Privacy Policy

PRIVACY AND PROTECTION OF EMPLOYEES PERSONAL DATA

1. Summary

Sercel is committed to maintaining the principles of integrity and trust with respect to the privacy of Personal Data of their Employees disclosed to Sercel and to comply with all related applicable laws with respect to their collection and use.

Sercel takes all reasonable measures to protect the Personal Data it collects and has no desire or intent to infringe upon individual privacy rights.

As part of this commitment, Sercel protects the privacy of Personal Data disclosed to Sercel by the Employees and their families, as well as Personal Data received by Sercel or from other sources, at all times before, during and after employment.

To ensure this commitment, Sercel agrees to comply in all material respects with all applicable privacy laws, rules and regulations, in particular the European Regulation (EU) 2016/679 the “GDPR” (General Data Protection Regulation) on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and repealing Directive95/46/EC) and Sercel agrees to implement any legislation enacted by the member states of the European Union (“European Laws”).

In compliance with any and all applicable laws and regulations, this General Instruction describes:

The nature of Personal Data that Employees generally disclose to Sercel or that Sercel may receive from other sources before, during or after employment;
How Sercel collects and uses the Personal Data received;
The rights of Employees regarding their Personal Data.

2. Definitions

“Personal Data” and “personal information” are defined as any information relating to a specific or identifiable individual, such as that individual’s name, photograph, address, telephone number, or social security number (or other identification number).

“Sensitive Data” means Personal Data which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data or data which concern health, sex life or sexual orientation.

Please note that Personal Data and sensitive data may have a different definition depending of the country.

3. Personal Data Collected

Sercel does not collect, use, or disclose Personal Data without the knowledge or consent of the individual from whom the information is collected or a lawful basis to do so exists.

Personal Data collected by Sercel is required as a consequence of the contractual relationship with the Employees to enable Sercel to carry out its contractual obligations to the Employees. Failure to provide this information may prevent or delay the fulfilment of these obligations.

Subject to applicable law, Personal Data collected may include the following:

name, date of birth, gender, marital status, and identification numbers including social security, driver’s license, tax identification and passport numbers; etc.

background information, including education (schools and dates attended, and degrees or diplomas obtained), training, work history (names of former employers, dates of employment, and compensation information), military and veteran status, etc.
home and office addresses, home, office and cellular telephone numbers, and home and office e-mail addresses; etc.
medical information, including personal contact, health information for Employees, their spouses and dependents; and,
Sercel work history, experience, competences, training, compensation elements information (including salary, bonus, options and benefits), and employment performance, etc.

4. Use of Personal Data

4.1. Notice

Sercel hereby informs Employees about:

the purposes for which Personal Data is collected and used; and
the types of third parties to whom Sercel may disclose the Personal Data.

4.1.1. The purpose and lawful basis of the processing

Sercel collects and uses the Personnal Data detailed in item III disclosed by the Employees or received from other sources in the context of their employment within Sercel for the execution of their employment contract, to comply with Sercel’s legal obligations and for legitimate operational and human resources purposes. Failure to provide Personal Data may prevent or delay the fulfilment of these obligations.

These legitimate purposes include (1) the management, the operations and activities of the Company, (2) the Employees communications, (3) maintaining a global directory, (4) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements, (5) development and training programs, (6) recruiting and hiring job future employees, (7) assessing qualifications and performance, (8) performing background checks and verifying references, (9) managing the Employees performance, (10) determining Employees compensation or payment, (11) managing the Employees termination process, and (12) other operational or general human resources purposes.

Sensitive data shall be processed only where required by local law and only where there is a legitimate purpose for Sercel in doing so.

4.1.2. The purpose and lawful basis of the processing

Sercel employees

Sercel discloses Personal Data to Employees of the Company who reasonably need to receive such Personal Data to perform their duties. In addition, within this frame, Sercel may disclose Personal Data to third parties on a limited and as needed basis, including without limitation and for example, third parties who advise the Company on compensation and benefit programs or administer such programs for Sercel or as otherwise required by law or stated in this General Instruction.

Third-party entities

In the event that Sercel or any portion of its assets are acquired, sold or transferred, Sercel may disclose personal information with the company involved to perform the operation and complete the transaction.

Services Providers

Sercel may disclose personal information to services providers such as but not limited to banks, insurers, logistics and courier services companies, tax agencies and benefit providers.

Sercel implements a general instruction that requires each of these third parties (except certain licensed professionals, such as doctors and lawyers, who are subject to independent and legally enforceable client confidentiality obligations which have the same effect as a confidentiality agreement) to sign agreement with clause that requires them to maintain confidentiality of Personal Data and prohibits them from disclosing such data to any other person or entity or using such data for any purpose other than that which Sercel has engaged them to provide.

Affiliates

Sercel may provide Personnel Data to its affiliates or related companies for legitimate business purposes or supply of services.

Legal Parties

In certain circumstances, Sercel may be requested or required to disclose Personal Data in response to valid legal process or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Such circumstances may include a search warrant, subpoena, court order or other request from a government or regulatory authority or agency. Sercel reserves the right to disclose such information in response to any such legitimate government or regulatory request or requirement.

Emergency cases

Sercel may also disclose Personal Data during emergency situations if the physical safety of an Employee or others is believed to be at risk, or to notify family members or government agencies of the location or condition of an Employee.

Sercel does not disclose or sell any Personal Data to any person or entity for marketing or any other commercial purposes.

4.2. International Transfer of Personal Data

Subject to compliance with applicable regulations, Personal Data may be transferred to any country in the world where Sercel does business, including countries where privacy laws may be more or less protective than the privacy laws where an Employee lives or works.

In particular, Sercel may transfer Personal Data of Employees located in the European Economic Area (“EEA”) to countries located outside the EEA. Where appropriate, Sercel will ensure that Employees are informed of such transfer and that appropriate transfer mechanisms are in place.

When transfers occur from the E.U. to the USA, these are governed by the Privacy Shield Principles.

Sercel Inc and Sercel-GRC and their subsidiaries certified that they adhere to the Privacy Shield Principles, which are explained and available at https://www.privacyshield.gov and which shall prevail on this General Instruction terms in case of discrepancy. Their Privacy Shield Principles certification can be viewed at https://www.privacyshield.gov/list.

The Federal Trade Commission (FTC) has jurisdiction over the Sercel Group US entities’ compliance with the Privacy Shield

US entities of Sercel’s Group will conduct an annual in-house verification to ensure their compliance with this General Instruction and to renew their EU Privacy Shield certifications accordingly.

4.3. Choice « opt in – opt out » and Onward Transfer

Sercel does not intend to disclose or use Personal Data in a manner not described herein. However, should at any time Sercel need to disclose or use Personal Data in a way that is compatible with the purposes for which it was originally collected or subsequently authorized, Sercel will offer each Employee a choice whether (“opt-in”) or not (“opt-out”) to allow such disclosure or use of that Employee’s Personal Data. In this situation, Employee’s consent must be received in writing (or a legally equivalent electronic form) before Sercel will disclose or use Personal Data in this manner. If an Employee does not consent to such disclosure or use, Sercel will take all reasonable measures to remove that individual’s personally identifiable information before the data is disclosed or used in such a manner.

When the processing of Personal Data is outsourced to a third party, Sercel will select reliable third party and processing will be subject to written agreements between Sercel and the relevant third party. These written agreements will specify that the third party has at least the same adequate level of security measures in place than those implemented by Sercel and will only process Personal Data on the specific written instructions of Sercel and only for the purposes mentioned.

Sercel is liable for appropriate onward transfers of Personal Data to third parties.

4.4. Personal Data Security

Sercel maintains commercially reasonable safeguards to store Personal Data collected from Employees in a secure-access operating environment and only accessible to Sercel Employees, agents and third parties on a need-to-know basis. Sercel uses security measures and procedures that comply in all material respects with applicable laws and industry standards to guard Personal Data against loss, destruction, misuse, improper disclosure, and unauthorized access or modification.

For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Sercel’s electronic information systems requires user authentication via password or similar means. Sercel also employs access restrictions, limiting the scope of employees who have access to Personal Data.

Sercel will notify data breaches within the legal required time of awareness to the EU Data Protection Authority, unless said breaches are unlikely to represent a risk to the rights and freedoms of the individuals concerned.

4.5. Personal Data Retention Period

Personal Data is not kept for longer than necessary to fulfill the purpose for which it was collected. Personal Data will generally not be retained longer than the term of the employment with Sercel, increased by the period of prescription and the period of limitation of actions unless there is any legal or regulatory provision requiring otherwise and afterward Sercel will destroy or delete Personal Data in a secured manner.

4.6. Personal Data Accuracy and Integrity

Sercel relies on the accuracy and integrity of its Employees Personal Data in order to comply with its business obligations. Sercel expects the Employees to inform it of any changes to their Personal Data such as changes to contact information, address, marital status, or any information affecting benefits or services provided by Sercel.

Sercel makes all reasonable efforts to ensure that Personal Data it collects and retains is reliable for its intended use, accurate, complete, and current.

4.7. Personal Data Access

Any Employee has a right to request access to their Personal Data and to correct any inaccuracies if any or to request their deletion if no longer needed.

Upon written request to the Privacy Officer and supervision of the related HR manager, Sercel will allow an Employee to review the Personal Data that Sercel stores and maintains about that individual in his or her personnel file, including information relevant to the use and disclosure of that person’s Personal Data. However, in certain limited circumstances Sercel may not be able to provide Employees with access to all of their Personal Data where such refusal is permitted or required by applicable law or regulation.

Should any Personal Data concerning an Employee be found to be no longer needed, inaccurate or incomplete or if an Employee has withdrawn his consent, Sercel will take all reasonable steps to erase or correct or update the information it maintains without undue delay unless applicable laws or regulations exempt Sercel from doing so.

4.8. Enforcement – Rescourse and Liability

Sercel will monitor its compliance with this General Instruction and address questions and concerns regarding its adherence.

In compliance with the European Laws and the EU-US Privacy Shield Principles, Sercel is committed to resolve complaints about collection and/or use of personal information. Any inquiry or complaint regarding this General Instruction should first be referred to Sercel Privacy Officer at data.privacy@sercel.com. Sercel will do its utmost to acknowledge any complaint or enquiry within one (1) month of receipt and to take all appropriate action to remedy any such issues. However, if Sercel is unable to satisfactorily resolve the issue, Sercel will inform the Employee of the reasons preventing the implementation of measure to resolve such issue. As mentioned in the item IV.7 above, the Employee has the possibility to lodge a complaint free of charge to the EU data protection authorities (DPAs). To contact the DPAs directly please visit: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Under the GDPR, Employees who consider that the processing of their Personal Data infringes their rights, have the right to an effective judicial remedy.

Finally, under the EU-US Privacy Shield Principles, if neither Sercel nor the DPA resolves the complaint, EU Applicants or Employees may seek redress with the Department of Commerce, the FTC, and as a last resort from the Privacy Shield Panel, a binding arbitration mechanism. To learn more about the Privacy Shield Panel, please click here: https://www.commerce.gov/tags/eu-us-privacy-shield.

5. Changes to this General instruction

Sercel reserves the right to make changes to this General Instruction from time to time in order to reflect a new Personal Data management practice consistent with current applicable laws and regulations.

Sercel will post any revision of this General Instruction on intranet or websites, or make it available through email, or other means.

This General Instruction was last updated in June 2018.

6. Privacy Officer

Any inquiry or complaint regarding this General Instruction should first be referred to Sercel Privacy Officer at data.privacy@sercel.com.

Sercel Privacy Officer is currently the Head of Legal Affairs.

The Privacy Officer ensures the compliance of this General Instruction with any applicable Laws and controls the implementation of Sercel’s policies and procedures managing the data collection and processing activities. Finally, any grievances or request pertaining to the General Instruction shall be addressed to the Privacy Officer.

PRIVACY AND PROTECTION OF THIRD PARTIES PERSONAL DATA

1. Summary

Sercel is committed to maintaining the principles of integrity and trust with respect to the privacy of Personal Data of Third Party disclosed to Sercel and to comply with all related applicable laws with respect to theircollection and use.

As part of its commitment, Sercel takes all reasonable measures to protect the Personal Data collected and does not wish to infringe Third Party’s rights.

Sercel provides this General Instruction to inform Third Party from whom the Company collects Personal Data about the types of information that may be collected, why and how Sercel uses this information. By providing Sercel with the information, the Third Party authorizes Sercel to collect and use its Personal Data as mentioned in the present General Instruction.

To ensure this commitment, Sercel agrees to comply in all material respects with all applicable privacy laws, rules and regulations, in particular the European Regulation (EU) 2016/679 the “GDPR” (General Data Protection Regulation) on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC and Sercel agrees to implement any legislation enacted by the member states of the European Union (“European Laws”)

Subject to all applicable laws and regulations, this General Instruction describes:

The nature of Personal Data that Third Parties generally disclose to Sercel or that Sercel may collect from other sources before, during or after the relationship;
How Sercel collects and uses the Personal Data received;
The rights of Third Parties regarding their Personal Data.

2. Definitions

Personal Data” and “personal information” are defined as any information relating to a specific or identifiable individual, such as that individual’s name, photograph, address, telephone number, or social security number (or other identification number).

“Sensitive Data” means Personal Data, which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data or data that concern health, sex life or sexual orientation.

Please note that Personal Data and Sensitive Data may have a different definition depending of the countries.

3. Personnal Data Collected

Sercel does not collect, use, or disclose Personal Data without the knowledge or consent of the Third Party from whom the information is collected or a lawful basis to do so exists.

Sercel collects Personal Data in order to comply with its business or legal obligations. Failure to provide the Personal Data may prevent or delay the completion of the associated obligations.

Sercel collects Personal Data collected orally or by written from Third Parties including through Sercel’s websites or social media or through cookies used by Sercel as specified below, or given in any other way during any commercial or administrative communications.

Subject to applicable law, Personal Data collected may include:

date of birth, gender, marital status, and identification numbers including social security, driver’s license, tax identification and passport numbers and résumé;

Third Party name, company name, address, phone number, fax number, and mailing/e-mail address;
financial and billing information, such as billing name and address, payment information (bank account information);
general information such as title, department name, fax number, and additional company information, such as shareholders names, annual revenues, number of employees.

Sercel might collect any Personal Data from children subject to the prior and express consent of their parents.

4. Websites, social media and use of cookies

A Third Party can access Sercel’s websites or social media without providing any personally identifying information.

However, should a Third Party opt in, the latter may provide Sercel with certain Personal Data. Sercel may use this information:

to correspond with the Third Party;
to allow the Third Party to participate in features or services offered on the websites or social media;
to provide the Third Party with a subscription or newsletter; or,
to transmit the Third Party’s resume within Sercel for possible employment opportunities.

If the Third Party subscribes to any service provided by Sercel through its websites or social media or otherwise and wishes to terminate that subscription and have all personally identifiable information about himself/herself removed from any list Sercel maintains, the Third Party is invited to contact Sercel by sending an e-mail to data.privacy@sercel.com, informing Sercel of his/her request. Sercel will promptly make all reasonable efforts to remove any personally identifiable information from its data bases. In addition, e-mail communications from Sercel inform the recipient how to stop receiving further communication from Sercel. Sercel invites Third Party to follow the instructions if he/she no longer wishes to receive e-mail messages from Sercel.

Sercel does not automatically log Personal Data about visitors to its websites or social media. Sercel does not use cookies to store Personal Data, nor does Sercel link non-personal information stored in cookies with Personal Data about specific individuals. Sercel may collect certain non-personally identifiable information from a visitor to its websites or social media such as what browser was used, what pages were accessed, and the Internet address of the service provider in order to compile statistics and analyse this data for trends.

Cookies are small text files that are placed on computer by websites or social media visited. They are widely used in order to make websites or social media work, or work more efficiently, as well as to provide information to the owners of the site.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Sercel’s websites or social media uses the following cookies:

Functional and analytical Cookies

These cookies are used to collect information about how visitors use Sercel’s site(s), which Sercel uses to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

1P_JAR	Google Analytics tracking
CONSENT	Google Analytics tracking
NID	Google Analytics tracking
_ga	Google Analytics tracking
_gat_UA-36289871-3	Google Analytics tracking
_gid	Google Analytics tracking
axeptio_all_vendors	Cookies users choice
axeptio_authorized_vendors	Cookies users choice
axeptio_cookies	Cookies users choice

More can be find out about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html

To opt out of being tracked by Google Analytics across all websites or social media visit http://tools.google.com/dlpage/gaoptout

5. Use of Personal Data

5.1. Notice

Sercel hereby informs Third Parties about:

the purposes for which Personal Data is collected and used; and
the types of Third parties to whom Sercel may disclose the Personal Data.

5.1.1. The purpose and lawful basis of the processing

Sercel collects and uses Personal Data from Third Parties as above mentioned in point III only as necessary for the Company’s normal business operations. At the time of collection, Sercel informs Third Parties about the purposes for which the Personal Data is used, which includes but is not limited to i) selling, shipping, delivering, maintaining, enhancing and supporting its products and services ii) complying with contractual obligations related thereto (including managing transactions, reporting, invoices, renewals and other operations related to providing products and services) iii) organizing and supplying training courses or business events iv) notifying of major websites or social media requests and/or communications v) answering to individual services requests or to any other communications of this kind vi) satisfying governmental reporting, tax, and other requirements (e.g., import/export) vii) complying with Sercel’s legal obligations and as otherwise required by law.

5.1.2. The recipients of the Personal Data

Sercel employees

Sercel discloses Personal Data to employees of the Company who reasonably need to receive such Personal Data to perform their duties.

Third-party entities

In the event that Sercel or any portion of its assets are acquired, sold or transferred, Sercel may disclose Personal Data with the company involved to perform the operation and complete the transaction.

Sercel Contractors

Sercel may disclose Personal Data to contracting parties such as but not limited to suppliers, subcontractors or Partners who assist Sercel in the assistance of its business.

Sercel Providers

Sercel may disclose Personal Data to suppliers, subcontractors, services providers such as but not limited to banks, insurers, logistics and courier services companies, tax agencies and benefit providers.

Sercel has implemented a General Instruction that requires each of these third parties (except certain licensed professionals, such as doctors and lawyers, who are subject to independent and legally enforceable client confidentiality obligations which have the same effect as a confidentiality agreement) to be bound by a confidentiality undertaking which compels them to maintain confidentiality of Personal Data and prohibits them from disclosing such data to any other person or entity or using such data for any purpose other than that which Sercel has engaged them to provide.

Affiliates

Sercel may provide Personal Data to its affiliates or related companies for legitimate business purposes.

Legal Parties

In certain circumstances, Sercel may be requested or required to disclose Personal Data in response to valid legal process or in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. Such circumstances may include a search warrant, subpoena, court order or other request from a government or regulatory authority or agency. Sercel reserves the right to disclose such information in response to any such legitimate request or requirement.

Emergency cases

Sercel may also disclose Personal Data if appropriate to protect the Company’s legal rights, during emergency situations if the physical safety of a Third Party or others is believed to be at risk, or to notify family members or government agencies of the location or condition of a Third Party.

Sercel does not disclose or sell any Personal Data to any person or entity for marketing or any other commercial purposes.

5.2. International Transfer of Personal Data

In particular, Sercel may transfer Personal Data of Third Parties located in the European Economic Area (“EEA”) to countries located outside the EEA. Where appropriate, Sercel will ensure that Third Parties areinformed of such transfer and that appropriate transfer mechanisms are in place.

When transfers occur from the E.U. to the USA, these are governed by the Privacy Shield Principles.

Sercel Inc. and Sercel-GRC certified that they adhere to the Privacy Shield Principles, which are explained and available at https://www.privacyshield.gov and which shall prevail on this General Instruction terms in case of discrepancy. Their Privacy Shield Principles certification can be viewed at https://www.privacyshield.gov/list.

The Federal Trade Commission (FTC) has jurisdiction over the Sercel Group US entities’ compliance with the Privacy Shield.

US entities of Sercel’s Group will conduct an annual in-house verification to ensure (i) their compliance with this General Instruction and (ii) to renew their EU Privacy Shield’s certification accordingly.

5.3. Choice « opt in – opt out » and Onward Transfer

Upon an on-line application for or an offer of employment, Sercel requests each individual to consent to the disclosure and use of Personal Data as described in this General Instruction. Sercel does not request further consent in this regard.

Sercel does not intend to disclose or use Personal Data in a manner not described herein. However, should at any time Sercel need to disclose or use Personal Data for a purpose other than the purposes for which it was originally collected or subsequently authorized, Sercel will offer each Third Party a choice whether (“opt-in”) or not (“opt-out”) to allow such disclosure or use of that Third Party’s Personal Data. In this situation, the Third Party’s consent must be received in writing (or a legally equivalent electronic form) before Sercel will disclose or use Personal Data in this manner. If a Third Party does not consent explicitly to such disclosure or use, Sercel will take all reasonable measures to remove that Third Party’s personally identifiable information before the data is disclosed or used in such a manner.

When the processing of Personal Data is outsourced to a third party, Sercel will select reliable third party and any processing will be subject to written agreements between Sercel and the relevant third party. These written agreements will specify that the third party has at least the same adequate level of security measures in place than those implemented by Sercel and will only process Personal Data on the specific written instructions of Sercel and only for the purposes mentioned.

Sercel is liable for onward transfers of Personal Data to third parties.

5.4. Personal Data Security

Sercel maintains commercially reasonable safeguards to store Personal Data collected from Third Parties in a secure-access operating environment and only accessible to Sercel employees, agents and third parties on a need-to-know basis. Sercel uses security measures and procedures that comply in all material respects with applicable laws and industry standards to guard Personal Data against loss, destruction, misuse, improper disclosure, and unauthorized access or modification.

5.5. Personal Data Retention Period

Personal Data is not kept for longer than necessary to fulfill the purpose for which it was collected. Unless otherwise stipulated by law, Personal Data will generally not be retained longer than the term of the social, business or contractual relationship with Sercel, increased by the period of prescription and the period of limitation of actions unless there is any legal or regulatory provision requiring otherwise and afterward Sercel will destroy or delete Personal Data in a secured manner.

5.6. Personal Data Accuracy and Integrity

Sercel relies on the accuracy and integrity of Third Parties Personal Data in order to comply with its business obligations. Sercel expects the Third Parties to inform it of any changes to their Personal Data such as changes to contact information, address, marital status, or any information affecting benefits or services provided by Sercel.

Sercel makes all reasonable efforts to ensure that Personal Data it collects and retains is reliable for its intended use, accurate, complete, and current.

5.7. Data Access

The Third Parties have a right to request access to their Personal Data and to correct any inaccuracies if any or to request their deletion if no longer needed.

Upon written request to the Privacy Officer, Sercel will allow a Third Party to review the Personal Data that Sercel stores and maintains about that Third Party in his/her personnel file, including information relevant to the use and disclosure of these Personal Data. However, in certain limited circumstances Sercel may not be able to provide Third Party with access to all of his or her Personal Data where such refusal is permitted or required by applicable law or regulation.

Should any Personal Data concerning a Third Party be found to be no longer needed, inaccurate or incomplete or if a Third Party has withdrawn its consent, Sercel will take all reasonable steps to erase, correct, or update the information it maintains without undue delay unless applicable laws or regulations exempt Sercel from doing so.

5.8. Enforcement – Rescourse and Liability

Sercel will monitor its compliance with this General Instruction and address questions and concerns regarding its adherence.

In compliance with the European Laws and the EU-US Privacy Shield Principles, Sercel is committed to resolve complaints about collection and/or use of personal information. Any inquiry or complaint regarding this General Instruction should be first referred to Sercel Privacy Officer at data.privacy@sercel.com. Sercel will do its utmost to acknowledge any complaint or enquiry within one (1) month of receipt and to take all appropriate action to remedy any such issues. However, if Sercel is unable to resolve satisfactorily the issue, Sercel will inform the Third Party of the reasons preventing the implementation of measure to resolve such issue. As mentioned in the item above, the Third Party has the possibility to lodge a complaint free of charge to the EU data protection authorities (DPAs). To contact the DPAs directly please visit: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Under the GDPR, the Third Parties who consider that the processing of their Personal Data infringes their rights have the right to an effective judicial remedy.

Finally, under the EU-US Privacy Shield Principles, if neither Sercel nor the DPA resolves the complaint, EU Third Parties may seek redress with the Department of Commerce, the FTC, and as a last resort from the Privacy Shield Panel, a binding arbitration mechanism. To learn more about the Privacy Shield Panel, please click here: https://www.commerce.gov/tags/eu-us-privacy-shield.

6. Changes to this General instruction

Sercel will post any revision of this General Instruction on intranet or websites, or make it available through email, or other means.

7. Privacy Officer

Any inquiry or complaint regarding this General Instruction should first be referred to Sercel Privacy Officer at data.privacy@sercel.com.

Sercel Privacy Officer is currently the Head of Legal Affairs.