1. FOREWORD

EUAM Ltd firmly believes that trust is key for developing successful and lasting relationships. In this respect, the protection of your personal data and privacy is no exception.

This is the reason why EUAM Ltd puts great emphasis on collecting and processing your personal data with utmost care and in compliance with the applicable legal framework.

In order to inform you in the most transparent manner, EUAM Ltd has prepared the privacy policy below, which explains in detail why and how your personal data are processed where you browse this website.

2. SCOPE AND PURPOSE OF THIS PRIVACY POLICY

This privacy policy (hereinafter the “Privacy Policy”) is intended to inform you, as a user of the EUAM Ltd website www.euamglobal.com (hereinafter the “Website”), about the way EUAM Ltd (hereinafter “EUAM Ltd”) processes, as controller, information enabling to identify you either directly or indirectly (hereinafter “Personal Data”) in the context of your use of the Website.

3. CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING

Where you use the Website, EUAM Ltd processes your Personal Data for various purposes, each of them being duly legitimated by a valid legal basis.

First, EUAM Ltd collects and processes your Personal Data for managing and following up any questions and/or requests you may submit. As such, please note that this processing is only carried out in the event you submit a question and/or request. Otherwise, your Personal Data are not processed for this purpose.

This processing requires that EUAM Ltd collect and process the following categories of Personal Data: (i) identification data (i.e. your first name, your last name, and your contact details); (ii) data related to your professional life (i.e. the identity of your employer and your job position); and (iii) the content of the message(s) you sent to EUAM Ltd as part of your question/request.
While processing your Personal Data for this purpose, EUAM Ltd relies on its legitimate interest, which consists in duly managing its relationships with you.

Second, if you are an investor, you may have been granted by EUAM Ltd an investor account enabling you to access specific pages and contents through the Website.

For managing your investor account, and notably ensuring that you are entitled to access contents dedicated to investors only, EUAM Ltd needs to process and collect your identification data (i.e. your first name, your last name, your contact details as well as your login and password for accessing your investor account) as well as data related to your professional life (i.e. the identity of your employer).
The legal basis of this processing is the necessity for EUAM Ltd to perform a contract to which you are a party.

Third, if you are willing to subscribe to its newsletter, EUAM Ltd needs to collect and process your email address, which is a Personal Data, in order to properly manage your subscription.

Please note however that EUAM Ltd will only send you its newsletter and process your email address accordingly provided it has obtained your prior consent, which constitutes the legal basis of this processing.

Lastly, as EUAM Ltd is willing to understand how users interact with its Website, it needs to process various browsing information resulting from cookies which qualify as Personal Data. Thus, the fourth category of processing EUAM Ltd carries out with your Personal Data is the performance of analytic operation related to the Website traffic and use.

In this respect, the legal basis EUAM Ltd relies upon is its legitimate interest which consists in: (i) better understanding the way its Website is browsed by users (including you); and (ii) improving the Website where needed.

In any event, and disregarding the processing purpose at stake, please note that EUAM Ltd will comply with a strict data minimisation principle and will thus only collect and process Personal Data which is necessary for the above purposes.

Besides, for managing your questions/requests, your investor account as well as your subscription to the newsletter, the provision of your Personal Data is a contractual requirement. In this respect, sharing your Personal Data with EUAM Ltd is thus mandatory, otherwise EUAM Ltd will not be able to: (i) address your questions/requests; (ii) manage your investor account (including to give you access to content specifically dedicated to investors); and/or (iii) send you its newsletter.

4. DATA RECIPIENTS

EUAM Ltd shares your Personal Data with third-party service providers and suppliers which assist EUAM Ltd for fulfilling the purposes specified in this Privacy Policy.

For example, to manage your investor account, EUAM Ltd relies on the services of Intralinks, Inc., which notably administers the portal through which you can log in. Thus, Intralinks accesses your Personal Data, notably your login and password.

Another example is to be found with respect to cookies. Indeed, to perform the analytic operations regarding your use of the Website, EUAM Ltd relies on the services of Matomo, which thus access and processes your Personal Data resulting from the use of cookies.

To the extent this is necessary, EUAM Ltd also communicates your Personal Data to other entities of the EUAM Ltd group (e.g. the question you submitted to EUAM Ltd actually concerns another entity of the EUAM Ltd group and the latter will thus contact you directly to answer your question if relevant).

Furthermore, as the case may be, EUAM Ltd shares your Personal Data with competent courts and any other governmental and/or public authorities requesting access to your Personal Data, within the extent legally permitted.

In any event, EUAM Ltd communicates your Personal Data to the above recipients on a strict need-to-know basis and only as necessary for fulfilling duly identified processing purposes.

California disclosure

All terms used under this section shall have the same meaning as those defined under the California Consumer Privacy Act of 2018 and all related amendments and regulations (“CCPA”).

EUAM Ltd does not sell the Personal Information of California residents.

Under certain circumstances and if you are a California resident, you have the following rights:

• Right to know about the processing of your information by EUAM Ltd in the preceding 12 months, including (i) the categories and specific pieces of Personal Information EUAM Ltd has collected about you; (ii) the categories of sources from which EUAM Ltd has collected your Personal Information, and the business or commercial purpose for the collection; (iii) the categories of third parties with whom EUAM Ltd has shared your Personal Information and the business or commercial purpose for said sharing.

Please note that you may only make a ‘right to know’ request to EUAM Ltd up to two times in any twelve-month period.

• Right to deletion of your Personal Data (subject to EUAM Ltd right to maintain your Personal Data for specific purposes permitted under the CCPA).
• Right to opt-out of the sale of your Personal Data to third parties.
• Right to non-discrimination when exercising any of the rights listed above (and any other rights under the CCPA and all related amendments and regulations).

You may submit requests to exercise one of your rights by emailing euamglobal@gmail.com, by registered mail at EUAM Ltd.

5. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

EUAM Ltd may need to transfer your Personal Data to other entities of the EUAM Ltd Group. Please note that some of these are located outside the EEA in countries that are not regarded by the European Commission (“EC”) as providing an adequate level of protection to Personal Data (e.g. China, Singapore, USA).

For transfers of your Personal Data to such countries, EUAM Ltd has implemented appropriate safeguards approved by the EC. This includes Binding Corporate Rules (“BCR”) between the various entities of the EUAM Ltd group or entering into Standard Contractual Clauses with the recipients of the Personal Data.

6. DATA RETENTION PERIODS

EUAM Ltd only retains your Personal Data for a retention period not exceeding what is necessary in light of the processing purpose at stake.

As a result, the data retention period implemented by EUAM Ltd depends upon the processing purpose as detailed below.

First, with respect to the management of your questions and/or requests, EUAM Ltd will not retain your Personal Data for more than five (5) years following the last contact on your initiative.

Second, regarding the management of your investor account, EUAM Ltd will retain your Personal Data until your investor account is closed. Nevertheless, if EUAM Ltd needs to retain your Personal Data for evidence purpose beyond the date your investor account is closed, the maximum retention period applicable will then be in line with the statute of limitation and will not exceed the period during which EUAM Ltd is required to retain evidence.”

Third, where EUAM Ltd processes your Personal Data for managing your subscription to its newsletter, your Personal Data will be retained by EUAM Ltd until you unsubscribe from the newsletter.

Lastly, the Personal Data processed by EUAM Ltd or on its behalf for performing analytic operations shall not be retained by EUAM Ltd after the analytic operations are finalized and the corresponding reports/summaries are completed.

Where the applicable retention period expires, EUAM Ltd either deletes your Personal Data or irrevocably anonymises it so that you can no longer be identified.

Where EUAM Ltd considers it does not need to retain your Personal Data in its active database, it will archive it and will ensure that access thereto is restricted to a limited number of persons who have an actual need to access your Personal Data.

7. YOUR RIGHTS AND OBLIGATIONS AS DATA SUBJECT

As a data subject, you benefit from various rights regarding the processing of your Personal Data. These are as follows:

1.    right to request from EUAM Ltd access to and rectification or erasure of your Personal Data;
2.    right to request from EUAM Ltd restriction of the processing concerning you;
3.    right to object to the processing of your Personal Data;
4.    right to portability of your Personal Data;
5.    right to specify guidelines regarding the use of your Personal Data after your death;
6.    with respect to the management of your subscription to EUAM Ltd newsletter, right to withdraw the consent you gave, at any time and without affecting the lawfulness of processing based on your consent before withdrawal thereof; and
7.    right to lodge a complaint with the French Data Protection Authority (CNIL).

EUAM Ltd is committed to utmost care when it comes to protecting your Personal Data and complying with the applicable data protection legal framework.

This is the reason why EUAM Ltd requires your assistance to this end. Thus, you commit to inform EUAM Ltd in case the Personal Data you shared with EUAM Ltd would become obsolete or inaccurate.

In addition, in the event you would provide EUAM Ltd with information enabling to identify directly or indirectly any other natural persons (e.g. you sent a request to EUAM Ltd with the contact email address available on the Website and share personal data concerning another natural personal in your email), you represent and warrant that, prior to sharing this information with EUAM Ltd, such other natural persons have been provided with this Privacy Policy and, to the extent applicable, have consented to the processing of their data.