditions of use may be amended or supplemented at any time, and Site users are therefore advised to consult them regularly.

This website is normally accessible to Users at all times. However, the Site owner may decide to interrupt it for technical maintenance purposes. In such a case, the Site owner will endeavour to inform Users of the dates and times of the intervention in advance. The website is updated regularly by the website owner. Similarly, the legal notices may be modified at any time: they are nevertheless binding on the User, who is invited to refer to them as often as possible in order to take cognizance of them.

3. Description of services provided

The purpose of the Website is to provide information concerning all of Velum's activities. Velum endeavors to provide information on the Site that is as accurate as possible. However, Velum cannot be held responsible for any omissions, inaccuracies or failure to update such information, whether caused by Velum or by third-party partners supplying such information.

All information on the Site is given for guidance only and is subject to change. Furthermore, the information on the Site is not exhaustive. It is subject to modifications having been made since it was put on line.

4. Contractual limitations on technical data

The Site uses JavaScript technology. The owner of the Site cannot be held responsible for any material damage linked to the use of the Site. Furthermore, Users of the Site undertake to access the Site using recent, virus-free hardware and with a last-generation, up-to-date browser. The Site is hosted by a service provider in the territory of the European Union in accordance with the provisions of the General Data Protection Regulation (GDPR: No. 2016-679).

The aim is to provide a service that ensures the highest level of accessibility. The host ensures continuity of service 24 hours a day, every day of the year. It nevertheless reserves the right to interrupt the hosting service for the shortest possible time, in particular for maintenance purposes, to improve its infrastructures, in the event of infrastructure failure, or if the Services generate traffic deemed to be abnormal.

The owner of the Site and the host cannot be held responsible in the event of malfunction of the Internet network, electronic communications networks, telecommunications networks, telephone lines or computer and telephony equipment, particularly in the event of network congestion preventing access to the server.

5. Intellectual property and counterfeiting

Velum is the owner of the intellectual property rights and holds the rights of use on all elements accessible on the Site, notably texts, images, graphics, logos, videos, icons and sounds. Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the Site, whatever the means or process used, is forbidden, except with the prior written authorization of the Site owner.

Any unauthorized use of the Site or of any of the elements it contains will be considered an infringement and will be prosecuted in accordance with the provisions of the French Intellectual Property Code.

6. Limitation of liability

Velum acts as the publisher of the Site.

Velum cannot be held responsible for any direct or indirect damage caused to the User's equipment when accessing and using the Site, and resulting either from the use of equipment, or from the appearance of a bug or incompatibility.

Velum cannot be held responsible for indirect damages (such as loss of market or loss of opportunity) resulting from the use of the https://www.velum.biz/ website . Interactive areas (possibility of asking questions in the contact area) are available to Users. Velum reserves the right to delete, without prior notice, any content posted in this area that contravenes French legislation, in particular provisions relating to data protection. Where applicable, Velum also reserves the right to hold the User civilly and/or criminally liable, particularly in the event of messages of a racist, insulting, defamatory or pornographic nature, whatever the medium used (text, photographs, etc.).

7. Management of personal data

The Customer is informed of the regulations concerning marketing communications, the law of June 21, 2014 for confidence in the Digital Economy, Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, as well as the General Data Protection Regulation (RGPD: No. 2016-679).

7.1 Persons responsible for processing personal data

Velum SAS, a SAS with share capital of €4,375,700, headquartered at Route de Molsheim 67870 Bischoffsheim represented by Mrs Anne VETTER-TIFRIT , its legal representative.

As the party responsible for processing the data it collects, Velum undertakes to comply with the legal provisions in force. Whenever Velum processes Personal Data, Velum takes all reasonable steps to ensure that the Personal Data is accurate and relevant to the purposes for which Velum processes it.

7.2 Purpose of data collected and legal basis

Velum may process all or part of the data collected from this Site for the following purposes, which are based on :

1. The User's consent
   • To improve navigation on the Site: connection and usage data.
   • To conduct optional satisfaction surveys on https://www.velum.biz/: email address.
   • For communication campaigns (SMS, e-mail): telephone number, e-mail address.
   • To build up a CV-library of CVs transmitted via the Site.
2. As part of the performance of a contract or pre-contractual measures
   • To respond to all applications for employment with Velum and implement the recruitment procedure.

Velum does not sell your personal data, which is therefore only used by necessity or for statistical and analysis purposes.

7.3 User rights and exercise of rights

In accordance with current European regulations, Site Users have the following rights:

• Right of access (article 15 RGPD).
• Right to rectify Personal Data concerning them (Article 16 RGPD), when they are inaccurate, incomplete, equivocal, outdated.
• Right to erasure of their Personal Data (Article 17 of the RGPD).
• Right to withdraw their consent at any time, where the purpose of the processing is based on their consent (Article 13-2c RGPD).
• Right to limit the processing of their data (Article 18 RGPD).
• Right to object to the processing of their data, particularly in the context of commercial prospecting (Article 21 RGPD).
• Right to data portability, where data is subject to automated processing based on the User's consent or on a contract (Article 20 RGPD).
• The right to define the fate of their data after their death and to choose to whom Velum should communicate (or not) their data to a third party that they have previously designated.

As soon as Velum becomes aware of the death of a User and in the absence of instructions from the User, Velum undertakes to destroy the User's data, unless it is necessary to keep such data for evidentiary purposes or to comply with a legal obligation.

Any User may exercise their rights by simple letter sent to Velum [Specific address] or by email addressed to the RGPD referent: [Specific email address].

In the event of reasonable doubts as to the identity of the data subject, the latter is hereby informed that Velum may ask for proof of identity in order to ensure the exact identity of the person making any request and to avoid the communication of data to an illegitimate third party.

If, after contacting Velum, the User considers that his/her rights have not been respected, he/she may refer the matter to the Commission Nationale de l'Informatique et des Libertés (CNIL) by letter sent to the address 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 or on its dedicated online form.

7.4 Data transfer outside the EU

Velum will not process, host or transfer Personal Data processed by this Site about its Customers to a country outside the European Union or recognized as "non-adequate" by the European Commission without prior notice to the User.

7.5 Recipients

The User's Personal Data may be processed and communicated:

• In-house: by authorized personnel, depending on the purpose of the data processing.
• Externally: by https://www.velum.biz/ subsidiaries and subcontractors (hosting providers for the Site and Site data), exclusively in order to achieve the purposes of the present policy.

7.6 Incident notification

Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. We therefore cannot guarantee absolute security. Should we become aware of a breach of security, we will notify the Users concerned so that they can take appropriate action. Our incident notification procedures take account of our legal obligations, whether at national or European level. We are committed to keeping our Customers fully informed of all matters relating to the security of their account, and to providing them with all the information they need to help them meet their own regulatory reporting obligations.

No personal information concerning the User of the https://www.velum.biz/ website is published without the User's knowledge, nor is it exchanged, transferred, assigned or sold on any medium whatsoever to third parties. Only the assumption of the purchase of Velum and its rights would allow the transmission of the said information to the eventual purchaser who would in turn be bound by the same obligation of conservation and modification of the data vis-à-vis the User of the https://www.velum.biz/ site .

7.7 Safety

To ensure the security and confidentiality of Personal Data, Velum uses networks protected by standard devices such as firewalls, pseudonymization, encryption and passwords. When processing Personal Data, Velum takes all reasonable measures to protect it from loss, misuse, unauthorized access, disclosure, alteration or destruction.

7.8 Shelf life

Data is kept in accordance with the statutory limitation periods and, failing this, for the following periods:

7.9 Mandatory or optional

The provision of Personal Data is optional except for those fields marked with an asterisk, for which the provision of Personal Data is mandatory, failing which Velum will be unable to respond to the User.