BPE reserves the right to modify this Privacy Policy as needed, for example to comply with evolutions in laws, regulations, BPE practices and procedures, or requests by supervisory authorities. In this case, BPE will inform impacted individuals of material changes in this Privacy Policy. BPE will post new versions on relevant internal and external websites and digital platforms. The main changes and reasons for changes between the current version of this Privacy Policy and the previous version of 25 May 2018 are the following:
- Specifying in our Cookie Notice examples of cookies and similar technologies we use.

Why this Privacy Policy?

BPE is committed to protecting your privacy and personal information. This Privacy Policy informs you of our privacy practices and of how personal information is protected. You should read it before accessing BPE digital content. BPE strongly supports the fundamental rights to privacy and data protection as well as compliance with national and international privacy laws.

This Privacy Policy describes how BPE processes and protects personal information of individuals who use our websites and other digital platforms as well as in the context of our offline business activities. BPE has adopted an internal Global Data Privacy Policy which is applicable to all our subsidiaries for the collection, processing, use, dissemination, transfer and storage of personal information. It imposes common rules for all of our subsidiaries of all countries, and aims at ensuring a high level of protection of personal information within BPE.

BPE has also established this Privacy Policy as an external publication of our Binding Corporate Rules (“BCR”), approved by data protection supervisory authorities of the European Union in November 2012 for the processing of personal information from the EEA as a data controller. In the BPE’s Binding Corporate Rules, we respect and take into account the major principles of EU data protection rules as one of our Head Offices is located in the European Union.

What is the scope of this Privacy Policy? Who is in charge of data processing?

This Privacy Policy applies to all BPE subsidiaries and digital content, unless a specific privacy notice has been released to supplement it or to replace it. You should check the privacy notices made available to you on each digital platform such as websites or applications.

BPE is a global company, with legal entities, business processes, management organizations, and system infrastructure that cross borders. This Privacy Policy applies to all BPE data processing activities run by our controlled subsidiaries, including product and service offerings and digital content (e.g. event registrations, websites, applications, tutorials, e-trainings, newsletters, advertising, and other communication). It may however be supplemented by a more specific privacy notice/statement/policy or even superseded by another policy, specific to a particular BPE program, product, service, content or entity. It is important that you read the statements made available to you for your full information. For instance, the processing of job candidate applications is governed by the privacy notice posted on our Career Portal.

The data controllers of the data processing activities are the BPE subsidiaries who have determined the data processing means and purposes. They may vary on a case-by-case basis. In many instances, BPE Industries SAS, 35 rue Joseph Monier 92500 Rueil-Malmaison - France, BPE’s Head Office, is the data controller of global data processing activities. For information you can contact us at Bpee.com
This Privacy Policy binds all BPE controlled subsidiaries, and their employees.
Any order made by you online is also subject to the terms and conditions provided on the relevant sites. You must read them.

Why do we collect and use personal information?

We use personal information for various purposes, including to fulfill orders and requests, to manage customer and prospect relationships, conduct surveys, improve our products, services, digital content as well as user journeys, manage user accounts and programs, analyze activities on our digital platforms, run marketing activities, provide user with contextual and relevant information, ensure the security of our activities, protect against fraud, and, more generally, run our business activities.

BPE collects personal information for the following purposes:

• - To fulfill orders of product, services and digital content. We collect this information to deliver your order, to obtain payment, to provide the functionalities of our applications, to communicate with you about the status of your order and for contract management purposes;
• - To better address future requests for information and support. We keep record of exchanges including personal information to provide an optimized service on contacting us for support;
• - For relationship management purposes which includes communicating about the products, services and digital content including email communications and messaging;
• - To conduct surveys and polls. We may collect personal information to complete surveys and contact you for follow-up. We use this information to measure satisfaction, get to know our customers better and improve products, services and digital content;
• - To improve our products, services and digital content; for instance, we analyze the use of our applications and websites in order to identify areas and functionalities where users have difficulties, and we improve them;
• - To learn about your browsing and searching activity. We collect navigation information when you visit our digital content or click on links for products and services. We collect this information to improve user experience for next visits (e.g., country selection or profile-focused content), help our websites run more efficiently, to gather broad demographic information to analyze the websites’ activity and performance, and to evaluate the relevance and effectiveness of our advertising to better serve our customers. We may use cookies and other identifiers or similar technologies (referred to hereinafter as "Cookies") to obtain information on the referring website, type of browser used, the content viewed, as well as the date and time of access to the digital content. You may read our Cookie Notice for more information on our use of Cookies and your options for managing Cookies;
• - To manage user digital accounts. We collect personal information at registration on our digital platforms (e.g. partner portal, ordering platform, mobile apps) to authenticate you, manage credentials to enable you to navigate through several digital platforms without having to re-authenticate (cf. single sign-on) and to interact with you;
• - To run promotional programs and activities: we collect personal information when you join a promotional or reward program or activity. We use this information to administer the program or activity, to send relevant e-mails about the program and activity, notify winners, and make the winners' list publicly available in accordance with applicable regulations and laws;
• - To send you marketing information by mail, fax, phone, text messages, email and electronic communications about promotions, news and new products or services that we think may be of interest to you in compliance with applicable opt-in and opt-out requirements. This can be conducted by BPE, its subsidiaries or selected third-parties acting on our behalf;
• - To provide you with certain communications and/or targeted information about our products and services (or of our subsidiaries) through pop-ups, banners, videos, emails and any other advertising format. For instance, we may provide you with contextual advertising or other content, based on browsing information. We may also use location data to inform you about local promotions and activities. Please read our Cookie Notice for more information on the use of Cookies and your options for managing them;
• - To combine information obtained online from different digital platforms and the information we collected about you offline to create a profile of you that we may use for giving you personalized services. For example, a user that we believe is an electrician (due notably to information provided at the time of registration and other information obtained from third-party sources), may see profile related advertising and/or on third-party websites and apps that a user with another energy-related specialty would not see. Similarly, users may see different content or receive different emails containing different advertisements or surveys. We may also use Cookies to geographically target users.
• - To ensure the security of our products, services and digital content, of our activities and of others, for the protection against fraud and the compliance with our terms and conditions and this Privacy Policy. We may also investigate potential breaches;
• - To enable or administer our business, such as for quality control and consolidated reporting;
• - To support corporate transactions or reorganizations in which BPE is involved;
• - For business continuity and disaster recovery;
• - To comply with legal obligations to which we are subject. For example, accounting and tax obligations;
• - Any other purpose otherwise conveyed to you.

What type of personal information do we process?

BPE processes various types of personal information including identity and contact related information, professional related information, information about preferences, interactions with us, financial related information, online traffic data and the content you provide to us. In most instances this information is obtained from customers, partners and users. We also purchase lists from marketing agencies and obtain information from our partners, through Cookies and social networks.

Personal information (also called personal data) is any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

The types of personal information we process about you may include:

• - Identity and contact related information, such as name, company, email address, phone number, photo, age range, contact addresses;
• - Professional information, such as customer type, purchasing authority, purchasing timeframe; acquisition and use of BPE products, services and digital content;
• - Information (e.g. energy consumption) which is specific to the digital platform you use
• - Your preferences such as product and service preferences, contact preferences, marketing preferences;
• - Your interactions with us such as queries, orders, claims, survey answers;
• - Financial-related information such as bank account details, credit card information;
• - Online traffic data such as IP address, device and system identifiers, your BPE user ID and password, referring website, type of browser used, consulted content, and location, based either on your IP address or on information transmitted by your mobile device;
• - Content that you have provided via online forums or otherwise (see section 6 “Your content” below).

This Privacy Policy does not cover personal information rendered anonymous, that is if individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or labor. If anonymized data becomes identifiable, then this Privacy Policy shall apply.

In most instances we collect personal information directly from users who have a business relationship with us. We may also obtain information through a reseller or a business partner, by purchasing customer lists from marketing agencies, from your online browsing experience, from social networks when you connect with these network’s credentials and through Cookies. You may obtain more precise information on the third-party source (if any) of personal information by contacting us at the email address indicated in section 10.

Your content

You may choose to contribute content, including photos or comments, to online forums, applications or other digital platforms operated by BPE. Your content must be harmless. It must respect the law, the rights and interests of others. You need to have obtained consent before sharing someone else’s data. You should apply caution before sharing information in a forum.

Any provision of personal information to BPE about another individual must be compliant with privacy laws, including with notice and consent requirements for the disclosure of that information.

While BPE strives to protect your personal information, providing it online on shared forums is not risk-free. If you post, comment, indicate interest, or share personal information, including photographs, to any forum, social network or blog, please be aware that any personal information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor BPE have control over. BPE is not responsible for the personal information you choose to submit in these forums. You should apply caution before deciding to share information about yourself or another person.

Who do we share personal information with?

We share personal information with the BPE subsidiaries and the service providers involved in our activities, with advertising and marketing agencies, with social networks if you use their login credentials, with third-party websites if you register with BPE credentials, competent regulatory bodies and authorities and business successors.

BPE is a global group of companies which works as one. To provide the best service to customers, prospects and users, personal data may be shared amongst personnel working for different entities. It may be the case, for example, for customer relationship management, sales or product support, marketing, product development purposes, improvement of the products, services and digital content, data quality checks, or security, finance, regulatory and compliance purposes.

We resort to service providers to carry out data processing activities and to provide our products, services and online content to you. These service providers include, without limitation, providers of hosting facilities, information systems, advertising and marketing agencies, IT support, security services, financial services, carriers who deliver products, outside accounting firms, lawyers and auditors.

We ensure all service providers working under contract for BPE are compliant with data privacy laws and aligned with BPE guidelines.

We also share the information as follows:

• - In connection with the provision of advertising, we may share some limited personal information (e.g. device identifiers, Cookie identifiers) with ad exchanges or agencies that manage advertising on third-party websites and apps on which you may see advertising.
• - You may access our digital content and/or register through login credentials of third-party websites (such as Facebook and LinkedIn). If you do so, we will be able to access some of the information you registered on these social networks, to assist you to pre-fill the registration form for BPE digital content. By using the login credentials of these third-party websites, you may at the same time inform your contacts on these sites that you have created an account with BPE. If you want to know more about the information accessible by your contacts on these sites and how to restrict their communication, we encourage you to read their terms of use and privacy policies.
• - BPE may disclose your personal information as necessary to potential buyers and successors in title, to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which BPE participates.
• - Where required by law or court orders or to protect our legal rights, we will disclose your personal information to government agencies, regulators and competent authorities.
• - In other ways described in this Privacy Policy or to which you have otherwise consented.
• - Aggregated with other information, in such a way that your identity cannot reasonably be determined (for example, statistical compilations).

We will not sell or rent your personal information to a third party without your permission.

How do we protect personal information?

BPE complies with widely recognized key data protection principles (fairness, purpose limitation, data quality, data retention, compliance with individuals’ rights, security) and takes reasonable measures for the security of personal information.

BPE respects the privacy rights and interests of individuals. BPE and its subsidiaries observe the following principles when processing personal information:

• 1. Processing personal information fairly and lawfully;
• 2. Collecting personal information for specified, legitimate purposes and not processing it further in ways incompatible with those purposes;
• 3. Collecting personal information which is relevant to and not excessive for the purposes for which it is collected and used. We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
• 4. Maintaining accurate personal information, and where necessary, kept up-to-date. We will take reasonable steps to rectify or delete information that is inaccurate or incomplete;
• 5. Keeping personal information only as long as it is necessary for the purposes for which it was collected and processed;
• 6. Processing personal information in accordance with individuals’ legal rights;
• 7. Taking appropriate technical, physical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal information;
• 8. When processing sensitive personal information, ensuring appropriate notice and consent or that the processing otherwise complies with applicable law;

BPE and all its subsidiaries must ensure that the above principles are complied with.

BPE and its subsidiaries are committed to taking commercially reasonable technical, physical, and organizational measures to protect personal information against unauthorized access, unlawful processing, accidental loss or damage, and unauthorized destruction. We offer the use of secure servers to enable you to place orders or to access your account information. We implement access control measures for our internal systems that hold personal information. Authorized users are given access to such systems through the use of a unique identifier and password. Access to personal information is provided to our staff for the sole purpose of performing their job duties. We sensitize our employees on proper use and handling of personal information. We also require our service providers to maintain compliant security measures. We implement security measures to determine the identity of registered users, so that appropriate rights and restrictions can be enforced for these users. In case of a registered user, we use both log ins and passwords for authentication. You are responsible for maintaining the security of your log-in credentials.

By using our digital content or providing personal information to us, you agree that we may communicate with you electronically or otherwise about related security, privacy, use and administrative activities. In spite of our efforts to implement appropriate security measures, online browsing carries inherent risks and we cannot guarantee that it is risk-free.

Third-party websites and social media

You should read the privacy policy of third-party websites and social media and adjust privacy settings as you see fit. Non-BPE websites and platforms are not covered by this Privacy Policy.

BPE digital platforms may provide links to third-party applications, products, services, or websites for the user convenience and information. If you access those links, you will leave the BPE digital platform. BPE does not control those third-party sites or their privacy practices, which may differ from BPE’s practices. We do not endorse or make any representations about third-party sites. The personal information you choose to provide or that is collected by, these third parties are not covered by the BPE Privacy Policy. We encourage you to review the privacy policy of any site you interact with, before allowing the collection and use of your personal information.

We also provide social media links that enable you to share information with your social networks and to interact with BPE on various social media sites. The use of these links may result in the collection or sharing of information about you. We encourage you to review the privacy policies and the privacy settings of the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites and to adjust these settings as you see fit.

What are your rights?

BPE will comply with your data protection rights, including your rights to request access to your personal information and to request that it be deleted or amended. You can always opt out of any direct marketing activity performed by BPE

BPE will comply with your data protection rights, including your rights to access and correct your personal information. You may inquire about the nature of the personal information stored or processed about you by any BPE entity. You will be provided access to your personal information, regardless of the location of the data processing and storage.

You can request access to your personal information and request that it be deleted or amended at any time. Individual Rights Requests can be sent to: bpee.com.
You always have the right to opt out of our marketing communications. Your prior consent is sought, when required by any applicable law. To opt out of marketing emails, simply use the functionality provided at the bottom of any email we send.
Country-specific sections may supplement this section.