At 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 (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 Wendel has made so as to respect your personal data

 

 

1. Scope of application of this Policy 

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 €185,117,204, 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 Kingdom, United States of America, Japan, Luxembourg, Netherlands, Singapore, Morocco) 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. 

 

2. Contexts and occasions on which we use the personal data we collect 

Wendel collects personal data in the following situations: 
  • When you fill out the contact form on the website www.wendelgroup.com (hereinafter the "Site"); 
  • When you browse 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.

3. Purposes and legal basis on which Wendel uses your personal data 

 

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 fill out the contact form to receive the Wendel Group's press releases​

 

 

To communicate with you and send you our press releases (information and external communication about Wendel's activities).

  • last name;
  • first name;
  • email address; 
  • function; and
  • country.

 

Wendel's legitimate interests for the purpose of good external communication 

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. 

  • first name;
  • last name; 
  • email address; 
  • company; 
  • function; 
  • country;
  • date you watched the webcast; 
  • length of time you watched; 
  • part of webcast you watched.
We need to use these data:
  • in part for performance of the contract (provide you with the requested service);
  • In part to pursue Wendel's legitimate interests.

When we solicit your services under a services contract:

 

 

  1. To allow us to manage the contractual relationship with our suppliers and in particular: contract, purchase order and delivery management, accounting, payments, and contractual relationship follow-up;
  2. So we can manage our accounting and meet our tax and anti-corruption/AML obligations under the Sapin 2 Act
  • last name, first name, telephone number, email address, telephone number of contact person at the service provider;
  • Company registration document (“Kbis” in France);
  • financial data related to our contractual relationship: invoices, bank account details, payment-related data;
  • data collected as part of the eight anti-corruption measures pursuant to the Sapin 2 Act and in general as part of Wendel's compliance program

 

We need to use these data:
  • for the performance of the contract between Wendel and your company (part 1 in the left-hand column);
  • to meet Wendel's legal obligations, and in particular those related to taxation, accounting and the provisions of the Sapin 2 Act (part 2 in the left-hand column)

When you become a Wendel shareholder and for the entire period during which you remain a Wendel shareholder:
Whether you (i) hold shares in pure 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.

 

 
  1. To identify all of Wendel's shares held in bearer form twice a year so as to have an overall view of who holds Wendel's share capital and be able to respond to questions from individual shareholders;
  2. Management of shares held in registered form: coordination with Société Générale’s securities services department, inviting outside shareholders to shareholders' meetings, managing employee shareholders and corporate officers (employee share ownership)
  3. Mailings of company-related information using the shareholder database, distribution of the letter to shareholders
  • identity information: last name, first name, address, email address;
  • number of shares, number of shares in shareholder agreements
  • type of shares;
  • type of shareholder (employee shareholder, holder of registered shares, holder of bearer shares, member of shareholder agreements);
  • early release, estate, gifting situations.
We need to use these data:
  • in part for the performance of contracts to which the individuals concerned (shareholders) are parties;
  • in part to pursue Wendel's legitimate interests in knowing who its shareholders are; 
  • in part to meet Wendel's legal obligations as an issuer of securities;
  • in part to pursue Wendel's legitimate interests for the purpose of good external communication. 

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
  • identity data: last name, first name, email address, telephone number;
  • financial data: amount invested, investment date, number of shares or units held, portion of capital gain at the time of a liquidity event;
 
We need to use these data:
  • in part for the performance of contracts to which the persons are parties;
  • in part to pursue Wendel's legitimate interests, in particular to reward its investment teams and track the shareholder structure of the companies in which it invests
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.
   
  1. Management of due diligence operations as part of the Wendel Group’s potential investments in companies;
  2. Analysis of the senior management teams of companies as part of investment or divestment operations
  • identity data: last name, first name, email address, telephone number, position/title;
  • financial data: compensation;
Wendel requires these data in order to pursue its legitimate interests.
 
 
 
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 dpo@wendelgroup.com
 
In addition, we use data in the following ways:
 

When you browse the Site (data collected via cookies); 

When you browse our Site, we might need to collect the following data: 
  • IP address; 
  • connection data; 
  • website you came from; 
  • data about your browser; 
  • data about your connection device; 
  • pages visited; 
  • date and time of your visit; 
  • duration of your session; 
  • geographic area. 
 
When you browse the Site, Wendel might collect this type of data using cookies or similar technologies, subject to the choices you have made about cookies, which you can change at any time. 
 
Cookies are small text files that store information in web browsers. These files exchange status information between the Site and your browser. They enable Wendel to remember you when you come back to the Site (in particular to facilitate access to webcasts and for the Site to remember your language) and to record your visit. 
 

Purpose of the cookies Wendel puts on the Site

We use cookies to: 
  • give you access to Wendel's webcasts after you register;
  • optimize the way our Site is displayed based on your device and your language; 
  • enable you to interact with Wendel on social media (in particular Twitter) using the buttons on the Site;
  • measure our Site's audience. 

 

Acceptance or refusal of cookies: 

We need to obtain your prior consent before reading or placing certain types of cookies, including cookies to measure audience and cookies for social media buttons. We ask for your consent through a banner that appears when you first connect to our Site, in accordance with the recommendation of the French Data Protection Authority (CNIL). 
 
You may decide to refuse or deactivate these cookies at any time. 
You can prevent these data from being collected by deactivating this function on your browser:
  • on Internet Explorer, open the “Tools” menu, then click “Internet options”, select the “Privacy” tab and move the slider to the desired level;
  • on Firefox, open the “Tools” menu, select “Options”, then click on the “Privacy” tab and untick “Accept cookies from sites”; 
  • on Google Chrome, go to Settings in the upper right-hand corner, then pull down the “Advanced” options in the left-hand panel and click on “Privacy and security”. Scroll to “Content settings” and select “Cookies”. Deactivate “Allow sites to save and read cookie data” and activate “Block third-party cookies”;
  • on Safari, go to “Preferences”, then “Privacy”, and select the level of blockage you want;
  • on Opera, go to “Settings”, then “Quick preferences”, then untick “Enable cookies”. 

4. Location and length of time during which your personal data are stored 

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:
  • For statistical analysis and in particular to measure our Site's audience and improve our Site, cookies are stored no longer than 13 months. 
  • 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 within 15 working days after receiving your unsubscribe request. 
  • 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 (five years after the end of such contractual relationship with Wendel in France, for example) and for the periods imposed by certain legal requirements (obligation to keep certain documents for 10 years to adhere to accounting and tax requirements in France, for example);
  • 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 (five years after the end of this contractual relationship with Wendel in France, for example) and for the periods imposed by law;
  • When you invest alongside Wendel, your data are stored for the full time you remain an investor alongside Wendel plus the applicable limitation period (five years after the end of this contractual relationship in France, for example) 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.

 

5. Persons to whom we communicate your data and who have access to your data 

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

6. Transfer of personal data to countries outside the European Economic Area  

 
Wendel is an international group. The Wendel Group has offices in France, the United Kingdom, the United States, Luxembourg, the Netherlands, Singapore and Morocco. 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 may access models of the standard contractual clauses that we use at the following URL: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32010D0087&from=FR   or https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32004D0915&from=FR ​
 

7. Your rights regarding Wendel's use of your personal data 

 
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 French Data Protection Authority (CNIL). We nevertheless ask you to contact us at the address below before filing any claim with the CNIL. 
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: dpo@wendelgroup.com
 

8. How to contact us  

 
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 dpo@wendelgroup.com or by writing to us at the following address: Wendel, Data Protection Officer, 89 rue Taitbout, 75009 Paris (France).