Data Protection Policy and Privacy Notice for Valeo Cyclee™

VALEO CYCLEE™ is a platform open to bicycle shops, accessible online at pro.valeocyclee.com as well as a customer service department accessible by telephone, enabling diagnostic and maintenance operations to be carried out on electrically-assisted bicycles equipped with the Valeo Cyclee™ drive system, parts and accessories to be ordered and technical documents to be consulted. Access to the Valeo Cyclee™ platform and customer service is restricted to bike shops that have opened a customer account with Valeo Service via the website (pro.valeocyclee.com).

The data controller of the Personal Data collected via the VALEO CYCLEE™ platform and services is the company Valeo Service, a simplified joint stock company registered in the Bobigny Trade and Companies Register under number 306 486 408, whose registered office is located at 70 rue Pleyel 93200 Saint Denis, hereinafter referred to as "Valeo".

The Personal Data collected when creating your customer account and using the VALEO CYCLEE™ platform are as follows:

• First and last names
• Email addresses:
  • contact
  • administrative (invoicing, delivery)
• Landline or mobile numbers

Personal Data is shared and managed exclusively by Valeo and its affiliated companies within Valeo, or its processors.

Where Valeo needs to use data processors, they are required to comply with the applicable general terms and conditions and may only use the data for clearly identified purposes.

When Valeo needs to transfer Personal Data outside the European Union, it implements all necessary safeguards to ensure the security of individuals' Personal Data.

Valeo is not involved in any transaction or trade in Personal Data. It does not sell any personal data to third parties.

Valeo will retain your Personal Data in a secure environment for as long as is necessary to fulfil the purposes for which they were collected or for as long as is required by applicable law, particularly civil, criminal, commercial law and the Regulations related to the VALEO CYCLEE™ platform and services.

Thus, the Personal Data collected on the VALEO CYCLEE™ platform will be retained for the duration of our business relationship and then beyond for a period of 10 years in order to allow the management of possible liabilities arising from the contractual relationship.

Valeo only collects the Personal Data necessary for registration on and use of the VALEO CYCLEE™ platform and services or for access to Valeo Customer Service.

Personal Data may be used for the following purposes:

• To open and manage your customer account
• To answer your questions or send you marketing or event information (particularly newsletters, SMS, e-mails; provided that you have given your consent or do not object thereto)
• To send and process purchase orders, invoices and credit notes
• To meet legal obligations
• To meet the requirements of internal audits
• To conduct polls and surveys
• To send you email alerts with information about Valeo
• To send newsletters on recent Valeo news according to the communication preferences you have chosen
• To deal with any questions, comments or other requests you may have sent to us through the website
  • For commercial and marketing purposes, including sending information about the Valeo Cyclee™ system, according to your communication preferences
  • For technical purposes, as part of dedicated technical assistance
• To measure the traffic on the website, to obtain information on the activities carried out on it

We collect and process your Personal Data in order to manage your online account and our contractual relationship. This processing is carried out on the basis of the need to execute the contract signed with you when you created your customer account.

Furthermore, your consent is requested for the sending of our Newsletters, emails and SMS related to promotional and commercial advertising, always leaving you the possibility to withdraw and manage your consent.

We are committed to ensuring the security, confidentiality and integrity of your Personal Data.

We take reasonable steps to protect against any unauthorised access to and unlawful use of your Personal Data, as well as against the loss, destruction or damage of your Personal Data. Valeo uses physical, logical and technical measures, as well as organisational and procedural controls to safeguard your Personal Data, all of which are subject to regular review.

When we entrust a third-party service provider with the processing of your Personal Data, we ensure that they are also bound by a contract that guarantees a high level of privacy protection and demand that (inter alia) they only act on Valeo's instructions and implement all necessary technical measures at all times to ensure the security of your Personal Data in compliance with the regulations.

In accordance with the provisions of the European Regulation on the protection of personal data no. 2016/679, you can exercise the following rights:

• Request access to your personal data
• Request the withdrawal of your consent: where this is the basis for processing your personal data
• Request the rectification of your personal data where they are inaccurate or incomplete
• Request the deletion of your personal data, also known as the "right to be forgotten" when one of the following conditions applies:
  • The personal data are no longer necessary for the purpose for which they were collected
  • You have withdrawn your consent and the processing no longer has a legal basis
  • You object to the processing of your personal data
  • Your personal data has been unlawfully processed
• Request a restriction on the processing of your personal data: you may exercise your right to restrict the processing of your data in any of the following circumstances:
  • You dispute the accuracy of the data
  • You need the data for litigation purposes
• Request the portability of your data: you have the right to request/claim that your personal data be provided to you in a "structured, commonly used and machine-readable format" and to transfer that data to another party
• File a complaint with the public data protection authority: you can file a complaint with the Commission Nationale Informatique et Libertés, or the national agency responsible for data protection in your country
• Give specific instructions for the storage, deletion and communication of your personal data after your death.

You can also exercise your right to object to and unsubscribe from Newsletters by using the link at the bottom of each newsletter.

If you have a legitimate reason, you can exercise this right in writing by sending a letter to our registered office address or an email to dpo.external@valeo.com

In order to exercise these rights, we will in some cases ask you to provide proof of identity and any information necessary to process your request.

Please note that the exercise of certain rights may prevent Valeo from providing you with services related to the VALEO CYCLEE™ system.

If you have any questions or concerns about data protection or your personal information, or if you wish to file a complaint, please contact the Valeo Data Protection Officer at the following address:

Valeo 100 rue de Courcelles 75017 Paris France dpo.external@valeo.com

Valeo reserves the right to modify this Privacy Policy at any time.

You will be informed of any significant changes by means of an update notification, which will bear the date of the update.