Privacy policy for Tactilon Agnet 500

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Last Modified: July 26, 2022

We, Airbus DS SLC and our Affiliates* (hereinafter also referred to as “we”, “Airbus” or “SLC”), a business unit of Airbus, are committed to protecting the rights of individuals in line with the General Data Protection Regulation (reference EU2016/679) of the European Parliament and of the Council 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 (hereinafter referred to as ‘GDPR’) as well as applicable national Personal Data protection laws and regulations (collectively referred to as “Data Protection Laws and Regulations”) where Tactilon Agnet 500 is processed in accordance with the SaaS Agreement and orders placed with the legal person that granted you a license to use Tactilon Agnet 500 (hereinafter referred to as “Customer”) (hereinafter referred to as “Agreement”).

The Tactilon Agnet 500 application might include links to other websites or applications which are not necessarily covered by this privacy policy. In this event, we encourage you to carefully read the relevant privacy policies.

This privacy policy explains what Personal Data we collect and how we use them as Data Controller and how you can control the use and disclosure of your Personal Data in this context. This Privacy Policy is only applicable to Personal Data processed by Airbus as Data Controller. Airbus also process Personal Data on behalf of the Customer and only on documented instructions from the Customer. Is such cases, the Customer acting as Controller is responsible for providing information to you about which Personal Data will be processed and how and, if applicable, for obtaining your prior consent. For more information on the Personal Data that may be processed according to the Customer as Controller, please refer to the Privacy Statement at the end of the Privacy Policy.

By using Tactilon Agnet 500, you consent to the data processing described in this privacy policy.

1. What is Personal Data?

A “Personal Data” is any information relating to an identified natural person or 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.

2. What Personal Data do we collect?

We collect and/or access the following categories of Personal Data:

• Personal Data you provided for registration:
  • Identification data: first name, last name, telephone number, employer name, job title and function, email address;
• Personal Data you provide us while using Tactilon Agnet 500 services:
  • Communications with you: requests for support;
  • IT data: IP address, user account, logs activities.

These Personal Data may also be provided by the Customer, in order to inform us or confirm the Customer granted you a license in accordance with the Agreement.

3. What are the purposes of the processing of your Personal Data?

We may process your Personal Data for the following purposes (hereinafter referred as the “Purposes”):

• to help us better understand how our customers use our Tactilon Agnet 500 application;
• to improve our websites, applications, services, and customer experience, for research and analytical purposes dedicated to improving our products, services, businesses, operations and processes;
• to provide Tactilon Agnet 500 application to you, in accordance with the Agreement and this Privacy Policy;
• to provide Tactilon Agnet 500 technical support and maintain your account;
• to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us and to enforce our policies, directives and processes;
• to comply with applicable legal obligations, including responding to an authority or court order or discovery request;
• to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.

We will use your Personal Data for the above Purposes only, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you with the relevant privacy information notice.

4. What is the legal basis for processing of your Personal Data?

We process your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data are:

• To comply with contractual obligations

We will process your Personal Data in order to provide Agnet 500 application to you.

• As a result of your consent

When you have consented to the processing of your Personal Data by us for certain services, you can withdraw consent at any time by following the instructions provided in Section 8. “What are your rights and how to exercise them?”

• Within the scope of a legitimate interest

On occasion, taking into account the minimum privacy impact for you, the processing of your Personal Data might be necessary for the following legitimate interest:

• For the analysis and optimisation of the Tactilon Agnet 500 application.
• For ensuring IT security (to detect security threats, frauds or other malicious or criminal activities) and the IT operation of Airbus.
• For prevention and investigation of criminal acts.
• For monitoring the compliance with our policies and standards.
• For security purposes, in particular managing access to our premises.

• On the basis of Airbus’ legal obligations or in the public interest

Airbus DS SLC, as any other company, is subject to legal obligations and regulations. In some cases the processing of your Personal Data will be necessary for Airbus in other to fulfil these obligations.

5. Who will receive your Personal Data?

The following parties may receive your Personal Data:

• The Customer when acting as a Data Controller;
• Authorised persons working for or on behalf of Airbus DS SLC, including our agents, service providers and advisers providing the variety of products and services we need such as IT services, hosting services maintenance and support, procurement services, compliance and security services, etc.;
• Other authorised third parties in connection with a reorganisation, merge or sale of Airbus DS SLC businesses and/or assets;
• Law enforcement or any relevant authorities where necessary to comply with applicable law.

6. Will your Personal Data be transferred to a third country/region outside the European Economic Area (EEA)?

We process your Personal Data in the EEA, mostly in France and Finland.
On occasion Personal Data might be transferred outside of the EEA to recipient(s) (including Affiliates) as defined in the section “Who will receive your Personal Data?” that are subject to appropriate safeguards through the legal framework of our Binding Corporate Rules (“BCR”) for transfer to Airbus Affiliates that can be found on our website www.airbus.com or viewed here Airbus BCR's or – through standard contractual clauses or an adequacy decision.

7. For how long will your Personal Data be stored?

We process and store your Personal Data as long as it is required to meet our contractual and statutory obligations. If your Personal Data is no longer required for the performance of the contractual or statutory obligations, these will be erased on a regular basis unless further processing is necessary, for instance, for preserving particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal statutes of limitation.

8. Security

We use technical and organisational security measures in order to protect the data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons.

Our security procedures are continually enhanced as new technology becomes available.

9. What are your rights and how to exercise them?

You may at any time exercise your Personal Data protection rights as listed below by contacting us at the contact details mentioned in this section:

• Right to access/obtain a report detailing the information held about you: You have the right to obtain confirmation as to whether or not your Personal Data is being processed by Airbus and if so, what specific Personal Data is being processed.
• Right to correct Personal Data: You have the right to change any inaccurate Personal Data concerning you.
• Right to be forgotten: In some cases, for instance, when the Personal Data is no longer necessary in relation to the Purposes for which they were collected, you have the right for your Personal Data to be erased.
• Right to restrict the processing of your Personal Data: You have the right to restrict the processing of your Personal Data by Airbus, for instance when the processing is unlawful and you oppose the erasure of your Personal Data. In such cases, your Personal Data will only be processed with your consent or for the exercise or defence of legal claims.
• Right to data portability: Under some circumstances provided by law, you have the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format and/or transmit those Personal Data to another data controller.
• Right to object: In some cases defined in law, you may ask us to stop processing your Personal Data.
• Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent. However, please note that if you withdraw your consent, you may not be able to access and use certain information, features or services.

To this effect, please contact Airbus in writing either by e-mail at the following address: marketing@securelandcommunications.com or by writing to the address below:

Airbus Defence and Space Oy, Hiomotie 32, 00380 Helsinki, Finland, Attention: Privacy.

In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document.

Airbus Data Protection Officer is available, at the following email address: dataprotection@airbus.com and at the address below:

Airbus SAS, Head of Data Protection, 2 rond-point Emile Dewoitine 31700 Blagnac cedex. France.

10. How to ask for assistance to the competent authorities?

If you remain unsatisfied, then you have the right to apply directly to a Data Protection Supervisory Authority. Listed below are the four main countries where Airbus operates and the relevant Supervisory Authority.

FRANCE: CNIL: Supervisory Authority France

GERMANY: each federal state has its own Data Protection Authority that can be found under the following link:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

SPAIN: AEPD: Supervisory Authority Spain

UK: ICO: Supervisory Authority UK

11. Cookies

A cookie is a small text file placed on an internet user's hard drive. It is generated by a web page server, which is basically the computer that operates a website. The information the cookie contains is set by the server and it can be used by that server whenever the user visits the site.

We use session cookies, necessary for you to log in to the Tactilon Agnet 500 application and stay connected until you take action to log out from the Tactilon Agnet 500 application. These cookies are stored only for the duration of your session.

These cookies are strictly necessary for you to connect to Tactilon Agnet 500 application, do not require your consent and cannot be switched off in our systems. They are set in response to your logging in request. You can set your browser to block or alert you about these cookies, but you will not be able to access the Tactilon Agnet 500 application. These cookies do not store any personally identifiable information.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org  or www.allaboutcookies.org

12. Changes to this Privacy Policy amendments

Airbus will update this Privacy Notice from time to time in order to reflect the changes in our practices and services and also to remain compliant to Data Protection Laws and Regulations. When we do, we will revise the "last modified" date.

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* For sake of clarity, the term “Affiliate(s)” means for the purpose of this Privacy Notice, any legal entity where Airbus Defence and Space as parent company owns directly or indirectly 50% or more of the shares and/or voting rights and/or the right to appoint the majority of the Directors of the Board.

Last Modified: July 26, 2022

This Privacy Statement explains what Personal Data may be processed by Airbus DS SLC and our Affiliates* (hereinafter also referred to as “we”, “Airbus” or “SLC”) on behalf of the Customer.

Those Personal Data are processed only on Customer’s documented instructions, acting as Data Controller. Therefore, the Customer is responsible for providing information to you about which Personal Data will be processed, for which purpose(s) and how to exercise your rights, and, if applicable, for obtaining your prior consent.

1. What Personal Data may we process on behalf of the Customer?

While you use Tactilon Agnet 500 services, we will process the following categories of Personal Data to provide you with the service:
• Communication content (messages, attachments, operational status and audio/video calls) while you use Tactilon Agnet 500 services.
The communication content will not be consulted by Airbus as Processor.
If the corresponding optional feature is activated by the Customer and/or you, we will process the following categories of Personal Data:
• Location data from your smartphone GPS sensor;
• First name, last name and phone number of the persons in your smartphone’s contact list;
• Recorded content (messages, audio/video calls and activity logs) from your use of the Tactilon Agnet 500 service;
• Device angle and accelerometer sensor data from your smartphone’s sensors.
When the feature is optional, it is disabled by default. The Customer is responsible to inform you of the Personal Data processing activities purpose(s) and associated mandatory information when the activation of such features is required by the Customer. For most of the features, you can also find the activation status in the Tactilon Agnet 500 settings.

2. What are the purposes of the processing of your Personal Data?

The Customer is responsible to inform you of Airbus acting as Processor on behalf of the Customer only process the Personal Data on Customer’s documented instructions. Therefore, the Customer acting as Controller is responsible for providing information to you about the specific purposes of these processing.

3. Who will receive your Personal Data?

The following parties may receive your Personal Data:
- The Customer acting as Controller;
- We acting as Processor;
- You as user of the Tactilon Agnet 500 service;
- Other recipients defined by the Customer.
However, the Customer is responsible to inform you of the recipients who may receive your Personal Data.

4. Will your Personal Data be transferred to a third country/region outside the European Economic Area (EEA)?

The Customer is responsible to inform you of any transfer of your Personal Data to a third country/region outside the EEA.

5. What are your rights and how to exercise them?

You may at any time exercise your Personal Data protection rights as listed below by contacting the Customer at the contact details mentioned by him:
- Right to access/obtain a report detailing the information held about you;
- Right to correct Personal Data;
- Right to be forgotten;
- Right to restrict the processing of your Personal Data;
- Right to data portability;
- Right to object;
- Right to withdraw consent.

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*For sake of clarity, the term “Affiliate(s)” means for the purpose of this Privacy Policy, any legal entity where Airbus Defence and Space as parent company owns directly or indirectly 50% or more of the shares and/or voting rights and/or the right to appoint the majority of the Directors of the Board.