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HITALTECH SA PRIVACY POLICY

Hitaltech SA respects individual privacy and values the confidence of its customers, employees, vendors, consumers, business partners and others. Hitaltech SA strives to collect, use and disclose Personal information in a manner consistent with the laws of the countries in which it does business, and has a tradition of upholding the highest ethical standards in its business practices. Hitaltech SA abides by the EU General Data Protection Regulation (GDPR). This GDPR sets forth the privacy principles that Hitaltech SA follows with respect to transfers of Personal information anywhere in the world, including transfers from the European Economic Area (EEA) to the rest of the world.

I. THE PRIVACY POLICY STRUCTURE

Hitaltech SA has a specific privacy representative who is responsible for Hitaltech SA's compliance with and enforcement of this Policy. Hitaltech SA educates its employees concerning compliance with this Policy and has self-assessment procedures in place to assure compliance. Hitaltech SA's privacy representative, and their legal counsels are available to any of its valued employees, customers, vendors, business partners or others who may have questions concerning this Policy or data security practices. Relevant contact information is provided herein.

II. SCOPE

This Policy applies to all Personal information received by Hitaltech SA in any format including electronic, paper or verbal. Hitaltech SA collects and processes Personal information concerning current and former employees and their respective family members, as well as applicants for employment through its Internet Web sites, electronic mail and manually. Hitaltech SA is the sole owner of information it collects from current and former employees, applicants for employment, customers, vendors and others. Hitaltech SA will not sell or share this information with third parties in ways different than what is disclosed in this Policy. On a global basis, Hitaltech SA will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this Policy.

Personal information collected by Hitaltech SA from employees and applicants for employment is maintained at its corporate offices in 1160 Brussels, 113A chaussée de Tervuren as well as the local office of the employee or applicant. Hitaltech SA collects Personal information for, among other things, legitimate human resource business reasons such as payroll administration; filling employment positions; administration and operations of its benefit programs; meeting governmental reporting requirements; security, health and safety management; performance management; company network access; and authentication. Hitaltech SA does not request or gather information regarding political opinions, religion, philosophy, sexual preference or any other discriminatory factors. To the extent Hitaltech SA maintains information on an individual’s medical health or ethnicity (as legally required), Hitaltech SA will protect, secure and use that information in a manner consistent with this Policy and applicable law.

Personal information collected by Hitaltech SA from prospective customers, consumers, vendors, business partners and others may be maintained at its corporate offices in 1160 Brussels, 113A chaussée de Tervuren or in other Hitaltech SA facilities. Hitaltech SA collects Personal information for, among other things, legitimate business reasons such as customer service; product, warranty and claims administration; meeting governmental reporting and records requirements; maintenance of accurate accounts payable and receivable records; internal marketing research; safety and performance management; financial and sales data; and contact information. All Personal information collected by Hitaltech SA will be used for legitimate business purposes consistent with this Policy.

III. DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Data Processor" means any third party that uses Personal information provided by Hitaltech SA to perform tasks on behalf of or at the instruction of Hitaltech SA.

"Hitaltech SA" means Hitaltech SA, its predecessors, successors, subsidiaries, divisions and groups.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Hitaltech SA to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal information.

"Sensitive Personal information" means Personal information that reveals race, ethnic origin, trade union membership, or that concerns health. In addition, Hitaltech SA will not collect Sensitive Personal Information unless required by law. However, Hitaltech will treat as sensitive Personal information any information legitimately received from a third party where that third party treats and identifies the information as sensitive.

IV. PRIVACY PRINCIPLES

The privacy principles in this Policy are based on seven principles.

(1) NOTICE: Where Hitaltech SA collects Personal information directly from individuals, it will inform them about the purposes for which it collects and uses Personal information about them, the types of third parties to which Hitaltech SA discloses that information, and the choices and means, if any, Hitaltech SA offers individuals for limiting the use and disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to Hitaltech SA, or as soon as practicable thereafter, and in any event before Hitaltech SA uses the information for a purpose other than that for which it was originally collected. Hitaltech SA may disclose Personal information if required to do so by law or to protect and defend the rights or property of Hitaltech SA.

(2) CHOICE: Hitaltech SA will require individuals to affirmatively and explicitly (opt-in) consent (a) for the provision of their Personal information to Hitaltech SA where not already authorized by law, (b) if such Personal information can be disclosed to a third party, and (c) if such Personal information can be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Hitaltech SA will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

(3) DATA INTEGRITY: Hitaltech SA will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Hitaltech SA will take reasonable steps to ensure that Personal information is relevant to its intended use, accurate, complete and current.

(4) TRANSFERS TO DATA PROCESSORS: Hitaltech SA will obtain assurances from its Data Processors that they will safeguard Personal information consistently with this Policy. Examples of appropriate assurances that may be provided by Data Processors include: a contract obligating the Data Processor to provide at least the same level of protection as is required by the GDPR. Where Hitaltech SA has knowledge that a Data Processor is using or disclosing Personal information in a manner contrary to this Policy, Hitaltech SA will take reasonable steps to prevent or stop the use or disclosure. Hitaltech SA holds it Data Processors accountable for maintaining the trust our employees and customers place in the company.

(5) ACCESS AND CORRECTION: Upon request, Hitaltech SA will grant individuals reasonable access to Personal information that it holds about them. In addition, Hitaltech SA will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete, as well as permit individuals to discretionary request the deletion of their Personal data. Any employees that desire to review or update their Personal information can do so by contacting Hitaltech relevant representative.

(6) SECURITY: Hitaltech SA will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Hitaltech SA protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. Hitaltech SA limits access to Personal information and data to those persons in Hitaltech SA's organization, or as Data Processors of Hitaltech SA, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.

(7) ENFORCEMENT: Hitaltech SA will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Hitaltech SA determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

V. DISPUTE RESOLUTION

Any questions or concerns regarding the use or disclosure of Personal information should be directed to the Hitaltech SA Privacy Representative at the address given below. Hitaltech SA will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Hitaltech SA and the complainant, Hitaltech SA has agreed to participate in any relevant dispute resolution procedures.

VI. INTERNET PRIVACY

Hitaltech SA sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, vendors, business partners and others. Hitaltech SA recognizes the importance of maintaining the privacy of Personal information collected through Web sites that it operates. Hitaltech SA's sole purpose for operating its Web sites is to provide information concerning products and services to the public. In general, visitors can reach Hitaltech SA on the Web without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via Hitaltech SA Web sites but are not required to do so. Hitaltech SA collects information from visitors to the Web sites who voluntarily provide Personal information by filling out and submitting online questionnaires concerning feedback on the Web site, requesting information on products or services, or seeking employment. The Personal information voluntarily provided by Web site users is contact information limited to the user's name, home and/or business address, phone numbers and email address. Hitaltech SA collects this information so it may answer questions and forward requested information. Hitaltech SA does not sell or share this information with non-Data Processor third parties.

Hitaltech SA may also collect anonymous information concerning Web site users through the use of "cookies" in order to provide better customer service. "Cookies" are small files that Web sites place on users’ computers to identify the user and enhance the Web site experience. None of this information is reviewed at an individual level. Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies. If visitors do so, however, some areas of Hitaltech SA Web sites may not function properly.

Few, if any, of Hitaltech SA's Web sites are directed toward children. Nevertheless, Hitaltech SA is committed to complying with applicable laws and requirements for the protection of children under the age of 16 years old.

Hitaltech SA Web site users have the option to request that Hitaltech SA not use information previously provided, correct information previously provided, or remove information previously provided to Hitaltech SA. Those that would like to correct or suppress information they have provided to Hitaltech SA should forward such inquiries to:

Hitaltech SA

Privacy Representative

113A chaussée de Tervuren

1160 Brussels

The inquiries should include the individual's name, address, and other relevant contact information (phone number, email address). Hitaltech SA will use all reasonable efforts to honor such requests as quickly as possible.

Hitaltech SA Web sites may contain links to other "non-Hitaltech SA" Web sites. Hitaltech SA assumes no responsibility for the content or the privacy policies and practices on those Web sites. Hitaltech SA encourages all users to read the privacy statements of those sites; their privacy practices may differ from those of Hitaltech SA.

VII. CHANGES TO THIS PRIVACY POLICY

The practices described in this Policy are current Personal data protection policies as of 1st May, 2018. Hitaltech SA reserves the right to modify or amend this Policy at any time consistent with the requirements of the applicable Directives, Regulations, national and local laws’ principles. Appropriate public notice will be given concerning such amendments.