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Last update: 14 May 2018

This Privacy Policy sets out and informs you of how PhD Business Solutions uses and protects the information you transmit to us, if any, when you use this site accessible from the following URL: https://www.phebbyphdbusinesssolutions.fr (the "Site").

Please note that this privacy policy may be modified or supplemented at any time by PhD Business Solutions, in particular in order to comply with any legislative, regulatory, jurisprudential or technological changes. In such a case, the date of its update will be clearly identified at the beginning of this policy. These modifications commit the User as soon as they are put online. It is therefore advisable that the User regularly consults this privacy policy and the use of cookies in order to be aware of any changes.

I. PERSONAL DATA

Generally speaking, it is possible for you to visit the PhD Business Solutions Site without communicating any personal information about yourself. In any case, you are under no obligation to transmit this information to PhD Business Solutions.

However, in case of refusal, you may not be able to benefit from certain information or services that you have requested. In some cases, PhD Business Solutions may ask you to provide your name, first name, e-mail address, telephone number, company and position (hereinafter your "Personal Information"). By providing this information, you expressly agree that it may be processed by PhD Business Solutions, for the purposes indicated in point 2 below as well as for the purposes recalled at the end of each form.

In accordance with the General Data Protection Regulation adopted by the European Parliament on 14 April 2016, and with the Data Protection Act of 6 January 1978 as amended, PhD Business Solutions informs you of the following:

• 1. Identity of the controller

The data controller is PhD Business Solutions, with its registered office at 65, Rue Jean Jacques Rousseau - 92150 Suresnes - France.

Tel: + 33 (0)1 74 70 77 37

• 2. Purposes of the processing

PhD Business Solutions may process your Personal Information:

(a) for the purpose of providing you with the information or services you have requested (in particular: sending you the Newsletter, a commercial offer, white papers or evaluating your level of compliance via a quiz); and/or

(b) to collect information that enables us to improve our Site, products and services (including through the use of cookies); and/or

• 3. Recipients

Only PhD Business Solutions is recipient of your Personal Information. These, whether in individual or aggregated form, are never passed on to third parties, notwithstanding the subcontractors that PhD Business Solutions uses (you will find more information about them in point 7 below). Neither PhD Business Solutions nor any of its subcontractors market the personal data of visitors and Users of its Site.

• 4. Shelf life

Your Personal Information is kept by PhD Business Solutions only for the time corresponding to the purpose of collection as indicated in 2 above, which may in any event not exceed 24 months.

• 5. Computer Rights and Freedoms

You have the following rights concerning your Personal Information, which you can exercise by writing to us at the postal address mentioned in point 1 or by filling in the form opposite.

o Right of access and communication of data

You have the right to access Personal Information about yourself.

However, due to PhD Business Solutions' obligation of security and confidentiality in the processing of personal data, you are informed that your request will be processed on condition that you provide proof of your identity, in particular by producing a scan of your valid identity document (in the case of a request through our dedicated electronic form) or a signed photocopy of your valid identity document (in the case of a written request).

PhD Business Solutions informs you that it will be entitled, if necessary, to oppose manifestly abusive requests (due to their number, their repetitive or systematic nature).

To help you in your approach, in particular if you wish to exercise your right of access by means of a written request to the postal address mentioned in point 1, you will find by clicking on the link following a model letter elaborated by the Commission Nationale de l'Informatique et des Libertés (the "CNIL").

https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

o Right to rectify data

Under this right, legislation gives you the right to request the rectification, updating, blocking or deletion of data concerning you that may prove to be inaccurate, erroneous, incomplete or obsolete.

You can also define general and specific guidelines concerning the fate of personal data after your death. If necessary, the heirs of a deceased person may demand that the death of their loved one be taken into consideration and/or that the necessary updates be made.

To assist you in this process, particularly if you wish to exercise, on your own behalf or on behalf of one of your deceased relatives, your right of rectification by means of a written request to the postal address mentioned in point 1, you will find by clicking on the link following a model letter drawn up by the CNIL.

https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

o Right of opposition

The exercise of this right is only possible in one of the following two situations:

1. Where the exercise of this right is based on legitimate reasons; or

2. When the exercise of this right is intended to prevent the data collected from being used for commercial prospecting purposes.

To help you in your approach, in particular if you wish to exercise your right of opposition by means of a written request addressed to the postal address indicated in point 1, you will find by clicking on the link following a model of letter elaborated by the CNIL.

https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

• 6. Response times

PhD Business Solutions undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period which shall not exceed 1 month from receipt of your request.

• 7. Authorised service providers and transfer to a third country of the European Union

PhD Business Solutions informs you that it uses its authorized service providers to facilitate the collection and processing of the data you have communicated to us. These service providers may be located outside the European Union and have communication of data collected through the various forms present on the Site (with the exception of the form allowing you to exercise your rights and freedoms which is offered and operated by PhD Business Solutions).

PhD Business Solutions has previously ensured that its service providers have implemented adequate guarantees and that strict conditions regarding confidentiality, use and data protection are respected. In particular, vigilance has been focused on the existence of a legal basis for any transfer of data to a third country. As such, one of our service providers is subject to internal company rules (or "Binding Corporate Rules") which were approved by the CNIL in 2016 when the others obey not only to Standard Contract Clauses but also to Privacy Shield.

• 8. Complaint to the competent authority

If you believe that PhD Business Solutions is not fulfilling its obligations with respect to your Personal Information, you may make a complaint or request to the appropriate authority. In France, the competent authority is the CNIL to which you can send an electronic request by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

II. COOKIE POLICY

When you first connect to the PhD Business Solutions website, you are warned by a banner at the bottom of your screen that information relating to your navigation may be stored in files called "cookies". Our cookie usage policy allows you to better understand the provisions we implement in terms of navigation on our website. In particular, it informs you about all cookies on our website, their purpose (part I.) and gives you the procedure to follow to set them (part II.).

• 1. General information about cookies on the PhD Business Solutions website

PhD Business Solutions, as the publisher of this website, may install a cookie on the hard disk of your device (computer, tablet, mobile etc.) in order to guarantee smooth and optimal navigation on our website.

Cookies" are small text files of limited size that allow us to recognize your computer, tablet or mobile phone in order to personalize the services we offer.

The information collected through cookies does not in any way identify you by name. They are used exclusively for our own needs in order to improve the interactivity and performance of our website and to send you content adapted to your interests. None of this information is communicated to third parties except when PhD Business Solutions has obtained your prior consent or when disclosure of this information is required by law, by order of a court or any administrative or judicial authority authorized to know it.

To help you better understand the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the PhD Business Solutions website, their name, purpose and retention period.

• 2. Configuring your cookie preferences

You can accept or refuse the deposit of cookies at any time

When you first log on to the PhD Business Solutions website, a banner will appear at the bottom of your screen briefly presenting information about the deposit of cookies and similar technologies. This banner warns you that by continuing your navigation on the PhD Business Solutions website (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your device. You are also deemed to have given your consent to the deposit of cookies by clicking on the "X" icon to the right of the banner at the bottom of your screen.

Depending on the type of cookie you are using, it may be necessary to obtain your consent to set and read cookies on your device.

a. Cookies exempt from consent

In accordance with the recommendations of the Commission Nationale de l'Informatique et des Libertés (CNIL), certain cookies are exempt from the prior collection of your consent insofar as they are strictly necessary for the operation of the website or have the exclusive purpose of enabling or facilitating communication by electronic means. These include session ID, authentication, load balancing session cookies and cookies to customize your interface. These cookies are entirely subject to this policy insofar as they are issued and managed by PhD Business Solutions.

b. Cookies requiring the prior collection of your consent

This requirement applies to cookies that are issued by third parties and that are described as "persistent" to the extent that they remain on your device until they are deleted or expire.

As such cookies are issued by third parties, their use and storage are subject to their own privacy policies which you will find a link to below. This family of cookies includes audience measurement cookies (including PIWIK), advertising cookies (which PhD Business Solutions does not use) and social network sharing cookies (including Facebook, YouTube, Twitter and LinkedIn).

Audience measurement cookies collect statistics about the use of various elements of the website (such as the contents/pages you have visited). This data contributes to improving the ergonomics of the PhD Business Solutions website. An audience measurement tool is used on this website:

o PIWIK whose privacy policy is available from the following link: https://piwik.org/privacy-policy/

Social network sharing cookies are issued and managed by the publisher of the social network concerned. Subject to your consent, these cookies allow you to easily share some of the content published on the PhD Business Solutions site, in particular via a "button" application sharing according to the social network concerned. Four types of social network sharing cookies are present on the PhD Business Solutions website:

o Facebook, whose cookie policy you can view by clicking on the following link: https://fr-fr.facebook.com/policies/cookies/

o LinkedIn, whose cookie policy can be found by clicking on the following link: https://www.linkedin.com/legal/cookie-policy?_l=en_EN

o Twitter, for which you will find the options dedicated to controlling or restricting the use of cookies as well as the cookie use policy: https://support.twitter.com/articles/20170518#

o YouTube, for which you will find the necessary help to delete cookies from the Google Chrome browser by clicking on the following link: https://support.google.com/youtube/answer/32050?hl=en but also the complete cookie policy from the following link: https://www.google.fr/intl/fr/policies/technologies/cookies/

c. You have various tools for setting cookies

Most Internet browsers are configured by default so that cookies are allowed. Your browser offers you the opportunity to modify these standard settings so that all cookies are systematically rejected or only part of the cookies are accepted or rejected depending on their issuer.

WARNING: We draw your attention to the fact that the refusal of the deposit of cookies on your device is nevertheless likely to alter your user experience as well as your access to certain services or features of this website. If necessary, PhD Business Solutions declines any responsibility concerning the consequences related to the degradation of your browsing conditions that occur because of your choice to refuse, delete or block cookies necessary for the operation of the site. These consequences cannot constitute a damage and you will not be able to claim any compensation for this fact.

Your browser also allows you to delete existing cookies on your device or to notify you when new cookies might be placed on your device. These settings have no impact on your browsing but make you lose all the benefit provided by the cookie.

Please read below the many tools available to you so that you can set the cookies placed on your device.

d. The settings of your Internet browser

Each Internet browser has its own cookie management settings. To find out how to change your cookie preferences, you'll find below links to the help you need to access your browser's cookie preferences menu:

Chrome : https://support.google.com/chrome/answer/95647?hl=en

Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies

Internet Explorer : https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Opera : http://help.opera.com/Windows/10.20/fr/cookies.html

Safari : https://support.apple.com/kb/PH21411?viewlocale=en_EN&locale=fr_EN

For more information about cookie control tools, you can consult the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

The information collected from this form whose input field is followed by an asterisk is necessary to process your request. However, information whose input field is not followed by an asterisk is optional and without consequence for the examination of your application. This information is transmitted exclusively to authorized persons of PhD Business Solutions members of the marketing management and is kept for a period not exceeding 24 months. In accordance with the Data Protection Act, you have a right of access, rectification and opposition to data concerning you, which you can exercise by sending a request by this form or by mail to the postal address indicated in paragraph I. of our privacy policy and use of cookies.