PRIVACY POLICY

4D is particularly committed to respecting privacy and protecting personal data. As part of its activity as a website publisher (www.4d.com, www.qodly.com, and any other website that we may publish and manage - the "4D Websites"), and software publisher, 4D may process information about you. For example, by filling out a form, by making a purchase on the store, by contacting our sales representatives, by registering for an event that we organize, by participating in a contest, by browsing the 4D Websites, you share information with us, some of which is likely to identify you or make you identifiable (“personal data”).

This Privacy Policy tells you how we collect and process your personal data.

f you have any questions about this document, please contact our data protection services at: dpo@4d.com.

We draw your attention to links contained on 4D Websites to other third-party sites. If you follow a link to one of these third-party sites, please note that they have their own privacy policies and that we have no responsibility or liability for their policies or treatment of your personal data. Please check these privacy policies before providing your personal data to these third-party sites.

ARTICLE 1: The data controller

The party responsible for processing the personal data subject to this document is 4D, a French Société par Actions Simplifiée (simplified joint stock company) with share capital of 2.034.900 euros, whose registered office is at 66, route de Sartrouville - 78230 Le Pecq, France, registered in the Versailles Trade and Companies Register under no. 318 918 851.

ARTICLE 2: Types of data collected

2.1 Data you send us directly

During the various contacts we have with you, you may be asked to provide us with information about yourself.

This data includes:

• Identification and contact data: the personal data that you provide to us, for example when you fill in a form on our 4D Websites, including, but not limited to: first names, title, date of birth, your e-mail address, postal address, telephone number, your country and your company (and/or the sector in which you work), your identifiers enabling you to access certain parts of the 4D Websites (forums, store, etc.).
• Encrypted information relating to your means of payment: we never have unencrypted access to this data. Payment is made via a certified payment service provider;
• Our commercial relationship and correspondence: subscriptions taken out, orders for products and services, invoices and payments where applicable; Your participation in promotional offers, competitions or events; Requests you have made to our technical support service; if you contact us, we generally keep a copy of this correspondence.
• Information relating to studies/surveys: we may also ask you to complete studies or surveys that we use for research purposes. In this case, we will collect the data that was provided in the survey you completed.
• Behaviour and use of the 4D Websites: details of your visits to the 4D Websites and data collected through cookies and other tracers, including, but not limited to, your IP address and domain name, browser version and operating system, browser language, access time, traffic data, location data, web logs, feeds on the 4D Websites, addresses of referring 4D Websites and other communication data. We may also collect data about the pages you view on the 4D Websites and other actions you take during your visit. In addition, we may also use these tools to detect whether you have opened an e-mail or clicked on a link contained in an e-mail. Different technologies may be used to collect this data, the main one being the cookie. Please read our Cookie Policy.
• Education and professional life, in the context of a job offer at 4D to which you would like to apply.

2.2 Data relating to under 18 years-olds

Our products and services are intended for adults capable of entering into contractual obligations. Users who are minor of 18 years old must obtain the consent of their legal guardian prior to the communication of personal data concerning them.

2.3 Exclusion of all sensitive data

As the data controller, 4D does not collect any sensitive data about you. The following are considered to be sensitive data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data relating to health or sexual orientation. If such information is communicated to 4D in any way, it will be deleted.

ARTICLE 3: Data Security

Any information you provide to us is stored on our secure servers or those of our subcontractors and is accessed and used in accordance with our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our 4D Websites, you are responsible for maintaining the confidentiality of that password and for complying with any other security procedures which we provide. We ask you not to share this password with anyone.

ARTICLE 4: Purposes

We use your personal data:

• To communicate effectively with you and to manage our business and our customer base, including responding to your requests: to respond to your requests for contact/free trial/demo requests, your request to register for events organised by 4D or your request for a meeting with one of our experts, to respond to your request for a partnership should you be interested in a business relationship with us, to respond to your application for employment, to otherwise communicate with you, or to fulfil our obligations arising from any agreement entered into between you and us..

  Legal basis: consent, legitimate interests (to provide you with up-to-date news and information about our products and services).

• To provide you with access to restricted areas of the 4D Websites: to provide you with an online account and access to restricted areas such as your user area. Please note that the provision of certain data (marked as such) is mandatory to create an account and that, without this data, we will not be able to provide you with all of our services.

  Legal basis: performance of the contract, legitimate interests (to enable us to perform our obligations and provide you with our services).

• To provide you with content about our products and services: to send you email alerts, updates, offers and invitations to 4D events. We may also use your data to market our own products and services and those of our selected business partners by email and, where required by law, we will seek your consent at the time we collect your data to carry out any of these activities. We will systematically offer you an option to unsubscribe from any future communications.

  Legal basis: consent, legitimate interests (to provide you with up-to-date news and information about our products and services).

• For research and development purposes: to analyse your behaviour on the 4D Websites to better understand your needs, our business and how to develop and improve our products and services.

  Legal basis: legitimate interests (to enable us to improve our services); consent where required by law.

• To personalize your experience on our 4D Websites: to measure the use and effectiveness of our 4D Websites with various technologies and to personalize your experience while on our 4D Websites, as well as to tailor our interactions with you (see the 4D Cookie Policy for more information).

  Legal basis: consent, legitimate interest (to improve the experience of users of our 4D Websites).

• To control certain activities: to monitor requests in order to guarantee quality of service, compliance with procedures and to combat fraud.

  Legal basis: legal obligations; establishment, exercise or defence of legal claims; legitimate interests (to guarantee the quality and legality of our services).

• To reorganise or make changes to our business: in the event that we: (i) are in negotiations to sell our business or part of it to a third party; (ii) are sold to a third party; or (iii) undergo a restructuring, we may need to transfer some or all of your personal data to the relevant third party (or its advisers) as part of any due diligence process for the purposes of considering any proposed sale or restructuring. We may also need to transfer your personal data to such restructured entity or third party after the sale or restructuring, for them to use for the same purposes as set out in this policy.

  Legal basis: legitimate interests (to enable us to make changes to our business).

• To comply with legal or regulatory obligations: We may process your personal data to comply with our regulatory requirements or to deal with regulators, where appropriate. This may include disclosing your personal data to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations carried out by such parties anywhere in the world or where we are required to do so by law. Where permitted, we will address any such request directly to you or inform you before responding, unless doing so would be harmful to the prevention or detection of crime.

  Legal basis: legal obligations; establishment, exercise or defence of legal claims; legitimate interests (to cooperate with law enforcement agencies and regulators).

ARTICLE 5: Data Retention

4D undertakes to keep personal data for a period that complies with legal provisions or is proportionate to the purposes for which it was recorded. Data relating to your browsing of our online services collected by cookies that you have authorised is kept for a specific period.

The table below shows the main periods for which your data is kept.

ARTICLE 6: Notification of Personal Data Protection Breaches

4D will notify you as soon as possible after becoming aware of any breach of DCP security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to DCP transmitted, stored or otherwise processed.

4D has an internal data leakage procedure, which is available on request from the data protection services (dpo@4d.com).

ARTICLE 7: Access to data collected by 4D

7.1 Access to data within 4D

The following may have access to some of your data:

• Technical support, administrative, accounting, IT and marketing & sales staff.
• 4D Group subsidiaries.

Staff with access to personal data are subject to an obligation of confidentiality (by means of a confidentiality agreement signed on recruitment).

7.2 Our data processors

We may also share your personal data with our data processors who perform services on our behalf, for the purposes described in this Privacy Policy. These include our hosting providers, backend infrastructure providers, infrastructure monitoring providers, contact management and message delivery service providers, support and contact request service providers, user database management service provider, and our security and maintenance providers.

4D imposes on its data processors a level of obligation at least as high in terms of protection of personal data as that set out in this policy and by the applicable regulations.

7.3 Our business partners

4D may offer you services or products from third party business partners. 4D draws your attention to the fact that if you decide to subscribe to the products or services of our commercial partners and you allow them to access some of your information, in particular by connecting to their sites or applications, their confidentiality policies and their cookie deposits are enforceable against you. We have no control over the collection or processing of your data by our commercial partners on their own platforms.

7.4 Police, judicial or administrative authorities

This applies when we are legally obliged to do so or to safeguard the rights, property and safety of 4D Group.

ARTICLE 8: Transfer of Data Outside the European Union

Generally, we store your personal data in the European Union. However, 4D may transfer personal data outside the European Union. In all cases, 4D undertakes not to transfer personal data, without putting in place the appropriate tools to supervise such transfers pursuant to Article 46 of the RGPD, outside:

• The European Economic Area (EEA), or
• Countries recognised as having an adequate level of security by the European Commission.

The Standard Contractual Clauses drawn up by the European Commission are concluded between 4D and third parties located outside the above-mentioned territories.

ARTICLE 9: Rights of Data Subjects and Procedures for Exercising Their Rights

In accordance with Regulation (EU) 2016/679 on the protection of personal data, you have the following rights with regard to your data: right of access to your data in our possession; right to obtain additional information concerning the processing of your data; right to update and rectify your data; right to erasure of your data; right to restriction of processing; in certain cases right to portability.

You also have the right to object to the processing of your personal data based on your consent or our legitimate interest (subject to exceptions provided for by law). In particular, you have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to refuse such processing by clicking on the link provided for this purpose in our marketing communications.

Please note that certain exceptions apply to the exercise of these rights and that you may not be able to exercise them in all circumstances. Moreover, these exceptions vary slightly from one EU Member State to another. For example, in France, in addition to the rights listed above, you also have the right to define guidelines on how you wish your personal data to be used after your death.

To exercise your rights, please write to 4D Legal Department, at the following postal address: 4D, 66 Route de Sartrouville. Parc les Erables- Bâtiment 4 - 78230 or Le Pecq - France or to the e-mail address dpo@4d.com. Before responding to your request, we may verify your identity and/or ask you to provide further information to respond to your request. We will endeavour to respond to your request within a reasonable time and, in any event, within the time limits set by law.

In the event of an unsatisfactory response, you may lodge a complaint with “Commission nationale de l'informatique et des libertés” (CNIL): https://www.cnil.fr/fr/plaintes, or with another competent authority. Please click here to consult the list and contact details of the competent authorities in the European Union:http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

ARTICLE 10: Data collected and processed as a data processor

If your employer or a partner company provides you with access to 4D products and services, or if you are a user of software developed using 4D technologies, we may process your personal data as a data processor. This data is collected and processed solely on behalf of our client (typically the entity that provides you with access to 4D products and services or said software) who acts as the data controller.

For further information on these data processing operations, please refer to the privacy policy of the data controller.

ARTICLE 11: Modifications

We may change the content of our 4D Websites from time to time and, therefore, our Privacy Policy and Cookies Policy may change in the future. If we change this Privacy Policy or our Cookies Policy, we will update the date of the last change below. If these changes are material, we will clearly indicate this on our 4D Websites.

This Privacy Policy was last updated in September 2023.