The website ensures the collection and processing of personal information in compliance with privacy rights, in accordance with Law No. 78-17 of January 6, 1978, relating to Information Technology, Files, and Civil Liberties.

EXTRUGENE is committed to protecting the personal data of its clients, users, anyone accessing its website, and more broadly, any individual whose personal data it may process. EXTRUGENE also recognizes the need to empower individuals to retain control over their personal data.

This Privacy Policy aims to inform data subjects about how EXTRUGENE processes their personal data and how they can exercise their rights.

This policy also complies with the requirements of the new data protection regulation (Regulation EU 2016/679 – GDPR).

1. Who is responsible for processing personal data?
   The data controller is EXTRUGENE, headquartered at 20 RUE DES CANADIENS, 27300 BERNAY, France.

This Privacy Policy concerns data processing activities carried out by EXTRUGENE as the data controller.

2. For what purposes and on what legal basis is personal data processed?
   EXTRUGENE processes personal data based on legal obligations and legitimate interest. Personal data may be processed for the following purposes:

• Processing based on consent:
  Managing contact requests, newsletter subscriptions, and cookie management (geolocation or indirectly identifying data).
  
  
• Processing based on legal obligation:
  Handling rights requests under the GDPR, managing claims and disputes.
  
  
• Processing based on legitimate interest:
  Managing business relationships (to maintain or renew business ties with users interested in the services), cookie management (to anonymously measure website audience and interaction), fraud monitoring (to detect and act on fraudulent activity), and handling disputes (to ensure legal protection).
  
  

3. What categories of personal data are processed?
   “Personal data” refers to any information relating to an identified or identifiable natural person. EXTRUGENE may process personal data such as your email address and identity details if you voluntarily contact us or subscribe to the newsletter.
4. Cookies and Social Networks
   extrugene.com may use “cookies” or trackers (small files of letters and numbers sent by a web server to your browser’s cookie file on your device) to facilitate site navigation, optimize site performance, and generate usage statistics. These cookies are not used for any other purpose and do not track unrelated data.

Under the GDPR, anonymous cookies for internal statistical purposes that do not identify users may be placed without requiring consent and are not shared with third parties.

You have the right, as per regulations, to access, object to, rectify, or delete any personal data collected via cookies or trackers. These rights are detailed in Article 9 of this Privacy Policy.

– You may click on social media icons provided on the extrugene.com website.
These features use third-party cookies to enhance site interactivity and are directly deposited by those services. Clicking these links may allow those platforms to access public personal data from your social media profiles. However, EXTRUGENE does not create or use an independent database based on these public social media details and will not process any private data from your social profiles.

If you do not wish EXTRUGENE to access this public information, you must configure your social media settings accordingly. EXTRUGENE is not responsible for third-party use of your data through social media links provided on its site.

5. Who may receive personal data?
   Your personal data is shared with internal EXTRUGENE departments as needed for the purposes outlined above, as well as with subcontractors for technical operations (e.g., database management, site maintenance), and partners when explicitly requested or required to deliver services.

Potential recipients include:

• EXTRUGENE’s executive, sales, IT, customer service, and administrative teams;
  
  
• Legal teams handling disputes (data in intermediate archives accessible only to authorized staff);
  
  
• GDPR rights request handlers;
  
  
• Technical subcontractors (e.g., data hosting, marketing distribution);
  
  
• Website management service providers;
  
  

EXTRUGENE will not sell your personal data to third parties. It may only disclose data to comply with legal obligations or administrative/judicial requests, or to protect its legal rights.

6. How is personal data collected?
   Personal data is collected directly by EXTRUGENE when a user voluntarily submits a contact request. No personal data is collected without your active input.
7. How long is personal data retained?
   Your data is stored in active databases and retained for varying periods based on the processing purpose:

• Contact request responses (Consent): Retained for as long as necessary to provide a response.
  
  
• Newsletter subscriptions (Consent): Retained until consent is withdrawn or for 3 years after your last interaction.
  
  
• Cookies (Consent): Retained until consent withdrawal or 1 month.
  
  
• Fraud management (Legitimate interest): Archived for the duration of the dispute.
  
  
• GDPR rights requests (Legal obligation): Retained for 1 year in active base, then archived for 5 years.
  
  
• Claims and disputes (Legal obligation & Legitimate interest): Retained as long as necessary for the case. Final decisions may be archived indefinitely for historical records.
  
  
• Contract execution: Retained for the full duration of the contract.
  
  

Data used for marketing purposes is stored for 3 years from your last contact with EXTRUGENE. Some data may be archived beyond these periods to fulfill legal obligations or for legal defense purposes.

8. Security
   EXTRUGENE implements all appropriate technical and organizational measures to ensure the security and confidentiality of your personal data.

This includes:

• Physical security of premises
  
  
• Secure authentication procedures (e.g., login credentials)
  
  
• Logging of access
  
  
• Data encryption where applicable
  
  

These measures help prevent unauthorized access, loss, alteration, or destruction of your data.

9. What are your rights regarding your personal data?
   Under applicable regulations, you have the right to:

• Access your personal data
  
  
• Rectify inaccurate or incomplete data
  
  
• Object to processing
  
  
• Request restriction or erasure
  
  
• Request data portability (where applicable)
  
  

You may also withdraw your consent at any time for consent-based processing or unsubscribe from communications regarding offers, news, or events.

You can also file a complaint with the CNIL (France’s data protection authority) if you believe your rights are not being respected.

10. How to exercise your rights?
    For any questions or to exercise your rights regarding your personal data, you can contact EXTRUGENE at:

📧 Email: f.gerard@extrugene.com

This version was last updated on July 16, 2025.