In effect as of 06/07/2026

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

The purpose of this Personal Data retention policy (hereinafter, the « Policy ») is to inform Users of the periods for which their Personal Data are retained by ADDEV, as well as the rules applicable to the archiving, deletion and anonymization of such Personal Data, in accordance with the storage limitation principle set out in Article 5.1.e) of the General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter, the « GDPR »).

The Policy supplements the Site’s privacy policy and cookie policy, available here, which the User is invited to refer to for any information regarding the Personal Data processing carried out by ADDEV (hereinafter, the « Processing ») and the rights available to the User.

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 For any information concerning the retention 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. PRINCIPLE OF LIMITING RETENTION PERIODS

2.1 In accordance with Article 5 of the GDPR, Personal Data cannot be kept indefinitely: they are kept in a form permitting identification of Users for no longer than is necessary for the purposes for which they are collected and processed.

2.2 In this respect, ADDEV determines a proportionate retention period for each category of Personal Data processed. ADDEV first checks whether a legal obligation imposes a retention period. If no legal period applies, ADDEV determines a period that is consistent and justified in light of the purpose of the Processing carried out, taking into account the needs of the business, the interests of the Users concerned, and the recommendations published by the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés, hereinafter, the « CNIL »).

2.3 At the end of their retention period, Personal Data are, as applicable, deleted, anonymized, or placed in intermediate archiving under the conditions described below.

3. LIFECYCLE OF PERSONAL DATA

3.1 For the duration of the Processing, Personal Data are kept in an « active database ». The active database hosts Personal Data and keeps them available only to authorized staff members who have a strict need to access them in order to carry out their duties.

3.2 Once the purpose of the Processing has been achieved, certain Personal Data may be placed in « intermediate archiving ». Intermediate archiving means that Personal Data are kept in a dedicated storage space, separate from the active database, and are accessed only on an occasional, justified basis, in particular (i) for an identified administrative purpose (for example, for evidentiary purposes in the event of litigation) or (ii) to comply with a legal obligation (for example, the retention of accounting documents). Access to Personal Data placed in intermediate archiving is restricted to specifically authorized persons and is subject to traceability measures.

3.3 The retention period for intermediate archiving is set according to the applicable legal obligations or, failing that, the applicable legal limitation periods.

3.4 At the end of these periods, Personal Data are deleted or anonymized, unless ADDEV is bound by a longer legal retention period or limitation period.

4. APPLICABLE RETENTION PERIODS

The retention periods applicable to the Processing carried out by ADDEV in connection with the use of the Site are determined in accordance with French law and CNIL recommendations. They are set out in the table below:

Processing activity	Retention period in active database	Retention period in intermediate archiving
Response to the contact form and management of prospects	Three (3) years from the collection of the Personal Data or from the last contact initiated by the prospect (for example, a request for documentation or a click on a hyperlink contained in an email).	None, except in the event of ongoing litigation.
Customer relationship management and sales follow-up (CRM)	For the entire duration of the contractual or commercial relationship. Personal Data may be kept for commercial prospecting purposes for a maximum period of three (3) years from the end of the commercial relationship.	Five (5) years from the end of the contractual relationship, with respect only to information strictly necessary for evidentiary purposes and the management of any disputes.
Management of job applications	Successful candidate: for the entire duration of the recruitment process, after which the data is added to the personnel file and retained in accordance with the periods applicable to human resources management. Unsuccessful candidate: up to three (3) months after the recruitment process is completed. With the candidate’s consent, Personal Data (CV, cover letter) may be kept for a maximum period of two (2) years from the last contact, for the purpose of building a CV database.	Five (5) years from the hiring decision, with respect only to information strictly necessary for evidentiary purposes (for example, to protect against potential discrimination claims).
Cookies and other trackers	Cookie lifespan: thirteen (13) months maximum from the date it is placed on the User’s device. Information collected via Cookies (in particular traffic statistics – Google Analytics): twenty-five (25) months maximum. Choices expressed by the User (consent or refusal): six (6) months.	None.
Management of requests to exercise rights	Strictly the period necessary to process the request.	Evidence relating to the processing of a request to exercise rights may be kept for up to six (6) years.

5. FATE OF PERSONAL DATA AT THE END OF THE RETENTION PERIOD

5.1 Deletion of Personal Data. At the end of the retention period set for the active database or, where applicable, for intermediate archiving, Personal Data are deleted from the information systems and applications in which they are hosted. This deletion is carried out, where possible, by means of automatic purging mechanisms configured in the software and solutions processing Personal Data or, failing that, by means of regular manual purging. Personal Data kept in paper format are securely destroyed (for example, using a shredder or a service provider specializing in the destruction of confidential documents).

5.2 Anonymization of Personal Data. Instead of being deleted, Personal Data may be anonymized. Anonymization consists of irreversibly making it impossible to identify or re-identify the User concerned, by any means whatsoever. Once anonymized, the data no longer constitutes Personal Data and data protection regulations no longer apply to it; it may then be kept indefinitely, in particular for statistical purposes.

5.3 Permanent archiving. Only data of historical, scientific or statistical interest justifying its retention may be subject to permanent archiving.

6. MANAGEMENT OF PERSONAL DATA

6.1 In accordance with applicable regulations, the User has, in particular, a right of access, rectification, erasure, objection, restriction and portability with respect to their Personal Data, as well as the right to withdraw their consent at any time. For further information on these rights and the conditions for exercising them, please refer to the privacy policy available here.

6.2 To exercise any of the above rights, or for any question relating to the Policy, 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.

6.3 If the User considers that their rights have not been respected, they may lodge a complaint with the CNIL: www.cnil.fr.

7. 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.