INFORMATION NOTICE RELATED TO PERSONAL DATA PROCESSING

Version 2 - 15/04/2021

… In a few words ...

I - About us

We are Manitou BF, SA, 430 rue de Aubinière 44150 Ancenis - France (RCS 857 802 508).

We are the parent company of production and distribution subsidiaries of our equipment and product lines, which are used in material handling and aerial work platform applications. Manitou BF and its subsidiaries also service the equipment and products lines worldwide.

We act as a data controller, meaning that we process personal data for the purposes we have identified through our business relations.

In this context, we offer a single contact e-mail address: privacy@manitou-group.com

II - What types of personal data do we use?

These are mainly the first and last name, telephone number, email address and identification data when you access our online services.

III - Why do we use your personal data?

We process your personal data relating to our business operations and activities to provide our products and associated services to you, within the context of our research activities, as well as within the framework of our obligations as a manufacturer or information provider.

IV - On which legal grounds do we rely?

We are authorised to process your personal data on the basis of:

V - What are your rights?

You have the right of access, rectification, erasure, restriction, objection and portability, where applicable.

You may also withdraw, at any time, the consent that you have provided.

An address to reference: privacy@manitou-group.com

VI - Are we sharing your personal data?

We may be required to share your personal data with the subsidiaries of Manitou BF (collectively with Manitou BF referred to as “Manitou Group” or the “Group”), with our own distribution network, and with partners to help us provide you with our best services.

VII - Are we transferring your personal data outside France? Outside the European Union?

Depending on the products and services we offer to you, we may be required to transfer your personal data outside of France and the European Union (e.g.: an order for equipment manufactured by our international subsidiaries).

We invite you to consult more specifically our complete information notice relating to personal data processing and cookies.

INFORMATION NOTICE RELATING TO PERSONAL DATA PROCESSING AND COOKIES

... For more information …

Manitou Group ensures compliance with privacy and ensures personal data privacy.

In a transparent manner, we want to provide you with the relevant information to understand the legal and legitimate processing of personal data that we perform.

The terms used here have the same definitions as those defined in the GDPR.

Manitou Group performs all processing operations (collection, consultation, use, transmission, …) in accordance with applicable legal requirements.

The following instructions will help you better understand our processing conditions, as well as the security measures we apply.

I - About us

We are the company Manitou BF, a corporation of limited liability under French Law, whose registered address is at 430 rue de l’Aubinière 44150 Ancenis - France. Tel. +33 2 40 09 10 11.

We are registered with the Trade and Companies Register of Nantes (France) under number 857 802 508.

We are the parent company of production and distribution subsidiaries of our equipment and product lines, which are used in material handling and aerial work platform applications. Manitou BF and its subsidiaries also service the equipment and product lines worldwide. We sell our products and services primarily through a network of independent dealers.

In terms of personal data, we act as a data controller, i.e. we process personal data for the purposes and reasons that we have identified through our commercial business activities.

II - What data are concerned?

Data may be qualified as personal - and thus be subject to compliance with the provisions of the GDPR and/or other applicable laws concerning Data Processing and Individual Liberties - when we are capable of, directly or indirectly, identifying an individual (usually designated by the term “subject”).

Some professional contact data (professional function, telephone number and email address) can thus be personal data if a subject is identified or is an identifiable person, as can an identification number, location data, or an online identifier.

To the extent that our customers are companies - legal entities not considered to be subject to the applicable laws - we collect very few personal datas.

In all cases, we do not collect, process or store personal data other than what is strictly necessary for the performance of our business.

III - Why do we use your personal data?

Manitou processes personal data within the framework of fulfilling its distribution or sales agreements (concessions or direct sale for renters and major accounts) and for service provision.

If these personal data are not processed by Manitou, we will not be able to perform our contractual and/or legal obligations, nor fulfil certain of our obligations in our capacity as a manufacturer.

Your personal data may have been obtained by an intermediary or a partner, or by the subsidiaries of Manitou Group.

Our primary data processing activities, which may include personal data, is defined below, particularly in terms of purpose, collection, legal basis, and storage period.

PURPOSE

Management of sales and service agreements with Manitou, particularly for the purposes of delivery, invoicing and customer relationship management.

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: Execution of the agreement and legitimate interest.

STORAGE PERIOD: the data will be kept throughout the term of the agreement.

PURPOSE

Consultation and use of our public websites (without authentication)

COLLECTION: Direct

BASIS: Execution of the agreement (General Terms and Conditions of Use).

We consider that it is in our legitimate interest to talk about our group and its strategy as well as to offer the maximum amount services possible to our direct and indirect customers.

As a Euronext Paris-listed company, we are also obligated to publish our annual report.

Other personal data may be collected if you make it freely available, e.g. within the framework of a request for contact. Manitou may use such data, based on the domain concerned, to respond to your requests, to improve its services, as well as for the purpose of the technical administration of websites.

STORAGE PERIOD: 3 years after the end of processing

PURPOSE

Consultation and Use of our website distribution network (with authentication) - management of your User profile

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: Execution of the agreement (General Terms and Conditions of Use). We consider it is in our legitimate business interests to offer a maximum amount of services to our direct and indirect customers.

Other personal data may be collected if you make it freely available, e.g. within the framework of a request or for profile creation. Manitou may use such data, based on the domain concerned, to respond to your requests, to improve its services, as well as for the purpose of the technical administration of websites.

STORAGE PERIOD: the data will be kept throughout the term of the agreement.

PURPOSE

Contact Form : you may contact our company via contact forms available on our websites

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: Your consent. Generally, we inform you as follows: “By submitting this form, I accept that the information entered will be used by MANITOU BF, the data controller, for the processing of my request. You may exercise your right of access, rectification, erasure, restriction, objection and portability, where applicable. To learn more, see Personal Data Information Notice.”

Internally, your personal data are processed, for example, by our purchasing department, external communications service, or by our sales or after-sales services.

You may withdraw your consent at any time by sending a request to privacy@manitou-group.com .

STORAGE PERIOD: We store your data for the duration necessary for your request, up to a maximum period of 3 years.

PURPOSE

Market Studies and Marketing: the sending of information or advertising, for deals and promotions, gifts and loyalty campaigns, satisfaction surveys, or any other action for marketing purposes, by mail, email, telephone, SMS, or by any other equivalent electronic means concerning Manitou Group’s products and services.

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: We consider it is in our legitimate interest to analyse the needs and uses of our direct and indirect customers to increase market share and to optimise our products and services.

This concerns the portfolio management of customers and prospective customers.

STORAGE PERIOD: We store your personal data indefinitely until you unsubscribe or until your cancellation request.

PURPOSE

After-Sales Services and Guarantees: we will provide an after–sales service for our equipment in order to ensure a follow-up of the mandatory support and maintenance. We offer a commercial warranty on our new equipment and make suggestions for warranty extensions.

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS Execution of the agreement (General Terms and Conditions of a Guarantee or extension).

Regulatory obligation as a manufacturer placing machines on the market.

Legitimate Interest (storage of evidence, model history,…)

STORAGE PERIOD: We store your personal data where we have not been notified of a transfer of ownership or scrappage.

PURPOSE

Sending newsletters

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: Your consent.

Generally, we inform you as follows: “By submitting this form, I wish to receive the newsletter and I thus accept that the information entered will be used by MANITOU BF for commercial purposes. You may exercise your right of access, rectification, erasure, restriction, objection and portability, where applicable. To learn more, see Personal Data Information Notice.”

You may withdraw your consent at any time through the proposed link at the bottom of the newsletter or by sending a request to:

privacy@manitou-group.com

STORAGE PERIOD: We store your personal data indefinitely until you withdraw your consent.

PURPOSE

Connected Services : We offer connected machines for sale, allowing in particular for the geolocation of the machines

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: The execution of the subscription agreement for this service and our legitimate business interests in improving the services and products.

STORAGE PERIOD: the data will be kept throughout the term of the agreement.

PURPOSE

Compliance with our legal and regulatory obligations as the manufacturer of products and equipment which are used in material handling and aerial work platform applications, and in our capacity as a licensor and seller. This includes processing associated with accounting standards and regulations and with tax obligations.

COLLECTION: Direct and indirect (through our dealers and subsidiaries).

BASIS: Legal and regulatory obligations. We believe it is also in our legitimate interest to keep certain data to act in accordance with good practices (reminder campaigns, warranty and maintenance history, ...).

STORAGE PERIOD: As required by applicable law and regulations.

We may need to use your personal data for purposes other than those referred to. In that case, we will notify you, and you will be able to exercise your rights in the matter (see “Art VII - what are your rights?”).

IV - Do we share your personal data? Are there other recipients of your personal data?

Manitou may be required to communicate certain personal data to its subsidiaries, distributors, service providers and partners, domiciled in France, or those within or outside the territory of the European Union.

If applicable, Manitou BF may be obliged to communicate certain personal data to the French or international authorities upon request (e.g. Administration, regulatory agencies, jurisdictions).

Finally, Manitou may provide personal data to contractually-linked partners if you have accepted this.

V - Do we transfer your personal data outside France? Outside the European Union?

The Manitou Data Centre is based in France.

For some services that we offer (including those accessible through the web), we use specialised partners (considered data processors) that may host the data outside of France and the European Union. For example, we use partners such as IT providers, social media providers, and marketing agencies.

VI - How long will your data be stored?

Personal data is stored for the duration necessary to the operations for which it was collected as required by the standards and authorisations of the CNIL [Commission nationale de l’informatique et des libertés (National Commission on Informatics and Liberty)] and for the duration of the statutory limitation period.

Regardless of the processing time required, we may be necessary to store data for periods during which our liability may be involved (i.e., evidentiary requirements). In this case, we will strive to ensure secure storage, especially as it concerns accessibility.

VII - What are your rights?

You have the right of access, rectification, erasure, restriction, objection and portability, where applicable.

You can also withdraw, at any time, the consent you would have provided, without this posing a threat to the lawfulness of processing based on your consent before your withdrawal.

An address to reference: privacy@manitou-group.com

In its capacity as data controller, and in order to ensure the security of your data (e.g.: to avoid a malicious request to delete your personal data without your knowledge), where applicable, we will be required to verify your identity when a request for the exercise of your rights is made (e.g.: the confirmation of certain data, a copy of your national identity card ...).

It is specified that, in certain cases, we will keep certain data only for carrying out our contractual, legal or defence obligations within the context of a complaint.

You may, especially if you believe that you have not obtained a satisfactory resolution in the course of the exercise of your rights, submit a claim to a supervisory authority (in France, CNIL at 3 Place of Fontenoy, 75007 Paris - www.cnil.fr).

VIII - What are the security measures put in place in order to protect the data?

Manitou implements proper technical and organisational resources in order to ensure a level of security appropriate to the risks, in accordance with current legislation in terms of data protection.

The IT system was designed according to the state of the art in IT and networks. We protect our facilities and our data based on the recommendations of the ISO 27000 standard.

The IT system has flow filtering technical equipment (firewall, proxy). The safety of the equipment is guaranteed by an antivirus device and the periodic installation of security patches provided by manufacturers.

Passwords are the first level of security. Internally, policy requires a regular password change and a specified level of complexity.

You should also be vigilant regarding the confidentiality of your authentication configuration (preserve your user IDs and passwords so that they are not disclosed to third parties).

IX - Cookies/Trackers

Manitou uses cookies for the operation of its websites.

Cookies are files that contain a certain amount of information (personal or not) and that allow browsing the website.

There are different types of cookies according to the purposes:

A banner is located on the various Manitou websites explaining the type of cookies used and allowing the internet user to object to their functioning and/or to configure their browser.

X/ Miscellaneous

This note is applicable only to processing for which Manitou BF is responsible.

Thus, on our sites, when there is a link to a third-party website, and you access it freely, this notice will not apply, especially if processing is carried out by another responsible party. It is the subject’s obligation to be vigilant with the disclosure of their personal data.

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