In effect as of 06/07/2026

In order to present its products and services, the company ADDEV MATERIALS (hereinafter, « ADDEV ») collects personal data (hereinafter, the « Personal Data ») of users (hereinafter, the « Users ») on its website https://neoheater-technology.tech/ (hereinafter, the « Site »).

The purpose of this Personal Data policy (hereinafter, the « Policy ») is to inform Users of the means implemented to collect, consult, process and retain Personal Data, and to present the rights available to them.

The Policy applies to all processing (hereinafter, the « Processing ») of Personal Data as defined by applicable regulations. Processing consists in particular of the collection, recording, organization, retention, erasure or destruction of Personal Data, including the combination of two or more of these activities.

ADDEV undertakes that any Processing of Personal Data is carried out using procedures and technical and electronic means that protect the confidentiality and security of Personal Data.

1. DATA CONTROLLER

1.1 The data controller, which collects Personal Data and carries out the Processing, is ADDEV MATERIALS, a simplified joint-stock company (société par actions simplifiée) with capital of €67,849,777.00, whose registered office is located at 30, Quai Perrache, Lyon (69002), France, registered under sole identification number 820 724 508 RCS Lyon, and whose VAT identification number is FR32820724508.

1.2 ADDEV acts as data controller with respect to the Personal Data collected on the Site, in accordance with Articles 13 and 14 of the General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter, the « GDPR »).

1.3 For any information concerning the Processing of Personal Data, the User may contact ADDEV by writing to ADDEV’s postal address, 30, Quai Perrache, Lyon (69002), France, by telephone at +33 (0)4.72.11.35.00, or by email at the following address: contact@addevmaterials.com.

2. COLLECTION OF PERSONAL DATA

2.1 The Personal Data that ADDEV may collect via the Site are as follows:

(i) Personal Data relating to the User’s identity: “last name”, “first name”, “email address”, “telephone number” and other information contained in the curriculum vitae (CV);

(ii) Personal Data relating to browsing: this is data that ADDEV collects while the User browses the Site, such as, in particular, the date and time of connection and/or browsing, browser type, browser language, IP address, pages viewed, and approximate location data.

2.2 When using the Site, information relating to the browsing of the User’s device may be recorded through files known as “cookies”. The Site uses in particular technical and functional cookies essential to the proper functioning of the Site, analytics cookies (Google Analytics), and advertising cookies. For more information on the use of cookies on the Site and how to disable them in the settings, we recommend that you consult the Cookie Policy available here.

[TO BE COMPLETED if other data is collected]

2.3 ADDEV only collects Personal Data strictly necessary for the Processing. Certain Personal Data may be mandatory or optional in accordance with what is indicated at the time the Personal Data is collected. The mandatory nature of providing certain information may be indicated by an asterisk.

3. PURPOSE AND LEGAL BASIS FOR THE COLLECTION OF PERSONAL DATA

The Personal Data collected in connection with the use of the Site are processed by ADDEV for the purposes described below:

Purpose of the processing	Use of Personal Data	Legal basis
Response to the contact form	Personal Data are used to interact with Users who have contacted ADDEV via the contact form and to respond to their requests.	Consent Legitimate interest of the data controller for the purpose of managing and monitoring its relationships, in particular commercial relationships, with its customers, prospects and, more generally, its contacts.
Management of job applications	Personal Data are used to review applications, assess the suitability of candidate profiles for the positions offered, contact candidates and follow up on the recruitment process.	Consent Legitimate interest of the data controller for the purpose of recruiting staff and managing the recruitment process.
Analysis of User behavior on the Site (Cookies – Google Analytics)	Personal Data are collected to understand how Users use the Site and to tailor offers to their needs. ADDEV uses Google Analytics (Google LLC) to analyze Site traffic and improve the User experience.	Consent
Management of the customer relationship and sales follow-up (CRM)	Personal Data are recorded in ADDEV’s CRM tool and used for sales management purposes.	Legitimate interest of the data controller for the purpose of managing and monitoring its relationships, in particular commercial relationships, with its customers, prospects and, more generally, its contacts.

4. RETENTION PERIODS

4.1 Users’ Personal Data will not be kept beyond the period strictly necessary for the purposes pursued as set out herein, in accordance with applicable regulations and laws. In this respect, Personal Data used for prospecting purposes may be kept for a maximum period of three (3) years from the closure of the User’s account or from the last contact with the prospect concerned. The Personal Data of customers bound by a contractual relationship will be kept for the entire duration of that contractual relationship, then archived for a maximum period of five (5) years from the end of said contractual relationship, for the purpose of managing any disputes and in accordance with applicable statutory limitation periods. Cookies and other trackers placed on the Site will be kept for a period not exceeding thirteen (13) months, in accordance with the deliberations of the French Data Protection Authority (Commission nationale de l’informatique et des libertés, hereinafter, the « CNIL »). Personal Data relating to job applications is kept for the period necessary to process the application. In the event of an unsuccessful outcome, it may be kept for a maximum period of two (2) years from the last contact with the candidate, unless the candidate objects.

For more information regarding the retention period of Personal Data, we recommend that you consult the Personal Data Retention Policy available here.

4.2 At the end of these periods, ADDEV undertakes, at its own expense and under its own responsibility, to delete or anonymize all of the Personal Data collected, unless ADDEV is bound by a longer statutory retention period or limitation period.

5. RECIPIENTS OF PERSONAL DATA

As part of its business activities and for the purposes specified above, ADDEV may share Users’ Personal Data with:

(i) ADDEV’s staff members, for internal administrative purposes or for the management of Users’ rights, for example;

(ii) Processors of Personal Data, who provide services on behalf of ADDEV and in accordance with its instructions, such as the Site’s host (Infomaniak Network SA, Switzerland), Google LLC (in connection with the Google Analytics tool), or the publisher of the CRM tool used by ADDEV;

(iii) And, where applicable, any person, authority or public body legally authorized to access such Personal Data, such as the judicial authorities or the CNIL, for example.

6. TRANSFER OUTSIDE THE EUROPEAN UNION

In addition to their potential transmission to the above-mentioned recipients, the Personal Data collected may be transferred to countries located outside the European Union, and in particular to the United States.

With regard to transfers to the United States, these may be carried out either to entities recognized as ensuring an adequate level of protection, or on the basis of appropriate safeguards, such as the conclusion of standard contractual clauses adopted by the European Commission, where the recipients do not benefit from an adequacy decision.

You can obtain further information on the safeguards governing these transfers by sending us a request using the contact details indicated in the Policy.

7. MANAGEMENT OF PERSONAL DATA

7.1 In accordance with applicable regulations, any individual using the Site may exercise, at any time, the following rights:

(i) A right of access: the User has the right to obtain confirmation from ADDEV as to whether or not Personal Data concerning them is being processed and, where it is, to obtain access to such Personal Data and a copy thereof;

(ii) A right of rectification: the User has the right to ask ADDEV to correct any inaccurate or incomplete Personal Data concerning them;

(iii) A right to erasure of Personal Data: the User has the right to ask ADDEV to erase certain data held about them. This right is not, however, an absolute right, and ADDEV may have legal or legitimate reasons for retaining such Personal Data;

(iv) A right to data portability: the User may request communication of the Personal Data they have provided to ADDEV in order to transmit it to another data controller;

(v) A right to object: the User may object at any time, on grounds relating to their particular situation, to the Processing of their Personal Data where such Processing is based on ADDEV’s legitimate interest;

(vi) A right to restriction of processing: in certain cases, the User may request the temporary suspension of the Processing of certain of their Personal Data;

(vii) The right to withdraw consent: the User may withdraw their consent at any time for Processing whose legal basis is consent. To exercise this right, the User may contact ADDEV by writing to its postal address, 30, Quai Perrache, Lyon (69002), France, or by email at the following address: contact@addevmaterials.com.

Withdrawal of consent will not affect the lawfulness of Processing carried out after such withdrawal.

(viii) The right to provide instructions regarding the fate of their Personal Data after their death.

7.2 To exercise any of the above rights, the User may contact ADDEV by writing to its postal address, 30, Quai Perrache, Lyon (69002), France, or by email at the following address: contact@addevmaterials.com.

7.3 ADDEV has a period of thirty (30) days from receipt of the User’s request to respond to it. This period may be extended by two (2) months in the event of complexity or a high number of requests.

7.4 ADDEV undertakes to implement all necessary means to ensure that the User’s rights regarding their Personal Data are respected. However, if the User considers that their rights have not been respected, they may lodge a complaint with the CNIL: www.cnil.fr.

8. LINKS TO THIRD-PARTY WEBSITES

The Site may link to other third-party websites or services operated by third-party companies. ADDEV exercises no control over these and cannot be held liable for the Processing of Personal Data carried out by such third-party sites. Users are invited to consult the privacy policies applicable to such third-party sites.

9. SECURITY MEASURES FOR PERSONAL DATA COLLECTED

9.1 Personal Data is strictly confidential and processed in accordance with Law No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, as amended by Law No. 2018-493 of 20 June 2018, the GDPR, and Decree No. 2019-536 of 29 May 2019.

9.2 Pursuant to the aforementioned texts, ADDEV undertakes to take all useful precautions to preserve the security and confidentiality of Personal Data and, in particular, to prevent it from being altered or distorted, or from being accessed by unauthorized third parties.

10. AMENDMENTS

The Policy may be amended at any time by ADDEV, in particular to comply with any regulatory, case-law, editorial or technical developments. Before browsing, the User should refer to the latest version of the Policy.