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USER PRIVACY POLICY FOR THE PLATFORM
ArcelorMittal Distribution Solutions France (hereinafter referred to as "we", "us", "our", "ArcelorMittal", or "Data Controller") considers the protection of personal data of users of its online platform (hereinafter "you", "your", and "Users") and the respect of your privacy to be of the utmost importance, and pays particular attention to these issues.
This privacy policy (hereinafter the "Policy") is therefore intended to inform you about how your personal data is processed when using the online services (hereinafter the "Services") offered on the ArcelorMittal Distribution Solutions France platform (hereinafter the "Platform").
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
1.1 Data Controller
We, ArcelorMittal Distribution Solutions France, act as the data controller for the processing of your personal data.
1.2 Contacting Us
To contact us or our Data Protection Officer (hereinafter "DPO"), please refer to Section 11 of this Policy (How can you contact us?).
2. WHAT PERSONAL DATA DO WE COLLECT?
When you use the Platform, we may collect the following categories of personal data about you:
2.1 Personal data you provide to us:
- any data necessary to identify you on the Platform (e.g. first name, last name, email address, postal address, phone number, login details, username, password, tax identification number);
- any personal data included in correspondence, including commercial correspondence, that you send to us or to another User of the Platform, where applicable;
- any personal data related to your purchases or sales made via our Platform (e.g. payment data including bank account and card information, and shipping and delivery details for products purchased on our Platform);
- any personal data relating to your location when you have expressly consented to it, and only for purposes necessary for product delivery;
- where applicable, reviews you have submitted to evaluate a sale or purchase made through our Services;
- where applicable, your responses to surveys and satisfaction questionnaires to help us determine what you like about our Services and the products available on the Platform;
- where applicable, any personal data contained in incident reports or support requests you submit regarding problems you may encounter using our Platform or Services (e.g. the subject of your request).
In some cases, providing your personal data is mandatory, without which we will be unable to provide you with the requested services and information. For example, if you contact us through the Platform, you must provide your email address so we can respond.
In any event, we will inform you when the provision of your personal data is required.
Furthermore, if you provide us with personal data relating to third parties, you undertake to ensure that such persons have been duly informed of the processing of their personal data in accordance with this Policy and, where necessary, have consented to such processing.
2.2 Personal data collected automatically when you use the Platform
We use cookies, web beacons, and similar technologies to collect personal data as part of your use of our Platform. We collect this data from the devices you use when accessing our Platform. The personal data collected automatically includes:
- technical data (e.g. IP address, login and usage data on the Platform, browser type, content you access or view, search terms used, download errors, time spent on certain pages, your device's advertising ID, etc.);
- any personal data relating to your use of our Platform (including, as applicable, the number of products posted or ordered, your response rate to messages from other Users, account creation and deletion dates, the average reviews you received or posted, etc.).
To learn more about our use of cookies and similar technologies, please refer to our Cookie Policy available here: [insert URL link] [Note LL: Add a hyperlink redirecting to the Platform's Cookie Policy].
3. WHY DO WE USE YOUR PERSONAL DATA?
The table below outlines the purposes for which we process your personal data and, for each purpose, the legal basis used to justify the processing. Depending on the context, we may rely on different legal bases to process the same personal data for different purposes.
You also have specific rights depending on the legal basis used. You always have the right to access, correct, or delete your information. These rights are described in Section 9 of this Policy (What rights do you have?).
We process your personal data for the purposes and according to the legal bases listed below:
| PURPOSES | LEGAL BASIS | CATEGORIES OF DATA CONCERNED |
| Manage your User account on our Platform (e.g., creation, management, and deletion of the User account). | Processing is necessary for the performance of a contract with you or to take pre-contractual steps at your request (e.g., acceptance of the Terms of Use). |
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| Manage our loyalty program if you are a member of the e-steel Club (when you represent a company that is part of the “e-steel Club”) (e.g., to offer you personalized discounts and benefits, conduct surveys to tailor our offer, etc.). | Processing is necessary for the performance of a contract with you. |
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| Manage our contractual relationship with you and fulfill our contractual obligations. | Processing is necessary for the performance of a contract with you (e.g., if you wish to purchase a product, we need your business contact information, which you will need to provide when creating your User account to make purchases online). |
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| Respond to requests and questions you may submit on the Platform, and more generally, manage our relationships with Platform Users (e.g., providing information and advice about using the Services such as welcome messages, new features, updates, etc.). | Processing is carried out based on our legitimate interest in ensuring proper communication with Users of our Services. |
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| Offer, personalize, and improve our Services (e.g., ensure proper functioning, fix bugs, test new features, gather feedback on our features and Services, conduct surveys and research to understand what you value and what can be improved, produce statistics). | Processing is carried out based on our legitimate interest in optimizing our tools and solutions to better meet the needs of Platform Users and prospects. |
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| Enhance your overall experience on the Platform, tailor content and advertising to your interests. | Processing is based on your consent (e.g., optional use of cookies and similar technologies or marketing email). |
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| Display your order history in your User account. | Processing is based on your consent. |
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| Conduct marketing and sales prospecting activities (e.g., sending personalized messages about the services we offer on the Platform). | Processing is based on your consent. |
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| Provide information about changes to the Platform. | Processing is necessary either (i) to comply with our legal obligations (e.g., updates required to maintain Service compliance) or (ii) for the performance of a contract with you (e.g., updates not required for compliance). |
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| Maintain a safe and trustworthy environment (e.g., preventing and combating cyber fraud such as spamming, hacking). | Processing is carried out based on our legitimate interest in ensuring compliance with applicable laws, enforcing our General Terms of Use, Purchase and Sales Terms, preventing fraud, improving security, and ensuring proper performance of our Services (e.g., analyzing traffic and connections on the Platform). |
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| Comply with legal and regulatory obligations that apply to us. | Processing is necessary to comply with the legal obligations to which we are subject (e.g., respond to requests from judicial or administrative authorities, complaints, and data subject rights requests). |
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| Manage any potential or actual dispute with you or third parties. | Processing is carried out based on our legitimate interest in defending our interests, including through legal proceedings. |
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In any case, please note that we will refrain from processing your personal data for any other purposes that would be incompatible with those listed above.
4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
As part of the processing of your personal data, if necessary, we may share your personal data with the following recipients:
- Our affiliates, i.e., companies that are part of the ArcelorMittal group within the European Union ("Group");
- Our service providers, external service suppliers, payment service providers, and associated insurance organizations, our agents, and co-contractors, to the extent that they help us achieve the purposes outlined in this Policy (e.g., we use IT service providers to host your personal data on our behalf);
- Competent jurisdictions, public authorities, government bodies, and law enforcement (e.g., in cases where we must comply with legal or regulatory requests); and
- Third parties who may collect your personal data on our Platform through cookies, web beacons, and similar tracking technologies, subject to your prior and explicit consent. These cookies are used in accordance with our Cookie Policy. [Note LL: Insert a link to the Cookie Policy]
Regardless of the recipient, we will only share your personal data with them if they strictly need to know it and only to the extent necessary to achieve the purposes identified in this Policy.
We do not sell your personal data.
5. DO WE TRANSFER PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?
We do not transfer the personal data collected through the Platform to recipients located in third countries outside the European Economic Area.
6. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain your personal data for no longer than is necessary in light of the purpose for which the data is processed and the applicable law concerning the Platform.
In other words, the retention periods we apply vary depending on the reason we process the relevant data. The table below indicates, for each purpose, the retention period applied to your personal data:
| PURPOSES | CATEGORIES OF DATA CONCERNED | RETENTION PERIOD |
| Manage your User account on our Platform (e.g., Creation, management, and deletion of the User account). |
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We will retain your personal data for a maximum period of 3 years from your last use of our Platform, if you have not closed your User account. OR We will retain your personal data until the closure of your User account, including upon the User’s request for deletion. |
| Manage our loyalty program if you are a member of the e-steel Club (when you are a representative of a company that is a member of the "e-steel Club") (e.g., to offer discounts and personalized benefits, conduct surveys to adapt our offering, etc.). |
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We will retain your personal data for a maximum period of 3 years from your last use of our Platform, if you have not unsubscribed from our loyalty program. OR We will retain your personal data until the end of your loyalty program, including if you have requested the deletion of your account. |
| Manage our contractual relationship with you and fulfill our contractual obligations. |
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We will retain your personal data for a maximum period of 3 years from your last use of our Platform, if you have not closed your User account. OR We will retain your personal data until the closure of your User account, including upon the User’s request for deletion. OR The content you create on our Platform is anonymized after the periods mentioned above but remains visible on our Platform. |
| Respond to requests and questions you may submit on the Platform, and more broadly, manage our relationships with Platform Users (e.g., providing information and advice regarding the use of Services (welcome message, new features, developments, etc.)). |
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We will retain your personal data for a maximum of 6 months from the last contact initiated by you, or earlier if you exercise your right to object. |
| Offer, personalize, and improve our Services (e.g., checking proper functioning, resolving and correcting any issues, testing new features to ensure they work well, gathering feedback on our features and services, conducting surveys and research to determine what you like about our Services and products for sale, and what can be improved, producing statistics). |
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We will retain your personal data for a maximum of 6 months, but in most cases, your data will be aggregated shortly after collection into statistics that no longer allow you to be identified. OR We will retain your personal data until you exercise your right to object, which may occur before the expiration of the aforementioned 6-month period. |
| Improve the overall experience of your visit to the Platform, tailor content and advertising to your interests. |
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We will retain your personal data for a maximum of 6 months, but in most cases, your data will be aggregated shortly after collection into statistics that no longer allow you to be identified. OR We will retain your personal data until you exercise your right to object, which may occur before the expiration of the aforementioned 6-month period. |
| Display order history in the User Account. |
| We will retain your personal data for 3 years from your last interaction with our Services. OR We will retain your personal data until you withdraw your consent through your User Account. |
| Carry out marketing and promotional activities (e.g. sending personalized messages about the services offered on the Platform). |
| We will retain your personal data for 3 years from your last interaction with our Services. OR We will retain your personal data until you withdraw your consent through your User Account. |
| Communicate updates about the Platform. |
| We will retain your personal data for the period during which we are subject to the relevant legal or regulatory obligations. OR We will retain your personal data for a maximum of 3 years from your last use of our Platform, if your User Account has not been closed. OR We will retain your personal data until the closure of your User Account, including upon your request for deletion. |
| Maintain a safe and trustworthy environment (e.g. prevention and combat of IT fraud (spamming, hacking)). |
| We will retain your personal data for a maximum of 6 months, it being understood that in most cases, your data will be aggregated shortly after collection into statistics that no longer allow you to be identified. |
| Comply with our legal and regulatory obligations. |
| We will retain your personal data for the period during which we are subject to the relevant legal or regulatory obligations. |
| Manage any potential or actual dispute with you or third parties. |
| If your User Account has received a negative review or report, we will retain your personal data for 2 years following the closure of your account including upon your request for deletion, or for 3 years in the absence of such a request. OR If your account has been suspended or blocked, we will retain your personal data for 2 or 10 years depending on the severity of the violation, starting from the suspension date, to prevent any circumvention of the Platform's rules. |
10. HOW TO EXERCISE YOUR RIGHTS?
To exercise your rights, we invite you to contact our DPO using the contact details provided in Section 11 of this Policy (How can you contact us?). In order to best process your request, we may ask you for certain additional information to confirm your identity and/or to help locate the personal data concerned by your request.
Please note that some of these rights are subject to specific conditions dictated by the applicable legal framework regarding personal data protection. Therefore, if your particular situation does not meet these conditions, we may unfortunately be unable to fulfill your request. In such cases, we will inform you of the reasons for our refusal.
In any case, please note that you may file a complaint with the Commission Nationale de l’Informatique et des Libertés (“CNIL”).
11. HOW CAN YOU CONTACT US?
If you have any questions or requests regarding the processing of your personal data under this Policy, including the exercise of your rights as described above, you can contact us (i) by email at dpo.distributionsolutionsfrance@arcelormittal.com; or (ii) by using the contact form provided for this purpose and referred to in Section 1.2 of this Policy (Contact Us); or (iii) by post at the following address: Data Protection Officer, ArcelorMittal Distribution Solutions France, 16 avenue de la Malle, 51370 Saint Brice Courcelles.
12. WHEN AND HOW WILL YOU BE INFORMED OF CHANGES TO THIS POLICY?
We periodically review this Policy to ensure compliance and to keep it up to date with the applicable personal data protection regulations.
You will be notified in the event of substantial changes to this Policy (for example, if the changes relate to the categories of personal data processed or the purposes of the processing), and we will provide you with a hyperlink to the updated Privacy Policy within 30 days before it goes live. This information will be sent to you by email and/or made available via a pop-up window displayed during your next visit to our Platform. This will give you the opportunity to review the amended Policy before deciding whether you wish to continue using our Platform.
Current version: ArcelorMittal Distribution Solutions France – Platform User Privacy Policy – v.1
Last update date: 06/04/2023