Cookies and personal data

Purpose

This policy sets out how we, Manutan Holding and its subsidiaries (hereinafter the 'Manutan Group' or 'Manutan' or 'We'), process the Personal Data (hereinafter 'Personal Data') that We collect and that you (hereinafter 'You') supply Us. It applies to all Personal Data about You collected as part of our relationships. We invite You to read this document carefully to find out and understand our practices in this regard.

The Manutan Group reserves the right to adapt or modify this Privacy Policy at any time. The updated version of this is available at www.manutan.com. Any new conditions will be brought to Your attention by online modification and will automatically apply to anyone who accesses them subsequently.

Who are we?

Manutan is one of the main players in multi-channel BtoB distribution in Europe, whose parent company Manutan Holding, a simplified joint stock company, is located at Avenue du 21e Siècle, ZAC Parc des Tulipes, 95500 Gonesse, registered in the Pontoise Trade and Companies Register under number 920 350 477.

We have more than 2,200 employees in Europe, spread across 27 subsidiaries and 17 countries.

As part of our activities, We process Personal Data about You in full compliance with the applicable regulations and in particular European Regulation 2016/679 of 27 April 2016 on the protection of natural persons (hereinafter 'GDPR'), as well as the amended French law of 6 January 1978 on data processing, files and freedoms (or 'French Data Protection Act').

What are our commitments?

We undertake to implement all the technical and organisational measures necessary to ensure compliance with the fundamental principles regarding collecting and Processing Personal Data and in particular the principles of:

legality, fairness and transparency: Personal Data are processed lawfully, fairly and transparently;
purpose limitation: Personal Data are processed for specified, explicit and legitimate purposes, and are not subsequently processed in a manner incompatible with the initial purposes;
data proportionality: the Personal Data collected are adequate, relevant and limited to that necessary for the Processing purposes;
data accuracy: the Personal Data are accurate and kept up to date. All reasonable measures are taken to ensure that inaccurate or obsolete data are erased or rectified, considering the Processing purposes.

How do we collect your Personal Data?

We collect Personal Data that You communicate to Us directly when You use Our website:

When You subscribe to be informed about regulated information relating to the Manutan Group;
When making an unsolicited application or when You respond to a job offer (application form, sending a curriculum vitae, covering letter, etc.);
When contacting Startuppers to present an innovative solution to Us.

The categories of Personal Data that We collect include:

Identification and contact information for subscription and the form reserved for Start-Ups and in particular first & last name, e-mail address, company name, experience, presentation, etc.
Information about applications and in particular, first & last name, e-mail address, telephone number and your working experience, as well as all the information that You send Us by submitting your application and/or your curriculum vitae: photo, skills, level of education, languages spoken, salary goals, home address, interests, marital status, etc. We collect and store these data solely as part of managing our own job offers and use them for no other purpose, particularly commercial purposes.

When you browse Manutan's websites, We may also collect data indirectly, in particular your IP address or other browsing data using cookies, small text files saved on your device (computer, tablet or mobile phone). These cookies allow Us to collect information and Personal Data for various purposes (statistics on visits to and use of the website, adapting the website to your settings, etc.).

As part of managing cookies, We also undertake to comply with data protection regulations. Thus, when required, Consent to cookies will be obtained using the cookie banner which will appear clearly and visibly during your first visit to the company's website.

You can change your cookie settings at any time. To find out more about how Manutan manages cookies, you can access the 'cookies' section of the website available at the following link: Cookies policy.

What are your Personal Data used for? (Processing purposes)

Your Personal Data are processed for the following main purposes:

The protection of our interests, in particular for :
- The management of fraud;
- The management of litigations;
- The management of our compliance with the various applicable legal obligations

Managing your applications for Manutan Group’s job offers (when submitting an unsolicited application or replying to a job offer for the Manutan Group), particularly to:
- Assess your skills, qualifications and suitability for the post you are applying for;
- Check your career background and references, to communicate;
- Discuss with you during the recruitment process.

Managing your online subscriptions to receive all regulated information communications relating to the Manutan Group automatically, particularly to:
- Receive the quarterly turnover;
- Communicate about half-yearly results.

Managing the Startuppers contact form, particularly to:
- Learn about and study a partnership proposal with your Start-Up;
- Discuss innovative solutions with You to improve Our customers', employees' or suppliers' experience.

Do we process all the Personal Data that you provide to us?

In accordance with Our commitments, We only collect data that We consider necessary to carry out our activities (principle of data minimisation).
However, certain data are essential and the fields in collection forms marked with an asterisk (*) must be completed. Otherwise, we will not be able to process your request.

What is the legal basis for Processing Personal Data?

Processing Your Personal Data is based on various legal requirements:

Your prior consent (please note that in this respect you have the right to revoke your consent at any time – see below 'What are your rights regarding Personal Data?');
The pursuit of our legitimate interest as Data Controller;
Compliance with a legal obligation when the legislation in force requires the aforesaid Data Processing.

Who can access your Personal Data?

Only authorised persons within our teams can access Your Personal Data, based on their business needs. Your Personal Data may also be sent to other group entities; this may involve processing your application in the Manutan Group companies in which the post is offered.

We may also need to communicate your Personal Data to service providers ('Subcontractors') whose services are necessary to carry out our activities as Data Controller. As an example, your Personal Data may be sent to service providers providing a recruitment service, information service, etc.

In this context, we undertake to use only Subcontractors that offer adequate guarantees and comply with our commitments on the protection of Personal Data.

How long are your Personal Data stored?

Personal Data are stored only for the period needed to achieve the purposes described in the section 'What are your Personal Data used for?'. In addition, the Manutan Group stores your Personal Data in accordance with the storage periods imposed by the applicable regulations in force and/or industry best practices.

These storage periods are defined based on the nature of the Processing purposes and particularly take account of the applicable legal provisions imposing a precise storage period for certain data categories, the applicable limitation periods and the recommendations of the local Supervisory Authorities regarding certain Data Processing categories.

Personal Data collected as part of the recruitment process and contact with the Starts-Ups are stored for a period of two (2) years following their collection or your last contact with our services.

Personal Data collected as part of subscription are stored for the entire duration of the contractual relationship with our service provider, GlobalNewswire Intrado.

Are your data secure?

We pay particular attention to the confidentiality and security of your Personal Data.

In this context, we implement appropriate technical and organisational measures to ensure an appropriate security level complying with industry best practices. Thus We meet regulatory requirements and protect data subjects' rights and data from the outset of designing Processing operations.

Furthermore, our Internet platform employs enhanced security measures, such as the use of robust encryption protocols, the protection of an application firewall, permanent supervision and regular external audits.

What are your rights regarding Personal Data?

Pursuant to the applicable data protection regulations, at any time you can exercise your rights as a data subject and request access, rectification, deletion and portability of data about you, as well as exercising your rights to limiting and objecting to Processing these data.

You can decide to withdraw your consent to processing of your Personal Data at any time. Withdrawing your consent does not prevent us from processing your Personal Data on the basis of other legal requirements, as applicable, such as storing your data in accordance with the applicable law.

How to exercise your rights?

These rights may be exercised by contacting: Manutan, Département Juridique Groupe, ZAC du Parc des Tulipes, Avenue du 21ème Siècle, 95500 Gonesse Cedex, or by e-mail to privacy@manutan.com.

In this context, please support your request with the information needed to identify you (first & last name, e-mail address) and an identity document as well as any information relating to your request and in particular: the right you wish to exercise and the name of the company involved in your request.

You also have the right to appeal to the local Supervisory Authority in the event of a breach of the applicable regulations on protection of Personal Data and particularly GDPR.

Who to contact?

For any further questions about this policy or the way Manutan processes your Personal Data, please contact us at the following address: privacy@manutan.com.
Glossary

i. 'Personal Data', any information relating to an identified or identifiable natural person (hereinafter 'Data Subject'); an 'identifiable natural person' is considered to be a natural person who can be identified, directly or indirectly, particularly by reference to an identifier, such as a name, identification number, location data, an online user name, or one or more specific pieces of information unique to their physical, physiological, genetic, psychological, economic, cultural or social identity;

ii. 'Processing', any operation or set of operations performed with or without the use of automated processes applied to Personal Data or Personal Data sets, such as collecting, saving, organising, structuring, storing, adapting or modifying, extracting, consulting, using, communicating by transmission, broadcast or any other means of release, comparing or interconnecting, limiting, erasing or destroying the data;
iii. 'Data Controller', the natural or legal person, public authority, service or other body that, alone or jointly with others, determines the Processing purposes and resources; when the purposes and resources for this Processing are determined by European Union law or the law of a Member State, the Data Controller may be appointed or the specific criteria applicable to their appointment may be specified by European Union law or by the law of a Member State;
iv. 'Subcontractor', the natural or legal person, public authority, service or other body that processes Personal Data on behalf of the Data Controller;
v. 'Recipient', the natural or legal person, public authority, service or any other body that receives communication of Personal Data, whether or not it is a Third Party. However, public authorities likely to receive Personal Data as part of a specific investigative role in accordance with European Union law or the law of a Member State are not considered to be Recipients; Processing of these data by the relevant public authorities complies with the applicable rules on data protection depending on the Processing purposes;
vi. 'Partner', a natural or legal person, public authority, service or body other than the Data Subject, the Data Controller, the Subcontractor and persons who, under the Data Controller's or Subcontractor's direct authority, are authorised to process the Personal Data;
vii. 'Consent' of the Data Subject, any freely given, specific, informed and unambiguous expression by which the Data Subject accepts, by a declaration or by a clear affirmative action, that Personal Data about them are subject to Processing;
viii. 'Supervisory Authority', an independent public authority established by a Member State.

Category of cookies	Purposes
Strictly Necessary Cookies	These cookies are necessary for the operation of the website and cannot be disabled in our systems. They are generally set in response to actions you have taken that constitute a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or be informed of the existence of these cookies, but some parts of the website may be affected.
Functional Cookies	These cookies are used to improve and personalize the functionality of the website. They may be set by Manutan, or by third parties whose services are used on our website pages. If you do not accept these cookies, some or all of these services may not function properly.
Perfomance Cookies	These cookies allow us to determine the number of visits and sources of traffic, in order to measure and improve the performance of our website. They also help us to identify the most/least visited pages and to evaluate how visitors navigate the website. If you do not accept these cookies, we will not be informed of your visit to our site.
Targeting Cookies	These cookies may be set within our website by our advertising partners. They may be used by these companies to profile your interests and serve you relevant advertisements on other websites. If you do not allow these cookies, your advertising will be less targeted.
Social Media Cookies	These cookies are enabled by the social networking services we have added to Manutan website to give you the ability to share our content with your network. They also allow us to track your browsing on other websites and profile your interests. If you do not allow these cookies, it may affect the content and messages displayed on other websites you visit and you may not be able to use or view the sharing tools.

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