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PRIVACY POLICY

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UMI, a simplified joint stock company, registered in the Lyon Trade and
Companies Register under number 798 755 00024, whose registered office is
located at 1-3 place Giovanni Da Verrazzano 69009 Lyon- France (hereinafter the
“Company” or “UMI”) undertakes to ensure that the Processing of Personal Data
referred to in this document complies with the applicable regulations on data
protection (European General Regulation 2016/679 on Data Protection – “RGPD”)
and with the French Data Protection Act n°78-17 of January 6, 1978 as amended.
UMI is the publisher of the website accessible at umi-innovation.com and the
associated web application (hereinafter the “Site” and the “Application”).

The following information is provided to you so that you may be aware of the
commitments regarding the protection of Personal Data of UMI, which acts as the
Data Controller of the Personal Data concerned.

The purpose of this Personal Data Privacy Policy is to inform you about how your
data is processed by UMI and the extent of your rights.


ARTICLE 1 – DEFINITIONS


PERSONAL DATA

Refers to any information that directly or indirectly identifies or makes
identifiable a natural person.


DATA SUBJECT

Means any natural person whose Personal Data is collected and processed by UMI.


DATA CONTROLLER

Refers to the person who determines the purposes and means of the Processing.
UMI has this capacity for the purposes of this Privacy Policy.


DATA PROCESSOR

Refers to the person who processes Personal Data on the instructions of the Data
Controller in the context of a service or provision.


DATA PROCESSING

Refers to any operation or set of operations carried out using automated or
manual processes on an electronic or paper medium, such as the collection,
recording, organization, structuring, storage, adaptation or modification,
extraction, consultation, use, communication by transmission and dissemination
of Personal Data.


ARTICLE 2 – PROCESSING OF PERSONAL DATA AND PURPOSES

UMI implements various processing operations whose legal bases are as follows:
your consent, its legal and regulatory obligations, its legitimate interests.

UMI processes and collects Personal Data:

 * That you provide directly to UMI. This may include your last name, first
   name, email address. You provide this information when, for example, you use
   the “contact our sale team” form on the Site.

 * Information that UMI automatically collects through cookies or other analysis
   tools. For example, this may include your IP address, browser, connecting
   device and operating system. This information is used to enhance your
   experience and help us improve our services.

 * Which are publicly accessible on the Internet when authorized by the
   publisher of the source site from which your Personal Data originated.

 * Processing No. 1: sending of e-mails to collect consent in the case of
   indirect collect of your Personal Data

The purpose of the Processing is to obtain your consent before any other
solicitation

In the case of this Data Processing, your Personal Data is collected indirectly
from the following sources: LinkedIn website, Videao, Xin or Researchgate.

It allows to:

 * Gather your consent to be solicited by UMI,
 * Register your Personal Data in our contact database.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Categories of Personal Data processed:

 * Contact data: Last name, first name, professional e-mail address, position,
   country, name of employer.

Data Subject:

Anyone who may be interested in participating in a market test and in UMI’s
business in general.

Automated decision:

The Data Processing does not involve automated decision.

 * Data Processing No. 2: Sending of communication concerning questionnaires
   related to a market test, articles and any other type of communication that
   may be of interest to you by electronic means

It allows to:

 * Send you questionnaires;
 * To send you e-mails on different subjects related to our activity,
   newsletter.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Category of Personal Data collected:

 * Contact information: Last name, first name, professional e-mail address

Data Subject:

Individuals who have consented to be included in UMI’s contact database either
at the time of direct collection or through indirect collection.

Automated decision:

The Data Processing does not involve automated decision.

 * Data Processing No. 3: Process/analyze your responses to the questionnaires

It allows to:

 * Analyze and process your responses to our questionnaires;
 * Produce a report for our partner (this report does not contain your contact
   data and is anonymized).

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Category of Personal Data collected:

 * Contact information: Last name, first name, professional e-mail address
 * Data possibly transmitted via the questionnaire: position, company name, etc.

Data Subject:

Individuals who have consented to receive solicitations from UMI and to
participate in a survey.

Automated decision making

The Data Processing does not involve automated decision.

 * Data Processing No. 4: to put you in contact with our partners

It allows to:

 * Transmit your Personal Data to our partners if you have consented to it.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Category of Personal Data collected:

 * Contact data: Last name, first name, professional e-mail address.

Data Subject:

Any person registered in UMI’s database who has consented to the transfer of
their Personal Data to an identified partner.

Automated decision:

The Data Processing does not involve automated decision.

 * Data Processing No. 5: to answer any request resulting from the sending of
   the form “Contact our sale team” available on our Site

It allows to:

 * Respond to your requests sent via the contact form of the Site.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Category of Personal Data collected:

 * Contact data: Last name, first name, professional e-mail address, all
   Personal Data provided in the free field.

Data Subject:

Persons sending the form to UMI.

Automated decision

The Data Processing does not involve automated decision.

 * Data Processing No. 6: Accessing your UMI account

It allows to:

 * Give you access to the services available on your UMI account

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Category of Personal Data collected:

 * Account login information: username, password.

Data Subject:

User of the Site and the Application.

Automated decision:

The Data Processing does not involve automated decision.

 * Data Processing No. 7: Responding to requests made via the “Ask a question”
   form available on the Site

It allows to:

 * Answer your questions,
 * Get in touch with you.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Data
Processing of his/her Personal Data.

Category of Personal Data collected:

 * Contact data: first name, last name, e-mail address, company name and any
   data you send us via the free “message” field.

Data Subject:

Any person asking UMI a question via the “Ask a Question” form available on the
Site.

Automated decision:

The Data Processing does not involve automated decision.

 * Data Processing No. 8: contact you following the sending of your CV and cover
   letter to the dedicated e-mail address as indicated on the “Join us” page
   available on the Site – process your application

It allows to:

 * Process your application,
 * Contact you and inform you of UMI’s position following the submission of your
   application,
 * Keep your data in our applicant database.

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Data
Processing of his/her Personal Data.

Article 6 (1) f) GDPR: processing is based on UMI’s legitimate interest

Category of Personal Data collected:

 * Contact and identification data: first name, last name, e-mail address,
   company name and any data you provide via your CV and cover letter (date of
   birth, place of birth, home address, marital status, number of children, etc.
   ) .

Data Subject:

Any person applying for a job posted on our Site.

Automated decision:

The Processing does not involve automated decision-making.

 * Data Processing No. 9: Process your request to join the UMI community –
   community registration

It allows to:

 * Process your request
 * Connecting community members
 * Send emails that may be of interest to the community member
 * Send UMI newsletters

Legal basis of the Data Processing:

Article 6 (1) a) of the GDPR: the Data Subject has consented to the Processing
of his/her Personal Data.

Article 6 (1) f) GDPR: processing is based on UMI’s legitimate interest

Category of Personal Data collected:

 * Contact and identification data: first name, last name, email address,
   company name and sector, associated keywords.

Data Subject:

Anyone interested in joining the UMI community.

Automated decision

The Data Processing does not involve automated decision.

Based on compliance with our legal and regulatory obligations, we also carry out
processing for the following purposes:

 1. Management of responses to official requests from public or judicial
    authorities authorized for this purpose;
 2. Compliance with the regulations applicable to our activity;
 3. Management of requests to exercise rights.


ARTICLE 3 –DATA RECIPIENTS

In order to achieve the purposes described above and to the extent necessary for
the pursuit of those purposes, the Personal Data collected by UMI may be
transmitted to any or all of the following recipients:

 * Internal UMI departments authorized to manage our relationship with you;
 * People in charge of marketing, sales, administrative and IT departments and
   their line managers;
 * The partners of the Site for the needs of the execution of the services;
 * Our partners who mandate us to carry out test markets when you have consented
   to the communication of your Personal Data.


ARTICLE 4 – DATA PROCESSOR

In accordance with its commitments, UMI chooses its Data Processors carefully
and requires them to:

 * A level of protection of Personal Data equivalent to his own;
 * Use of Personal Data or information solely for the purpose of administering
   the services they are to provide;
 * Strict compliance with applicable laws and regulations regarding privacy and
   Personal Data;
 * The implementation of all appropriate measures to ensure the protection of
   Personal Data that they may be required to process;
 * The definition of the technical and organizational measures necessary to
   ensure security.

UMI concludes with its Data Processors, in accordance with legal obligations,
contracts defining precisely the conditions and modalities of the Processing of
Personal Data.


ARTICLE 5 – PERSONAL DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

The various categories of Personal Data collected and processed by UMI may be
transmitted to Data Processors located in countries outside the European Union
such as the United States.

In case of transfer of all or part of the Personal Data subject to Data
Processing to a third country, i.e. located outside the European Union or not
presenting a level of protection recognized as adequate within the meaning of
the regulations, or to an international organization, UMI undertakes to provide
the appropriate guarantees provided for within the regulations and to ensure
that its Data Processors respect them.

Such transfers may be governed by a cross-border flow agreement drawn up in
accordance with the standard contractual clauses for data controllers and
processors issued by the European Commission and currently in force.


ARTICLE 6 – RETENTION PERIOD OF PERSONAL DATA

PurposesRetention PeriodManaging our relationship with you as a user of the
umi-innovation.com websiteThe data is kept for three years from the last
incoming contactThe realization of statistics and analyses in order to improve
the use of the site umi-innovation.comThe data is kept for three years from the
last incoming contactManaging our relationship with you as a community memberThe
data is kept until you unsubscribeManaging cookies not subject to consentThe
retention period does not exceed 13 monthsThe use of your contact data for
sending questionnaires and any communication by electronic means (including in
particular responses to solicitations via the forms available on the site
umi-innovation.com)The data is kept for the duration of your registration with
the UMI community or for three years from the last incoming contactManaging
cookies subject to consentThe retention period does not exceed 13
monthsManagement of requests to exercise rightsThe data is kept for one or six
years depending on the right exercised


ARTICLE 7 – SECURITY MEASURES

UMI attaches particular importance to the security of your Personal Data.

UMI is committed to implementing:

 * Physical security measures to prevent access to your Personal Data by
   unauthorized persons;
 * Identity and access controls via an authentication system and password
   policy;
 * An authorization management system;
 * Processes and devices allowing to trace all the actions carried out on the
   information system and to carry out, in accordance with the regulations,
   reporting actions in case of incident impacting the Personal Data.


ARTICLE 8 – EXERCISE OF RIGHTS

In accordance with the provisions of the amended French Data Protection Act and
the RGPD, you have a right to access, rectify, delete, limit, oppose and a right
to the portability of Personal Data concerning you. To exercise all these
rights, please send your request to our Data Protection Officer at the following
e-mail address: dpo@umi.us (please also send us a copy of your identity card).

a. Right of access

You have a right of access to the Personal Data processed by UMI. This right
allows you to review the Personal Data we have about you and, if you wish, to
request a copy.

b. Rights to request the rectification

Under applicable data protection regulations, you may request that we correct
inaccurate Personal Data about you. You may also request that incomplete
Personal Data about you be completed, including by providing a supporting
statement.

In order to make it as easy as possible for you to exercise this right, we
invite you to make these changes and additions directly in your account, if
necessary. If you believe that other Personal Data concerning you should be
modified or completed and that you are unable to make this change yourself, we
invite you to contact our Data Protection Officer at the following address:
dpo@umi.us.

c. Right to request the erasure

You have the right to obtain from us the erasure, as soon as possible, of
Personal Data concerning you, subject to our legitimate interest or any legal
obligation requiring us to keep it.

For security reasons and to avoid unwanted erasure of the account, we invite you
to take this step by contacting us at the following address: dpo@umi.us.

d. Right of limitation

You may request UMI to limit the Processing of your Personal Data, where any of
the following apply:

 * you challenge the accuracy of your Personal Data. In this case, we will hide
   your Personal Data for a period of time that allows us to verify its
   accuracy;
 * you believe that the Processing of your Personal Data is carried out
   unlawfully and you demand instead the limitation of their use;
 * we no longer need your Personal Data for the purposes of the Data Processing
   but it is still necessary for you to establish, exercise or defend a legal
   claim;
 * you have exercised your right to object under Article 21(1) of the GDPR.

We will proceed to limit the Processing of your Personal Data, while verifying
whether the legitimate reasons we are pursuing prevail over your right.

If we decide to lift the limitation on the Processing of your Personal Data, we
will inform you.

e. Right to object

You may opt-out of receiving communications, including commercial
communications, from UMI. To this end, we provide you with an unsubscribe link
in all the emails we send you.

You may also object, on legitimate grounds, to the Processing of your Personal
Data, unless it is in response to a legal obligation imposed on UMI.

f. Right to portability

You may at any time request the portability of your Personal Data to UMI. In
exercising this right, we undertake to transmit to you within a reasonable
period of time and in a machine-readable format the Personal Data you have
provided to us, whether declared by you or generated by your activity on the
Site.

g. Right to Withdraw Consent

You have the right to withdraw your consent at any time as well as to refuse the
Processing of your Personal Data for personal reasons.

h. Right to file a complaint with a supervisory authority

The supervisory authority competent to deal with any request concerning us is
the Commission Nationale de l’Informatique et des Libertés (CNIL).

If you wish to submit any request to the CNIL, you will find below the contact
information:

CNIL (NATIONAL COMMISSION FOR INFORMATION TECHNOLOGY AND LIBERTIES)

3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

Phone: 01 53 73 22 22

Please note! The CNIL does not receive the public and does not provide any
information on site.

If you wish to file a complaint with the CNIL, you can fill out the online
complaint form available at the following address:
https://www.cnil.fr/fr/plaintes

If you have a question about your rights regarding data processing and
liberties, you can consult the CNIL website: www.cnil.fr.


ARTICLE 9 – COOKIES

Browsing the Site may cause cookies to be installed on your terminal (by the
Company and/or its Data Processors). When you connect to the Site, you are asked
to configure your choices regarding cookies.

a. Definition

A cookie is a small text file, deposited on your terminal, via the Internet
browser, for example when visiting a site, reading an email, installing
software, etc.

A cookie does not allow you to be identified but records information about your
browsing.

b. Types of cookies used

The different types of cookies and their purposes :

 * Consultation of the Site entails the deposit by UMI of cookies on your
   terminal in order to simplify and improve your navigation on the Site and to
   personalize the services offered to you under the conditions defined below.

 * Necessary cookies: these are those that are strictly necessary for the proper
   functioning of the Site (for example: cookies that allow us to remember your
   choice on the deposit of cookies, certain audience measurement cookies).
   These cookies contribute to the technical functioning of the Site and cannot
   be deactivated.

 * Functional cookies: these cookies make it possible to improve navigation on
   the Site and in particular to make navigation more fluid and personalized
   without being essential to the proper functioning of the Site (for example:
   memorization of connection information to your UMI account, etc.).

 * Analytical cookies or audience measurement: these cookies allow UMI to know
   the use and performance of the Site and to improve its operation (for
   example, the most visited pages of the Site, the number of people connected
   at a given time and the place of connection, etc.). )

c. Cookie retention time

UMI stores the cookies listed above, subject to your consent and settings, for a
maximum of 13 months.

d. Cookie settings

When you log on to the Site, you are invited to set your cookie preferences. You
can modify your choices at any time. However, the setting of cookies is likely
to have effects on your navigation on the Site. It is therefore advisable to set
the parameters of cookies according to their respective purposes.


SECTION 10 – MODIFICATION OF THE PRIVACY POLICY

This Policy was last updated on the date indicated on page 1. UMI reserves the
right to modify this Privacy Policy. If this Privacy Policy changes, UMI will
not lower the level of protection afforded to your Personal Data.


FAQ


PURPOSES OF THE PROCESSING


The processing has two purposes: first, to identify experts in some particular
knowledge domain, e.g., experts in phonic isolation in vehicles or experts in
motor control systems. The second purpose is to contact those professionals to
ask them some questions about one innovation in their field of expertise. This
contact has no commercial goal whatsoever but it is indeed in a legitimate
interest of having an expert’s advice.


RECIPIENTS OF PERSONAL DATA


The data will be disclosed, if the subject authorizes to do so, only with our
clients who drive the innovation being tested. Most of our clients are based in
Europe, mostly in France. All the data is stored in servers in Europe.


RIGHT TO BE FORGOTTEN


You have the right to request a rectification or erasure of your personal data
or even restrict its processing.


SOURCES OF THE PERSONAL DATA



Where the personal data are not collected from the data subject, any available
information as to their source: except for the e-mail address, we collect the
data from publicly available sources like:

 * Patent information
 * Professional profiles
 * Academic profiles
 * Company websites

Note that the content of those sites is not stored in our database or any of our
systems.
For the e-mail address, we have developed an algorithm for identifying the
e-mail using the information collected before. Once we have this information
is not transferred to any person or organization outside UMI unless the
concerned person agrees to do so.


CATEGORIES OF PERSONAL DATA CONCERNED


The data we have is the minimum required to perform our processing. This is:
 * Last name
 * First name
 * Company

 * Job
 * Country
 * E-mail address


PERIOD OF STORAGE


The data will be stored for three years counting from the las interaction i.e.,
message exchanges between you and us, or until you decide, and demand us to
delete all of your personal data which is done in within 3 working days.


RIGHT TO LODGE A COMPLAINT


You have the right to lodge a complaint with a supervisory authority: we are
located in France, so the competent supervisory authority is the CNIL.


AUTOMATED DECISION-MAKING



The existence of automated decision-making, including profiling, referred to in
Article 22(1) and (4) and, at least in those cases, meaningful information about
the logic involved, as well as the significance and the envisaged consequences
of such processing for the data subject.

Today we don’t have an automated decision-making process. We validate the
profiles we have found by taking a sample and validating the accuracy of the
search by hand. If the accuracy is shown to be low, no data is stored.

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