I. Legal notice

Vallair (Capital) a simplified joint-stock company (SAS) with a share capital of 101.570 Euros with its head office at BAT 770 Aéroport Châteauroux Déols Marcel Dassault, 36130 DEOLS SIREN 450 794 177 R.C.S. Châteauroux

II. The privacy policy / charter

The Privacy Charter contains all the information regarding our personal data protection policy, as well as the rights inherent to the personal data of the company.

Article 1: Definitions
– “Vallair” or “we” – a simplified joint-stock company incorporated under French law, registered with the Commercial Court of Châteauroux under number 450 794 177. Vallair’s head office is located at BAT 770 Aéroport Châteauroux Déols Marcel Dassault, in Deols (36130) France and its subsidiaries Vallair Solutions and Vallair Industry.

– “User” or “you” – any and all natural persons using our website and our services, acting on his/her own behalf or on behalf their company, including our subscribers and persons who are partaking in our Free Trial. For clarity, this definition extends to any and all persons who visit and/or use our Website.

– “Website” – our Website, accessible at Vallair.aero

Article 2: Who is controlling the Processing of the Data collected by Vallair?
Controller refers to the natural or legal person who, alone or jointly, collects personal data and determines the purposes and means of the data processing. Vallair is responsible for processing your personal data, which is collected in the course of you navigating our Website and using our services.
If the personal data processed concerns third parties, you undertake to obtain the prior consent of the third party concerned and to further inform him/her of the existence and content of the present Charter, particularly of the rights he/she has regarding his/her personal data in accordance with Article 8 of this Charter.

Article 3: What is the law on processing personal data?
We collect and process personal data only on a legal basis, in accordance with the EU Regulation (EU) 2016/679 on the General Data Protection (“GDPR”).
In accordance with the GDPR, we collect and process personal data as follows:

• With your consent to process your data for specific purposes;
• To execute a contract to which you are a party;
• In meeting our legitimate interest in informing the public, by re-using information from the public domain and offering our services; and
• In the course of complying with our legal obligations.

The processing of personal data is thus carried out for the following purposes:

• Pursuit of our legitimate interest; and
• Compliance with our legal obligations.

Article 4: What personal data is processed by Vallair?

A. Data Processing regarding any and all Visitors to our website
When you visit our Website at vallair.aero and use our services, by default your web browser sends us a set of information that we collect automatically. This information includes:

• • Your IP address;
  • Information on the device you are using (e.g. computer, smartphone, etc.), as well as information on your operating system, such as the type and version (e.g. Windows, Mac, Android, etc.);
  • The Internet browser you used, as well as its version and language;
  • The time of your visit;
  • The pages you visited on our Website;
  • Your location; and
  • The website that redirected you to our Website.

This information is analysed and used to measure the audience of our Website. It is also essential for improving the user experience (e.g., site accessibility, data security, personalisation, etc.).

The information is automatically collected and stored by Vallair in compliance with its Personal Data Protection Policy. It is archived after 12 months and destroyed five years after it has been archived.

We collect data regarding your location only to know your time zone, which allows us to provide the fastest possible response to your requests and questions. The information is automatically collected and stored by our provider in compliance with the GDPR.

We also collect your personal data when you voluntarily contact us through the various channels present on our Website, including the contact form. This data allows us to process your request and to answer you as soon as possible. The information thus collected is archived and kept until you exercise your right to erasure and/or object, and for a maximum of three years.

Processing the data of our customers, prospects, and Vallair account holders
The aforementioned information is archived and kept for a period of five years from the termination of your contract with Vallair. In order to comply with our accounting obligations, supporting documents (purchase orders, invoices, etc.) are kept for a period of ten years.

Commercial purposes
We may use your personal data, which you voluntarily provided us with in the course of creating your account and/or taking out a subscription, for commercial purposes. This information is obtained either directly from you when creating your account or taking out our subscription, or during our communication (e.g. telephone, e-mail, etc.), when you request a service, such as a subscription, a Free Trial or a demonstration.

With respect to prospects, we may collect your data through information publicly available on your website or your LinkedIn profile for commercial purposes. You may object to the processing of such data for commercial purposes at any time, in accordance with the paragraph G of the Article 8 below. Your personal data will be kept for 3 years after your last solicitation for exchange. We collect and process your personal data in accordance with our legitimate interest in offering you our content and services.

Article 5: is your Personal Data transferred to Third Parties in France or Abroad?
The personal data that we process as set out in Article 4 above is collected and processed solely for our own purposes and are not, under any circumstances, sold to third parties.

The personal data is transferred only to service providers with whom we collaborate to carry out our day-to-day business and with whom we have concluded a personal data processing contract. These service providers are located in France and abroad (both within and outside the EU). In terms of service providers located outside the EU, we have duly verified that their policies ensure an effective and efficient level of confidentiality and protection of personal data during transfers.

Article 6: Our Cookies Policy
We use cookies and trackers in order to measure the audience of our Website and for the sole purpose of continuously improving the user experience (e.g. site accessibility, data security, personalization, etc.)

Cookies are temporary text files stored directly on your device (e.g. on your computer or smartphone). They allow us to collect various information, including technical information, information relating to your browser (search engine, connection time, pages visited, etc.), or information relating to your browsing preferences.

The data collected and processed by us in this way will not, under any circumstances, be sold to third parties or processed for advertising purposes. It is kept for a period of 13 months.

Article 8: What Rights do you have to your Personal Data?
In accordance with the GDPR, you have rights to the data that we automatically collect from you when you use our Website and services.

These rights include:

A. Right of access to your personal data (Article 15 of GDPR)
You may contact us in order to find out what personal data is processed by Vallair and to check its content.

We will provide you with a copy of all of your personal data that is processed. Specifically, we will provide you with the following information:

• • Categories of personal data collected;
  • Purposes of using your personal data;
  • Categories of recipients who were able to access such data;
  • Envisaged period for which the personal data will be stored; and
  • Possible transfer of your data to a third (non-EU) country or to an international organisation.

B. Right to rectification of your personal data (Article 16 of GDPR)
You may request the rectification of inaccurate, incomplete or obsolete personal data.

C. Right to erasure (‘right to be forgotten’) of your personal data (Article 17 of GDPR)
You can request the erasure of your personal data without undue delay if one of the following grounds applies:

• • the personal data is no longer necessary in relation to the purposes for which they were initially collected or processed;
  • you withdraw your consent to the processing of your personal data;
  • your personal data have been unlawfully processed (e.g. publication of pirated data);
  • your data was collected when you were a minor;
  • your personal data have to be erased for compliance with a legal obligation;
  • your object to the processing of your personal data has no overriding legitimate grounds for us not to comply with this request.

D. Right to restriction of processing (Article 18 of GDPR)
You may request the restriction of processing of your personal data if one of the following grounds applies:

• • you contest the accuracy of certain data during the verification of the data;
  • the processing of personal data is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
  • when, even if we no longer need to process your personal data, the data is necessary for the establishment, exercise or defence of legal claims; or
  • when you have exercised your right to object to us processing your personal data, pending our verification of legitimate grounds authorizing us to continue processing your personal data.

E. Right to withdraw the consent (Article 7 of GDPR)
Where the processing of data is based on your prior consent, you may withdraw your consent at any time without giving any reason.

F. Right to data portability (Article 20 of GDPR)
You can receive your personal data (which you have voluntarily transmitted to us) in a structured and machine-readable format, for your personal use or in order to pass it on to a third party.

G. Right to object (Article 21 of GDPR)
Subject to a legitimate reason relating to the particular nature of your situation, you may object to the processing of your personal data on the basis of necessity for the performance of a task carried out in the public interest or in pursuit of a legitimate interest.

We may deny your objection if we can prove that there are compelling legitimate grounds for processing your data which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

This prior justification is not opposable to you when the right to object relates to the marketing purposes.

H. Right of referral to the CNIL or legal action (Article 12 of GDPR)
In the event of a dispute relating to the processing of your personal data, you may lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL) or file a claim to the competent court.

Article 9: How to exercise your rights?
You may exercise your rights as set forth in Article 8 above, or ask any questions you may have regarding this Charter, by emailing us at the following e-mail address: [gdpr@vallair.aero]. In accordance with Article 12 of the GDPR, we will respond to your request as soon as possible and no later than one month of receipt of the request.

Any request to exercise your rights to your personal data must be accompanied by a valid document proving your identity, otherwise your request will not be processed.

Article 11: Privacy Charter Updates
In order to comply with changes in the law, technology or Vallair’s business, this Privacy Charter may be modified at any time.