Personal data proctection policy

Dernière mise à jour : 14 / 02 / 2020

Eurazeo SE, a company incorporated under French law and registered with the Paris Trade and Companies Registry under no. 692 030 992, located at 1 rue George Berger, 75017 Paris, France or any other Eurazeo entity worldwide (Luxembourg, United States, China and Brazil) (hereinafter “Eurazeo”) processes personal data (“Personal Data” as defined hereinafter) as part of its activity.

Pursuant to EU regulation 2016/679 of April 27, 2016 (the “General Data Protection Regulation” or “GDPR”), the purpose of this policy is to inform natural persons (“You” or “Your”) on how Eurazeo collects and uses such Personal Data and the resources you have available to control such use, the manner in which Eurazeo communicates such data to third parties when necessary, and in what circumstances and how Eurazeo keeps this Personal Data confidential.

1. Scope of application for this personal data protection policy

Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to that natural person (hereinafter the “Personal Data”).

This data protection policy (hereinafter the “Policy”) sets out the principles and guidelines applicable to all Personal Data processed by Eurazeo for various categories of persons whose data is collected and processed by Eurazeo, i.e. website visitors, service providers, shareholders, co-investors, heads of companies in which Eurazeo plans to invest, with the exception of its employees and persons applying for a position at Eurazeo.

Eurazeo collects and processes Personal Data in the following situations:

– when You browse its website;
– when You complete the form to register for Eurazeo web conferences and watch web conferences;
– via social media platforms (Facebook, Twitter, LinkedIn and Youtube);
– when You take part in a competition or event organized by Eurazeo;
– during discussions between You and Eurazeo, particularly those that take place in Eurazeo’s offices or during meetings or trade fairs, interviews;
– during communications with Eurazeo by telephone, e-mail or any other means.
 E.g.: information submitted to Eurazeo studies and surveys conducted for research purposes.
– when Eurazeo hires You as part of a service agreement;
– when You wish to invest in a portfolio company alongside Eurazeo;
– when You become a Eurazeo shareholder and during the entire time that You remain a Eurazeo shareholder;
– when Eurazeo plans to invest in one of the companies that You manage or in which You are one of the main executives.

This Policy is applicable regardless of how Your Personal Data is collected or processed.

2. What personal data is used by Eurazeo, why is it used and what legal basis is it processed?

You will find below, according to your status (website user, shareholder, co-investor, service provider, etc.), information on how your data is used (purposes of processing), as well as the legal basis justifying such processing in accordance with the applicable regulations.

2.1. When brewsing the Eurazeo website, you complete a contact form to receive Eurazeo press releases or access a web conference organised by Eurazeo

What Personal Data is used?

The information that You disclose to Eurazeo may involve Your identification, particularly Your surname, first name, postal address, the company You work for or represent, Your e-mail address and Your telephone number, information regarding the request You are sending Eurazeo and may also include recordings relating to our correspondence and Your responses to various surveys.

The information You must disclose to Eurazeo is marked with an asterisk.

Some of your Personal Data may be collected automatically, including:

– Technical information, including anonymous data collected by the host server for statistical purposes, the IP (Internet Protocol) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. Refer to the section on cookies for further information on the collection and use of such data;
– Any Personal Data that you agree to share and which features in your public profile on a third-party social network. This data mainly includes Your identifiers (surname, first name, IP address and information that you allow social networks to share with their partners).

Eurazeo obtains some of Your Personal Data from sources outside of the company, including in other entities held by Eurazeo or other third-party entities, such as audience measurement service providers.

For what purposes is it used?

This Personal Data is used to:

– ensure communication and/or the exchange of information with Eurazeo website users;
– communicate with You and send you our press releases (external information and communications relating to our business and that of our portfolio companies);
– enable you to access and follow a web conference and conduct statistical analyses, particularly audience measurement, to develop and improve the web conferences.

On what legal basis is it processed?

This processing is:

– partly necessary to fulfill a contract, especially when you send us a request which we answer or when we provide you with a service that enables you to access our website or a web conference;
– partly necessary to pursue Eurazeo’s legitimate interests, when we send you press releases. or information on how Eurazeo assesses its legitimate interest, please contact us at the following e-mail address: legal@eurazeo.com.

2.2. When you take part in a competition or event organized by Eurazeo

Eurazeo may organize competitions or events and specifically it organizes an annual photo competition with varying themes.

What Personal Data is used?

In these instances, the following Personal Data is collected: surname, first name, address, postal code, city/town, telephone; e-mail, surname, first name, telephone, possibly the company you work for or represent.
For the photo competition, the previously mentioned information is collected as well as the following Personal Data: age, e-mail address of the representative where necessary, photograph, CV.

For what purposes is it used?

The Personal Data collected on this occasion is processed in order to:
– manage your participation in the competition or event organized by Eurazeo;
– communicate with you on this occasion;
– manage communications with the prizewinner;
– manage the allocation of the prize money, the use of the competition winner’s photos;
– satisfy the legal and regulatory obligations incumbent upon the competition or event organizer.

On what legal basis is it processed?

This processing is:
-partly necessary to fulfill a contract, particularly Personal Data that is strictly required to manage the organization of the event or determine and communicate with the prizewinner;
– partly based on your consent.

2.3. When you a Eurazeo Shareholder

When you become a Eurazeo shareholder, your Personal Data is collected and processed whether you are:

– a bearer shareholder;
– a registered shareholder (in this case, your data will be collected by BNP Paribas Securities Services).

What Personal Data is used?

On this occasion, the following Personal Data is collected: your identifiers, mainly your surname, first name, postal address, e-mail address; number of shares, type of shares; type of shareholder (employee shareholder, directly or intermediary registered shareholder, bearer shareholder, member of shareholder agreements).

For what purposes is it used?

The Personal Data collected on this occasion is processed in order to:
– get to know all Eurazeo shareholders, with either bearer or registered shares;
– manage relations with shareholders, particularly in connection with the regular transmission of Eurazeo updates and information;

On what legal basis is it processed?

This processing is:

-partly necessary to fulfill a contract to which the relevant persons (shareholders) are party;
– partly necessary to pursue Eurazeo’s legitimate interests in order to get to know and communicate with its shareholders. For information on how Eurazeo assesses its legitimate interest, please contact us at the following e-mail address: legal@eurazeo.com;
– partly necessary to comply with legal obligations as the issuer of securities;

2.4. When you wish to invest alongside Eurazeo

What Personal Data is used?

On this occasion, the following Personal Data is collected: your identifiers, mainly your surname, first name, postal address, e-mail address; telephone number; financial data, particularly amounts invested, date of the investment, number of shares held.

For what purposes is it used?

The Personal Data collected on this occasion is processed in order to:

-manage relations with Eurazeo’s investors or potential investors;
– communicate with our investors or potential investors, particularly in connection with the regular transmission of Eurazeo updates and information.

On what legal basis is it processed?

This processing is:

– partly necessary to fulfill a contract to which the relevant persons are party;
– partly necessary to pursue Eurazeo’s legitimate interests to communicate with its investors and potential investors. For information on how Eurazeo assesses its legitimate interest, please contact us at the following e-mail address: legal@eurazeo.com.

2.5. When Eurazeo plans to invest in one of the companies in which you are one of the managers or main executives

What Personal Data is used?

On this occasion, the following Personal Data is collected: your identifiers, mainly your surname, first name, postal address, e-mail address; telephone number; financial data, particularly compensation.
Eurazeo obtains some of Your Personal Data from sources outside of the company, including in other entities held by Eurazeo or other third-party entities, such as service or business providers.

For what purposes is it used?

The Personal Data collected on this occasion is processed to manage audit operations (due diligences) in connection with potential Eurazeo investments in the company in which you are one of the managers or main executives.

On what legal basis is it processed?

This processing is necessary to pursue Eurazeo’s legitimate interests. For information on how Eurazeo assesses its legitimate interest, please contact us at the following e-mail address: legal@eurazeo.com.

2.6. When you are one of Eurazeo’s service providers

What Personal Data is used?

On this occasion, the following Personal Data is collected: identifiers of the contact within the company acting as Eurazeo service provider, mainly his or her surname, first name, postal address, e-mail address; telephone number; information on the company acting as service provider; financial data associated with the contractual relationship: invoices, bank details, payment data; data collected and processed as part of supplier assessments pursuant to the applicable legislation, and particularly in France, the Law on transparency, anti-corruption and the modernization of the economy (“Sapin II law”).

For what purposes is it used?

The Personal Data collected on this occasion is processed in order to:

– manage the contractual relationship with our service providers, i.e. manage the contract, orders, deliveries, accounting, payments, and more generally, monitor the contractual relationship by regularly communicating with the service provider;
– satisfy Eurazeo’s legal obligations, particularly its tax and anti-corruption and money laundering obligations and meet the requirements of the Sapin II law in France.

On what legal basis is it processed?

This processing is:
– partly necessary to fulfill the contract between Eurazeo and your company;
– partly necessary for Eurazeo to comply with its legal obligations and especially its tax and accounting obligations and those relating to the Sapin II law.

2.7. Possible processing for any category of persons covered by the Policy

For all categories of persons covered by this Policy, Eurazeo may also be required to set up processing in order to:
– detect, prevent and reduce fraud or other illegal activities; 
– safeguard the network and information systems that enable us to protect your Personal Data from risks of loss or deterioration, theft or unauthorized access;
– reply and/or assist a public authority or body with an ongoing investigation or ongoing legal proceedings in accordance with applicable regulations;
– verify the accuracy of your data in our possession, so that we can then grant the requests that you may submit in accordance with Section 6 of this Policy.
 
This processing may involve all the Personal Data collected by category of persons and is:
– partly based on Eurazeo’s legitimate interest, insofar as this processing is of benefit to Eurazeo but does not infringe upon your interests and fundamental rights. For information on how Eurazeo assesses its legitimate interest, please contact us at the following e-mail address: legal@eurazeo.com
– partly based on Eurazeo’s legal obligations, and in particular (i) its obligation to secure and keep confidential the Personal Data processed in accordance with the GDPR; (ii) its obligations to grant the requests of public authorities or bodies; and (iii) its obligations to grant the requests of the relevant persons based on Articles 15 to 22 of the GDPR.

3. With whom does Eurazeo share your personal data?

Your Personal Data is used exclusively by the relevant Eurazeo internal departments to best respond to your requests, i.e., depending on the purpose: Legal Department, Information Services Department, Communications Department; Financial Reporting Department, Taxation Department, Accounts Department.

Your Personal Data will not be sold or exchanged with third parties for commercial prospection purposes.

It may however be transmitted to third parties in certain cases, when strictly necessary depending on the purposes mentioned in the previous section, in the following contexts:

to Eurazeo portfolio companies, for the reasons listed in Article 2 of this Policy, in order to best meet your requirements and requests in a consistent and harmonized manner;
to legal or financial authorities, government agencies or public bodies, at their request and within the limit of what is authorized by regulations, if required by law or if Eurazeo honestly believes that such disclosure is reasonably necessary to comply with legal proceedings (e.g. a mandate, subpoena or any other legal decision) or protect the rights, property or personal security of Eurazeo, its partners or the general public;
to service providers acting as subcontractors within the meaning of applicable regulations to perform services in line with our services or business. These service providers are involved in hosting, storage, analysis, marketing, communications, data processing, database management or IT maintenance. These service providers only act on Eurazeo’s instructions and will only have access to the Personal Data of relevant persons to carry out these services and will be bound to the same security and confidentiality obligations as Eurazeo;
to providers or partners performing services for Eurazeo (custodians, distributors, business providers, lawyers, auditors, etc.);
to third parties as part of a merger, acquisition or sale of all or part of Eurazeo’s assets, whose user acknowledges that it has been informed.

Furthermore, when you enroll in an event organized by Eurazeo, Eurazeo may share your name, the name of Your company and your electronic address with other participants and sponsors of the same event for organizational and communication purposes and to exchange ideas.

4. Where can your personal data be transferred ?

Please note that in certain cases Eurazeo may be required to transfer Your Personal Data outside the European Union, mainly to Eurazeo portfolio companies and its service providers as mentioned in the previous section.  The location of Eurazeo Group Companies is available on the Eurazeo website (https://www.eurazeo.com/fr).

Prior to its transfer, Eurazeo will verify the level of data protection applicable in the relevant country.

If the country is not considered to offer a suitable level of protection in accordance with the GDPR, Eurazeo will set up the necessary guarantees to transfer the data in compliance with the GDPR, including by signing standard contractual clauses with the entities to whom the data is transferred pursuant to Articles 46 and 47 of the GDPR.
You can access the models of standard contractual clauses that we use at the following address: https://eur-lex.europa.eu/legal-content/FR/TXT/HTML/?uri=CELEX:32010D0087&from=FR or https://eur-lex.europa.eu/legal-content/FR/TXT/HTML/?uri=CELEX:32004D0915&from=FR depending on the situations involving the recipients.

5. For how long will Eurazeo keep your personal data?

Eurazeo does not store Your Personal Data longer than is required. Storage periods may vary according to the types of data and processing.

Eurazeo processes and uses Your Personal Data in accordance with the law and will store your Personal Data:

(i) only for the reasonable time required to achieve the objectives mentioned above in Section 2, i.e. during the time necessary to meet any of your requests, to manage participation at an event and its consequences, and more generally over the duration of our contractual relationship;

(ii) as long as is required by operational, regulatory and legal constraints, mainly to meet the storage obligations for certain documents (e.g. obligation to store certain documents for ten years to comply with accounting and tax requirements in France), and according to the applicable limitation periods (i.e. generally 5 years in France upon expiry of the contractual relationship with Eurazeo). Likewise, data will be stored to secure rights of defense and respond to legal claims and requests from authorities and regulators until expiry of the relevant storage period or until a final decision is issued on such claims.

6. What are your rights and how can you exercise them ?

Eurazeo has introduced adapted Personal Data protection measures to verify that such data is used in accordance with the above purposes and ensure that it is accurate and up to date.

Under the applicable regulations, you have the following rights:

Right to information: You have the right to be informed in a precise, accurate, transparent and accessible manner regarding information that concerns You. This is why we have drafted this policy;
Right of access: You can obtain precise information concerning the processing of your Personal Data and a copy of the data concerning You that we process;
Right to rectification: If you consider that your Personal Data is inaccurate or incomplete, you can request that this data be rectified or completed accordingly;
Right to erasure: You can request the erasure of your Personal Data, to the extent permissible under the regulations;
Right to restriction of processing: In certain cases, you can request that the processing of your Personal Data be restricted;
Right to withdraw your consent: The consent you have given to process your Personal Data (see Section 2 above to determine consent-based processing) can be withdrawn at any time;
Right to data portability: When this right applies, which is to say when the processing is automated and based on consent or the fulfillment of a contract (see Section 3 above to determine the processing covered by this right), you can ask Eurazeo to communicate your Personal Data, or, when it is technically feasible, have it transferred to a third party, without any objection from Eurazeo;
Right to object to the processing of your Personal Data when the processing is based on the legitimate interest of Eurazeo (see Section 2 above to determine processing based on legitimate interest): You can at any time object to the processing of your Personal Data on grounds relating to your particular situation, unless Eurazeo can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or when such data is necessary for the establishment, exercise or defense of legal claims.

Eurazeo reserves the right not to grant certain requests based on particular circumstances and in all cases in accordance with the applicable laws and regulations.

Should You wish to exercise the aforementioned rights or simply ask questions concerning the processing of your personal data, you can send an e-mail to the following address by identifying yourself and the scope of the request:
– by simple letter

Eurazeo
Legal Department
1 Rue George Berger
75017 Paris

by e-mail:

legal@eurazeo.com

Pursuant to the applicable regulations, in addition to the aforementioned rights, You have the right to file a claim with the competent data protection authority (such as the CNIL in France: www.cnil.fr or the CNDP in Luxembourg: www.cnpd.public.lu/fr). We nevertheless ask that you get in touch with us using the aforementioned contact information before filing any claim with the competent data protection authority.

7. What security measures are in place?

Our objective is to securely store your data at all times during its processing. From the moment we receive your Personal Data, we put in place appropriate technical and organizational measures and various controls to prevent, to the extent possible, any accidental or unlawful destruction, loss, alteration, revelation or unauthorized access.

8. What cookies are used?

Our sites use cookies (including Google Analytics cookies) to obtain an overview of the volumes and preferences of our visitors when they browse our sites.

“Cookies” are small pieces of data that are sent to your computer and stored on its hard disk so that our website will recognize you when you visit.

You can block these cookies by setting your browser’s preferences. For more information on our use of cookies and how to block them on your computer, please refer to the applicable “cookies” policy on the website (https://www.eurazeo.com/fr/mentions-legales).

9. Change in policy and contact?

Eurazeo may update its Policy at any time and post it on-line indicating the date of the revision. We invite you to consult the Eurazeo website on a regular basis.
 
CONTACT US 
Please send any request for information concerning this Policy to our e-mail address: legal@eurazeo.com

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