To do

PRIVACY POLICY

Throughout the following documentation, we would like to draw your attention to the processing of personal data carried out by Vetrotech. We ask that you please read our Privacy Policy carefully. If you have any questions or comments about this Privacy Policy, you can always address them to us via the contact information specified in Section 2.

Whenever this Policy references “Vetrotech”, “we”, “us”, or “our”, it refers to Vetrotech the Vetrotech subsidiary responsible for servicing your geographic location.

This policy applies to our customers, users of our websites and social media profiles, users of third-party services and applications offered on behalf of Vetrotech, and in general, subjects that contact us to inquire about our company.

1 OVERVIEW
The following Privacy Policy informs you about the type and extent of processing of so-called personal data by Vetrotech. Personal data is information that identifies you or that allows to identify you directly or indirectly.

Our data processing activities can essentially be divided into five categories:

I. Processing of inquiries: data required to assist you and handle your requests for information and / or services, as well as employment applications.

II. Contract execution: all data required for the execution of a contract with Vetrotech. External service providers may be involved in the execution of such contracts, e.g. logistics companies or subcontractors. Some of your data may be shared with these third parties to the extent required.

III. Website / third party services: various information is exchanged between your device and our server, or that of third party services that provide services on our behalf. This can also be personal data. This information is exchanged in order to provide you with access to your client account, access to requested materials, etc.

IV. Advertisement: contact information may be processed based on the basis of provided consent, in order to provide you with promotional materials and / or invitations to discover more about our products and services.

V. Online presence and website optimization: certain information is collected from your device and is used to optimize our website or to display advertisements in the browser of your device.

Your data is managed in compliance with the locally-established legal obligations. It is only used for the purposes above mentioned in a relevant and proportionate manner. Our processes require your identification for the processing of your requests, for the compliance with our legal obligations, and / or for the improvement of your experience with our products and services.

2 NAME AND CONTACT DETAILS OF THE DATA CONTROLLER
Personal data concerns about the use of our website, your client account, newsletter subscriptions, or other applications and services offered on behalf of Vetrotech can be addressed to us directly via the above provided address or the following e-mail address: privacy.contact.vetrotech@saint-gobain.com .

3 PURPOSES OF DATA PROCESSING, LEGAL BASES AND LEGITIMATE INTERESTS PURSUED BY VETROTECH
3.1 PROCESSING OF INQUIRIES
We collect and process your personal data when you provide information via our website forms, third party services, our social media platforms, or direct contact by phone or e-mail.

As example, this includes information provided at the time of registering an account or subscribing to the services we provide via our website; posting materials or requesting services or information; managing your client account online (including accessing documentation), submitting an application for an existing job vacancy, etc. We may ask you for additional information when you report a problem with our website. If you complete any surveys requested for research purposes, we will collect information in such circumstances as well.

The information you give us may be personal data such as:

I. Name and last name,

II. Gender,

III. Company name,

IV. Address,

V. Country of residence

VI. E-mail address,

VII. Phone number,

VIII. Inquiry details and files you may choose to upload to our website,

IX. General information required for the job application.

3.2 USE OF OUR WEBSITE
When you visit our website, the browser used on your device automatically sends information to the server of our website and temporarily stores it in a so-called log file. We have no influence on this. The following information are collected without your intervention and stored until automated deletion:

I. The IP address of the requesting internet-enabled device,

II. The date and time of access,

III. The name and URL of the retrieved file,

IV. The website / application from which the access was made (referrer URL),

V. The browser you use and, if necessary, the operating system of your internet-capable computer as well as the name of your access provider.

The IP address of your device and the other data listed above are used by us for the following purposes:

I. Ensuring a smooth connection setup,

II. Ensuring comfortable use of our website,

III. Evaluation of system security and stability.

Furthermore, we use cookies, tracking tools and social media links that are available in our website. The exact procedures on how your data will be used for this are described in more detail in Section 3.6 below.

If you have consented to the so-called geolocation in your browser or in the operating system, or other settings of your device, we use this function to offer you individualized services (for example, the location of the nearest branch) related to your current location. We process your location data exclusively for this function.

3.2.1 Mouseflow

Section 3.2.1 applies exclusively to users of our Lunax website: www.lunax.com , a product line of Vetrotech.

Our website uses Mouseflow, a web analysis tool of Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark, to record randomly selected individual visits (but only with an anonymous IP address). This creates a log of mouse movements and clicks for the sole purpose of randomly sampling individual site visits and deriving potential improvements to the site. The information is not personal due to the anonymization and will not be disclosed to third parties. Should you not want your visits to be recorded, you can deactivate them directly from Mouseflow via the following link: www.mouseflow.de/opt-out/ .

3.3 USE OF THIRD PARTY SERVICES: SHOWPAD
If you have requested to receive materials presented to you via Showpad, certain information will be required to provide you with access to the platform and the requested content. For this purpose, we will only process your e-mail address.

The corresponding data processing agreements are put in place to justify and limit the processing that Showpad does on our behalf.

3.4 CONCLUSION, EXECUTION OR TERMINATION OF A CONTRACT
3.4.1 Data Processing for the Execution of a Contract

The activity of Vetrotech is defined as the design, development, manufacture, and distribution of sustainable fire-resistant and security glass and systems; as well as dynamic glass solutions, for the electronic tint of windows, skylights, and curtain walls.

In this context, we process the data required to complete, execute or terminate a contract with you. This data includes:

I. Company, first name, last name

II. Billing and delivery address

III. E-mail address

IV. Billing and payment data

V. Telephone number

VI. Any other information you provide us with in the context of the execution and/or conclusion of the contract.

You provide us with the data based on the contractual relationship between us. We store the data collected for the execution of the contract until expiry of the statutory or possible contractual warranty and guarantee rights. After expiry of this period, we retain the information required by commercial and tax law of the contractual relationship for the statutory periods. For this period (usually ten years from the conclusion of the contract), the data will be reprocessed in the event of a review by the tax authorities.

Provided that you have made purchases from us, your data, in combination with similar entries, can be subject to sales analysis. Our interest for conducting sales analyses is supported by our need to measure our sales performance, assess the effectiveness of our sales force, and set targets for our manufacturing capacity.

In reference to the execution of a contract, you may be asked to complete a satisfaction survey. We will collect your information in this circumstance as well. This information is offered by you voluntarily.

3.4.2 Identity, Creditworthiness and Transmission to Credit Agencies

If necessary, we check your corporate identity by using information from service providers (e.g. Bloomberg or Thomson Reuters World Check) as well as other external sources, such as sanction lists published by the US, UN or EU. The legitimate interest for this results from our obligation to comply with legal and regulatory obligations, as well as the verification of your business identity for the prevention, detection and avoidance of fraud or corruption, notably by providing services to individuals or entities subject to economic or commercial sanctions. The verification uses information about your business only. Indirect processing of personal data may happen in case of an association between your personal information and your business registration (e.g.: John Doe, General Manager of John Doe & Associates). The result of our inquiry will be added to your customer file for the duration of the contractual relationship.

In the event of a delay in payment, and provided that other legal requirements are met, we will submit the necessary data to a company commissioned with the assertion of the claim. The settlement of a contractual claim is to be regarded as a legitimate interest of our business.

3.4.3 Export Compliance and Legal Check

Depending on your location, prior to the execution of a sales contract, we may check your business name and address for possible association with countries, entities, or individuals listed for economic or export control sanctions. The legitimate interest results from our obligation to comply with applicable regulation against sanctioned countries and individuals, and conduct effective legal watch on trade restrictions.

The screening uses information about your business only. Indirect processing of personal data may happen in case of an association between your personal information and your business registration (e.g.: John Doe, General Manager of John Doe & Associates).

3.5 DATA PROCESSING FOR ADVERTISING PURPOSES
3.5.1 Advertising Purposes of Vetrotech and Third Parties

The following basic data for marketing activities will be processed:

I. First name, last name;

II. E-mail;

III. Preferred language;

IV. Country of residence; as it allows us to place you under a certain location category and deliver information about products and services that are available in your area;

V. Professional activity; as it allows us to place you under a certain contact category and deliver information about products and services that are relevant for your sector.

3.5.2 Relevant Advertisement

In order to deliver only promotional information that is relevant to you, we categorize your profile based on information that you provide about your professional activity (builders, architects, general contacts, etc.).

3.5.3 Newsletters

Via our website, we offer you the opportunity to sign up for our newsletter. In order to be sure that no errors have occurred when entering the email address, we use the so-called double-opt-in procedure: after you have entered your email address in the registration field, we will send you a confirmation link.

You can revoke your consent at any time. For this, a short note by email to the specified contact details under Section 2 will be sufficient. In addition, your consent can be removed via a link available in the respective email in which the newsletter is sent to you. You can use the “unsubscribe” link to exercise your right of consent withdrawal.

We use third party services provided by MailChimp to manage the distribution of our newsletter services. MailChimp is a company certified under the EU-U.S., as well as the Swiss-U.S. Privacy Frameworks.

If you object to the processing of your data for advertising purposes, the affected contact address will be blocked for further advertising processing. We point out that in exceptional cases, even after receipt of your objection, there may be a temporary delivery of advertising material. This is technically due to the necessary lead time for the cease of advertisement and does not mean that we do not implement your objection.

3.6 ONLINE PRESENCE AND WEBSITE OPTIMIZATION
3.6.1 Cookies – General Information

We use so-called cookies on our website, including Google Analytics cookies. Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies store information which result from connection with the specific device used. However, this does not mean that we are immediately aware of your identity.

On one hand, the use of cookies serves to make the use of our website more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website or that you have already logged in to your customer account. If you visit our site again to discover our services, cookies will automatically recognize that you have already been with us and what inputs and settings you have made, so you do not have to re-enter them. On the other hand, we use cookies in order to statistically assess the use of our website and to evaluate it for the purpose of optimizing our offer and to display information tailored to your specific needs. When you visit our site, these cookies allow us to automatically recognize if you have already browsed our content.

The storage period of cookies depends on their purpose and is the same for everyone. You can delete cookies and clear your browsing data directly from your browser’s settings. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or to be notified when cookies are created. Please note that disabling cookies completely may mean that you cannot use all features of our website.

3.6.2 Social Media Links

Our website may contain links that direct you to the social networks Facebook, Twitter, YouTube, LinkedIn and Xing (the “social network”), in order to connect you with the content displayed in these platforms and make our company better known. When you access a social network site via a link, responsibility for compliance with data protection is to be guaranteed by the respective providers.

If you establish a connection with the social network of your choice, your browser connects directly to the providers’ servers. Through this integration, the social network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile or are currently not logged in to your account. This information (including your IP address) will be transmitted from your browser directly to a provider’s server and stored there. If you are logged in to your account, the provider can immediately assign the visit to our website to your profile. If you interact with the website, for example by clicking a "Like" or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.

For information about the purpose and scope of the data collection and the further processing and use of the data by the requested social network, as well as related rights and settings options for the protection of your privacy, please refer to the privacy policy of the selected provider.

4 RECIPIENTS OF YOUR DATA
Within the strict framework of the purposes stated in this Privacy Policy, or where legitimate reasons apply, your data may be processed jointly with other Vetrotech affiliated companies or other companies of the Saint-Gobain Group, partners, subcontractors, service providers, and/or parties that are required in order to fulfill your request. In some cases, we may thus transfer your data to these third-parties’ databases outside your country of residence. In such event, and unless specified otherwise in this policy, this will occur in accordance with applicable data protection laws to ensure that any personal data processing by such service providers is protected to our standards.

5 DATA SECURITY
We use appropriate technical and organizational security measures to protect your personal data against manipulation, partial or complete loss, and against unauthorized access by third parties. Our security measures are continually being upgraded in line with regulatory and technological developments, and are reviewed on a periodic basis by our information technology and information systems team.

6 WEBSITES
The following list details the websites hosted by Vetrotech and covered under the scope of this policy:

www.vetrotech.com
www.lunax.com

Last Updated: 28.09.2018