XDInnovation has always recognized the importance of privacy for its partners in the digital age. It is also aware of the responsibilities associated with the processing of personal data. This Privacy Policy discloses XDInnovation’s privacy practices with respect to the collection, use, retention or other processing of personal data in connection with its websites, mobile applications where this Privacy Policy is referenced, its social media pages (“Sites”) and the products and services provided by XDInnovation to its customers (“Services”). It explains the rights and choices individuals have regarding their personal data.

Please note that additional country-specific terms and conditions may apply, as noted at the end of this Policy.

This Policy applies to the processing of personal data by XDInnovation as a data controller, that is, as the person who determines the categories of personal data to be collected online or offline and the purposes for which it is collected.

This Policy does not apply to:

• Personal Data of XDInnovation employees and candidates,

• Personal Data that XDInnovation processes on behalf of its customers or other third parties as specified in the applicable contract.

This Policy provides information on:

• The types of personal data XDInnovation may collect about you (e.g., contact information);
• How personal data is collected;
• The purposes and legal basis for processing your personal data (e.g. to comply with the law, for marketing purposes with your consent);
• Your Rights and Choices Regarding Your Personal Data: Depending on your jurisdiction, you may have legal rights associated with XDInnovation’s processing of your personal data, including rights of access, correction, deletion, transfer or objection to the processing of your personal data. Regardless of where you live, XDInnovation will honor your request to decline to be contacted for marketing purposes;
• How to contact us.

For your convenience, hyperlinks may be published on the XDInnovation Sites that point to other websites or applications that XDInnovation does not own or control. This Policy does not apply to them and XDInnovation is not responsible for the content of third party websites. XDInnovation encourages you to read the privacy policies of other Web sites you visit and services you use.

Personal data is any information relating to an identified or identifiable natural person. A person is “identifiable” when he or she can be identified, directly or indirectly, in particular by reference to an identification number or to one or more elements that are specific to him or her.

In any event, XDInnovation’s processing of personal data is limited to that which is necessary for the purposes set out in this Policy.

For the purposes detailed below, XDInnovation processes the following personal data:

• Personal and professional contact information, such as first and last name, mailing address, e-mail address, telephone number(s) and position;
• Profile information such as user ID, login and password, profile picture, university, degree, certification and courses taken, type of organization (company, school, etc.), name, size, department, industry and industry sub-sectors;
• Transaction information: purchases made through the XDInnovation Site, event registrations and billing information (such as credit card information, bank account information), signature;
• Health-related data Health Information: If you attend an XDInnovation event, you may be asked for health information in order to identify and accommodate people with disabilities or special dietary needs, as well as other personal data needed to be processed throughout the event;
• Usage Information such as IP and Mac addresses, logs of how you use XDInnovation Services, including data from cookies as described below and through XDInnovation’s marketing preference center, if any.

This personal data may be collected by XDInnovation in the following ways:

• Directly to you through the Services or communicated in some other manner;
• Automatically;
• Through third parties, such as:
  • – Your employer, school or other organization to which you belong,
  • – Third parties that you have authorized to share your personal data with XDInnovation;
  • – Public databases.

The provision of personal data identified as mandatory is voluntary but is necessary to provide you with the XDInnovation Services.

Please note that the XDInnovation Services are not intended for children who are considered minors under applicable data protection laws. If you are a minor, you may not use the XDInnovation Services unless you have prior permission from your parent or guardian. If XDInnovation learns that it has collected personal information from a child, it will delete that information as soon as possible.

XDInnovation uses your personal data in accordance with the law. The legal bases and purposes for which XDInnovation processes your personal data are described below:

With your consent

• To communicate with you, including when you request information about XDInnovation Services, register on the XDInnovation Site, participate in surveys or allow XDInnovation to take specific actions (e.g., posting your testimonials or recommendations on the XDInnovation Site) and generally to manage XDInnovation’s communication and marketing activities;
• Identify your needs and interests and provide you with the most appropriate Services;
• To allow you to use the XDInnovation website interactively and to access all its features;
• Allow you to display certain personal information related to your profile when exchanging ideas and other information about the XDInnovation Services with other users of the XDInnovation site, including the 3DEXPERIENCEplatform.

Enter into an agreement to provide XDInnovation Services

• Allow you to: register for an event, seminar, webinar, enter a contest, including tracking and administering the events you have registered for and entered, and registering for XDInnovation community forums; create an account to access the XDInnovation Services and obtain a login such as the ” 3DEXPERIENCEID ” ;
• To enable XDInnovation to manage its business relationship with you, (in connection with business opportunities, business offers, purchases, contracts, orders, invoices, delivery, support services – including critical information for users of the XDInnovation Services – and security of the Services or XDInnovation professional services;
• Manage your training and/or certification on XDInnovation Services, which may include tracking your learning progress to make this information available to you;
• To operate, maintain, administer and improve the Services.

To meet the following legitimate interests

XDInnovation considers and assesses the potential impact (both positive and negative) of processing your personal data on your privacy, as well as the rights you have, before proceeding with such processing for purposes based on legitimate interest. Unless XDInnovation has obtained your consent or is otherwise required or permitted by law, XDInnovation will not use your personal data in situations where the impact of processing it on your privacy will be such that it overrides XDInnovation’s legitimate interest in processing your personal data to:

• To enhance your experience, better understand your needs and interests, and personalize your experience with the XDInnovation Services including remembering your settings;
• Allow XDInnovation to manage its marketing activities for similar products or services if you already use XDInnovation Services;
• To enable XDInnovation to manage its business relationships when you act on behalf of a prospect or customer of XDInnovation (in connection with business opportunities, sales offers, purchases, contracts, orders, invoices, delivery, support services – including information essential to users of XDInnovation Services – and security of the Services or XDInnovation professional services);
• Manage the 3DS Anti-Piracy and Compliance program;
• Create anonymous data for analysis;
• Protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activities as well as for security and prevention under the 3DS Cybersecurity Program.

XDInnovation may combine your personal data with other relevant publicly available information or personal data collected through other processing.

Comply with the law:

• Manage XDInnovation’s obligations with respect to compliance laws, including anti-bribery laws, applicable export laws, trade sanctions and embargoes issued by the European Union and its member states, the United States of America and other countries as applicable. This may include (i) automated checks of all user registration data as set forth in this Policy and other information you provide about your identity against sanctioned lists; (ii) regular checks whenever a sanctioned list is updated or when you update your information; (iii) blocking access to XDInnovation Services in the event of a potential match; and (iv) contact you to confirm your identity in the event of a potential match;
• Store your financial data with a third party payment provider;
• To comply with legal requests and procedures such as responding to subpoenas or requests from government authorities, as detailed below.

XDInnovation does not keep your personal information longer than necessary for the purposes described above. Retention periods may vary depending on the categories of data and processing. In determining the appropriate retention period for personal data, XDInnovation takes into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which XDInnovation processes your personal data and whether XDInnovation can achieve those purposes by other means, and applicable legal requirements:

• when you have given your consent, until you withdraw it;
• where XDInnovation has entered into a contract with you or your employer, based on the term of the contract plus any applicable local statute of limitations;
• where XDInnovation has a legitimate interest in using your personal data, for a limited period of time appropriate to ensure fair processing of your personal data or until you object to the use of your personal data, subject to XDInnovation’s compelling legitimate grounds for further processing that override your interest in objecting or for the establishment, exercise or defence of legal claims).
• Where XDInnovation is required to comply with a legal obligation, the retention period will be determined in accordance with applicable law;
• Where your personal data is necessary to establish its rights or to defend against legal claims, XDInnovation will retain your personal data until the end of the relevant retention period or until final resolution of the relevant claims.

At the end of the retention period, your personal data will be deleted or made anonymous using processes and methods that comply with data protection standards.

XDInnovation does not rent or sell information, but may share your personal data, which is necessary to fulfill certain business purposes, with the following categories of organizations:

• Within XDInnovation : As a global company, XDInnovation may share your personal information for purposes consistent with this Policy (e.g., to provide support services to you).
• With trusted XDInnovation partners
  • • – Event and Marketing Sponsors: XDInnovation may share your personal information with trusted sponsors with whom XDInnovation conducts events or marketing promotions. When you register for an event hosted by XDInnovation, XDInnovation may share your name, company contact information and email address with other participants and sponsors of the same event for communication and idea exchange.
    • – XDInnovation Business Partners: XDInnovation may share your personal data with XDInnovation business partners, such as resellers assigned to you, in order to provide you or your employer with appropriate offers or Services.
    • – Third parties acting on behalf of XDInnovation: XDInnovation may engage third party companies and individuals as necessary and disclose your personal data to them in connection with the services they perform for XDInnovation, to administer and provide the Services on behalf of XDInnovation (such as training, customer support, hosting, payment services to enable you to purchase XDInnovation Services, emailing and database management services). These third parties will use your personal data only as directed by XDInnovation and in a manner consistent with this Policy, and are prohibited from using or disclosing your personal data for any other purpose.

• To Third Parties to Comply with Applicable Laws : In certain circumstances, XDInnovation may, under applicable law, disclose some of your personal information to governmental authorities or law enforcement officials or private parties, (a) if XDInnovation has a good faith belief that such disclosure is reasonably necessary to comply with a judicial proceeding (e.g., a warrant, subpoena or other court order) (b) enforce the terms and conditions governing the XDInnovation Services, (c) protect the rights, property or safety of XDInnovation, XDInnovation’s customers or the public; and (d) protect, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activities. XDInnovation will review applications to ensure that they comply with applicable laws. If a request contains too much information, XDInnovation will try to reduce it and, if possible, object to the production of information.
• To third parties to serve or protect the legal and business interests of XDInnovation XDInnovation: XDInnovation may sell, transfer or otherwise share all or part of its business or assets, including your personal data, as part of a business arrangement (or potential business arrangement) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of a bankruptcy, change of control or liquidation of XDInnovation in whole or in part, in which case XDInnovation will use its best efforts to require the recipient to comply with this Privacy Policy.

When you access an XDInnovation Site, please note that by continuing to use it, if you are in a country other than the XDInnovation Site, you consent to the transfer of your personal data to a country other than your own where data protection laws may not be as protective as yours.

As part of its multinational organization, XDInnovation may transfer your personal data from one country or region to another country or region, including anywhere in Africa, Asia, Europe and the Americas. This may occur, for example, when XDInnovation provides you with Services such as training, customer support or hosting services.

Whenever XDInnovation transfers your personal data to countries that are not considered by your country’s authorities (e.g., the European Commission) to provide an adequate level of protection for personal data, the transfer will be based on safeguards recognized by your country’s authorities as providing adequate protection for personal data, such as the standard contractual clauses issued by the European Commission, your informed consent to the transfer, or other relevant mechanisms.

Please contact us if you would like more information about the mechanism XDInnovation uses to transfer your personal data.

Depending on the applicable data protection laws, you may have some or all of the following rights regarding your personal data:

• the right of access to your personal data;
• the right to obtain a copy of your personal data held by XDInnovation;
• the right to request that your personal data be corrected, completed, updated or deleted;
• the right to limitation of processing;
• the right to object to specific processing of your personal data if such processing is based on legitimate interests;
• the right to portability. and
• If the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time (e.g. a request to unsubscribe from marketing communications).

For any request to XDInnovation, please contact a member of the XDI team.

Depending on the size of the request, XDInnovation may charge the applicant a reasonable amount to cover the costs incurred in connection with such a request. XDInnovation reserves the right to deny you access to your personal data in the specific cases provided for by the applicable laws and regulations.

XDInnovation may ask you for specific information to confirm your identity or process your request. Applicable law may require or permit XDInnovation to deny your request, but in all cases, XDInnovation will provide you with an explanation of its position, subject to legal restrictions.

XDInnovation has taken appropriate technical and organizational safeguards to prevent the loss, misuse, unauthorized access or disclosure, alteration or destruction of your personal data while it is being transmitted to XDInnovation and once it is in its possession. However, despite XDInnovation’s efforts to protect your personal data, XDInnovation cannot guarantee the infallibility of this protection against data leakage due to the inevitable risks associated with the Internet.

It is important that you exercise caution to prevent unauthorized access to your personal data. You are responsible for maintaining the confidentiality of your password and account information. Therefore, you should be sure to log out when using a shared computer.

Cookies used by XDInnovation

In order to improve your experience on the XDInnovation Services, XDInnovation uses cookies or other similar technologies that may process your personal data.

XDInnovation uses different types of cookies depending on the Services involved:

• Strictly necessary cookies are always used; they are required for you to use the XDInnovation Services properly and cannot be disabled. For example, they allow you to save your personalization settings (choice of language, presentation of a service, saving your basket).
• Functional cookies are used to improve the performance of XDInnovation Services, to provide you with enhanced functionality and a more personal experience by collecting information when you use XDInnovation Services. Functional cookies also include analytics and performance cookies that are used to collect information about traffic to the XDInnovation Site and how users use the XDInnovation Services. The information collected may include the number of visitors to the XDInnovation Sites, the websites that referred you to the XDInnovation Sites, the pages you visited on the XDInnovation Site, the time of day and duration of your visit to the XDInnovation Site, whether you have visited the XDInnovation Site before, and other similar information. XDInnovation uses this information to improve the operation of the XDInnovation Site, to gather broad demographic information and to monitor the level of activity on the XDInnovation Site.
• Advertising cookies are used by XDInnovation or third parties to profile your interests and provide you with personalized, targeted content. They do not store personal data directly, but are based on the unique identifier of your browser and Internet equipment.

Disabling cookies

You may delete or reject functional and advertising cookies at any time via the cookie banner or by clicking on the “Manage my cookie preferences” link in the footer of the Site. However, if you do not agree to some of them, certain features and functionality of the Services may not function properly and you may experience some inconvenience in using them. For example, XDInnovation may not be able to recognize your computer or mobile device and you may have to log in each time you visit the XDInnovation Site. If you choose to delete advertising cookies, you will still see ads, but they may not be relevant to you.

XDInnovation is committed to protecting your personal information. You can contact XDInnovation, if :

• you have questions about this Policy;
• you encounter any difficulty in accessing your personal data or regarding your rights as set out above;
• you believe that XDInnovation is not in compliance with the GDPR or applicable local data protection laws;
• you have reason to believe that the security of your personal data has been compromised or that it has been misused.

If you wish to report a complaint by filing a complaint with the Group Data Protection Officer at XDInnovation, you should send a letter to the address listed at the end of this Policy or submit your complaint using the form referenced above indicating (in addition to the information required by the form and depending on the type of rights) the name or reference of the processing operation concerned and any additional information reasonably requested by the Group Data Protection Officer at XDInnovation.

If you normally reside in the European Union, Liechtenstein, Norway or Iceland, you have the right to file an application with your local data protection authority.

Where applicable, contacts for XDInnovation’s local data protection officers are available in the national or regional supplementary conditions below.

XDInnovation reserves the right to modify and update this Policy at any time in accordance with XDInnovation’s requirements and circumstances, or as required by applicable laws and regulations. XDInnovation encourages you to periodically visit this page to obtain the latest information on its data protection practices. In the event of material changes to this Policy, XDInnovation may notify you by e-mail or by any other means that XDInnovation reasonably believes will contact you. This may include posting a specific announcement on the XDInnovation Sites.

Any changes to this Policy will be effective upon XDInnovation’s posting of the new terms and/or implementation of the new changes in the Services.

Depending on where you live, certain additional conditions detailed below may apply to you. Where the Policy refers to “personal data”, it shall be interpreted, where appropriate, as “personal information” as defined by applicable data protection law.

XDInnovation Headquarters

41, Avenue des trois peuples
78180 Montigny-Le-Bretonneux
FRANCE

Last modified: November 28, 2022