DATA PROTECTION AND COOKIES

VAZIVA attaches the utmost importance to the protection of the personal data and privacy of its beneficiaries and of any person accessing its websites.

This Privacy and Cookie Policy ("Policy") describes what types of personal data about you may be processed by VAZIVA and any of its subcontractors or partners.

All operations on your personal data are carried out in compliance with the regulations in force and in particular with Law No. 78-17 "Informatique et Libertés" of January 6, 1978 as amended and Regulation No. 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("Regulation"),

The user of the site acknowledges having read and accepted this Policy at the same time as accepting the site's General Terms of Use. If the user disagrees with these terms, he/she is free not to use the sites and not to provide any personal data.

ARTICLE 1 - DEFINITIONS

"Personal data" - any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.

"Processing of personal data" - any operation or set of operations which is performed upon data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

"Controller" - the natural or legal person, public authority, department or other body which, alone or jointly with others, collects and processes personal data ;

"Recipients" - the natural or legal person, public authority, department or other body that receives communication of personal data, whether or not it is a third party.

"Authorized third party" - a natural or legal person, public authority, service or organization, placed under the direct authority of the controller or processor, who is authorized to process personal data;

ARTICLE 2 - SCOPE OF APPLICATION

VAZIVA carries out an activity within the meaning of French law no. 2004-575 of June 21, 2004 on confidence in the digital economy.

The purpose of this personal data protection policy (hereinafter the "Policy") is to inform Data Subjects of how their personal data is collected and processed by VAZIVA.

ARTICLE 3 - IDENTITY OF THE DATA CONTROLLER

Personal data is collected by VAZIVA, Société Anonyme (SA) with capital of 2,482,600.00 Euros, headquartered at CARRE SUFFREN, 31-35 RUE DE LA FEDERATION, 75015 PARIS, SIREN number 817 609 266, represented by Mr Patrick BERTHE, in his capacity as Chairman.

Data Protection Officer (DPO): Mr Guillaume-Alexandre PITHIOUD

The information collected in the questionnaire is recorded in a computerized file by the Data Protection Officer (DPO). The legal basis for data processing is the one required to hold a payment card.

Data marked with an asterisk in the questionnaire must be provided. Otherwise, registration will not be successful.

The data collected will be communicated only to the following recipients: the acceptance network, the bank processor and partner companies needed to deliver the service.

They are kept for five (5) years unless you renounce the services offered and request deletion of the data from the DPO. You may access, rectify or request the deletion of your personal data at any time, or exercise your right to limit the processing of your data.

To exercise these rights or if you have any questions about the processing of your data under this scheme, please contact the address given or send an e-mail to the following address: dpo@vaziva.com .

If, after contacting us, you feel that your rights under the Data Protection Act have not been respected, you can submit a complaint to the CNIL by quoting the number DPO-72128.

ARTICLE 4 - PROCESSING OF PERSONAL DATA

As part of the operation of its website https://vaziva.group, VAZIVA collects data about you. This data is processed in accordance with the purpose for which it was collected. Some information is compulsory and some optional, indicated by an asterisk (*) on the collection forms.

a) Purpose

This processing is essential for the following purposes:

- Access to a User account to consult personal information
- Access to the history of your social activity files
- Consultation of subsidy consumption
- Management of social benefits
- Access to promotional offers
- Administrative management: creation and management of the database, production of statistical reports or lists of beneficiaries, sending of mailings
- Sending solicitations and messages, on condition that the User ticks the appropriate acceptance box when registering for Services.

The processing of data is based either on your consent, which you express (by filling in the collection form, by writing to us directly, by accepting prospecting operations), or on the contract or on a legal obligation, or on the basis of the Organization's legitimate interest in organizing the management of its missions.

b) Processed data

When data is collected, the User will be informed whether certain data is mandatory or optional. Data marked with an asterisk on the registration form is mandatory. Failure to do so will prevent the User from accessing and using the Services.

VAZIVA may also collect personal data for other purposes, taking care to obtain the prior consent of the persons concerned.

In particular, VAZIVA may collect the following data:

- Identity: title, surname, first names, address, telephone number (landline or mobile), e-mail address, date of birth, e-mail address, family composition

- Postal details: address, additional address, zip code, city

- Contact data: messages sent to the site via contact forms ("Ideas or suggestions"), correspondence that may be sent to us.

- Additional information: all information useful for the performance of a service.

- Visitor statistics: IP address, cookies, e.g. pages consulted by the user, date and time of consultation (see details on cookies below).

The compulsory or optional nature of the data that Data Subjects may be asked to provide will be indicated on the collection forms by an asterisk. In the absence of answers, the person concerned will not be able to benefit from the services. In any event, VAZIVA undertakes to process all data collected in a manner that complies with the regulations in force, and in particular with the amended "Informatique et Libertés" law of January 6, 1978 and Regulation no. 2016/679.

c) Recipients of collected data

The personal data collected on this site is used exclusively by VAZIVA.

In the event that VAZIVA entrusts data processing activities to subcontractors, the latter will be chosen in particular for their sufficient guarantees regarding the implementation of appropriate technical and organizational measures, particularly in terms of reliability and security measures.

With the express prior consent of the User, data may be transmitted to VAZIVA's partners. This consent may be withdrawn at any time by the User.

d) Data transferred to public authorities and/or bodies

In accordance with the regulations in force, data may be transmitted to the competent authorities upon request, and in particular to public bodies, exclusively to meet legal obligations, court officers, ministerial officers and bodies responsible for debt collection.

e) Data transferred abroad

No data is transferred outside the European Union. However, VAZIVA reserves the right to transfer your personal data in order to comply with its legal obligations, and in particular if required to do so by a court order.

VAZIVA will then contractually determine compliance with data protection and information security provisions with the recipients concerned, and will take all necessary measures to ensure that third parties strictly observe these guarantees.

f) Shelf life

VAZIVA will keep your personal data in a secure environment for as long as is necessary to fulfill the purposes for which it was collected or for the minimum retention period required by applicable law, in particular civil and commercial law. Certain personal data may be kept by VAZIVA for longer periods exclusively for archival purposes, in the public interest, for scientific or historical research or for statistical purposes.

For the purposes of implementing its accounting and tax obligations, the Personal Data of Beneficiaries used in particular for invoicing purposes will be kept for a period of TEN (10) years from the end of the services. The Personal Data of Beneficiaries will be kept for the duration of the Services concerning them, as well as for an additional period of THREE (3) years corresponding to the statute of limitations in fiscal/social matters, in the case of services provided within the framework of social works. These periods are extended by the legal periods of prescription in the event of litigation or dispute. Personal data collected as part of prospecting operations will be kept for a period of three (3) years from the last contact from you. In the case of the Newsletter, data will be kept until you unsubscribe. Data collected via collection forms will be kept for one (1) year from receipt of the request. The retention period for a classified ad, the results of a survey or the results of a competition may not exceed one year. Photos sent by beneficiaries may not be kept for more than 5 years.

ARTICLE 5 - PROTECTION OF MINORS' PERSONAL DATA

VAZIVA does not collect or retain personal data from minors under the age of 15 without verifiable parental consent, although holders of parental authority may request to receive information about their child and ask for it to be deleted.

ARTICLE 6 - COOKIES

The User is hereby informed that, when connecting to the Site or the Applications and using the Services, cookies or other technologies are used, subject to the choice expressed by the User; this choice may be modified at any time.

During its period of validity, a cookie enables its issuer to recognize the terminal concerned (computer, tablet, smartphone, etc.) each time this terminal accesses digital content containing cookies from the same issuer. A cookie records information about your computer's browsing on our site (the pages you have visited, the date and time of your visit, etc.), which we can read on your subsequent visits.

These cookies facilitate navigation and improve the user-friendliness of the website. The User may prevent the storage of cookies by configuring his/her browser settings as indicated below. In this case, access to certain services and sections of the site may be altered, or even impossible. The site may use several types of cookies:

Browsing cookies on the Site and Applications :

Browsing Cookies are used to improve the performance of the Services, in order to provide the User with a better use of the Site and Applications. These Cookies do not require the User's prior knowledge and consent to be deposited on the User's terminal. More specifically, these browsing Cookies enable the User to:

To adapt the presentation of the Site and the Applications to the display preferences of the terminal (language used, display resolution, operating system used, etc.) during Users' visits to the Site and the Applications, depending on the display or reading hardware and software that the terminal is equipped with;

To allow access to a reserved area subject to login and password; To store information relating to the form the User has filled in on the Site and Applications, or to information the User has chosen on the Site or Application; To provide the User with access to his or her account, including but not limited to the shopping cart, payment, order history, or any other area reserved for customers, using his or her login and password; To implement security measures, for example when the User is asked to reconnect to content or a Service after a certain period of time has elapsed. Refuse cookies

The User may configure his or her browser software so that Cookies are stored in the terminal or, conversely, so that they are rejected, either systematically or depending on the sender. The User may also configure his or her browsing software so that acceptance or rejection of Cookies is proposed from time to time, before a Cookie is likely to be recorded in his or her terminal.

Each browser is configured differently to manage Cookies and User choices. This is described in the browser's help menu, where you can find out how to modify your cookie preferences:

For Internet Explorer™

For Safari™

For Chrome™

For Firefox™

For Opera™

In this case, the user is informed that access to certain services and sections of the site may be altered or even impossible.

At any time, the User may choose to express and modify his or her wishes with regard to Cookies.

The length of time cookies are retained varies according to the type of cookie. Most of our cookies are self-destructing once the connection has been terminated. These are known as session or browsing cookies.

ARTICLE 7 - PERSONAL RIGHTS

In accordance with Regulation (EU) 2016/679 on the protection of personal data, the User has the following rights over his or her data: right of access, right of rectification, right to erasure (right to be forgotten), right of opposition, right to limitation of processing, right to portability. The User may also have additional national rights (e.g.: to define directives relating to the conservation, deletion and communication of your personal data after your death).

For reasons relating to his or her particular situation, the User may object to the processing of data concerning him or her. To exercise these rights, the User may request modification of this data using the form in the "support" section, or by e-mail to dpo (at) vaziva.com.

Subject to a breach of the provisions below, the User has the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) www.cnil.fr or with the Data Protection Supervisory Authority of his/her place of residence.

ARTICLE 8 - SAFETY MEASURES

In view of technological developments, implementation costs, the nature of the data to be protected and the risks to the rights and freedoms of individuals, VAZIVA implements all appropriate technical and organizational measures to guarantee the confidentiality of the personal data collected and processed and a level of security appropriate to the risk.

ARTICLE 9 - CHANGES TO THE PRIVACY POLICY

If VAZIVA modifies this Policy, or if legal or regulatory texts require it, it will be published on our sites and will be effective as soon as it is published. Consequently, we invite you to refer to it each time you visit our sites, so that you are aware of the latest version, which is permanently available on our websites. For any information on the protection of personal data, the User may also consult the website of the Commission Nationale de l'Informatique et des Libertés (CNIL) www.cnil.fr or of the Autorité de Contrôle à la Protection des Données of his place of residence.