Mersen Graphite Privacy Policy

Introduction 

Mersen Corporate Services SAS (hereinafter “Mersen”) is committed to safeguarding the privacy and personal information of all users of its website (hereinafter the “User” or “Users”). It actively invites Users to take note of this Privacy Policy which ensures that this information is protected. 

Mersen is also committed to complying with the core principles of the French data protection act of January 6, 1978, as amended, and European Regulation No. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, given that the Group’s headquarters are located in the European Union and it processes data that concerns residents in the European Union.

This Privacy Policy seeks to protect personal information and applies to all Mersen Group entities and subsidiaries with regard to the collection, processing, use, disclosure, transfer and storage of data. It requires all entities in all countries to comply with a shared set of provisions that guarantee a very high level of protection for personal information.

1. Scope of application

This Privacy Policy explains the way in which Mersen and Mersen Group entities process the personal information of Users who visit the Mersen website (hereinafter the “Website”). 

2. Collecting personal information

The Website collects personal information in three ways:

• directly, when Users choose to share personal information with Mersen;
• indirectly and automatically, using Google Analytics;
• indirectly, using cookies.

a.    Information Users choose to share with Mersen

The personal information that Users choose to share with Mersen includes all information collected directly by the Website, as well as any other type of information that Mersen expressly requests Users share with the Company, such as: 

• last name, first name, address, email address and telephone number;
• education and professional status;
• comments;
• interests and preferences for marketing purposes.

Personal information is processed for the purposes described in paragraph 3 and is declared to the French National Commission for Data Protection and Privacy (CNIL), via declaration No. […].

Insofar as personal information may sometimes be collected by way of a questionnaire, Users acknowledge that Mersen, in accordance with Article 32 of the French data protection act, as amended, has provided them with the following information:

• “1° the identity of the data controller and of their representative, if any;
• 2° the purposes of the processing for which the data are intended;
• 3° whether replies to the questions are compulsory or optional; […]
• 6° the rights granted them by Section 2 of this Chapter, including the individual’s right to decide what should happen to their personal information after their death.”

b.    Information collected automatically by Google Analytics

The Website uses Google Analytics, supplied by Google Inc. (“Google”), to analyze its website traffic. The tool collects anonymous data in order to monitor trends in website traffic without individually identifying each visitor, and uses its own set of cookies to track visitor activity. It also generates statistical reports that are used to improve the quality of the Website.

Automatically collected information includes: 

• The User’s IP address;
• Information about the User’s computer, such as their type of connection, current browser, and operating system, as well as their cell phone or tablet operating system, and other device identifiers;
• The User’s URL connections, as well as the date and time of connections and the content viewed on the Website;
• The cookies generated through the use of the Website, which are transferred directly to a Google server in the US where they are stored.

To disable cookies and block the automatic collection of data, some browsers display a message when a cookie is sent that users can then refuse on a case by case basis (see the help and support menu on your browser to configure this feature). In addition to refusing cookies, users can also install an add-on that disables Google Analytics and stops the tool from collecting information about their browsing history: https://tools.google.com/dlpage/gaoptout?hl=en

Google Analytics terms and conditions:  http://www.google.com/intl/en/policies/privacy/partners/

c.    Cookies

Cookies are small text files that often have a unique ID and are stored on User hard drives. They are sent by the website being viewed by the User to the User’s browser, and are then stored on their hard drive. 
The main types of cookies used are “http” cookies and trackers that are sent and read when a website is visited, whatever the type of device used, including computers, cell phones and tablets. 

Cookies allow Mersen to collect information about User visits to the Website for statistical purposes, and to make the Website more user-friendly and improve the browsing experience.
Users are asked to explicitly consent to cookies being collected before the data is stored.
User consent for cookies and cookie processing is valid for a period of 13 months.

Users are also able to configure their browser to block cookies and still have access to certain Website functionalities. By blocking cookies, Users nonetheless accept that certain features and functionalities may be lost. 

Users can find many resources on the Internet about cookies and how to manage their preferences like https://www.allaboutcookies.org or https://en.wikipedia.org/wiki/HTTP_cookie.

Depending on their browsers, Users can follow the links below for more information on how they can disable and delete cookies:

• Mozilla Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
• Internet explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
• Safari: https://support.apple.com/kb/PH21411?viewlocale=en_US&locale=en_US

3. Using personal information 

Personal information collected through the Mersen Website is used to:

• Enable Mersen to respond to Website User requests, in particular regarding job applications, or contact Users by email to keep them informed about certain matters;
• Develop content and improve the Website, and provide any necessary technical support to Users;
• Conduct canvassing and marketing operations;
• Generate marketing statistics; 
• Manage business relations with Users;
• Target certain Users as part of a recruitment drive;
• Compile files (marketing files, client files, etc.) to be declared to the relevant authorities;
• Contact Users regarding Mersen products or services;
• Analyze User data to develop new products or services and improve existing ones;
• Prevent or detect any potential threats to the safety and security of Mersen products or services, as well as fraud or any illicit activity.

More specifically, for personal information linked to a job application, Users are informed that only answers to questions preceded by an asterisk are compulsory. However, candidates who fail to answer all of the compulsory questions may compromise their application. All other answers are optional and have no effect on their application. 

In accordance with the French Labor Code (Code du travail), Users are informed that the recruitment procedure implemented by Mersen is as follows:

Recruitment procedure

• Applications to Mersen are made using the online form in the “Join Us” section.
• They are reviewed by the HR department of the recruiting entity within one week of being sent.
• Users who do not receive a reply from Mersen within three weeks should assume that their application has not been successful. 
• CVs and cover letters are kept for six months.
• The HR department may contact candidates by any means of communication indicated (telephone or email). 
• The HR department and the candidate will then organize one or several telephone or face-to-face interviews. 

Users are informed that all personal information will be filed electronically, processed confidentially and kept for six months following the last communication with the candidate.

Only authorized Mersen employees have access to this information, which is used for strictly internal purposes only.

User candidates can access, correct or delete personal information by contacting Mersen.

• By post: MERSEN CORPORATE SERVICES SAS, Direction des ressources humaines, Tour EQHO, 2 avenue Gambetta, CS 10077, 92066 LA DEFENSE CEDEX France; or,
• By email: webmaster.groupe@mersen.com

4. Accessing personal information 

The following persons may, within the limits of their respective responsibilities, access Users’ personal information:

•    Persons responsible for marketing, sales, customer relations and business development, administrative services, the Website, IT and logistics and recruitment, as well as their line managers;
•    Departments responsible for oversight (statutory auditors, departments responsible for internal control procedures, etc.)

Personal information collected by Mersen via the Website is used for strictly internal purposes only and will not be communicated, sold or disclosed to any third party, without the explicit authorization of the User in question or unless otherwise required by law.

Users of the Website do however authorize Mersen to share all information collected with existing suppliers and subcontractors, on the condition that it is strictly necessary to share such information in order to fulfill the purposes set out above, and on the condition that said suppliers and subcontractors are bound by the same obligations regarding data protection and confidentiality. Where this is the case, all suppliers, subcontractors or related companies will be notified if personal information is to be modified or deleted.

5.  Social media

Users are informed that the Website may also provide access to features from social networks, forums, chatrooms, blogs (in particular Facebook profile pages, Twitter accounts and LinkedIn accounts) and other services on which Users may display personal information. All information published or communicated by Users through these services is deemed to be in the public domain. 

The Website uses “Social Share Privacy” to allow Users to share content, should they wish to do so, through social media, email or by adding pages to their list of favorites. Mersen does not collect or record any personal information through this plugin.

Mersen posts on its social media pages are managed by the Group’s Communication department from Monday to Friday between 9am and 6pm CET.

The department also moderates any comments to posts after they have been posted.

The following comments are systematically deleted:

• Aggressive comments;
• Illegal or illicit comments, or any statement that goes against the rules of Internet good practice;
• Any comment that does not comply with the rules of the sites on which the pages are hosted;
• Comments written in texting language or capital letters;
• Abusive comments, spam, trolling or promotional content (advertising, classified ads, etc.);
• Private conversations that bear no relation to the matters dealt with on Mersen’s page;
• Comments containing personal contact details.

Users can contact Mersen directly:

• By post: MERSEN CORPORATE SERVICES SAS, Direction des ressources humaines, Tour EQHO, 2 avenue Gambetta, CS 10077, 92066 LA DEFENSE CEDEX France; or,
• By email: webmaster.groupe@mersen.com

Any comments regarding moderation can also be made via private messaging or email.

Content posted by Users does not necessarily reflect Mersen’s point of view. Users are solely responsible for their own posts, including comments, photos and links. Mersen cannot under any circumstances be held responsible for such comments or their consequences.

6. Storing personal information

Personal information collected through forms filled out by Users is stored for no more than the time required to fulfill the stated purpose.

7. Child protection

Mersen does not knowingly collect personal information from any individual under the age of 18. The Website does not seek to target minors.

8. Managing personal information

Users can manage their preferences regarding data sharing when they connect to the Website in question by updating their account settings. They can also use the opt-out notification on their web browser, an unsubscribe request or any other means to achieve the same end.

9. User rights regarding personal information 

Regarding their personal information, Users have the right to:

• Access any personal information that is stored in Mersen’s databases; 
• Oppose the processing of information when it is incomplete, inexact or out of date;
• Correct any personal information when it is incomplete, inexact or out of date;
• Delete any personal information;
• Retract prior consent given to process their personal information;
• Decide ahead of time what should become of their personal information in the event of their death;
• Transfer their own personal information.

To exercise these rights or to make a claim, Users can contact Mersen’s Communication department:

• By post: MERSEN CORPORATE SERVICES SAS, Direction des ressources humaines, Tour EQHO, 2 avenue Gambetta, CS 10077, 92066 LA DEFENSE CEDEX France; or,
• By email: webmaster.groupe@mersen.com

For security reasons and to prevent any fraudulent requests, Users must provide proof of identity when they seek to exercise these rights. Once their request has been processed, their proof of identity will be destroyed.

Users can also contact the relevant data protection authorities directly. 

10. Safeguarding personal information

Mersen uses a variety of security measures to protect the information it collects and guarantee the confidentiality and accuracy of personal information. These measures include restricted access to the server other than the http and https servers (ports 80 and 443), local access to the database as well as regular back-ups and updates of the server and software, and CAPTCHAs to prevent brute force attacks.

11. Transferring personal information

Users’ personal information may be transferred to entities located in other countries within and outside the European Union for the purposes set out in this policy. Whenever personal information is transferred to another country, precautions are taken to ensure the data remains under adequate protection. 

All data transfers are made:

• To countries recognized by the European Commission as ensuring an adequate level of protection;
• To countries not recognized by the Commission as providing adequate protection, when the transfer is governed by contractual clauses similar to binding corporate rules or those of the European Commission.
• To certain Mersen entities in the US that, with regard to certain services, have been awarded the Privacy Shield certification set up by the US Department of Commerce.

12. Changes to the Privacy Policy

In the event of a change to the Privacy Policy, Mersen will publish the revised version marked with the date of the revision. 

The current version of the Privacy Policy was last updated on May, 22^nd 2018.
 

13. Contact

Users who have any comments or questions regarding Mersen’s Privacy Policy or the processing of personal information can contact Mersen:

• By post: MERSEN CORPORATE SERVICES SAS, Direction des ressources humaines, Tour EQHO, 2 avenue Gambetta, CS 10077, 92066 LA DEFENSE CEDEX France; or,
• By email: webmaster.groupe@mersen.com