AXYNTIS' PRIVACY POLICY

Last updated: May 16, 2023

1.      General statement

We take your privacy very seriously and are committed to protecting it. We believe that you should be able to easily find out what personal data we collect and use, and understand your rights concerning it.

This privacy policy (the “Privacy Policy”) explains our policies and practices regarding how we collect, use, and disclose the personal data we collect on our website.

We recommend that you read this Privacy Policy carefully as it contains important information about your personal data.

This Privacy Policy is designed so that you can easily access the section that interests you.

Please feel free to contact us if you have any questions or comments about this Privacy Policy (see "How to Contact Us" below).

The terms “Axyntis,” “we,” us,” and “our” refer to the Axyntis Group and its affiliates as processors of your personal data, unless otherwise specified in this Privacy Policy.

2. Who are we?

 Axyntis Group is a simplified joint-stock company with a capital of 34,702,940 euros, whose registered office is located at 198, Avenue de France, 75013 Paris, France, and which is registered in the Paris Trade and Companies Register under number 494 439 235.

Centipharm is a simplified joint-stock company with a capital of 1,525,000 euros, whose registered office is located at Chemin de la Madeleine, 06130 Grasse, France, and which is registered in the Grasse Trade and Companies Register under number 326 171 378.

Orgapharm is a simplified joint stock company with a capital of 37,056,572 euros, whose registered office is located at Zone Industrielle Rue du Moulin de la Canne, 45300 Pithiviers, France, and which is registered with the Orléans Trade and Companies Register under number 479 719 049.

Steiner (dyes division) is a simplified joint-stock company with capital of 1,350,837 euros, whose registered office is located at 9 route de Rouen, 27950 Saint Marcel, France, registered in the Evreux Trade and Companies Register under number 553 650 482.

Centipharm, Orgapharm, and Steiner are the companies of the Axyntis Group. Axyntis is the parent company of the Axyntis group.

You will find our contact information in the "How to contact us" section below.

3. What personal data do we collect and how is it collected?

Personal data is information relating to an identified or identifiable natural person. For example, it includes a person's name, address, and gender.

We may collect personal data directly from you (e.g., when you apply online for a job) or indirectly (e.g., from your electronic devices that interact with our websites, electronic forms, or mobile applications (“Digital Platforms”).

3.1.    Data you provide directly to us

You may provide us with data:

when you apply for a job on our website;

when you use our Digital Platforms, for example, to write us a message in the "Contact Us" section;

Depending on what you provide to us, such information may include:

your identity (including your first name, last name, gender, image, nationality);

your contact information (including mailing address, e-mail, phone numbers);

your personal status (including your marital status);

other information you may provide by filling out forms or contacting us (including your comments or other communications to us).

We will inform you when your information is needed to process your request, to respond to your inquiries or applications. Failure to provide this information may delay or make it impossible to process your request, respond to your questions and provide products or services.

We strive to ensure that the personal data we hold is accurate at all times. We, therefore, encourage you to update your data in case any changes occur. We may also ask you to update your information from time to time.

We recommend that you provide only the data requested or necessary for your request, except for sensitive data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health, sex life, or sexual orientation.

3.2.   Data gathered indirectly

We may collect data when you use our Digital Platforms, including your IP address or other navigational data (including browser, operating system, device model), through cookies or similar technologies placed on your device. Some cookies are necessary for the proper functioning of our Digital Platforms and others are used for analytical purposes that help us provide you with more personalized services and a better digital experience. For more information about cookies and how to change your preferences, you can click on the Cookies page.

If you provide us with personal data about someone else, you must ensure that you have the right to disclose such data to us and that, without further action by us as required by data protection law, we can collect, use and disclose such data for the purposes described in this Privacy Policy. For example, you should ensure that the individual is aware of the various topics outlined in this Privacy Policy. The individual must also give the consent set out in this Privacy Policy concerning how we process their personal data.

3.3.   Minimum age

We remind you that we do not directly or indirectly collect personal data from persons under the age of 16, without prejudice to any local law setting a different minimum age. We, therefore, ask that you do not provide us with personal data of individuals who do not meet these criteria.

4. Why do we collect your personal data and how do we use it?

We collect and use your personal data on one or more of the following legal bases:

we have obtained your prior consent. Please note that with this particular legal basis, you have the right to revoke your consent at any time (see below “What are your rights regarding your personal data?”) »);

we have a legitimate interest in carrying out the processing and this legitimate interest is not overridden by your interests, fundamental rights, or freedoms;

 we have to process your personal data to comply with the laws and regulations in force.

Depending on the context, we may use your personal data to:

make checks to identify yourself and verify your identity;

send you marketing communications, with your prior consent (see “Marketing Communications” section);

manage your applications to our job offers;

respond to your questions, suggestions, and requests, including requests to exercise your rights;

manage claims and litigation;

protect you, employees, and others in our companies and our property;

monitor and improve our Digital Platforms;

to carry out statistical analyses, particularly to adapt our offer of products and services;

improve our products and services;

comply with our legal obligations, which includes providing information to regulators when required by law, including to comply with our legal obligations to prevent and combat fraud, money laundering, and terrorist financing.

5. Marketing communication

With your prior express consent (usually obtained by checking a particular box on a form), you may receive information regarding offers, services, products or events from Axyntis and/or other Axyntis group companies. In this case, you also agree that your contact information may be shared with other Axyntis Group companies for this purpose. You can also consult the list of Axyntis group entities and their location in the section “FINE CHEMICAL MADE IN FRANCE”

We rely on your consent to process the personal data you provide to us for this purpose. Therefore, if you no longer wish to receive such information, you may withdraw your consent at any time (see below “What are your rights regarding your personal data?”) »).

6. How long do we keep your personal data?

Your personal data is processed for the period necessary for the purposes for which it was collected, to comply with legal and regulatory obligations and for the duration of any period necessary for the establishment, exercise, or defense of legal claims.

To determine the most appropriate retention periods for your personal data, we have specifically considered the amount, nature, and sensitivity of your personal data, the purposes for which we have collected your personal data, as well as applicable legal requirements. For example:

Regarding our prospects (potential customers): your data is kept for three years after your last action, then deleted or archived to comply with legal retention obligations;

Regarding our clients: your data is kept for the duration of our commercial relationship and up to ten years, then deleted or archived to respect the legal obligations of conservation;

Regarding our candidates: your data is kept for six months after your last action, then deleted or archived to comply with legal retention obligations;

Regarding the cookies used on the Digital Platforms: they are stored for up to 13 months from the time they were installed on your device.

7. How do we disclose and transfer your personal data?

We may disclose your personal data only to the parties named below and for the following reasons:

We disclose your personal data to Axyntis employees who need to have access to your personal data and who are authorized to process it for the above-mentioned purposes and who undertake to keep it confidential.

We may disclose your personal data to departments within Axyntis Group companies responsible for customer relations, communications, legal affairs, finance, internal audit, IT management, and security for the purposes set out in this Privacy Policy and to provide you with a consistent level of service across Axyntis Group companies. This may include providing you with the products and services you have requested, improving the services provided, and, with your consent, sending you marketing communications about offers, services, products, or events (for this purpose you may revoke your consent at any time. See “What are your rights regarding your personal data?” below.

We may also communicate personal data to third parties acting on behalf of Axyntis and approved by Axyntis. All such processing is based on our prior instructions outlines in a binding contract that complies with the requirements of applicable law. Said disclosures are made on different grounds, including:

o   IT development and support;

o   Hosting and conducting marketing and economic studies and marketing campaigns;

o   Verification of your information.

These service providers are committed to respecting confidentiality and are not authorized to use your personal data for any other purpose. We also require them to apply appropriate security measures to protect your personal data.

We may be required by mandatory provisions of applicable law or in connection with legal proceedings or other legal requests, to disclose your personal data to authorities or third parties.

We may also disclose or process your personal data under applicable law to defend our legitimate interests (for example, in civil or criminal proceedings). For example, we may disclose such personal data as necessary to identify, contact, or bring legal action against an individual or entity that is violating our Terms and Conditions of Sale and Use or is causing distress or harm to other users of our Digital Platforms.

-   In the event of a third-party acquisition of Axyntis or companies of the Axyntis Group, or all or part of their assets, your personal data may be included in the transferred assets.

8. How do we protect your personal data?

All your personal data is strictly confidential and will only be accessed on a need-to-know basis by Axyntis staff and other duly authorized Axyntis group entities as well as independent service providers acting on our behalf under appropriate technical and organizational security measures.

Axyntis Group has implemented security measures to protect your personal data from unauthorized access and use. We follow appropriate security procedures in the storage and disclosure of your personal data to prevent unauthorized access by third parties and to prevent accidental loss of your data. We limit access to your personal data to those who legitimately need to access it for business reasons. Persons accessing your data will be subject to a duty of confidentiality to Axyntis.

We also have procedures in place to address any suspected data breach. We will notify you and any relevant supervisory authority of a suspected data breach where we are required to do so by law.

We also require those to whom we transfer your personal data to comply with the above. Unfortunately, the transmission of information via the internet is not completely secure. We therefore cannot guarantee the security of your personal data that you have transmitted to us via the Internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be liable for any unauthorized use, distribution, damage, or destruction of your data, except to the extent that we are required by law to assume such liability. Once we receive your personal data, we will apply the security measures mentioned above.

9. What are your rights regarding your personal data?

Under the applicable data protection law, you may at any time request access, rectification, deletion, and portability of your personal data, or restrict or object to its processing. A summary of these rights is set out below:

Your right to access: the right to receive a copy of your personal data.

Your right to rectification: the right to ask us to rectify any errors in your data or to complete it.

Your right to be forgotten: the right to ask us to delete your personal data in certain situations.

Your right to limit processing: the right to ask us to restrict the processing of your personal data in certain circumstances, for example, if you challenge the accuracy of the data.

Your right to data portability: the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and/or to transmit such data to a third party, in certain situations.

Your right to object to processing: the right of opposition:

—   at any time during the processing of your personal data for direct marketing purposes;

—   in certain other situations, for our further processing of your personal data, for example processing based on our legitimate interests.

Where the processing of your personal data is based on your consent, you may at any time decide to withdraw it. If your consent is withdrawn, this will not affect the processing of your personal data based on other legal grounds, such as the processing of your personal data to comply with applicable laws and regulations.

If you no longer wish to receive our advertising information, we remind you that you can revoke your consent to direct marketing at any time directly from the unsubscribe link included in every advertising email we send you. If you do, we will promptly update our databases and take all reasonable steps to respond to your request as quickly as possible, but we may continue to contact you to the extent necessary in connection with any product or service you have requested.

You also have the right to file a complaint with your local data protection authority in the event of an alleged violation of the data protection rules applicable to you.

To exercise any of these rights, please contact us using the contact information below (see “Contact Us”).

Please note that if you exercise any of the above rights, you will be asked to let us know which right you wish to exercise and to provide us with certain information (such as a copy of an ID card, passport, or other legally recognized identification) for identification purposes to process your request and to protect you against fraudulent requests from third parties.

10. How to contact us?

If you have any questions about your account, or wish to revoke your consent, ask general questions or file a complaint, you can contact our communications department:

- By email: contact@axyntis.com (attention Anna TELLAI)

- By telephone: +33 (0)6 65 62 10 13

- By letter: Axyntis Group / axyntis.com, 198 Avenue de France, 75013 Paris

If you have any questions or concerns about our Privacy Policy or data processing, you can contact the Group's Data Protection Officer at contact@axyntis.com (attention Anna TELLAI)

11. Changes to this Privacy Policy

This Privacy Policy reflects our current practices and may be changed and updated from time to time. When we post changes to this Privacy Policy, we will change the “Effective Date” at the top of this Privacy Policy to indicate when such changes became effective.

If we materially change this Privacy Policy, we will notify you by posting a notice of the change at the beginning of this Privacy Policy and on the home page of the “axyntis.com” website.