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PERSONAL DATA PROTECTION POLICY

Dated 02/01/2020

Introduction

The protection of your personal data is of the utmost importance to VALLOUREC.

VALLOUREC takes all necessary precautions to ensure that your personal data is handled securely and in accordance with regulations when you are browsing its "Vallourec Mediacenter" media library (hereinafter referred to as "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 January 6, 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 Tubes, a company under French law entered in the Nanterre Trade and Companies Register under no. 411 373 525 with registered address at 27 avenue du Général Leclerc, 92100 Boulogne-Billancourt (France), (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 "Vallourec Mediacenter" media library.

1. Conditions for collection of Personal Data

VALLOUREC collects personal data either online (especially via collection forms when creating the account allowing access to the Site, downloading downloadable content, logging in, and emailing us) 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 sent via the Site

The cookies that we place on Your Terminal are exclusively technical cookies that enable the Site to work properly while you are browsing it. 

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

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"):

  • To enable interactive and personalized use of the Site;
  • To identify Your needs and to provide You with the most relevant services;
  • To monitor the proper functioning and security of our Site;
  • User account creation and management, particularly in cases of inactivity;
  • Access authorization and tracking of downloads (as well as their histories);
  • Monitoring document usage (searches and requests) on the mediacenter;
  • To give You access to all of the features and options offered by the Site and any other purpose associated with these and listed above;
  • Management of rights requests based on the GDPR and the French Data Protection Act, as amended.

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

The data subject is required to provide this information if they wish to benefit from the services of the mediacenter. If the data subject does not provide the information, they may not be able to benefit from the services of the Site.

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.

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 under the "Your rights to access Your Personal Data" section 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 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.

Furthermore, VALLOUREC will only share your personal data to authorized and identified recipients. In particular, VALLOUREC may provide access to your personal data to its potential service providers acting as subcontractors in order to perform services related to VALLOUREC's IT services and applications (hosting, storage, and computer maintenance in particular).

These third-party service providers only act on instructions from VALLOUREC and will be bound to the same security and privacy obligations as VALLOUREC. VALLOUREC is committed to choosing subcontractors located within the EU/EEA.

However, VALLOUREC needs to anticipate that in the future some recipients may be located in a country outside the EU/EEA that does not offer an appropriate level of data protection compared to that of European data protection. Where necessary, VALLOUREC will choose service providers who accept standard European contract clauses as approved by the European Commission and will require that they take all organizational and technical measures ensuring 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 consent 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 identified recipients (potential subcontractors, subsidiaries of the Vallourec group).

Some companies in the Vallourec group are located outside the European Union, in countries without personal data protection equivalent to European legislation. The Vallourec group has put the necessary safeguards in place to manage such transfers to a non-member country.

6. Security measures

VALLOUREC endeavors 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 it 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

27 avenue du Général Leclerc 92110 Boulogne Billancourt 

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 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.