PRIVACY POLICY

PREAMBLE
These legal notices available on the site are intended to define the terms and conditions of use of
the Smart Global Privacy® site and to define the role and obligations of each.

I. PERSONAL Data

It is possible to visit the Smart Global Privacy® Site without you providing any personal Data about yourself. In any case, you are not obliged to transmit this Data to Smart Global Privacy®.

However, in case of refusal, you may not receive certain Data or services that you have requested. This
is why Smart Global Privacy® may need to ask you for your name, first name, e-mail address, telephone number, company and position (hereinafter your “Personal Data”). By providing this Data, you expressly agree
that it may be processed by Smart Global Privacy®, for the purposes indicated in point 2 below as well as for the purposes recalled at the end of each form.

In accordance with the General Data Protection Regulation adopted by the European Parliament on 14 April
2016, and with the Data Protection Act of 6 January 1978 as amended, Smart Global Privacy® informs you on the following points:

• 1. Identity of the controller

The data controller is Smart Global Privacy®, with its registered office at 1 rue du Gabian 98000 MONACO.
Telephone: +377 97.98.29.64

• 2. Purposes of the processing

Smart Global Privacy® may process your Personal Data:
(a) for the purposes of providing you with the Data or services you have requested (such as sending you
the Newsletter, commercial offer, your level of compliance, etc.); and/or
(b) for the purposes of collecting Data that may enable us to improve our Site, our products and
services (including through cookies); and/or
(c) for the purposes of contacting you about various events related to Smart Global Privacy®, including product updates and client assistance.

• 3. Recipients

Only Smart Global Privacy® is the recipient of your Personal Data. This Personal Data, whether in individual or aggregate form, is never transmitted to a third party, however Smart Global Privacy® uses subcontractors (you will find more Data about them in point 7 below). Neither Smart Global Privacy® nor any of its subcontractors market the personal data of visitors and Users of its Site.

• 4. Data Retention Period

Your Personal Data is kept by Smart Global Privacy® only for the time corresponding to the purpose of collection as indicated in 2 above, which may in any event not exceed 24 months.

• 5. Computer Rights and Freedoms

Concerning your Personal Data, you have the following rights, which you can exercise by writing to us at
the postal address mentioned in point 1 or by contacting us via our contact form.

o Right of access and communication of data

You have the possibility to have access to Personal Data concerning you.
However, due to Smart Global Privacy®’s obligation of security and confidentiality in the processing of personal data, you are informed that your request will be processed on condition that you provide proof of your
identity, e.g. not the production of a scan of your valid identity document (in case of a request by our
dedicated electronic form) or a signed photocopy of your valid identity document (in case of a written
request).
Smart Global Privacy® informs that it will be entitled, if necessary, to oppose manifestly abusive requests (by their number, their repetitive or systematic character).

o Right to rectify data

In this respect, legislation grants you the right to request the modification, updating, blocking or
deletion of data concerning you which may prove to be inaccurate, erroneous, incomplete or obsolete.
You can also define general and specific guidelines concerning the fate of personal data after your
death. If necessary, the heirs of a deceased person may demand that the death of their loved one be
taken into consideration and/or that the necessary updates be made.

o Right of opposition

The exercise of this right is only possible in one of the following two situations:

1. Where there are legitimate grounds for exercising this right; or
2. When the exercise of this right is intended to prevent the data collected from being used for
commercial prospecting purposes.

• 6. Response time

Smart Global Privacy® undertakes to respond to your request for access, rectification or opposition or any other additional request for Data within a period that should not exceed 1 month from the date of receipt of
your request.

• 7. Authorised service providers and transfer to a third country of the European Union

Smart Global Privacy® informs that it uses authorized service providers to facilitate the collection and
processing of the data you have communicated to us. These service providers could be located outside the
European Union and have data collected through the various forms on the Site (with the exception of the
form allowing you to exercise your rights to Data technology and freedom, which is offered and operated
by Smart Global Privacy®). Smart Global Privacy® has previously ensured that its service providers have implemented adequate guarantees and that strict conditions regarding confidentiality, use and data protection are respected. In particular, vigilance has been focused on the existence of a legal basis for any transfer of data to a third country.

• 8. Complaint to the competent authority

If you believe that Smart Global Privacy® is not fulfilling its obligations with respect to your Personal Data, you will be entitled to make a complaint or request to the appropriate authority.

II. COOKIE POLICY

When you first connect to the Smart Global Privacy® website, you are informed that Data relating to your browsing may be stored in files called “cookies”. Our cookie usage policy allows you to better understand the
provisions we implement in terms of navigation on our site. For example, it informs you about all
cookies present on our website, their purpose (part I.) and gives you the procedure to follow to set
them (part II.).

• 1. General Data about cookies on the Smart Global Privacy® website

Smart Global Privacy®, as the publisher of this website, may place a cookie on the hard disk of your device (computer, tablet, mobile etc.) to ensure smooth and optimal navigation.
Cookies” are small text files of limited size that allow us to recognize your computer, tablet or mobile
phone in order to personalize the services we offer.
The Data collected through cookies can in no way identify you by name. They are used solely for our own
needs to improve the interactivity and performance of our website and to offer you content tailored to
your interests. None of this Data is communicated to third parties except when Smart Global Privacy® has obtained your prior consent or when disclosure of this Data is required by law, by order of a court or any
administrative or judicial authority authorized to know it.
To help you better understand the Data that cookies identify, you will find below a table listing the
different types of cookies that may be used on the Smart Global Privacy® website, their name, purpose and storage period.

• 2. Configuring your cookie preferences

You can accept or reject cookies at any time.

When you first log on to the Smart Global Privacy® website, a banner will appear on your screen briefly displaying Data about the setting of cookies and similar technologies. This banner informs you that by continuing
your navigation on the Smart Global Privacy® website (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your device. You are also deemed to have
given your consent to the deposit of cookies by clicking on the “X” icon to the right of the banner
appearing on your screen.
Depending on the type of cookie you are using, it may be necessary to obtain your consent to set and
read cookies on your device.

a. Cookies that are exempt from consent

In accordance with the recommendations of the European Union’s regulatory authorities, certain cookies
are exempt from obtaining your prior consent; they are strictly necessary for the operation of the
website or have the ultimate objective of enabling or facilitating communication by electronic means.
These include session ID, authentication, load balancing session cookies and cookies to customize your
interface. These cookies are entirely subject to this policy insofar as they are issued and managed by
Smart Global Privacy®.

b. Cookies that require your prior consent

This requirement applies to cookies that are issued by third parties and that are referred to as
“persistent” if they remain on your device until they are deleted or expire.

As such cookies are issued by third parties, their use and storage are subject to their own privacy
policies which you will find a link to below. This family of cookies includes audience measurement
cookies (notably Google Analytics), advertising cookies (which Smart Global Privacy® does not use) and social network sharing cookies (notably from YouTube, Twitter and LinkedIn).

Audience measurement cookies collect statistics about the use of various elements of the website (such
as the contents/pages you have visited). This data contributes to improving the ergonomics of the Smart
Global Privacy® website. An audience measurement tool is used on this website:

Social network sharing cookies are issued and managed by the publisher of the social network concerned.
Subject to your consent, these cookies allow you to easily share part of the content published on the
Smart Global Privacy® site, in particular via a “button” application sharing according to the social network
concerned. Four types of social network sharing cookies are available on the Smart Global Privacy®

o Facebook site, whose cookie policy can be viewed by clicking on the following link:
https://fr-fr.facebook.com/policies/cookies/

o LinkedIn, whose cookie policy can be found by clicking on the following link:
https://www.linkedin.com/legal/cookie-policy?_l=en_FR

o Twitter, whose options for controlling or restricting the use of cookies as well as the cookie usage
policy can be found at: https://support.twitter.com/articles/20170518#

o YouTube, whose help on deleting cookies from the Google Chrome browser can be found by clicking on :
https://support.google.com/youtube/answer/32050?hl=fr but also the complete policy in respect to cookies
at following link : https://www.google.fr/intl/fr/policies/technologies/cookies/

c. You have various tools for setting cookies

Most Internet browsers are configured by default so that cookies can be stored. Your browser offers you
the possibility to modify these standard settings so that all cookies are systematically rejected or
only part of the cookies are accepted or rejected depending on their issuer.

ATTENTION: We draw your attention to the fact that refusing to accept cookies on your device could
nevertheless alter your user experience and your access to certain services or features of this website.
Smart Global Privacy® declines all responsibility for any consequences related to the deterioration of your browsing conditions that may arise as a result of your choice to refuse, delete or block cookies
necessary for the operation of the site. These consequences could not constitute a damage and you will
not be able to claim any compensation for this fact.

Your browser also allows you to delete existing cookies on your device or to notify you when new cookies
might be placed on your device. These settings have no impact on your browsing but make you lose all the
benefit provided by the cookie.

Please take note below of the many tools that are available to you so that you can set cookies placed on
your device.

d. Your Internet browser settings

Each Internet browser has its own cookie management settings. To find out how to modify your cookie
preferences, please find below the links to the help you need to access the menu of your browser
provided for this purpose:

Chrome : https://support.google.com/chrome/answer/95647?hl=en

Firefox : https://support.mozilla.org/fr/kb/activer-desactiver-cookies

Internet Explorer :
https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

Opera : http://help.opera.com/Windows/10.20/fr/cookies.html

Safari : https://support.apple.com/kb/PH21411?viewlocale=en_EN&locale=en_ENG

For additional Data on cookie control tools, you can consult the CNIL website at:
https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

e. The setup of the tooL tarteaucitron

The cookies can also be deactivated directly via the tarteaucitron tool set up on the Smart Global Privacy® site.
Interactive, it allows you to manage your cookies via a banner available at the bottom right of the page
viewed (“Service Management” button) and lists all active cookies. To deactivate a cookie, simply click
on the cross next to the service offered. If all cookies are disabled, the banner dedicated to
collecting user consent will reappear when the page is refreshed.

If you have any questions or require additional Data regarding this cookie policy, please contact us
using our contact form.

III. LEGAL CONDITIONS AND DATA

Smart Global Privacy® hereinafter referred to as “the Site” is published by SMART GLOBAL PRIVACY SARL, a limited liability company, with a capital of 15,000 euros, registered under number 17S07390 in the Répertoire du Commerce et de l’Industrie since 30 April 2014 and under number 17S07390 in the Répertoire du NIS. Smart Global Privacy® has made a simplified declaration to the Commission de Contr^le des Datas Normatives (CCIN) concerning the processing of personal data under the numbers n°2017.05065 and n°2017.05093.

Smart Global Privacy® has a license to practice from the Princely Government issued by the Minister of State on 22 February 2017.

The registered office is located 1 rue du Gabian 98000 MONACO – Principality of Monaco
Email address: communication@smart-gdpr.eu

The Editing director is Mr Guignard.

OBLIGATIONS

Any user of the Smart Global Privacy® site expressly undertakes: not to use the Smart Global Privacy® site to disseminate and promote computer viruses, Trojan horses or any other program of the same nature, to violate computer systems or to disrupt the proper general operation of sites;

to assume alone any direct or indirect material or bodily damage caused and to make his own any dispute
that may arise;

to release Smart Global Privacy® from any liability in this regard.

PERSONAL DATA

he personal data collected and processed by Smart Global Privacy® are those that the USER OF THE Smart Global Privacy®
SERVICE voluntarily transmits, in particular via registration or contact forms.

The USER OF THE Smart Global Privacy® SERVICE undertakes to provide accurate and up-to-date Data and to inform Smart Global Privacy® without delay of any change to this Data by sending an e-mail to contact@smart-gdpr.eu, to make any corresponding changes to his personal space without delay.

The personal files have been the subject of a simplified declaration to the CCIN n°2017.05065 and
n°2017.05093 in accordance with the law relating to data processing, files and freedoms.

In accordance with the aforementioned law, Internet users who have completed an online registration form
have a right to Data, opposition, access and rectification of data concerning them. His right is
exercised by sending a letter by simple mail to the address of the registered office indicated at the
head of the present, and by indicating his name, first name, date and place of birth, postal and
electronic address.

MODIFICATION OF THE GENERAL TERMS OF USE OF THE PLATFORM

Smart Global Privacy® reserves the right to modify these legal notices. In view of possible extensions and improvements to the operation of the site, Smart Global Privacy® reserves the right to unilaterally modify these legal notices at any time, without notice.

In particular, it is up to the visitor to consult and accept the legal mentions of the site at the time
when he visits or contributes to it. Each use of the site constitutes acceptance of the latest version
of this site’s legal notice.

In the event of significant changes to these legal notices, the new legal notices will come into force
the following day after their publication on the Smart Global Privacy® website.

INTELLECTUAL PROPERTY

The content of the site may not be modified, copied, distributed, framed or reproduced without the
consent of Smart Global Privacy®.

Smart Global Privacy® is a registered trademark of Smart Global Privacy SARL.
Copyright © 2017-2087 Smart Global Privacy®
USPTO Patent pending n°62592565

APPLICABLE LAW AND COMPETENT JURIDICTIONS
It is expressly stipulated that the legal notices are governed by Monegasque law. Any dispute arising in
connection with the execution of this contract shall be submitted to the competent courts of Monaco.