PRIVACY POLICY

FOR WWW.LEBRONZE-ALLOYS-NA.COM

(Last updated January 2024)

This Privacy Policy applies to all personal data processing performed

by LEBRONZE ALLOYS NORTH AMERICA, LLC. and LEBRONZE ALLOYS (France) (together hereinafter referred to as the “Data Controller(s)”),

in accordance with (i) the Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), (ii) the French Law n°78-17 of 6^th January 1978 on Data Protection and Freedom of Information, known as the Data Protection Act (as amended by Law n°2018-493 of 20th June 2018 on personal data protection), (iii) the (UK) Data Protection Act 2018, and by any subsequent laws, (iv) all applicable (US) federal, state, and local laws and regulations, including without limitation, the Communications Decency Act (47 U.S.C. § 223, et. seq.) and the Digital Millennium Copyright Act (17 U.S.C. § 101, et. seq.), and by any subsequent acts.

subject to the following terms and conditions:

1. Data processing

1.1 Data Controller

The joint Data Controllers are:

LEBRONZE ALLOYS NORTH AMERICA, LLC., a limited liability company, incorporated according to the Laws of the State of Delaware (USA), registered in the Division of Corporations under number 2666689, whose head office is located at 251 Little Falls Drive, Wilmington, DE19808 (USA) (hereinafter referred to as “LEBRONZE ALLOYS N.A.”),

And its holding company:

LEBRONZE ALLOYS (France), a simplified joint-stock company, incorporated according to the Laws of France, with a share capital of 12 494 622,20 EUR, registered in the Division of Corporations under number 572 196 129, whose head office is located at Voie de Châlons, Route départementale 977, 51600 Suippes (France),

—

The contact details for the Data Controller are:

Postal address: LEBRONZE ALLOYS NORTH AMERICA, 65 Ballou Blvd, Bristol, RI 02809 (USA),

E-mail address: rgpd@lebronze-alloys.com

1.2 Data processing purposes

“General” / “Sales” contact form: Data are processed in order to respond to requests for information, orders for manufactured goods sold by LEBRONZE ALLOYS N.A., and offers for sales of products to LEBRONZE ALLOYS N.A.

“Brochure” contact form: Data are processed in order to respond to requests for brochures about the products and/or activities of LEBRONZE ALLOYS Group.

Direct marketing: Data are processed in order to send newsletters and targeted information about new products, trade fairs etc. likely to be of interest to the data subject.

1.3 Legal basis for the processing

The legal basis for the data processing is the consent of the data subject.

2. Processed data

2.1 Categories of data

“General” / “Sales” contact form:

• Title (Mrs. / Mr.)
• Surname,
• First name,
• Company,
• Telephone number,
• E-mail,
• Country,
• Purpose,
• Material,
• Message,

“Brochure” contact form:

• Title (Mrs. / Mr.)
• Surname,
• First name,
• Company,
• Position,
• Telephone number,
• E-mail,
• Country,

Direct marketing:

• Surname,
• First name,
• Company,
• Position,
• Telephone number,
• E-mail,
• Country,
• Sector of activity,

2.2 Data source

All data are collected directly from the data subject.

2.3 Mandatory data collection

All data are mandatory, unless stated otherwise. Mandatory data are marked with an asterisk and/or comment.

“General” / “Sales” and “Brochure” contact forms: No response will be given to requests for information or brochures or to job applications unless the data are supplied. If no data are supplied, the data subject will not receive a response.

Direct marketing: No marketing will be sent unless the data are supplied. If no data are supplied, the data subject will not receive marketing.

2.4 Automated decision-making

The data processing will not involve any automated decision-making.

3. Data subjects

“General” / “Sales” and “Brochure” contact forms: The data subjects are persons who request information or brochures via the contact forms available on the website https://lebronze-alloys-na.com/.

Direct marketing: The data subjects are persons who consent to receive marketing via the website https://lebronze-alloys-na.com/ by ticking the relevant box in the contact form mentioned above.

4. Data recipients

4.1 Categories of recipients

“General” / “Sales” contact forms: All or some of the data may be sent to employees of the Data Controller, in particular those working for its Sales and Marketing Departments, depending on their needs.

Direct marketing: All or some of the data may be sent to employees of the Data Controller, in particular those working for its Sales and Marketing Departments, depending on their needs.

4.2 Transfers of data outside the United States

“General” / “Sales” contact forms: Data may be transferred outside the United States, to subsidiaries of the LEBRONZE ALLOYS Group only.

Direct marketing: Data may be transferred outside the United States, to subsidiaries of the LEBRONZE ALLOYS Group only.

5. Data storage duration

“General” / “Sales” and “Brochure” contact forms: Data will be stored for three (3) years from the date of last contact with LEBRONZE ALLOYS Group or until the data subject withdraws their consent (by sending an e-mail to the contact details in Point 6.2), subject to any subsequent actions taken (e.g. contract signed, order placed, etc.).

Direct marketing: Data will be stored for three (3) years from the date of last contact with LEBRONZE ALLOYS Group or until the data subject withdraws their consent (by sending an e-mail to the contact details in Point 6.2 or clicking the “unsubscribe” link in the mail-out).

6. Cookies

6.1 Definition of a computer cookie

A cookie is a small file stored by a server on the hard disk of the user’s terminal (computer, smartphone, tablet, etc.) and associated with a website domain.

6.2 Function of a computer cookie

Cookies serve multiple purposes, such as:

• Keep the choice expressed by the users on the deposit of cookies;
• Authenticate a user to a service;
• Remember the contents of a shopping cart on a merchant website;
• Customize the user interface (e.g., language selection);
• Measure the audience of a website;
• Display personalized or non-personalized advertising;
• Share on social networks;
• Etc.

Cookies require the prior consent of the user, unless they are strictly necessary for the provision of an online communication service expressly requested by the user or have the sole purpose of enabling or facilitating communication by electronic means.

6.3 Computer cookies used by LEBRONZE ALLOYS on the Website

LEBRONZE ALLOYS Group uses cookies on its Website https://lebronze-alloys-na.com/, as follows: