INTRODUCTION

When you use the Wakastellar solution website (s) (and its products: Wakasign, Wakastart, Wakabooster) belonging to the JDS Conseil Group (hereinafter, “the Site (s)”), you are entrusting us with certain personal data. We attach great importance to the protection and security of our Users' data and we have written this Personal Data Protection Policy (hereinafter, “the Charter”) to inform you of our privacy practices.

This Policy was designed to provide you with the information you need to understand what Personal Data we collect, why we collect it, and how you can update, export, or delete it.

The Charter is intended to apply to users when they browse the Site, and is an integral part of the General Conditions of Use.

If you have any questions, do not hesitate to contact us directly at the email address: contact@jds-conseil.com

DEFINITION

The Definitions contained in the General Conditions of Use of this site are also applicable to this Personal Data Protection Charter.

Personal Data: Refers to any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). An “identifiable natural person” is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity, or to one or more elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity.

Sensitive Data: Sensitive Data is a particular category of Personal Data. This is information that reveals the alleged racial or ethnic origin, political opinions, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health, or data concerning the sexual life or sexual orientation of a natural person.

Data Controller: Means the natural or legal person, public authority, service or other body that, alone or jointly with others, determines the purposes and means of the processing; when the purposes and the means of this processing are determined by Union law or the law of a Member State, the Data Controller may be appointed or the specific criteria applicable to his appointment may be provided for by Union law or by the law of a Member State, the Data Controller may be appointed or the specific criteria applicable to his appointment may be provided for by Union law or by the law of a Member State, the Data Controller may be appointed or the specific criteria applicable to his appointment may be provided for by Union law or by the law of a Member State. a Member State

Site: Refers to the website (s) published by the JDS Conseil Group and owned by it.

Data processing: refers to any operation or set of operations carried out or not carried out using automated processes and applied to data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, adaptation or modification, extraction, consultation or modification, extraction, consultation, modification, modification, extraction, consultation, use, use, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, adaptation or modification, extraction, consultation, modification, extraction, consultation, modification, extraction, consultation, use, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, limitation, deletion or destruction.

User: Refers to any person visiting the Site (s) made available by the JDS Conseil Group.

--- Who is responsible for processing your data?

WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The JDS Conseil Group, a simplified joint stock company with a share capital of 440,760€, registered with the Nantes Trade and Companies Register under number 529 773 368 whose head office is at 17 rue de la Guillauderie, 44118 LA CHEVROLIÈRE, France, 44118 LA CHEVROLIÈRE, France, is Responsible for the processing of Personal Data collected in connection with the use of the Site in the European Economic Area and in the United Kingdom.

In this regard, please note that no transfer of your personal data is carried out outside the European Union. In general, your Personal Data is never disclosed to persons outside the JDS Conseil Group organization.

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WHAT DATA IS COLLECTED AND WHEN IS IT COLLECTED

As part of your browsing on the Site, the JDS Conseil Group may collect the following Personal Data:

- Information relating to the identity of the Site User

When you send a message via the contact form available on the Site, the information collected is the name, surname, name of the company for which the person works, their email, telephone number, and any information contained in the message accompanying their request.

We therefore collect Personal Data:

- When you or your organization requests information about services via the contact form on the Site.

- When you correspond with us in any way.

- In this context, we only process Personal Data that you provide to us directly.

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WHY IS YOUR PERSONAL DATA COLLECTED AND PROCESSED BY THE JDS CONSEIL GROUP?

We collect and use data to:

1. Manage user requests

We use the information collected to provide customer support, including to:

Send answers to Users' questions and inquiries;

Study and deal with problems that the User may encounter on the Site;

Monitor and improve the quality and processes of our customer support.

2. Carry out a marketing activity

The JDS Conseil Group may use the data collected to promote its services to Users, for example, to send them communications concerning the group's solutions, events, surveys, and news.

3. Communicate about our developments

The JDS Conseil Group may use the data collected to inform Users of changes made to the CGU and/or the Charter.

The JDS Conseil Group does not sell or share Users' Personal Data with third parties for direct marketing purposes, except with the express consent of the Users.

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HOW DO WE JUSTIFY THE PROCESSING OF DATA?

The legal basis for the processing of Data is the User's consent to the collection of data when completing the contact form.

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WHO DO WE DISCLOSE YOUR DATA TO?

As your data is strictly confidential, it is not subject to any communication to third parties.

Based on legal obligations, your Personal Data may be disclosed pursuant to a law, regulation or pursuant to a decision of a competent regulatory or judicial authority.

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RESPONSIBILITY FOR TREATMENT

The JDS Conseil Group undertakes to comply with the regulations in force applicable to the Processing of personal data and, in particular, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applicable from 25 May 2018 (hereinafter, “the Regulation”).

It is the responsibility of Users to check whether the Regulation is applicable to them and to take the necessary measures to comply with the legislation in force.

The JDS Conseil Group processes Personal Data, within the meaning of article 24 of the Regulation, in the capacity of data controller.

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HOW LONG IS YOUR DATA KEPT BY THE JDS CONSEIL GROUP?

The data collected will be kept by the JDS Conseil Group for a period of one year from the date of sending a request via the contact form on the Site.

Means for purging data are put in place in order to provide for its effective deletion as soon as the retention or archiving period necessary to achieve the determined or imposed purposes is reached.

In accordance with law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, you also have the right to delete your data that you can exercise at any time by contacting us at contact@jds-conseil.com.

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WHAT ARE YOUR RIGHTS?

You may have the following rights under applicable laws and exercise these rights in accordance with point 10 of the Charter:

Right of access (Art. 15 of the RGPD):

You have the right to request confirmation of the processing of your Personal Data on the one hand and, where appropriate, on the other hand, to request access to the Personal Data that we hold about you.

Right to rectification (Art. 16 of the RGPD):

You have the right to request the correction of Personal Data that is inaccurate.

Right to erasure (Art. 17 of the RGPD):

You have the right to request the deletion of Personal Data in certain circumstances, and in particular if you believe that your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw the consent on which our processing is based and where there is no other legal ground for the processing.

Right to restriction of processing (Art. 18 of the RGPD):

You have the right to ask us to limit the processing of your Personal Data in certain circumstances, in particular if you believe that the Data we process is incorrect.

Right to data portability (Art. 20 of the RGPD):

In certain circumstances, you have the right to receive the Personal Data that you have provided to us upon request, in a structured, commonly used and machine-readable format, and you have the right to transmit this information to another data controller without hindrance, or to ask us to do so.

Right to object (Art. 21 of the RGPD):

You have the right to object to the processing of your Personal Data in certain circumstances, in particular if we process it based on the legal basis of our legitimate interests or if we use it for marketing purposes.

For any questions concerning your rights and the security of Personal Data, you can contact our Personal Data referent at the following address: contact@jds-conseil.com.

You also have the right to file a complaint with a competent supervisory authority regarding the respect of your rights referred to above using the following contact details:

By post by writing to: CNIL — Complaints Department — 3 Place de Fontenoy — TSA 80715 — 75334 PARIS CEDEX 07

On the CNIL website: https://www.cnil.fr/fr

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WHAT ARE THE COOKIES USED BY THE SITE AND HOW CAN YOU OPPOSE THEIR USE?

Session cookies are essential for browsing our Platform and for the provision of services that you request from us. This cookie disappears once the browser is closed, so it cannot be inactivated.

Your web browser may provide you with options for using cookies. Please note that if you delete, or choose not to accept, cookies, you may not be able to fully use the features of the services offered through the Site.

In accordance with legal provisions, your consent to the collection of cookies is valid for 13 months.

We use cookies and automatically collected information to:

Personalize our Site and the services provided through it, for example by storing your Data so that you do not have to enter it again when you use, or the next time you use, our Platform and the services provided via it;

Control the statistics of visits to the Site, such as the total number of visitors and pages viewed;

Depending on your local version of the Site, by following: Cookie Settings you will find the specific settings to select if you do not want the site (s) to use all or any of the cookies mentioned above.

You can also deactivate the installation of “cookies” by configuring your browser in this sense.

To configure cookies, follow these instructions:

For Mozilla Firefox: Select the “Tools” menu, then “Options”. Click on the “Privacy” icon, locate the “Cookies” menu and then choose the options you want.

For Microsoft Internet Explorer 6.0 and later: Select the “Tools” menu, then “Internet Options.” Click on the “Privacy” tab and use the slider to select the level you want.

For Safari: From the Safari menu, select “Preferences,” then click “Security” and select the options you want.

For Google Chrome: select the Chrome menu, then choose “Settings” and click “show advanced settings.” In the “Privacy” section, choose “Site Settings”; then, in the “Cookies” section, select your options.

Please note that restricting cookies may impact your user experience and prevent you from using certain parts of our Platforms or services.

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HOW DO YOU SEND YOUR PRIVACY REQUESTS TO THE JDS CONSEIL GROUP?

To exercise your rights, please send your request as indicated below, specifying the following information: name, surname, email address and any other information required to confirm your identity so that we can process your request (e.g. your mailing address).

If you have questions or comments about this Privacy Policy or how the JDS Conseil Group collects and uses your Data, you can also contact:

By mail: JDS CONSEIL, 17 rue de la Guillauderie, 44118 LA CHEVROLIERE, France

By email: contact@jds-conseil.com

You can also contact our support and/or customer relations teams if you have other questions about this Charter.

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MODIFICATION OF THE PRIVACY POLICY

As changes may be made to this Charter without notice, we invite you to consult it regularly.