Personal Data Protection Policy

Purpose and Scope of the Policy

Novéa Energies, a subsidiary of Groupe RAGNI, attaches the utmost importance and care to the protection of privacy and personal data, as well as to compliance with applicable legislation.

Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”) provides that personal data must be processed lawfully, fairly and in a transparent manner. Accordingly, this Personal Data Protection Policy (hereinafter the “Policy”) aims to provide you with clear and transparent information regarding the processing of your personal data, in particular in the context of your browsing activity and operations carried out through our website.

Data Controller

The data controller of your personal data, within the meaning of applicable data protection legislation and in particular the GDPR, is Novéa Energies, a Société par Actions Simplifiée with a share capital of EUR 222,203, whose registered office is located at 4 rue G.J Mendel, 49070 Beaucouze, France.

You can find all information relating to Novéa Energies on our Legal Notice page.

Why Do We Collect Your Personal Data?

This Policy applies to the collection and processing of your personal data for specified purposes and on different legal bases.

Within the framework of the performance of a contract or pre-contractual measures, your data are processed for the following purposes:

• Management of quotations;
• Management of orders and purchases;
• Management of your Novéa Link customer account;
• Management of contracts with customers / suppliers;
• Management of complaints and after-sales service.

Based on your consent, your data are processed for the following purposes:

Management of cookies requiring your consent, in particular:

• Audience measurement cookies used to measure website traffic and performance;
• Advertising cookies used to track conversions and measure the effectiveness of marketing campaigns.

Within the framework of the legitimate interests of Novéa Energies, your data are processed for the following purposes:

• Management of information requests;
• Management of communications;
• Management of relationships with prospects / customers;
• Organisation and management of commercial events;
• Management of unsolicited applications or applications submitted in response to a job offer;
• Ensuring the proper functioning and continuous improvement of the website (via technical cookies);
• Management of pre-litigation and litigation matters.

Within the framework of legal and regulatory obligations to which Novéa Energies is subject, your data are processed for the following purposes:

• Maintenance of general and subsidiary accounting records;
• Management of your data protection rights.

Personal Data We Collect

Personal data are processed in accordance with the data minimisation principle set out in the GDPR. The nature and scope of the personal data processed vary depending on your relationship with Novéa Energies, including in particular:

• Identification Data: information enabling us to identify you, such as your surname, first name and telephone number. We also collect your email address and your postal address (where payment is made, the postal address is required to issue an invoice).
• Professional Data: information provided in the context of a recruitment process or professional relationship, including your CV, cover letter, diplomas, professional experience, skills and, where applicable, any other information necessary for evaluating your application or managing the employment relationship.
• Login Data: information required to access your personal account, such as passwords and other authentication data.

We also collect your IP address for maintenance and statistical purposes.

• Financial Data: banking details (e.g., bank account identification details).
• Browsing Information: information relating to your navigation on our website.
• Data Collected via Our Network of Commercial Agents/Distributors: our network of agents/distributors conducts commercial prospecting and manages ongoing customer relationships. In this context, agents may collect personal data such as your contact details (surname, first name, email address, telephone number) and information relating to your commercial needs or interests. Such information is transmitted to Novéa Energies to ensure continuity of the commercial relationship and follow-up of your requests.

Recipients of Your Personal Data

Your data are intended for authorised employees of Novéa Energies responsible for contract management and legal compliance, within the scope of their respective duties.

They may also be communicated, where necessary and within the limits of their respective responsibilities, to the following recipients:

• Entities of Groupe RAGNI where activities are outsourced within the Group (in particular for communications);
• Our network of commercial agents / distributors;
• Service providers acting on our behalf, in particular for:
  • Order transport management
  • Data hosting
  • Commercial prospecting
  • Website audience analysis
  • After-sales service management
• Duly authorised public authorities (judicial or supervisory authorities) in compliance with our legal and regulatory obligations;
• Regulated professionals (lawyers, bailiffs, etc.) involved in the implementation of guarantees, debt recovery or litigation.

Where your data are communicated to our service providers, they are contractually required not to use the data for purposes other than those initially defined. We make every effort to ensure that such third parties preserve the confidentiality and security of your data.

In all cases, only strictly necessary data are communicated. We implement appropriate measures to ensure secure transmission of your data.

We do not sell your personal data.

Transfers of Data Outside the European Economic Area

Novéa Energies endeavours to store personal data in France or within the European Economic Area (EEA).

However, certain data collected when you use our website or services may be transferred to other countries, for example where some of our service providers are located outside the EEA.

In such cases, transfers are carried out:

• To countries recognised as providing an adequate level of protection;
• Under Standard Contractual Clauses adopted by the European Commission;
• Under Binding Corporate Rules.

If you wish to obtain further information regarding such transfers, please contact us using the details provided in the “Your Contacts” section.

Technical and Organisational Security Measures

Novéa Energies implements appropriate technical and organisational measures to protect personal data against loss, destruction, alteration, unauthorised access or disclosure.

Such measures may include restricted access to authorised personnel, pseudonymisation, encryption, secure authentication procedures, backup systems and regular security reviews.

Data Retention Periods

Your personal data are retained at least for the duration of processing related to our contractual relationship. Beyond this period, retention may be extended to comply with statutory limitation periods and legal or regulatory obligations.

Where you exercise your rights, the Data Protection Officer processes your personal data for the purpose of handling your request (title, surname, first name, copy of identity document, nature of the request, response provided). These data are retained for five (5) years, except for copies of identity documents, which are retained only for the time strictly necessary for verification or legal compliance.

More detailed information regarding retention periods may be obtained upon request under your right of access (see section “Your Rights Regarding Your Personal Data”).

Your Rights Regarding Your Personal Data

You may exercise your rights at any time by contacting Novéa Energies at the address indicated in the “Your Contacts” section.

• Right to object: you may request that your personal data no longer be subject to specific processing, except where processing is based on a legal obligation or the performance of a contract.
• Right to withdraw consent: for all processing activities based on your consent, you may withdraw it at any time.
• Right of access: you may request access to your personal data and additional information regarding the processing carried out.
• Right to rectification: you may request correction of inaccurate or incomplete personal data.
• Right to erasure: you may request deletion of your personal data, subject to legal retention obligations.
• Right to restriction of processing: you may request limitation of processing under the conditions provided for by the GDPR.
• Right to data portability: you may request a structured copy of the personal data you have provided for transmission to a third party.
• Right to provide instructions regarding the fate of your data after your death.

If you are not satisfied with the response provided or in the absence of a response, you may lodge a complaint with the CNIL via its website.

Your Contacts

To exercise your rights or for any further information or complaint, you may contact the Data Protection Officer (DPO) of Novéa Energies by email at dpo@novea-energies.com.

When submitting a request, please specify as precisely as possible the scope of your request, the right exercised, the processing concerned and any relevant information. Proof of identity may be requested where reasonable doubt exists.

The exercise of rights is strictly personal and may only be carried out by the data subject or their duly authorised legal representative.

Amendments to this Policy

Novéa Energies may amend this Personal Data Protection Policy where necessary. You will be informed of any substantial modification (for example, by a specific notice on our website).

Last update: November 2025