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Terms of Use – HEDERA-22® Website

December 2022

1. General

The access and use of this website are subjected to the General Terms of use set out below. These conditions of use contain legal information relating to the visit and use of the website www.hedera22.com hereunder referred to as “the Website”.

Please read these conditions of use carefully before visiting the Website or using it in any way. By accessing this Website and any page thereof or making use of it in any way, you acknowledge your agreement with and your understanding of these Terms of use.

If you do not agree to these Terms of Use, please do not access or use this Website.

2. Information

2.1. Editor of the Website

This Website http://www.hedera22.com/ is edited by :

HEDERA-22   S.A.

Registration number/VAT : BE0630.923.236

Headquarter address : Bd du Rectorat, 27b, 4000 Liège, Belgium

Email : info@hedera22.com

Phone : +32 475 41 36 27

2.2. Website hosting

HEDERA-22 website is hosted by OVH company and data are stored in France at:

OVH, 2 rue Kellermann, 59100 Roubaix, France

3. Privacy policy

We take the greatest care to protect the personal data which you provide to us. You will find hereunder our rules with regards to personal data protection (Privacy Policy).

4. Intellectual property rights

4.1. Content

The wire frame or layout and all components of the Website as well as the Website itself are protected by intellectual property law (in particular copyright law, trademark law and design rights) or any other applicable law. The user acknowledges that HEDERA-22® is the sole owner of all intellectual property rights on this Website and on the components contained within the Website, in particular, without limitation, the texts, photographs, graphs, icons, people’s images, drawings, models, illustrations, soundtracks, logos, trademarks, software, etc.

A temporary non-exclusive licence is granted to the Internet user to use the Website. Nevertheless, no property or other intellectual property right is assigned to the Internet user. This licence only gives the Internet user the right to access the contents of the Website, consult the information and use the services offered on the Website in a regular manner, and only for his own private use.

The partial or full reproduction, use, distribution, publication, transmission, amendment or sale of all or any part of the elements on the Website by any means and for any reason whatsoever is forbidden unless expressly authorised previously by HEDERA-22®.

You may apply for this authorisation by writing to the following address: info@hedera22.com and by providing details of the contents you wish to reproduce, the reason for reproduction and of the reproduction media contemplated.

4.2. Trademarks

The « HEDERA-22® » trademark is a registered trademark. The trademarks and logos displayed on this Website are either owned by or licensed to HEDERA-22® S.A. Users are not permitted to use these Trademarks for any purpose without the prior written consent of HEDERA-22® or such third party that may own the Trademark which consent may be granted or denied in such owner’s sole discretion.

5. Hyperlinks

5.1 Creation of hyperlinks to this Website

Links to the front page or to one of the internet pages of the Website may not be created without the previous and written agreement of HEDERA-22®. In any case, these links are subject to the mention of « HEDERA-22® » or any other equivalent or more precise mention being clearly indicated on the link itself or close to it.

Any direct or in depth link to documents other than an internet page, notwithstanding their form or content, are forbidden unless expressly authorised by HEDERA-22®.

Authorisation applications for the creation of the links referred to in this article must be sent to the following address: info@hedera22.com. In your application, you must indicate the address of the (URL) page on which the link on the third party site is intended to be posted.

5.2. Inclusions and use of frames

Any use or reproduction, even partial, of one or several of the elements of the Website in a third party site by means of processes known as inclusion, frames, in lining or any other process of a similar nature are strictly forbidden.

5.3. Links to other external websites

The Website may contain links to third parties websites or web pages. Third party websites are provided solely for your convenience and information. HEDERA-22® does not provide any guarantee and declines any liability with regard to both the hypertext links created on the HEDERA-22® Website to third parties’ websites and the contents of these Internet sites.

Access to these websites is at the user’s risk. User is fully aware that these Internet sites may be subject to other provisions regarding the protection of privacy and/or, in a general manner, other Terms of use than those applicable to this Website.

6. Information provided on the Website

HEDERA-22® takes the utmost care regarding the quality of its Website for both its content and user-friendliness. It takes all reasonable measures to provide correct and up-to-date information on the Website.

However, information on the Website may contain typographical errors or inaccuracies and may not be complete or up-to-date. Therefore, HEDERA-22® reserves the right to correct any errors, inaccuracies or omissions and to change or update contents of the Website at any time without prior notice.

7. User Obligations

While using the Website, you agree :

• not to disrupt or interfere with the security of, or otherwise abuse, the Website, or any services, system resources, accounts, servers or networks connected to or accessible through the Website or affiliated or linked websites;
• not to disrupt or interfere with any other user of the Website or affiliated or linked websites;
• not to upload, post, or otherwise transmit through or on this Website any virus or other harmful, disruptive or destructive file;
• not to use or attempt to use another’s account, service or system without authorization from HEDERA-22®, or create or use a false identity on this Website;
• not to transmit through or on this Website spam, chain letters, junk mail or any other type of unsolicited mass email to people or entities who have not agreed to be part of such mailings;
• not to attempt to obtain unauthorized access to the Website;
• not use this Website for any purpose that is unlawful or may impair the reputation and honour of HEDERA-22®;
• not to reproduce on any support whatsoever any content of the Website without authorization.

In addition, you agree that you are solely responsible for actions and communications undertaken or transmitted via the Website.

You warrant the truthfulness and correctness of any information communicated on this Website.

You agree to indemnify, defend and hold harmless HEDERA-22®, its officers, directors, employees, agents, suppliers and third party partners from and against all losses, expenses, damages and costs, including reasonable attorneys’ fees, resulting from any violation of these Terms of Use.

8. Access to the Website

HEDERA-22® makes every effort to ensure uninterrupted availability of the Website (accessible 7 days a week, 24 hours a day).

Nevertheless HEDERA-22® cannot guarantee a continuous, uninterrupted and secured access to the Website. HEDERA-22® may interrupt, at any time and without prior notice, the access to the Website in case of risk of misuse or fraud or in order to perform maintenance or to implement any improvement or modification.

HEDERA-22® shall do its utmost to limit the duration of such interruptions and shall, whenever possible, inform the Internet users of these interruptions and their estimated duration.

Without prejudice to its indemnification rights, HEDERA-22®  reserves the right to prohibit, at any time and without prior notice, the access to all or a part of the Website to the Internet user for the following reasons: violation of the present Terms of use, use of the Website for unlawful or immoral purposes, infringement on the integrity, the security or the reputation of the Website.

9. Liability & Warranties

Except as otherwise expressly provided and to the maximum extent permitted by law, this Website and its content including all materials, information or services on this Website or linked from this Website are provided “AS IS” and “ AS AVAILABLE” without warranty of any kind. HEDERA-22® and its suppliers and partners hereby expressly disclaim all warranties of any kind, whether express or implied, including but not limited to implied warranties or merchantability, fitness for a particular purpose or non-infringement of third party rights.

HEDERA-22® make no warranty that this Website will meet your requirements or expectations, that access to this Website or any information, opinion or service linked from this Website will be uninterrupted, timely, secure, or error-free or that results from such use will be accurate or reliable.

HEDERA-22® cannot ensure that any file or other data you download from this Website will be free of all viruses, malware, contamination, trojan horses or other harmful software or program elements.

The use of HEDERA-22® Website is at user’s own risk.

HEDERA-22® shall not be liable in any manner whatsoever for direct, indirect, incidental, consequential, loss of data, income or profit, punitive damage and/or claim of third party resulting from the use of, access to, or inability to use the information and/or the service contained respectively offered on this Website or any damage arising out of or in connection with the use of this Website even if HEDERA-22® was informed of the possibility of such damage.

HEDERA-22® makes no representation about and has no responsibility in relation to any product/service or information you obtain from third party website linked to this Website.

10. Safety

HEDERA-22® has implemented safety measures to protect the personal information you provide, against non authorised access and use. However, the user recognises that he/she has been informed that no data forwarded on internet is 100% secured and any information communicated on the internet may potentially be intercepted and used by persons other than their intended recipient.

11. Nullity of a clause

Whenever possible, the provisions of these terms of use shall be interpreted so as to be valid and enforceable under applicable law. However, if one or more provisions of these terms of use is found to be invalid, illegal or unenforceable (in whole or in part), the remainder of the provision and of these terms of use shall not be affected and shall continue in full force and effect as if the invalid, illegal or unenforceable provision(s) had never existed. Moreover, in this case, HEDERA-22® shall amend the invalid, illegal or unenforceable provision(s) or any part thereof with a new provision which embodies as closely as possible the purpose of the invalid, illegal or unenforceable provision(s).

12. Modification

HEDERA-22® reserves its right to amend, correct or withdraw information and prices provided on the Website at any time without prior notice.

The user will be informed of the modification by the mention of latest modification date and version on the Website.

13. Governing law – Disputes

These legal mentions shall be governed and construed in accordance with Belgian law without taking into account conflict of rules principles.

All disputes arising from or otherwise related to this Agreement about its validity, interpretation or execution shall then definitively be settled by the Belgian courts of Liège (Belgium).

HEDERA-22® reserves its rights to require and obtain injunctions or orders to defend its rights under these legal mentions.

User agrees that regardless of any statute or law, any claim or cause of action against HEDERA-22® must be filed within one year of such claim or cause of action arising.

___________________________

PRIVACY POLICY

Date : Dec 22^nd 2022

GENERAL

We have always carefully protected personal data that we collect and process. To this end, HEDERA-22 undertakes to fully comply with the regulations in force applicable to the processing of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (also named General Data Protection Regulation – GDPR ”) and the Belgian law of July 30^th 2018 on the protection of individuals with regards to the processing of personal data.

The purpose of this « Privacy policy » statement is to describe how HEDERA-22 collects, uses and discloses your personal information, whether as part of the assistance we give you for any question you ask us, about your visit on our website or blog, the provision of a service from us or a service we ask you, your application for a job offer or simply as part of our collaboration.

This Privacy Policy therefore applies to personal data of the following users:

• users of our Website or blog;
• our customers;
• candidates for a job offer;
• our suppliers, collaborators, partners, private or public, and any other people whom we have contact with in the framework of the development of our activity;
• the visitors to our premises;
• shareholders and members of the board of HEDERA-22.

We reserve the right to amend this Privacy Policy at any time. Please visit our website for any change.

_________________

1. What types of personal data do we collect ?

1.1. Internet users of our website / blog

It is possible to visit our website without providing any personal data. However, when you visit our website, we may automatically collect certain information whether or not you decide to use our services. These information include your IP address and the date, time and frequency of you access to our website and how you browse its content.

We automatically collect your data using cookies, depending on your browser settings for the use of cookies. To find out more about our cookies policy, including how we use them and the choices you have, please see our « Cookie Policy » notice available on our website.
We also collect data from you when you contact us through the website / blog, for example by using the « chat » function or when you ask us a question. The data we collect, following your request, will mainly be:

• your name (mandatory)
• your email (mandatory)
• any other personal data that you have voluntarily communicated to us.

1.2. Our Customers

When you use HEDERA-22 Services for genomic analysis, production or targeting of biomolecules, or any other related service, we process some personal data. These personal data vary depending on the service requested. In principle, the personal data collected is limited to names, first names, address and ECB number of our customers, which are the data necessary for the provision of our services and invoicing. Personal data relating to the employees of our legal entity clients may also be requested for the monitoring and management of your request. For services involving the storage of customer personal data by HEDERA-22, our company will act as a personal data processor and the terms and conditions of our services will be specified by specific contractual clauses.

1.3. HEDERA-22 Collaborators or partners

If you are a collaborator or partner of HEDERA-22, we may collect personal data which are however limited. HEDERA-22 does indeed, in principle, only need the contact details of the people in your company who are in charge of the collaboration that binds your company with HEDERA-22 in order to manage and monitor the missions or dossiers between us.

We will therefore request the following data:

• Last name and first name
• E-mail address
• Telephone number (mobile and/or office phone)

1.4. Suppliers/Sub-contractors

If you are a Supplier or Subcontractor of HEDERA-22, we may collect personal data which are however limited. HEDERA-22 does indeed, in principle, only need the contact details of the people in your company who are in charge of the subcontract that binds your company with HEDERA-22 in order to manage and monitor the requested services.

We will therefore request the following data:

• Last name and first name
• E-mail address
• Telephone number (mobile and/or office phone)

In some cases, we may collect your bank data in order to settle the invoices if your bank account is not in the name of your company. We may also hold additional information that someone in your company has chosen to share with us. If for any reason we need additional personal data, we will notify you our request.

1.5. Public/Private partners

If you are a public or private partner of HEDERA-22, we may collect personal data which are however limited. HEDERA-22 does indeed, in principle, only need the contact details of the people within your organization / company who are in charge of the business which links your organization / company with HEDERA-22 in order to ensure the management and monitoring of our collaboration or the dossier. We therefore may collect the following data:

• Last and first name;
• E-mail address;
• Telephone number (mobile and/or office phone).

We may also hold additional information that someone in your organization / company has chosen to share with us. If for any reason we need additional personal data, we will notify you.

1.6. Applicants for a job offer, trainees, temporary workers, employees, independent contractors.

As a candidate for a job offer, an intern or temporary or independent collaborator with HEDERA-22, we may collect the following data:

• Last name ;
• Age / date of birth;
• National Identity Number or equivalent;
• Sex / gender;
• Marital status ;
• Contact information (mail, telephone, address);
• Education and professional experience ;
• Immigration status (whether or not you need a work permit);
• Nationality / citizenship / place of birth;
• A copy of your driving license and / or passport / identity card;
• Social security number and other tax information;
• Information relating to disability;
• Information on any criminal record if this is required for the position to which you wish to apply;
• Information on your current salary, your pension plan and your benefits;
• Information on your areas of interest and specific needs regarding your future job;
• Additional information that you choose to communicate to us;
• Additional information received from Customers / partners or found from third-party sources;
• IP address.

Please note that the above list of categories of personal data that we may collect is not exhaustive.

These data are necessary to assess your job-related skills and capabilities in the frame of pre-contractual relationship, to enable us to conclude an employment contract or to meet legal obligations.

1.7. Guests to our premises and offices

If you visit us in our premises and offices, we may collect the following personal data:

1.8. HEDERA-22 Shareholders

• last name and first name
• E-mail
• phone number
• any other data required to ensure compliance with the safety procedures of our infrastructures.

If you are an individual shareholder or a representative of institutional or private shareholder, we may collect or become aware of the following information:

• Name, first name, address, telephone number, e-mail address;
• additional identifying information (eg copy of identity card / passport);
• information relating to the shares held by yourself or your company (in particular the amount of shares, dismemberment of ownership (owner / beneficiary), pledges on the shares and types of share right);
• financial information relating to yourself or your company (bank account number for the dividends payment);
• information relating to your family (household composition, heirs, your acts of donation) (only for individual shareholders);
• content of your communications with us (if relevant);
• your electronic identification data (audio and / or video recordings such as those made through your IT tool integrated camera during remote or recorded meeting sessions).

1.9. Members of the board of HEDERA-22

If you are sitting on our board, we may collect or review the following personal data:

• Name, first name, address, telephone number, e-mail address;
• additional identifying information (including but not limited to date and place of birth, nationality, copy of identity card / passport);
• information about your family (eg marital status, household composition);
• your education and professional experience (eg employment and education history, professional qualifications and experience);
• your current position;
• details on your missions within HEDERA-22 (dates and duration of the mandate, attendance / absence);
• data relating to your remuneration (amount, expense reimbursement requests, insurance details and bank details);
• your electronic identification (usernames, passwords, audio and / or video recordings such as those made through your IT tool integrated camera during remote or recorded meeting sessions) ;
• pictures of you (with your consent); and
• more generally, the information you communicate to our board meetings or in the scope of board meetings.

2. How are personal data collected ?

2.1. Visit of our website / blog
We may collect data automatically via our cookies or collect data that you voluntarily provide us via our website, e-mail or on the phone in order for us to reply to your request.

2.2. Customers

We may collect personal data relating to our customers as part of our interaction with them during meetings, or via our website, by e-mail, on the phone, during workshops, seminars or during our surveys or marketing activities.

2.3. Customers / Suppliers / Partners

We may receive personal data directly from you :

• When you proactively contact us, usually by phone or email;
• When you access to our website;
• Through our employees / collaborators within the framework of their missions.

If applicable and in accordance with applicable laws and regulations, we may obtain further information about you through:

•  Third-party market studies and online and offline media analysis (which we can carry out ourselves or through third parties);
• Public databases.

2.4. Candidates for a job offer, employees, trainees, temporary workers or independent contractors

We may collect personal data from applicants as follows :

• You communicate your personal data directly to us by post or by any other electronic means;
• Your data are communicated to us by other sources such as our customers, an employment agency, a third party, a services / jobs offer site or company.
• During your visit to our website (see above).

2.5. Visitors

We collect your personal data during your visit by registering your data in the visitor book logbook.

2.6. Our shareholders and members of the board

We collect your personal data when signing the shareholder agreement with HEDERA-22 or the agreement confirming your mandate within HEDERA-22 and, in general, when HEDERA-22 acts with you in the frame of your mandate or position within our company.

3. Purposes and legal bases of data processing

 In general, personal information is only used to allow us to provide the requested service, to respond to a commercial order, to communicate with you, to improve or develop our services or products, to offer you targeted advertising and services, to protect us and our customers or partners, or to benefit from a service or product that we have purchased from you.

More specifically, we use your personal data to:

• Allow us to improve your user experience of our website; the legal basis being your consent to the use of cookies and our legitimate interest to offer an optimal website (Article 6,1 a) and Article 6,1 f) GDPR) ;
• Communicate with you to answer your questions and requests, subject to your explicit consent. The legal basis is your consent (Art. 6.1 a) GDPR);
• Allow you to benefit from the services we offer within a contractual relationship. The legal basis is a contract between you and our company (Article 6.1 b) GDPR);
• Allow us to benefit from the services we have requested through a contract (sales, subcontracting or collaboration contract) or be able to contact you about our agreements. The legal basis is the contract that binds us as well as our interest in obtaining from you a service in accordance with your contractual obligations (Article 6, 1 b));
• Assess the suitability of your profile in relation to our job offers in the frame of a pre-contractual obligation, which is covered by Article 6, 1 b) GDPR;
• Ensure the management of our contractual relationship within the framework of an internship, employment or interim contract, allowing us to comply with legal provisions relating to social security, occupational health, pension system, insurance regime and tax obligations; ensure the exercise and enjoyment of the individual and collective rights and benefits associated with employment; allow us to keep track of your work; allow you to access and use our IT tools and manage the termination of the employment relationship. The legal basis is the contract that binds us (Article 6,1 b) GDPR) and the legal and regulatory obligations to which we are subject to (Article 6, 1 c) GDPR);
• Comply with the legal and regulatory obligations, the legal basis being Article 6,1 c) GDPR;
• Send you invitations, promotions, offers, for events, in particular networking events, as well as general information on sectors of activity that may be of interest to you. This communication is legally based on your explicit consent (Article 6,1 a) GDPR);
• Promote HEDERA-22 offers and services related to the services you have used. This communication can be done by mail, e-mail or telephone. The legal basis being our legitimate interest (Article 6,1 f) RGPD) to offer you similar services to those you have already used with HEDERA-22. However, you can, at any time, refuse these direct marketing communications by notifying us or by using the unsubscribe link which will be found in our e-mail communication;
• Subject to your prior express consent, we may share your personal information with third party partners, who may send you marketing communications in connection with their products and services. However, you can, at any time, refuse these direct marketing communications by notifying us or by using the unsubscribe link that will be found in our communication. The legal basis for this processing is your explicit consent (Article 6,1 a) GDPR);
• Carry out satisfaction studies or surveys in order to adapt and improve our services or products. The legal basis is your explicit consent (Article 6,1 a) GDPR);
• Help us establishing, exercising or defending legal claims. These may be situations where we need to seek for legal advices with respect to a legal proceeding where we are required by law to retain or disclose certain information as part of the legal process. The legal basis for our processing is our legitimate interest and compliance with legal and regulatory provisions (Article 6,1 f) and Article 6,1 c) GDPR);
• The security of our services and websites / blogs. In this case, we use your personal data to help us verifying the activities of users of our services, our website or blog, in order to promote safety and prevent any activity that is potentially illegal or in violation of our terms or policies. This processing is based on our legitimate interest that we have to contribute to the security of our services and our goods (Article 6, 1 f) GDPR);
• The safety of our premises and offices. This processing is based on our legitimate interest in ensuring the security of our infrastructures, the confidentiality of our trade secrets and the safety of people within our infrastructures (Article 6, 1 f GDPR).

With regards to our relationship with shareholders, we process the personal data of individual shareholders in order to:

• analyze the shareholders structure of our company; communicate about and organize shareholder meetings (including sending meeting invitations or minutes); to pay dividends to our shareholders, if relevant; to interact and answer questions from shareholders; to carry out any legal publication; convert dematerialized shares into registered shares and vice versa; to write meetings minutes. This processing is based on the signed Shareholders’ Agreement (Article 6,1 b) GDPR – contract) and the legal obligations to which we are subject to (Article 6,1 c) GDPR).

With regards to the Board of Directors members, we process their personal data in the scope of:

• the organization and preparation of the board and committee meetings (including the presence/absence register; the creation and maintenance of directories; the management of contractual compensation (and other social benefits) or professional costs); the compliance with our policies (safety, communication, confidentiality) and legal requirements, withholding taxes and insurance, management of suspected cases of breach or fraud, carrying out audits, litigation; the investments and divestments management; meeting minutes reporting; to ensure any publicity imposed by law; for any other purposes required by law or authorities. These treatments are based on the signed Agreement confirming your mandate (Article 6,1 b) GDPR – contract) and the legal obligations to which we are subject to (Article 6,1 c) GDPR).

When the legal basis for the processing is our legitimate interest, HEDERA-22 shall ensure that the impact of data processing on the protection of your privacy is as limited as possible and in all cases, that the balance between HEDERA-22 and its partners’ interests and the potential impact on the protection of your privacy is not disturbed. If you still have objections to this processing, you can exercise your right of opposition explained below.

HEDERA-22 will not sell or rent your personal data to third parties, unless you have authorized it.

4. What are your rights regarding the processing of your personal data by HEDERA-22, and who can you contact?

You have rights regarding the processing of your personal data. Our company is at your disposal for any further information relating to your personal data. You can also contact our Data Protection Officer (DPO) at info@hedera22.com or via mail at the address referenced in the present privacy policy.

Your main rights are the following:

• Right to consult your personal data

You can consult your personal data at any time. All you have to do is to contact us at the address mentioned below (DPO). We will provide you with the most complete possible overview of your data, the purposes, the recipients of these data, the retention periods and the existence of an automated decision-making process, if any.

• Right to rectify your data

Sometimes, the data in our possession may no longer be up to date or correct. You can ask us to correct, amend or complete your personal data  at any time. However, it is your responsibility to specify the data you wish to rectify.

• Right to limit the processing of your data

You have the right to ask us to restrict the processing of your personal data under certain conditions, namely;

• when you dispute the accuracy of the data;
• when you have objected to the processing and we are in a period of assessment to establish whether the legitimate reasons pursued by the controller prevails over those of the data owner;
• when you believe that the processing of your personal data would be unlawful but you do not wish to exercise your right to erase your data;
• when we no longer need your personal data for the purposes listed above but you need them in the context of legal proceedings.

• Right to object

If you consider that your personal data are not being used in an appropriate way, you can object to their processing provided that the processing is based on our legitimate interests or on your explicit consent and that your opposition is appropriate and based on reasons relating to your particular situation.

To exercise this right, you are required to indicate the specific processing you object to and for what specific reasons. This information is necessary in order to be able to ensure a balance of interests.

Please note that we will not be able to comply with your objection request if:

• we can demonstrate that we have legitimate and compelling reasons to process your data which prevails over your interests or another reason which justifies the continued processing of your personal data (eg: legal obligation);
• we process your data for the purpose of establishing, exercising or defending legal claims.

• Right of portability

In the event that your personal data is processed within the framework of contractual obligations or explicit consent and provided we use automated processes, you have the right to request that your personal data be transferred to you in a commonly used structured format, or be transferred to another controller appointed by you. However, the law on the protection of privacy sets some limits to this right which is therefore not applicable to all data.

• Right to delete your personal data

In the cases authorized by the GDPR Regulation, you can ask us that we proceed to the deletion of your personal data via a simple request. This right, however, is not absolute. The exercise of this right can only be implemented in the following cases:

• the personal data are no longer necessary for the purpose for which they were collected;
• the data owner withdraws the consent on which the processing is based and there is no other legal basis for the processing;
• the data owner objects to the processing and there are no compelling legitimate grounds for the processing or the data owner objects to the processing for prospecting purposes;
• the personal data have been the subject of unlawful processing;
• the personal data must be erased to comply with a legal obligation provided for by European Union law or by Belgian law;
• the personal data has been collected in the frame of the information company service offer.

• Right to file a complaint

You have the right to file a complaint against any violation of your rights to the Data Protection Officer if you consider that HEDERA-22 has not acted in accordance with the applicable legislation (see contact information for DPO under the « Data Controller” chapter).

You can exercise your rights, ask us any question or comment about this policy at the address mentioned under the « Data controller » chapter. We will do our best to process your request as soon as possible, and in any case, within one month (subject to extensions authorized by law).

5. Data Controller

In accordance with the Belgian law dated 8 December 1992 on the protection of privacy with regards to the processing of personal data and its subsequent modifications, as well as with European regulations including Regulation 2016/679, General Regulation on Data Protection also entitled GDPR, the person responsible for your personal data protection is:

HEDERA-22   S.A.

Registration number/VAT: BE0630.923.236

Headquarter : Bd du Rectorat 27b, 4000 Liege, Belgique

Email : info@hedera22.com

Phone : +32 475413627

To contact us, you can send your request directly to the Data Protection Officer at the following email address or at the postal address mentioned above:

Mr Marc Hanikenne

Permanent representative

mail : info@hedera22.com

For any request, we will ask you for a copy of your identity card or document as a proof of your identity. We may also request any additional information we deem necessary regarding your request. Considering we have access to your personal information that we hold, we will not charge you for this access unless your request is « clearly unfounded or excessive ». In this case, we may charge you a reasonable administrative fee to the extent permitted by law.

Belgian Data Protection Authority

You may contact the Data Protection Authority in Belgium as follows:

• Phone: +32 (0)2 274 48 00
• Fax: +32 (0)2 274 48 35
• E-mail:  contact@apd-gba.be
• mail: Belgian Data Protection Authority, Rue de la Presse 35, 1000 Brussels, Belgium.

6. Security

HEDERA-22 has implemented numerous technical, physical and organizational security measures in order to ensure the integrity, confidentiality and availability of the data of any people who interacts with HEDERA-22.

HEDERA-22 has, in particular, implemented security measures to protect personal data stored in computer servers against unauthorized access, inappropriate use, alteration, illegal or accidental destruction and accidental loss.

HEDERA-22 is engaged in a process of monitoring and continuous improvement of its security procedures in order to take into account new technologies or new risks.

HEDERA-22 has also put in place contracts and imposed specific obligations with its subcontractors, partners or staff so that the manual and electronic processing of any personal data is treated confidentially and with appropriate security measures in order to avoid misuse of this data.

If you suspect improper use, loss or unauthorized access to your personal information, please notify immediately our DPO at info@hedera22.com.

7. Who has access to my personal data?

We can share your personal data with the following categories of people provided that they have an imperative need to know your personal data for the mission they perform or on the basis of a ‘need-to-know’:

• our collaborators who are called upon to process your file (employees, independent contractors, partners);
• collaborators of our subsidiaries or partners in research, or any other ministry or public authority involved in research files;
• employees of tax, insurance, mutual insurance, bank or any other public body when the law or any other regulation requires that your personal data be communicated to them;
• third-party service providers who act on our behalf including in particular lawyers, bailiffs, external consultants, auditors, IT providers, communication companies, building cleaning and maintenance staff, staff in charge of security of goods and people, etc .;
• any representative of the public authority, judicial police officers, officers of the Public Prosecutor’s Office, police services within the framework of the prevention and repression of offenses and in general, any authority legally authorized to deal with them;
• researchers or university research services that collaborate with us;
• the employees of our partners who work with you.

8. Will my personal data be transmitted outside of Belgium ?

In fulfilling its missions, HEDERA-22 works with companies based in the European Union and IT servers are situated inside European Union.

In principle, no personal data is stored outside the European Union territory. In the event that HEDERA-22 is required to communicate your personal information to service providers, partners, joint ventures, subsidiaries whose head office is located outside the European Economic Area, standard contractual clauses adopted by the European Commission would be imposed on the recipient if the protection of personal data is not sufficiently guaranteed in the country of destination.

9. How long will my personal data be kept for ?

We only keep your personal data for the time necessary for the purposes described above.

In principle, we will delete your personal data from our systems if there is no contact with you after an uninterrupted period of 13 months.

As part of a contract with HEDERA-22, we keep your personal data for a period of 5 years from the end of the contract between us. However, we may keep your personal data for a longer period of time if required by law or regulation.

Regarding the personal data of the collaborators of our partners or our customers, the personal data will be deleted at the end of a period of 2 years after we are informed by our partner or customer that you no longer work with them.

Regarding candidates for employment with HEDERA-22, personal data will be kept at the end of the candidate selection period for a maximum of 2 years.

We may also keep your data for periods which are imposed on us by any law or regulation in force (ex: billing obligations or contractual obligations).

ACCOUNTING RECORDS
Records	Duration	Beginning	Law
Supporting documents that can be used as proof with regards to third parties: documents on which each accounting entry is based	3 years	from January 1 of the year following the end of the financial year	Art III.86 Code of economic law
Invoices	7 years	from January 1 following their issue	Art 60 §1 et 4 C Vat – circular AAFisc n14/2014 ,  4 april 2014

10. Modifications and amendments

We may bring changes to this Privacy Policy from time to time in order, primarily, to adapt to new legal and regulatory requirements. Any modification takes effect immediately after the publication of the updated Privacy Policy. When you continue to use our services after the effective date of the amended Privacy Policy, we will consider that you accept these modifications. Uadated version is available on the website.

_________________________

COOKIES POLICY

December 2022

1. What is a cookie ?

Our website uses the technology known as « cookies » or other similar technologies. A cookie is a small data file that our web server sends to a connecting terminal (computer, tablet, smartphone, etc.) as soon as you visit our website and which includes a unique identification number. Some cookies are essential for the use of our site. Cookies generally allow easier and faster interaction between your terminal and our website. Cookies can also be used to make the content of a website more relevant to the visitor or to personalize the displayed content. Finally, cookies can also be used for statistical purposes to better understand how visitors use our website and the services we offer.

HEDERA-22 undertakes to comply with the Belgian law of July 10, 2012 laying down various provisions in the field of electronic communications and transposing into Belgian law all of the European regulations entitled “Telecom Package” regulating communication networks and electronic services (EU Directives 2009/140/EC and 2009/136/EC and Regulation (EC) No. 1211/2009) as well as all subsequent amendments. We therefore inform you about the type of cookies we use, their purpose, their retention period and how to modify your privacy settings in order to restrict the use of specific cookies.

• What types of Cookies do we use?

Our website uses the following cookies :

1. Essential and technical cookies

These are essential cookies for any navigation. They are not directly accessed to or stored by our website. They also do not contain any personal data other than your IP address, which is necessary for Internet browsing. These are, for example, cookies that help you navigate in the website and return to previous pages, or performance or load balancing cookies.

• Functional cookies

When useful, we may use functional cookies to record the choices you made on our website, such as the language choice. This information is stored on your workstation only and is used by us anonymously. These cookies are essential and cannot be refused.

• Statistics and performance cookies

Statistical or analytical cookies collect information relative to your browsing on our website and allow us to improve the user-friendliness, the content and to better adapt the website to the visitors wishes. These cookies are not essential for browsing our website but can facilitate your research, optimize your experience and help us better target your expectations, improve our offer, or optimize the functioning of our website. You can therefore refuse these cookies when you log in to our website.

Google Analytics:

Among the statistical cookies, our site uses Google Analytics. Google Analytics deploys internal cookies to generate reports relative to the interactions of the HEDERA-22 website users. However, these cookies do not allow personal identification of internet users. The data stored in Google Analytics are deleted according to the legal period (13 months) ; you have the right to access, port and delete this data.

The three cookies types deposited by Google Analytics are the following cookies: _ga, _gat and _gid.

They record an encrypted unique identifier, which is used to generate statistical data on how the visitor uses the website. They do not in any way allow your identification, either during your visit, or during data analysis.

More precisely:

_GA: Is a cookie associated with Google Universal Analytics, which is an update of the most used Google analysis service. This cookie is used to distinguish unique users by assigning a randomly generated number as a customer ID. It is incorporated into each page request on a swebite and is used to calculate visitor, session, and campaign data for site analytics reports. It is scheduled to expire after 24 months.

_GID: This cookie is associated with Google Universal Analytics. It stores and updates a unique value for each visited page (duration 1 minute).

_GAT: This cookie is associated with Google Universal Analytics. It is used to limit the flow of request, which limits data collection on high traffic websites. (session cookie).

You can unsubscribe from Google Analytics via the following link : https://tools.google.com/dlpage/gaoptout.

The statistical analysis has been configured so that it is strictly anonymous and allows us to identify specifically the most visited pages, the visits duration and the overall habits of our application users.

It is also a way for us to detect navigation difficulties on our website and to assess the efficiency of our service offer.

• Social network cookies (third party cookies)

Beside Google Analytics, our web site may present third parties cookies. These include cookies relating to your interaction with your social media accounts or to adverts. You can disable cookies from a third party provider by visiting www.aboutads.info.

We are likely to include on our website third parties computer applications, which allow you to share with other people content from our website or to make them know about your consultation or your opinion on a content of our website. This is particularly the case of the “Share” and “Like” buttons from social networks such as Facebook, Twitter, Google +, etc.

Third parties (social networks) are notified of your visit to our site through their cookies. By storing their cookies on your workstation, these third parties can recognize you on a subsequent visit to their site. Social media cookies (eg Facebook, Twitter, Pinterest, Instagram, Youtube) can be blocked or deleted by your browser options. In addition, we offer you the possibility of refusing these cookies when you visit our site (acceptance of third-party cookies and statistics). For more information on the use of your personal data in relation to social networks, and since social network cookies are managed by the editor of the social network site, we invite you to consult the networks privacy policies of such relevant third parties.

• Cookies storage duration

Most of the cookies we use are session cookies. These cookies facilitate the operations carried out on our website during a browsing session. Your session begins when your internet browser screen opens and ends when you close it. Session cookies are temporary and are deleted the moment you close your browser.

Other cookies used are persistent cookies. They remain on your hard drive for a predefined period of time, maximum 30 months, or until you delete them. They are activated each time you visit the website that placed the relevant cookie (such as cookies placed by social media).

• Cookies management

You can refuse cookies when the request for acceptance is offered to you. You can also deactivate cookies and oppose their registration by configuring your browser in the appropriate way. Finally, you can at any time delete cookies already installed on your computer or on your mobile device. To change your browser settings to restrict cookies, you will find instructions below for the most common web browsers:

Internet Explorer :

•  In Internet Explorer, choose the “Tools” menu then “Internet options”
• Choose the « Confidentiality » tab
•  Under the « Confidentiality » tab, select the desired level (settings above « medium » disable cookies).
• Click on “OK”.
• For more information: Cookies-InternetExplorer

Mozilla Firefox :

• In « Firefox » choose the « Preferences » menu
•  In the « Privacy and security » tab, select the options that suit you
•  Click on “OK”.
•  For more information: Cookies-Mozilla

Google Chrome browser :

• Click on “Settings” at the top of your browser window.
• then, click on « Advanced settings »
• In « Confidentiality » section, click on « site settings »
• click on cookies
• you can then choose between:
  • Activate cookies: next to « Blocked », turn the button to the activated position.
  • Disable cookies: disable the option « Allow sites to save / read cookie data. »
• For more information: Cookies-GoogleChrome

Safari browser :

• Click on « Safari » at the top of your browser window and select the « Preferences » option.
• Click on « Confidentiality » then choose your preferences
•  Click on “Save”.
• for more information: Cookies-safari

Opera browser :

• Go to Settings then “Preferences”.
•  Click on « Advanced » then choose the « Cookies » tab
• Then choose your preferences
• Click on “Ok”.

For any additional information to delete or control cookies, you can use the Help function of your browser or consult the following website : http://www.allaboutcookies.org/

Information regarding the use and deletion of cookies in tablets and mobile phones browsers can be found in your electronic device manual.

• Additional information

If you have any questions or comments regarding cookies after reading this cookies policy, you can contact us at the following address:

HEDERA-22   S.A.

Registration number/VAT : BE0630.923.236

Siège social : Bd du Rectorat 27b, 4000 Liege, Belgique

Email : info@hedera22.com

• Amendments

HEDERA-22 reserves the right to unilaterally modify this cookie policy in order to meet the standards imposed by any applicable law. Changes will be published on the website. Please refer to this page from time to time for any new information that may be added.