Within Wendel, we take privacy and the protection of personal data very seriously.
For this reason, we are committed to implementing the measures required to ensure the protection, privacy and security of your personal data and to use these data in accordance with applicable rules and in particular European Regulation 2016/679 of April 27, 2016 (hereinafter the “General Data Protection Regulation” or “GDPR”) and any applicable local laws regarding the protection of personal data, including the French Act 78-17 dated 6 January 1978, the so-called French Data Protection Act and the Luxembourg Act dated 1 August 2018 on the organization of the National Commission for Data Protection and implementation of the GDPR, amending the Labour Code and the amended Act of 25 March 2015 laying down the compensation regime, as well as the conditions and procedures for the advancement of civil servants and any other law or regulation that may supplement or replace it (hereinafter the “Applicable Regulations”).
The objective of this personal data protection policy (hereinafter the “Policy”) is to inform you of how we use your data and what commitments the Wendel group has made so as to respect your personal data.
The purpose of this text is to present the Policy with regard to the ways in which Wendel uses the personal data of the various categories of persons whose data Wendel collects (website visitors, suppliers, service providers, shareholders, co-investors, executives of companies in which Wendel plans to invest), except for employees and persons applying for employment at Wendel.
The terms “you” and “your” refer to all persons whose data is used by Wendel, be they persons browsing the website, persons filling out the contact form on the website so as to receive the Wendel Group’s press releases, persons registering for Wendel’s webcasts, shareholders, co-investors, Wendel’s service providers/suppliers, and executives of companies in which Wendel plans to invest.
This Policy is not intended to apply to websites of other companies or organizations and related websites to which you might be directed via our hyperlinks. If you access those sites, you will be subject to the privacy and personal data protection rules in effect on those sites. We cannot be responsible for the content and the application of those rules.
Wendel, a European company with an executive board and a supervisory board and share capital of €188,324,166, with its head office at 89 rue Taitbout, 75312 Paris Cedex (France), registered in the Paris Companies Register under the SIRET number 572 174 035 00061, and whose Intercommunity VAT number is FR29 572 174 00061, or any other Wendel office in the world (United States of America, Luxembourg) with which you are in direct contact (hereinafter “Wendel”) will be considered as responsible for data usage in the meaning of the applicable regulations with regard to personal data. The terms “we”, “us” and “our” in this Policy refer to Wendel.
Wendel collects personal data in the following situations:
- When you browse the website www.wendelgroup.com (hereafter the “Site”);
- When you fill out the registration form for Wendel’s webcasts and watch those webcasts;
- When we solicit your services under a services contract;
- When you wish to make an equity investment alongside Wendel;
- When you become a Wendel shareholder and for the entire period during which you remain a Wendel shareholder;
- When Wendel plans to invest in one of the companies that you manage.
Based on your status (website user, shareholder, co-investor, supplier, etc.), the table below shows you how we use your data (together referred to as “purposes of use”), as well as the legal basis for that use, in accordance with the Applicable Regulations.
|How and why we use your data (Purposes of use)||Kinds of data we can collect about you||Legal basis for the use of your data|
|When you register for a webcast and watch the webcast|
To enable you to access and watch the webcast: process your request to access webcasts, provide you with the service you requested and carry out statistical analyses, in particular to measure webcast audiences so as to develop and improve Wendel’s webcasts.
We need to use these data:
|When we solicit your services under a services contract:|
We need to use these data:
|When you become a Wendel shareholder and for the entire period during which you remain a Wendel shareholder:
Whether you (i) hold shares in registered form (in this case your data are collected by Société Générale’s securities services department); (ii) are an employee shareholder or a corporate officer; or (iii) hold shares in bearer form.
We need to use these data:
|When you wish to make an equity investment alongside Wendel;
As part of co-investment transactions you carry out alongside Wendel
Manage the co-investment of Wendel’s executives and employees and that of the management teams of portfolio companies
We need to use these data:
|When Wendel plans to invest in one of the companies of which you are the/one of the executive(s):
Wendel might need to collect and use data about you that you make available as part of our due diligence concerning the company of which you are the/one of the executive(s). Wendel might also extend its due diligence to the verification of your professional and personal references.
||This processing is necessary:
When you browse the Site, Wendel may be required to place Cookies on your terminal.
When use of your personal data is based on Wendel’s legitimate interests, Wendel analyzes and evaluates the potential impact (positive and negative) of that use on you and your interests, rights and freedoms. For all information on how Wendel evaluates its legitimate interest, please contact us at the email address above firstname.lastname@example.org
Wendel stores personal data for the time necessary to meet the purposes for which we collect them. These purposes are specified above in the table in Section 3 of the Policy. The following criteria are used to determine how long they are stored:
- To respond to your request to receive the Wendel Group’s press releases and for Wendel to send those press releases to you, personal data are stored for the full time you are registered to receive these communications. You can unsubscribe from these communications at any time by going to the unsubscribe form. In that case, we will delete your personal data at the latest within 15 working days after receiving your unsubscribe request.
- Unsubscribe from the shareholders’ communication list: click here;
- To enable you to access and follow the Wendel Group’s webcasts, personal data are kept for the duration of the use of the service and for the periods imposed by certain legal requirements;
- When your personal data are collected and used in the management of contractual relationships with suppliers, your data are stored throughout the duration of the contractual relationship plus the applicable limitation period (for example five years after the end of such contractual relationship with Wendel in France, ten years after the end of such contractual relationship with Wendel in Luxembourg) and for the periods imposed by certain legal requirements (for example, obligation to keep certain documents for 10 years to adhere to accounting and tax requirements in France and in Luxembourg);
- When your data are collected by virtue of your status as a Wendel shareholder, they are stored for the full time you remain a Wendel shareholder plus the applicable limitation period (for example, five years after the end of this contractual relationship with Wendel in France, ten years after the end of such contractual relationship with Wendel in Luxembourg) and for the periods imposed by law;
- In addition, should you apply to the Wendel Shareholder Advisory Committee in your capacity as a Wendel shareholder, your personal data will be retained for a maximum period of 2 years if your application is not accepted. If it is accepted and you join the Wendel Shareholder Advisory Committee, your personal data processed in this context will be kept for the full time you remain a member of said Committee, and for an additional period as specified above;
- When you invest alongside Wendel, your data are stored for the full time you remain an investor alongside Wendel plus the applicable limitation period (for example, five years after the end of this contractual relationship in France, and ten to thirty years after the end of such contractual relationship with Wendel in) and for the periods imposed by law;
- When Wendel plans to invest in a company of which you are the/one of the executive(s), your data are stored for the duration of the due diligence and applicable limitation periods.
- When Cookies are placed on your terminal, they are kept for the duration indicated in the Cookies Policy.
Your personal data are accessible internally only to the departments that must access data for the purposes mentioned in the table above in Section 3. Specifically, these are (depending on the purpose): the General Secretariat, the Legal department, the IT department, the Communication and Sustainable Development department, the Financial Communication department and the Tax department.
Sharing of personal data with third parties
Wendel might share your personal data with third parties in the event it is strictly necessary, depending on the purposes mentioned in the table above, in the following situations:
- Wendel’s service providers. Wendel might be required to communicate personal data or make personal data available to companies that render services to us: website, webcast and software hosting and maintenance companies, communication agencies and service providers, data analysis companies, survey companies, statutory auditors and outside advisors (lawyers, auditors).
Wendel’s service providers use your personal data in accordance with our instructions and on our behalf. Through specific clauses in the contract, Wendel ensures that its service providers take all reasonable and appropriate security measures, both organizationally and technically, to prevent any disclosure, use, alteration, accidental loss or destruction of your personal data and that they access your personal data only to the extent necessary to provide their services.
- Wendel also shares personal data so as to adhere to legislation in force. Wendel communicates personal data when Wendel is legally authorized to do so or if Wendel is required to do so to comply with legislation in force or any judicial proceeding (including requests from the public authorities and the courts), so as to respond to any request or claim or protect the rights, property or security of Wendel, its shareholders and employees or the general public.
- Third parties to whom we decide to sell, transfer or merge part of our company or our assets. We may also seek to acquire other companies or to merge with them. In the event of changes affecting our company, the third parties with whom we are in contact in this context may use your personal data in accordance with the terms of this Policy.
Wendel is an international group. The Wendel Group has offices in France, the United States and Luxembourg. As a result, and when strictly necessary for the purposes mentioned in the table above, Wendel might transfer your personal data outside the European Economic Area to various entities in the Wendel Group and/or to the type of third parties mentioned above.
Should Wendel transfer personal data to countries outside the European Economic Area, whether to companies in the Wendel Group or to third parties mentioned in Section 5 above, Wendel will do so in a secure manner, in compliance with the Applicable Regulations. Certain countries might not have laws providing a framework for the use of personal data that is considered sufficient by the European Union. In this specific case, we will take all necessary precautions to ensure that these transfers take place in accordance with the Applicable Regulations and that the related third parties comply with the terms of this Policy. In particular, these precautions might include the signature of appropriate, standard contractual clauses that have been approved by the European Commission, in accordance with Article 47 of the GDPR. You can obtain a copy of the standard contractual clauses that we use by contacting us at the following email address: email@example.com.
In accordance with the Applicable Regulations, you have the following rights regarding your personal data:
- The right to access your data. You have the right to receive a copy of your personal data and to verify that Wendel uses your data in compliance with the law.
- The right to correct your data. You have the right to correct incomplete or erroneous personal data that Wendel has about you.
- The right to oppose the use of your data when it is based on Wendel’s legitimate interests or that of a third party (to determine the use to which this right applies, please refer to the table in Section 3 of this Policy) and when a reason connected with your specific situation prompts you to oppose such use.
- The right to have your data deleted. You have the right to ask Wendel to delete your data when there is no reason justifying their continued use by Wendel.
- The right to limit the use of your data. You have the right to ask Wendel to discontinue the use of your data in certain cases specified by law.
- The right to the portability of your data. You have the right to ask that Wendel transfer your data to a third party or to your attention. This right is applicable only when the use is based on performance of a contract or the consent of the person involved (to determine the use to which this right applies, please refer to the table in Section 3 of this Policy).
- The right to withdraw your consent to the use of your data if the legal basis of the use is your consent (to determine the use to which this right applies, please refer to the table in Section 3 of this Policy).
- The right to file a complaint with the supervisory authority in your country (the contact details of which are available at the following address: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080) about our privacy and personal data protection practices. We nevertheless ask you to contact us at the address below before filing any complaint with the competent supervisory authority.
Should you wish to exercise any of these rights and/or if you have questions about these rights, you may contact Wendel at the following address: firstname.lastname@example.org
If you have questions or comments about the manner in which we use your personal data, or if you wish to exercise one of the rights mentioned above, please contact us by sending an email to email@example.com or by writing to us at the following address: Wendel SE, Data Protection Officer, 89 rue Taitbout, 75009 Paris (France).
- What is the scope of this Notice?
- What personal data do we collect, why and on what legal basis?
- How long do we keep your personal data?
- Who is your personal data shared with and who has access to your personal data?
- Personal data transfers outside the European Union
- How do we ensure the protection and security of your personal data?
- What are your rights?
- How to contact us?
Within Wendel group, we take the respect of privacy rights and the protection of personal data very seriously.
This is why we are committed to taking adequate measures to ensure the protection, confidentiality and security of your personal data and to only processing and using such personal data in compliance with applicable laws, and in particular European Regulation 2016/679 dated April 27th, 2016 (hereinafter the “General Data Protection Regulation” or “GDPR”) and the applicable local provisions, including the French Act No. 78-17 dated January 6th, 1978 and the Luxembourg Act dated August 1st 2018 on the organization of the National Commission for Data Protection and implementation of the GDPR, amending the Labour Code and the amended Act of 25 March 2015 laying down the compensation regime, as well as the conditions and procedures for the advancement of civil servants and any other law or regulation that may supplement or replace it (hereinafter “Applicable Legislation”).
The purpose of this data protection notice (hereinafter the “Notice”) is to give you information on how we process your personal data and on the commitments made by Wendel to ensure that your rights are respected.
This Notice applies to all processing of personal data implemented by the Wendel Group in Europe (meaning, any group entity to whom you have applied) in relation to candidates submitting job applications spontaneously or in response to a job offer (hereinafter the “Candidate(s)” or “you”). Each entity of the Wendel Group in Europe to whom an application is made (Wendel SE, or Wendel Luxembourg SA) will be deemed the controller of the processing implemented by it (hereinafter “Wendel”, “we”, “us” or “our”).
Personal Data collected:
We collect the following personal data in this context:
- identification and contact information (surname, name, email address, postal address, phone number);
- résumé and educational and professional background;
- cover letter;
- centers of interest;
- any information we collect during interviews in connection with the recruitment process;
- any information you voluntarily provide to us in the context of the recruitment process.
Such information is collected from you directly, or is provided to us by third persons, including recruitment/search firms (job offer websites, recruitment firms, etc.) and/or by the references given to us during the recruitment process.
Purposes for which we use your personal data:
Wendel processes the information collected directly from you or from third parties in order:
- to examine your job application, so that we can decide whether your profile corresponds to the position to which you have applied or any other position at Wendel; and
- more generally, to manage the recruitment process, including to contact you and set up interviews; and
- to contact you in the future, provided you do not object, if opportunities arise at Wendel that could correspond to you or interest you.
Legal grounds on which we process your personal data:
Our processing is based:
- in part, on the need to perform precontractual measures, in other words to examine your application for a position at Wendel. We need to process your personal data to decide whether we want to enter into an employment relationship with you;
- in part, on the legitimate interest of Wendel, when your application documents are kept by Wendel to be able to get in touch with you again in case future opportunities arise. In effect, this processing (based on the storage of your application documents) contributes to optimizing our recruitment process and benefits both you and us without adversely affecting your interests or your fundamental rights and freedoms.
We keep your personal data as long as necessary to achieve the purposes for which they were collected and processed pursuant to section 2.
If your application is successful and you join Wendel, your personal data will be kept for as long as you remain with Wendel (the entire duration of your employment relationship with us) and for the applicable statute of limitation period, after which time your personal data will be deleted under the conditions of the Applicable Legislation and local specificities in force in each country.
Conversely, if your application is unsuccessful, your personal data will be kept for a period of 24 months, after which time your personal data will be deleted unless you want us to keep your personal data for a longer period.
Your personal data can be accessed internally only by the departments having a need to access such personal data for the purposes indicated in section 2, namely: the human resources department, the department where the position you have applied for is located, any other relevant departments involved in the recruitment process, and if necessary, depending on the position to be filled, Wendel’s executive board.
We may share some of your personal data inside and outside the European Union, to the extent necessary for the purposes indicated in section 2, with the following entities:
- Wendel SE,
- Wendel Luxembourg SA,
- Wendel North America LLC.
Sharing your personal data with our offices throughout the world is necessary to ensure a coherent group recruitment policy (some of our directors may work in those subsidiaries), and to permit you to access international mobility programs.
Your personal data can also be shared with:
- public authorities, agencies or other bodies to which we are required to disclose some of your personal data in accordance with applicable laws;
- French or foreign public authorities, agencies or other bodies in response to a court order, administrative or judicial process of any nature or valid law enforcement measures.
We may also share your personal data with service providers acting as processors within the meaning of Applicable Legislation, who provide services to us in relation to some of the processing activities implemented using your personal data. In particular, such service providers provide us with hosting, data processing, database management, IT or other related services. These service providers act only on instructions from Wendel and will only have access to your personal data if necessary for them to perform their services and will be under the same security and confidentiality obligations as Wendel.
The subsidiaries or offices of Wendel, service providers or other third parties listed above in section 4, with which Wendel may share your personal data may be located abroad, and in particular outside the European Economic Area and in the United States of America.
In such case, Wendel will require that they take, in accordance with Applicable Legislation, all technical and organizational measures to ensure an adequate level of protection of your personal data and will implement appropriate safeguards in accordance with Articles 45 and 46 of the General Data Protection Regulation. This may involve the signature of Standard Contractual Clauses approved by the European Commission. You can obtain a copy of the model clauses by contacting us at the following e-mail address: firstname.lastname@example.org.
In accordance with Applicable Legislation, you have the following rights in relation to your personal data:
- a right of information: you have the right to obtain clear, transparent, intelligible and easily accessible information about the way in which we use your personal data and about your rights. This Notice is intended to provide you with that information.
- a right of access: you have the right to access the personal data we hold about you (provided your access request is not manifestly unfounded or excessive, in particular because of its repetitive nature), and to obtain a copy thereof. If you wish to access the personal data we hold concerning you, please contact us as indicated in section 8 below.
- a right of rectification: you have the right to obtain the rectification of any personal data concerning you that is inaccurate or out-of-date and/or to obtain the completion of any incomplete personal data (provided your request is not manifestly unfounded or excessive, in particular because of its repetitive nature). If you wish to make changes to your personal data, please contact us as indicated in section 8 below.
- a right to erasure: in some cases, you have the right to obtain the erasure or deletion of your personal data. This is not an absolute right, as we may have legal or legitimate grounds for keeping your personal data. If you wish us to erase your personal data, please contact us as indicated in section 8 below.
- a right to restriction of processing: this right means that our processing of personal data concerning you is restricted, with the result that while we may keep your personal data, we may not use or process such personal data. This right applies in specific circumstances, namely:
- in case the accuracy of personal data is contested by the data subject (i.e. you), for a period enabling Wendel to verify the accuracy of the personal data;
- in case the processing is unlawful and the data subject (i.e. you), objects to their erasure and requests the restriction of their use instead;
- in case Wendel no longer needs the personal data for processing purposes, but they are required by the data subject for the establishment, defense or exercise of legal claims;
- if the data subject (i.e. you) objects to processing based on the legitimate interests pursued by us, pending verification as to whether the legitimate grounds pursued by Wendel override those of the data subject or not.
If you wish to obtain a restriction of processing, please contact us as indicated in section 8 below.
- a right to object to the processing of your personal data when such processing is based on the legitimate interest of Wendel (to determine what type of processing is involved, see section 2 of this Notice): you can object at any time to the processing of your personal data on grounds relating to your particular situation, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless such personal data is required for the establishment, exercise or defense of legal claims. If you wish to exercise your right to object to processing or obtain more information on how to exercise it, please contact us as indicated in section 8 below.
- a right to data portability: you have the right to receive personal data concerning you, which you have provided to us and that are present on our database, in a structured, commonly used and machine-readable format. This only applies to personal data you have provided to us, directly or indirectly, and only when the processing is based on your consent or on performance of a contract and is carried out by automated means. We invite you to view the list of legal grounds we rely on for the processing of personal data (see section 2) to determine whether our processing is based on a contract or on consent. For more information, please contact us as indicated in section 8 below.
- where applicable, meaning when you have applied for a position to work for us in France, a right to give us specific instructions on what to do with your personal data after your death. If you wish to exercise this right or obtain more information about how to exercise it, please contact us as indicated in section 8 below.
- a right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint with the data protection authority in your country (the contact details of which are available at the following address: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080) about our privacy and personal data protection practices. However, we invite you to contact us at the address below before lodging a complaint with the competent data protection authority.
Cookies are small text files that are placed on your hard drive when you visit a website and are used to store information on web browsers (“Cookies“). These files allow the exchange of information between the website and your browser.
When you browse the website https://www.wendelgroup.com/ (the “Site“), Wendel – a European company with an executive board and a supervisory board and share capital of €188,324,166, with its head office at 89 rue Taitbout, 75312 Paris Cedex (France), (hereinafter, “Wendel” or “We“) – may deposit Cookies on your terminal. Except for Cookies that allow us to save the choice you have made concerning the deposit of other Cookies, Wendel will obtain your consent prior to the deposit of Cookies via a Cookie management tool that is displayed on your web page (generally at the bottom left of your screen), and that accompanies your visit on the Site.
- What is the purpose of the Cookies placed on the Site by Wendel?
- enable you to interact with Wendel on social media using the buttons on the Site; and
- save your choices regarding the deposit of Cookies by our Site.
- What cookies are deposited by Wendel on the Site?
Wendel uses two categories of Cookies on the Site:
- Social network cookies: these cookies are deposited on your terminal when you use the buttons for sharing content and articles on the Site on third-party social networks (YouTube, LinkedIn, Twitter, Vimeo). These Cookies allow you to interact from the Site with these social networks, in particular to allow you to react to certain news and/or blog articles on the Site and to share them. In this context, certain data will be collected by the social networks concerned. We invite you to read their policies relating to cookies to have more information on the collection and processing of data that they put in place:
- Cookies allowing to save the choice you have made concerning the deposit of Cookies: these Cookies are automatically deposited on your terminal while you browse, without it being necessary to obtain your prior consent. However, you can delete and/or block these Cookies, via the settings of your browser, if you wish. The Cookies concerned are the following:
- How to configure the deposit of Cookies?
We obtain your consent for the deposit of the relevant Cookies via a Cookies configuration panel displayed (generally at the bottom left of your screen) the first time you browse our Site. You are free to accept or decline Cookies individually or in their entirety. Without your explicit consent, these Cookies will not be deposited on your terminal.
You can modify your choice regarding these Cookies at any time by using the Cookies control panel, which remains present in the form of a bubble while you browse on the Site.
- How long will the Cookies be stored?
The Cookies allowing to save your choice relative to the deposit of Cookies on your terminal by the Site, have a conservation period of 6 months. After this period, your consent to the deposit of Cookies will be requested again.
The other Cookies deposited on your terminal are stored no longer than 13 months.