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PRIVACY NOTICE

1.     Purpose of this Notice

This privacy notice (“Notice”) describes how EUTELSAT S.A., in its capacity as data controller (“Data Controller”), collects, uses, processes and transfers your personal data, as described in more detail below. “Personal Data” means any individually directly or indirectly identifiable information about you, collected or otherwise received by the Data Controller. The Data Controller processes any Personal Data fairly, lawfully, and in accordance with all applicable laws.

2.     Personal Data that the Data Controller Collects

The Data Controller may collect your Personal Data, including but not limited to: name and surname,  date of birth, home address, fixed and/or mobile telephone number, email, and any data relevant for the purposes of the data processing defined in Article 3 below. The Data Controller will not collect any sensitive data about you. “Sensitive data” are defined as those personal data directly or indirectly revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade-unionist character, as well as personal data concerning health and sex life.

The Data Controller will collect your Personal Data directly from you, when you will visit the Tooway website and will request to be contacted back in order to receive information on Tooway services. The Data Controller may also obtain your Personal Data from third parties if you have previously consented to the sharing or assignment of your Personal Data by said third parties. The Data Controller will inform you at the time of entering your data into the Data Controller’s database of such disclosure and give you the right to object, should you wish so. The provision of your Personal Data is voluntary, but the refusal to provide such data or to have such data processed by the Data Controller will result in the Data Controller being unable to contact you and provide you with any information on Tooway services.

3.     Use of Personal Data

The Data Controller will process your Personal Data exclusively in order to (i) respond to your request of information about Tooway services, or (ii) enter into a contract for the provision of Tooway services, if requested by you, or (iii) to comply with obligations imposed by applicable laws and regulations and to establish or defend a legal claim involving the Data Controller. If you did not request any information on Tooway services, the Data Controller will process your Personal Data for the purposes under (i) above only with your express consent. The Data Controller will list your Personal Data in a database only for the time necessary for the purposes for which the Personal Data were collected or as required by law, but will not make any use of said database for marketing purposes without your consent.

4.     Disclosure and International Transfer of Personal Data

Within the Data Controller organization, access to Personal Data will be given to the Data Controller’s authorized distributors (but only if you intend to enter into a contract for the provision of Tooway services), to the data processor(s), as appointed, and to those persons who need such access for the purposes listed above, or who will process such Personal Data in their capacity as persons in charge of the processing. These persons or entities could be located in France, Italy, UK, Germany, Poland, Turkey, Norway, Denmark, Sweden, Spain, Estonia, Latvia, Lithuania, Greece, Romania, Hungary, Czech Republic, Austria, Bulgaria and Croatia, and therefore your Personal Data could be transferred to other EU or non-EU countries, but only for the above purposes. However, any transfer to entities based outside of the EU will only be effected pursuant to the EU Commission Decisions on standard contractual clauses for the transfer of personal data to controllers established in third countries (so-called controller to controller transfers), or, as the case may be, on standard contractual clauses for the transfer of personal data to processors established in third countries (so-called controller to processor transfers). The Personal Data will under no circumstance be disseminated.

In particular, we wish to highlight that your Personal Data will be disclosed to the Data Controller’s authorized distributors only if you intend to enter into a contract for the provision of Tooway services.

With reference to such Personal Data, said distributor will then act as a data controller for the purposes of entering into such contract, and the relevant data processing will be subject to the data privacy laws applicable to the distributor as well as its privacy policy that the distributor will duly provide you with.

5.     Data Security and Data Processing Conditions

The Data Controller endeavors to maintain all the physical, technical and organizational security measures necessary to protect Personal Data against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure, use or access, in compliance with all applicable laws. Personal Data is processed electronically and also manually according to methods and procedures consistent with the above mentioned processing purposes.

6.     Retention and Accuracy of Personal Data Collected

The Data Controller will retain Personal Data no longer than is necessary for the purposes described in this Notice or as required by law. If changes need to be made to your Personal Data, please notify us right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in Personal Data, we will endeavor to make necessary changes as promptly as possible.

7.     Data Controller and Data Processor

For the purposes of this Notice, the Data Controller is EUTELSAT S.A., Département Marketing Tooway, 70, Rue Balard, 75015 Paris, France.

The database containing your Personal Data will be hosted and managed by a data processor appointed by Data Controller for the purposes set forth in this Notice.

8.     Access to Personal Data and Other Privacy Rights

You will always have the following rights:

(i)         To obtain confirmation as to whether or not your Personal Data exists, and communication of such data in intelligible form.

(ii)         To obtain: a) updating, correction or, when of interest, integration of your Personal Data; b),  deletion of your Personal Data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, also regarding their content, to the entities to whom or which the data were communicated or distributed , unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.

(iii)        To object, in whole or in part: a) for legitimate reasons, to the processing of your Personal Data; b) to the processing of your Personal Data where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

If you have any questions about this Notice or if you want to enforce your privacy rights, please contact the Data Controller, at the following contact details: EUTELSAT S.A., Département Marketing Tooway, 70, Rue Balard, 75015 Paris, France.

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