Privacy policy

Introduction

Welcome to “BEHUB-E”, an internet site (hereinafter the “Site”) that is owned and operated by VALLOUREC DIGITAL SOLUTIONS, LLC (hereinafter called “VALLOUREC”, “us”, “we”, “our”). The protection of Your Personal Data is of the utmost importance to us and we have adopted this Privacy Policy (“Policy”) to explain how we collect, use, share, and safeguard Your Personal Data (as defined below). This Policy applies to all information, including Personal Data , that we collect about You, both online and offline. 1 Please note that the rights discussed in certain sections of this Policy may be subject to exemptions or limitations under applicable law. Please review this entire Policy carefully. By accessing and using the Site, You acknowledge acceptance of the terms of this Policy. If You do not agree with or You are not comfortable with any aspect of this Policy, You should immediately discontinue access or use of our Site.

This Policy contains the following sections:

• Definitions
• Our Collection of Personal Data
• How We Use Personal Data
• Cookies
• Links to Other Websites
• How Long We Keep Personal Data
• Transfer of Personal Data
• Sharing of Personal Data
• Security Measures
• Your Rights Regarding Your Personal Data
• Updates to the Policy
• Questions / Contact

1. Definitions

The terms defined below will have the following meanings, whether used in the singular or the plural:

• “Personal Data” means any information relating to an identified or identifiable natural person. A person is “identifiable” if he or she 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 elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of him or her, including “personal information” or other similarly defined information under Applicable Data Protection Laws.
  
  
• “Device” means the different means by which the Site will be accessible, including smartphones, tablets, online computers (PC or Apple) and any object that is connected or can be connected to another object or to the internet
  
  
• “You”, “Your”, “User(s)” means any person accessing the Site and whose Personal Data can be collected during their visit to the Site.
• “Applicable Data Protection Laws” means applicable data protection laws that apply to us and/or the Personal Data that we collect from or about You, including, the most recent version in force of the French Data Protection Act No. 78-17 of 6 January 1978, the provisions of European Union General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter “EU GDPR”), and the provisions of the EU GDPR as it forms part of the laws of the United Kingdom by virtue of Section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR” and, together with the EU GDPR, the “GDPR”) and UK Data Protection Act 2018.
  
  
• “Processing” includes in particular the use, storage, recording, transfer, adaptation, analysis, summarization, modification, declaration, sharing and destruction of the Personal Data according to what is necessary given the circumstances or legal requirements.
  
  

Terms used in this Policy that are not otherwise defined shall have the meaning ascribed to them under Applicable Data Protection Laws.

2. Our Collection of Personal Data

VALLOUREC collects Personal Data either online (through Your Device using cookies, login data, during Your navigation on the Site’s pages, or via collection forms2 ) or offline. VALLOUREC collects certain information directly when it is provided by You (or Your representative), and other information may be collected about You automatically when You visit our Site. You are required to provide certain Personal Data if You wish to establish a business relationship to benefit from our products or services. If You do not provide that data, You may not be able to place an order on our Site. We will only use Your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use Your Personal Data for an unrelated purpose, we will notify You and we will explain the legal basis which allows us to do so. Please note that we may process Your Personal Data without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

2.1. Information Provided by You Directly

Depending on how You interact with us, we collect certain Personal Data directly from You including: • Identifiers.

• Including Your business name, business contact name and tax ID number, or other business identification number.
  
  
• Professional Contact Details. Business postal address, email address and telephone number, and employer.
  
  
• Profile Data. Such as a Username and password, and preferences.
  
  
• Marketing, Communications and Correspondence Data. This includes Your preferences in receiving marketing from us and third parties, Your communication preferences, and records of information provided by You when You contact us with questions, feedback or for other reasons.
  
  

2.2. Information Collected About You Automatically

We may automatically collect Your Personal Data as You interact with our Site, such as browsing actions, patterns, hardware model, device ID and internet protocol (IP) address. The information we may collect automatically from You includes:

• Log Files. These include IP addresses, browser version, browser types, internet service providers, pages visited, entry/exit pages, referring sites, platform types, connection speed and demographic information.
  
  
• Navigational Data. This includes information gathered while You browse the Site, including what pages You visited and how long various features are used.
  
  
• Cookies. These are text files containing small amounts of information which are stored on Your browser or device when You visit our Site. Further information on our use of cookies is set out in Section 4 (Cookies). 
  
  

2.3. Information Collected From Other Sources

We may separately collect Your Personal Data from other third parties and public sources, as required or permitted by applicable laws, such as public databases, resellers, joint marketing partners and social media platforms.

3. How We Use Personal Data

We Process Personal Data for various purposes as described below. Where required under Applicable Data Protection Laws, we have established a lawful basis to do so and have outlined such bases below.

3.1. Purpose for Processing Personal Data

We Process the information we collect for our purposes associated with the growth, maintenance, and management of our business. Depending on how You interact with us, we may use Your Personal Data and other information for a number of purposes, including the following purposes (hereinafter the “Purposes“):

• Operate and continuously improve the Site, its functionalities and the services. We use Your Personal Data to ensure that You have the best experience possible on our Site and the best quality possible for our service. In order to achieve this, we use Your Personal Data for various purposes related to Site operation and improvement, including to answer Your requests and questions, provide help-desk and support services, run tests and satisfaction surveys, and analyze Site User statistics.
  
  
• Manage Our Relationship With You. We Process Personal Data to manage our relationship with You, including to execute orders placed on our Site, fulfill a contract that we have with You, properly display the right user, and analyze the business to help answer questions and analyze the relationships between buyers and sellers.
• Safety and prevention of illegal activities. We may use Personal Data to protect our company, our customers and the Site. This includes detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity.
  
  
• Compliance with Laws. VALLOUREC is subject to various legal requirements in the jurisdictions in which we operate that require us to collect, process, disclose and retain Your Personal Data in order to comply with those laws. We may be required to retain Your data for extended periods of time, and to provide copies of such data to law enforcement, governmental or other regulatory authorities, or third parties, as applicable.
  
  
• Collecting Analytics for Site Improvement. We also process Your Personal Data to improve and optimize our Site for the benefit of Users. This processing is used for the purposes of analysis and statistical study of the use of our Site. For more information please review Section 4 (Cookies).

3.2. Lawful Basis for Processing

Where required under Applicable Data Protection Laws, we have established a lawful basis for the processing of Your Personal Data. Such bases include:

• Legitimate Interests. We process Personal Data for our legitimate business interest in managing and promoting our business, provided that our interest is not overridden by Your interest. In identifying and relying on this basis for certain processing, we have weighed our legitimate interest as a business against Your rights and freedoms and have determined that such processing will not unfairly impact Your rights. If You would like further information on how we balanced these interests, You can contact us using the details below in Section 12 (Questions/Contact). Please note that you have a right to object to the processing of Your Personal Data where that processing is carried on for our legitimate interest.
  
  
• Legal Requirements. We may need to process Your Personal Data in order to comply with certain legal and regulatory requirements, including to establish, exercise or defend legal claims, respond to a judicial process, law enforcement or governmental agency.
  
  
• Contract. Depending on the circumstances, we may need to process Your Personal Data for the performance of a contract to which You are a party, or related pre-contractual steps.
  
  
• Consent. We may process Your Personal Data with Your consent, as required under Applicable Data Protection Laws. You have the right to withdraw this consent at any time where we are relying on consent to process Your Personal Data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. For additional information please review Section 10 (Your Rights Regarding Your Personal Data) below.

4. Cookies

When You visit the Site, some information relating to your browsing may be recorded in “cookie” files installed on Your Device. A cookie is a file installed on Your Device that records information relating to navigation on a website.

Cookies have many functions. In particular, they allow You to navigate between pages in an efficient manner, they remember Your preferences and generally improve the user experience. Cookies allow the ads that appear on Your screen to be more relevant and adapted to Your interests. 

4.1. Our Use of Cookies on the Site

The Website uses both Cookies issued by VALLOUREC, placed directly by us on Your Device, and third-party cookies, set by third parties on our behalf. We use third-party cookies to help us analyze the use of our Site.

We use both Strictly Necessary Cookies and Audience Measurement Cookies, which are described in more detail below. 

4.2. Strictly Necessary Cookies 

Strictly Necessary Cookies are essential to enable You to use the Site and to use its features, such as access to Your user account. These cookies are activated following actions You perform that correspond to a request for services, such as configuring Your privacy preferences, logging in, filling out forms or using a shopping cart. These cookies do not collect any information that could be used for marketing or targeting purposes. The chart below describes which Strictly Necessary Cookies we use on the Site:

4.3. Audience Measurement Cookies

Audience Measurement Cookies allow us to know, among other information, the number of visits on the Site’s pages and which pages are consulted. This information allows us to improve the Site and to always offer You a better experience. We do this through using tools such as Google Analytics and other similar cookies. Google Analytics is a Google tool for web traffic analysis that enables website owners to better understand the behavior of their users. This tool uses cookies to collect information and generate reports on usage statistics of a website without that individual users are identified personally by Google. You can find out more information about Google Analytics here. 

The chart below describes which Audience Measurement Cookies we use on the Site:

4.4. How to Control Cookies 

You can delete cookies at any time, and where required under applicable law, withdraw Your consent to the use of cookies. We offer You several ways to manage Your choices regarding the installation of cookies. Your cookie settings may modify Your browsing on the Website or even prevent the use of certain features of the Website.

You can control our uses of cookies through our cookie banner and Your internet browser.

• Cookie Banner 

You can manage your cookie and / or withdraw Your consent at any time by accessing our cookie banner.

• Internet Browser

You can configure Your Internet browser to allow or reject cookies. You can also configure your browser so that You are offered the option of accepting or rejecting cookies before a cookie is likely to be stored on Your terminal.

Below, we have provided additional information for each browser, as well as information about the Google Analytics audience measurement cookies that we use:

• Internet Explorer. Internet explorer does not enable the management of cookies on a case-by-case basis. To delete all cookies, click here and follow the instructions.
• Safari. To manage cookies, click here and follow the instructions.
• Chrome. To manage cookies, click here and follow the instructions.
• Firefox. To manage cookies, click here and follow the instructions.
• Opera. To manage cookies, click here and follow the instructions.
• Google Analytics. You can prevent the use of Google Analytics cookies on Your device by using Google’s opt-out tool, available here.

More information is available via the “Help” tab of Your browser.

5. Links to Other Websites

This Site may include links to third-party websites, plug-ins and applications You may be interested in. Clicking on those links or enabling those connections may allow third-parties to collect or share data about You. Unless expressly authorized by You, VALLOUREC will not share any of Your Personal Data with these third parties.

VALLOUREC has no control over the content of these third-party websites or the practices of these third parties in relation to protection of the Personal Data they may collect. As a result, VALLOUREC is not responsible for the contents of third-party sites or the practices of these third parties in relation to Personal Data protection and recommends that You review the information practices of these third parties.

6. How Long We Keep Personal Data

The Personal Data collected is kept for the period required for fulfillment of the various Purposes described in this Policy. In determining the appropriate retention rate for Personal Data, we take into consideration the amount, nature and sensitivity of the relevant Personal Data, the applicable legal, regulatory, taxation, account or other requirements, the potential risks of harm from unauthorized use or disclosure of such Personal Data, and whether we are able to achieve the relevant purposes through other means. In any event, we will only retain Your Personal Data for as long as reasonably necessary or required to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, taxation, accounting or reporting requirements.

The Personal Data collected is promptly deleted should any of the following events arise:

• expiration of the relevant retention period;
• exercise of Your right to delete in accordance with Applicable Data Protection Laws and conditions laid down in Section 10 (Your Rights Regarding Your Personal Data) of this Policy; or
• deletion of the Site by VALLOUREC for any reason whatsoever.
  
  

For log journals, our retention period is 1 year, subject to the above. 

7. Transfer of Personal Data

Our services are hosted and operated in multiple geographic regions. Any Personal Data that we collect may be transferred, accessed and processed outside of Your country, including in the United States. If You are located in the EEA, the U.K., Canada, or other regions with laws governing the processing of Personal Data that may differ from U.S. law, please note that Your Personal Data may be transferred to countries that do not have the same data protection laws as the country in which You initially provided the information.

We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to countries other than the country where You are located. In particular, we may transfer Personal Data to countries for which adequacy decisions have been issued by the European Commission, or the Secretary of State in the U.K. or other relevant bodies in other jurisdictions or use contractual protections for the transfer of Personal Data to third parties, such as the European Commission’s Standard Contractual Clauses. You may contact us to obtain a copy of the safeguards we use to transfer Personal Data outside the EEA or the U.K.

8. Sharing of Personal Data

VALLOUREC is the sole recipient of the data collected. VALLOUREC will only send Your Personal Data to third parties in the following cases:

• You have given Your consent or directed us to share this information with third parties.
  
  
• VALLOUREC receives a request from a legal authority, or any other administrative authority authorized by law and requesting this information in accordance with the legislative provisions in force, or where we believe in good faith that the disclosure of Personal Data is required to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our applicable policies.
  
  
• We are sharing or providing access Your Personal Data with certain thirdparty service providers that provide services to us such as Amazon Web Services, Google and Bing and performing services relating to VALLOUREC’s IT services and applications (hosting, storage and IT maintenance services in particular). These third-party service providers act only on instructions from VALLOUREC and will be bound by the same security and confidentiality obligations as VALLOUREC.
  
  
• In the event that another company acquires a controlling interest in VALLOUREC, or if we experience another change of control event, such as a merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information, including Personal Data, among the assets transferred to the acquiring company. We may further share Your Personal Data with other entities that we plan to merge with and/or be acquired by. Should such circumstances arise, we will require that the new combined entity follow this Personal Data Protection Policy with respect to Your Personal Data. You will receive prior notice of any change in the applicable policies

9. Security Measures

VALLOUREC uses a combination of physical, technical, organizational and administrative security controls designed to maintain the security of Your Personal Data and protect it against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of the Personal Data in our possession. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for Your rights and freedoms posed by the processing of Your Personal Data, we use commercially reasonable physical, administrative and technological methods to transmit Your Personal Data securely and store Your Personal Data. However, as the Site is hosted electronically, we can make no guarantees as to the security or privacy of Your Personal Data.

10. Your Rights Regarding Your Personal Data 

Under Applicable Data Protection laws, Users may have certain rights with regard to their Personal Data, including, where applicable:

• Request access to and rectification of Your Personal Data.
  
  
• Correct Personal Data that we hold where it is incomplete or inaccurate.
  
  
• Restrict the processing of Your Personal Data in certain circumstances.
  
  
• Object to the processing of Your Personal Data in certain circumstances, including where we process Personal Data for direct marketing purposes or where we have processed such data on the basis of our legitimate interests.
  
  
• Request that we erase Your Personal Data under certain circumstances.
  
  
• Ask for a copy of Your Personal Data to be provided to You, or to a third party, in an accessible, commonly used, machine readable format.
  
  
• Withdraw Your consent to the processing of Your Personal Data at any time (where applicable).
  
  
• Where applicable, lodge a complaint at any time about the processing of Your Personal Data with Your local data protection authority. For Users located in the EU/EEA, to find the contact information for Your country’s data protection authority or similar body, please refer to the list provided on the European Commission’s website.

11. Updates to the Policy

Use of the Site is subject to the Policy in force at the time of use.

From time to time, VALLOUREC may modify the Policy according to its needs or if it is required to do so by applicable law or regulations. These updates will be made without advance warning and will be circulated online.

The previous Policy will then be terminated by operation of the law and replaced by the new version, which will be made immediately enforceable for any User from the date it is put online. 

12. Questions / Contact

To exercise Your rights, or for any question regarding the collection or processing of Your Personal Data, please contact us by e-mail at: data.protection@behub-e.com.