PERSONAL DATA PROTECTION POLICY

The purpose of this Personal Data Protection Policy (hereinafter “Policy”) is to explain you what personal data we collect about you, how we process it and how you can assert your rights.

This Policy was updated on September 30, 2021.

1. Who is responsible for the processing of your personal data?

SBM Développement, located at 60 Chemin des Mouilles, 69130 Écully and registered in the Lyon Trade and Companies Register under number 399 189 224 is responsible for the processing of your personal data.

2. What personal data do we process about you?

The personal data we process are those you provide us by:

• Filling out a form via the Contact page of our Website. When you complete this form, some of the information requested are mandatory. They are marked with an asterisk. If you don’t complete that information, SBM will not be able to process your request.
• Sending us an e‐mail via the following email address: contact@sbm‐company.com.
• Communicating us your application for a job offer via the following email address: recrutement@sbm‐company.com.

Finally, we collect your personal data through the cookies set on our Website.

Therefore, the personal data that you can communicate to us include the following categories: your identity, your contact details, your job title, your training and professional experience, your interests, your financial data, your professional profiles on social networks (LinkedIn or others). The cookies allow us to collect the date and time of connection, the search engine you used and your IP address. For more information on cookies, you can refer to paragraph 7 of this Policy.

3. Why do we process your personal data?

We process your personal data exclusively for the purpose of:

• Answering your enquiry with all the relevant information you required.
• Providing you with the documentation you have requested from us or for any other reason for which you have contacted us.
• Assessing your skills and interests, checking your references and communicating to internal departments the recruitment process of your application when you respond to our job offers

You may refer to paragraph 7 which sets out the reasons why we use cookies on our Website.

We process your personal data because we have a legitimate interest in providing you with all the answers and information necessary to your contact request and as part of your recruitment process. In relation to cookies, we process your personal data on the basis of your consent.

4. How do we protect your personal data?

Our information systems are protected against unauthorized access. Only members of our internal departments have access to your personal data, based on a personal identifier or other means of authentication and only if it is relevant to the performance of their tasks.

SBM has put in place appropriate technical and organizational measures to protect your personal data against destruction, loss, alteration, unauthorized, unlawful or accidental disclosure, misuse and damage. For example, we have implemented anti-virus softwares, back-up procedures etc.

5. To whom your personal data are disclosed?

Your personal data can be sent:

• To internal SBM employees who need it, and this within the strict limitation of their responsibilities.
• To third party organizations. Where this is the case, we ensure that they have security and storage measures for personal data and that they comply with data protection laws as we do.
• To countries outside the European Economic Area (EEA). Where this is the case, SBM ensures that this international transfer of data has an adequate level of safeguards and security. The safeguards we use to protect those transfers include the standard contractual clauses in force and validated by the European Commission.
• In the event that your personal data are transferred to a government authority, we will inform you at the time of transfer.

6. How long do we keep your personal data?

SBM undertakes to keep your personal data only for as long as it is necessary to provide you with all the information and documentation you required. Once this objective is reached, your data will be deleted.

When you apply for our job opportunities, if your application is unsuccessful, your personal data will be retained for a maximum period of 3 years from the date of receipt of your application, unless you expressly request that they are deleted at the end of the recruitment process. If your application is successful, your personal data will be included in your employee’s general personal file. You will be informed separately about how SBM processes employee’s data.

7. What is SBM cookie policy?

During your visit on this Website, cookies and other trackers may be installed or may be used to access information contained on your terminal equipment.

• What is a cookie?

A cookie is a piece of information downloaded on your computer, your phone or any other device you use when you visit a website. It contains several information about your preferences and past actions.

• What cookies do we use?

We use mandatory cookies that are necessary for the proper functioning of the Website.

We also use cookies that allow us to improve the performance of the Website.

When you first visit our Website, you will be asked to accept or refuse the cookies. Cookies that are mandatory for the proper functioning of the Website are not subject to your consent. As regards to the other cookies, your acceptance or refusal will be saved in a technical cookie stored on your web browser.

You can change your mind at any time by clicking on the “Cookies” button at the bottom of the page. This new choice will then be taken into account and will prevail.

8. What are your rights?

We are committed to respecting your rights when we process your personal data.

• Right of access

You have a right of access, which allows you to obtain confirmation of whether or not your personal data are being processed and other additional information.

• Right of rectification

You have a right to ask for the rectification of your personal data i.e., complete your personal data which may be inaccurate, incomplete or out of date.

• Right to erasure

You have a right to erasure that allows you to request us the deletion of your personal data under the following conditions:

• your personal data are no longer necessary for the purposes for which we processed them
• you withdraw the consent you previously gave us to process your personal data, provided that there is no other legal basis for us to continue such process
• you object to the processing of your personal data for prospecting purposes
• your personal data are not legally processed
• your personal data must be deleted in order to comply with applicable legislation

If none of the above conditions are met, SBM will not be able to respond favorably to your request. This is the case if we are obliged to keep your data to comply with a legal obligation.

• Right to data portability

You have the right to require us to transmit your personal data to you or to have them transferred to another data controller in a structured, commonly used and machine‐readable format.

• Right to object

You have the right to object to the processing of your personal data at any time given certain circumstances.

• Right to withdraw consent

You have the right to withdraw your consent at any time where the basis for processing your personal data is based such consent. SBM will then cease processing your personal data without prejudice to any previous operations for which you have consented.

• Right to define post‐mortem directives

You have the right to define specific directives relating to the retention, deletion, and communication of your personal data after your death. These instructions will only apply to the processing carried out by us and will be limited to that scope.

9. How to assert your rights?

To assert your rights, you can contact the Personal Data Manager by email at the following address: privacy@sbm‐company.com. Your request must be accompanied by a copy of your identity document (identity card or passport) which will be used to prove your identity and grant your request.

SBM reserves the right to reject any misuse of the right concerned, in particular if the request is unfounded or if it is excessive especially because of its repeated nature.

If after contacting us, you feel that your rights have not been respected, you may submit a complaint to the competent national authority based on your location : here.