PRIVACY POLICY

In accordance with the law “Informatique et Libertés” n ° 78-17 of January 6, 1978, as well as the new General Data Protection Regulation (GDPR), you have the right to access, modify, rectify and delete data related to you.

The purpose of this Privacy Policy is to give you all the information relating to the protection of your personal data set up by Iwase Cosfa Europe.

This Privacy Policy is relevant for any physical person sharing their personal data directly or indirectly with Iwase Cosfa Europe by visiting our website or exchanging by email.

In accordance with the provisions of article 5 of European Regulation 2016/679, the collection and processing of data from site users respect the following principles:

• Legality, loyalty and transparency: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his data is collected, and for what reasons his data is collected;

• Limited purposes: the collection and processing of data is carried out to meet one or more objectives determined in these General Conditions of Use;

• Minimization of data collection and processing: only the necessary data for the proper execution of the objectives pursued by the site are collected;

• Data storage reduced over time: the data is kept for a limited period, of which the user is informed. If this amount of time cannot be communicated to the user;

• Integrity and confidentiality of the data collected and processed: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

In order to be lawful, and in accordance with the requirements of article 6 of European regulation 2016/679, the collection and processing of personal data can only take place if they meet at least one of the conditions below. after listed:

• The user has expressly consented to the processing;

• Processing is necessary for the proper performance of a contract;

• The processing meets a legal obligation;

• The processing is explained by a necessity related to the safeguarding of the vital interests of the data subject or of another physical person;

• The processing can be explained by a necessity related to the execution of a mission of public interest or which relates to the exercise of public authority;

• The processing and collection of personal data is necessary for the legitimate and private interests pursued by the controller or by a third party

“Personal data” means all the data that we are likely to record through our various forms and that can allow us to identify you.

In accordance with applicable regulations, personal data means any information relating to an identified or identifiable physical person. Is deemed to be an “identifiable physical person” a physical person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements related to their physical, physiological, genetic, psychic, economic, cultural or social identity.

The recipients of the data are of several types:

• the teams from Iwase Cosfa Europe;

• the subcontractors for the execution of the concerned processing,

• and if you have expressly accepted it, the business partners of Iwase Cosfa Europe.

These categories of recipients are supplemented, where appropriate, by categories specific to each treatment and expressly referred in the notices appearing on the data collection form or in the shared emails.

Iwase Cosfa Europe takes care of storing your personal data within the European Union with hosts who are subject to European regulations relating to the protection of personal data. Your personal data is thus stored by Iwase Cosfa Europe in a secured way and in accordance with regulations.
The storage periods used by Iwase Cosfa Europe comply with the regulations applicable on the day hereof, namely:

• For customer data used for commercial prospecting purposes, limited to a period strictly necessary for the achievement of the purposes for which the data was collected.

• For the information entered in the single personnel register as well as the data relating to pay slips and receipts for the balance of any account, a period of five years from the date on which the employee or the intern left the establishment.

• For contracts concluded electronically, a period of 10 years when it relates to an amount equal to or greater than 120 euros.

• For merchant accounting documents and supporting documents, a period of 10 years.

Iwase Cosfa Europe reserves the right to create additional and / or complementary means of collection. As such, Iwase Cosfa Europe will specify, in accordance with the regulations, the retention periods specific to the processing concerned on the data collection form.

All personal data is collected by the company Iwase Cosfa Europe, whose head office is located at 105 rue Anatole France, with the telephone number: 01 78 99 42 00.

The person responsible for processing personal data is: Paul Noeuvéglise. He can be contacted as follows: by email at ice.privacy@iwasecosfa.com

The data controller is responsible for determining the purposes and the means used for the processing of personal data. It undertakes to protect the personal data collected, not to transmit it to third parties without the user having been informed of it and to respect the purposes for which this data has been collected.

If the integrity, confidentiality or security of the user’s personal data is compromised, the controller undertakes to inform the user by any means.

– The data you send us directly

The personal data collected is directly provided by candidates, customers, suppliers, business partners or users of the Iwasecosfa.eu site. This is for example the data that you enter when you apply for an offer or that appear on your CV, or data that you transmit to us when filling out contact forms.

When you fill out one of our forms, the following data may be collected and / or saved:

• Last name
• First name
• E-mail
• Telephone number
• Town of residence
• Professional status (employee, self-employed, etc.)
• IP address (es)
• And any other information you would like to share with us

The data collected may in no case include sensitive personal data, such as government identifiers (such as social security numbers, driver’s license numbers, or taxpayer identification numbers), complete credit card or account numbers personal banking, medical records or information relating to requests for care associated with individuals.

– Data collected through cookies

A cookie is a text file deposited during the consultation of a site, an application or an online advertisement and stored in a specific space of the hard drive of your computer or your mobile device. Cookies are managed by your Internet browser and only the issuer of a cookie can decide to read or modify the information contained therein.

A cookie has a limited validity period. Its deposit and storage on your terminal are done in compliance with the applicable legislation and subject to the choices you have expressed and which you can modify at any time, under the conditions specified in article 8 below.

A cookie does not identify you personally. It allows its transmitter to recognize your terminal and to collect a certain number of information related to the navigation carried out from this terminal.

Cookies have several functions, such as allowing you to navigate efficiently on a site or an application, remembering your choices, the goods and services you want to buy, and offering you relevant advertising content according to your expressed interests while browsing. You will find more information on cookies on the Cnil website:

www.cnil.fr

In accordance with the GDPR and the Data Protection Act No. 78-17 of January 6, 1978, the user

has the rights listed below.

For the data controller to grant his request, the user is required to communicate his first and last name as well as his email address.

The data controller is required to respond to the user within a maximum of 30 (thirty) days.

You have the following rights:

• Right of access to your personal data;
• Right to rectify your personal data if it is inaccurate or incomplete;
• Right of limitation under the conditions referred to in article 18 of the European regulation;
• Right to erase your personal data if:

– They are no longer necessary regarding the purposes for which they were collected or otherwise processed;

– You withdraw your consent regarding the treatments subject to consent (ex: commercial prospecting);

– You validly object to the processing;

– They have been subjected to unlawful treatment; or

– A law requires it.

• Right to object on legitimate grounds,
• Right to the portability of your data,
• Right to define directives relating to the fate of your personal data after your death and,
• For treatments based on consent, withdraw your consent at any time.

The user can read, update, modify or request the deletion of data concerning him, by respecting the procedure set out below:

The user must send an email to the person responsible for processing personal data, specifying the subject of their request and using the contact email address provided above.

In the case where the data controller decides not to respond to the user’s request, and the user wishes to contest this decision, or if he thinks that one of the rights has been infringed above listed, he is entitled to seize the CNIL (National Commission for Information Technology and Liberties, https://www.cnil.fr ) or any competent judge.

All your personal data is processed, stored and used with all the security necessary by Iwase Cosfa Europe via a private server based in France.

This data may, depending on your actions on our site, also be stored, managed and used by third-party tools, necessary for the proper functioning of our activities.

Also, we ensure that these tools comply with the standards set by the new General Data Protection Regulations, in force since May 25, 2018 within the European Union.

Iwase Cosfa Europe reserves the right to modify this Confidentiality Policy at any time, in application of changes made to the laws and regulations in force.

We advise you to check this page regularly in order to stay informed, in real time, of our procedures and rules relating to your personal data.

QA: Quality Assurance Supervisor

PDT: President

RCSR: Responsible for CSR