INCO GROUP PRIVACY POLICY

1. INCO'S COMMITMENT TO PROTECTING PRIVACY
INCO is committed to protect your privacy online.
Consequently, we comply with all applicable legislation. To achieve a high level of privacy,
we have decided to use as standard for all our entities the obligations set by the European
Union Regulation n° 2016/679 of the European Parliament and of the Council of 27 April
2016 on the protection of natural persons with regard to the processing of personal data andon the free movement of such data and repealing Directive 95/46/EC (hereinafter “GDPR”).
This privacy policy (hereinafter “Policy”) formalizes our commitments and legal obligations toyou and describes how we process your personal data.
2. WHO WE ARE
In this Privacy policy, “INCO” means:●●INCO entities together; orThe INCO entity you have been in contact with, through its website or by participating
to an INCO program. Your data are processed by this entity, excepted in some cases
explained in this policy.

Depending on your country, your personal data are processed by the following entity, acting
as data controller:

Country

INCO Group EntityContact for questions
regarding personal data

FranceInco Dorbeljin

dpo@inco-group.co

Inco.org
Inco France
Inco & Co
Inco Ventures
Inco FDD

Other countries

Inco Dorbeljin

dpo@inco-group.co

Inco.org
Inco France
Inco & Co
Inco Ventures
Inco FDD
Inco Community gGmbH
Inco Community Inc.
Inco Ventures
Inco Australia
Inco Tunisie SARL
Inco Polska LLC

3. SCOPE OF THIS POLICY AND DATA PROCESSED BY THIRD-PARTIES
If you are involved in one of our programs, you already know that we work with local
partners. In such case, the partner you have been in contact with will process your personal
data on our behalf, in accordance with our instructions. However, this partner may also
process your data in its own name and on its own behalf. We recommend that you read its
privacy policy. Would you have any demand related to personal data processed by a partner
we would refer your demand to this partner.
Additionally, our websites may include links towards third party websites or third party plug-in
and cookies (see Article 10. on Cookies). These third parties process your personal data for
their own purposes and may apply different privacy rules. It is your responsibility to read theirprivacy policy. We decline all responsibility regarding the processing of your personal data bythird parties.

4. YOUR ACCEPTANCE OF THIS POLICY
The use of our services and your participation to our programs implies your full acceptanceof this Policy.

We may modify this Privacy policy from time to time. Consequently, we recommend that you
consult it regularly.
This Policy will always be accessible on our websites.

5. WHAT PERSONAL DATA DO WE COLLECT?
In accordance with the principle of minimization, we only collect and process the minimal
amount of personal data needed. Whenever we can, we limit access to your personal dataand implement security measures such as pseudonymization.
Depending on the context, we collect the following personal data:
On participants or applicants to our programs:•

Identification data: e-mail, name and surname, phone number•

Profile data of students: age, gender, education, location.

•
Social-economic and/or legal status, depending on the program: employment status,
range of income, employment sector, part of underserved community, migration status, etc..
•
Special categories of data, depending on the program: personal data revealing racialor ethnic origin, political opinions, religious or philosophical beliefs, data concerning health(including disabilities) or data concerning a natural person's sex life or sexual orientation,
trade union membership.
•Information on training progress.

•Communication materials: photographs, video and audio recordings.

On the person making a proposal of partnerships or sharing a job offer with our participants:•Identification data: name and surname, e-mail, phone number, position held andentity.
On applicants to a job in an INCO entity:•Identification data: name and surname, e-mail, phone number, address.

•Relevant data regarding applicant qualifications and wishes.

6. WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE
RETAIN IT?
The table below sets out why we process your data, the lawful basis for the processing andthe associated retention period:

Objectif / Activité

Base légale

Durée deconservation

Direct application to a program

Legitimate interest to selectapplicants/Consent if sensitive data areincluded

1 yearAccess and use of online
learning platforms

Consent

Programduration

Measuring progress of learners
and improve our programs

Legitimate interest to collect data needto improve our programs

Programduration

Understanding the profile ofparticipants

Consent

Programduration

Measuring the social impact ofthe program

Consent

Programduration

Communication materials forpromotion and education
purposes

Consent

5 years

Answer your proposition ofpartnership or share your job
offer with participants

Legitimate interest to process your datain order to assess your demand andanswer it

3 years

Litigation risk management

Legitimate interest to retain data for theestablishment, exercise, or defense oflegal claims

5 years

Process application of job
applicants

Legitimate interest to select applicants

2 years

7. RECIPIENTS OF YOUR PERSONAL DATAYour personal data may be shared internally with our services. In case of need, yourpersonal data may be shared to other entities of INCO.
If you’re involved in the Work In Tech Program, your personal data will be also processed byour partner on our behalf.
Your data are also processed by our software providers.

8. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS
For the purposes set out in article 6 of this Policy, we may transfer your personal data tointernal or external recipients located who may be in countries offering different levels ofpersonal data protection.
Consequently, in addition to implementation of this charter, we employs appropriate
measures to ensure secure transfer of your personal data to an INCO entity or to an external
recipient located in a country offering a different level of privacy from that in the country
where the personal data was collected.

9. DATA SECURITY
We take appropriate technical and organizational measures to protect your personal data
against illicit or accidental destruction, alteration or loss misuse and unauthorized access,modification or disclosure.
In particular, we pseudonymize your personal data as much as possible.

10. COOKIESINCO uses cookies on its websites.
A) What is a cookie
Cookies are small text files sent to your browser by a web server in order to return
information to this server.

Cookies ensure smooth functioning of websites or enhance navigation. They may collectinformation on you and your navigation, which can be personal data. You are warned by abanner displayed on our website that we send cookies to your device, which are then stored
on it and remain active for a certain period.
B) Types of cookies
INCO cookies (« first party cookies »): these cookies are sent to your device by our website
i.e., by our company.
Third party cookies: this type of cookie is sent to your device by third party entities, with
their own web server. By doing so, these entities may collect your personal data. We do not
exercise any control over the processing of personal data by this type of cookies. We decline
all responsibility regarding the processing of personal data by these entities.
Please find the list of companies that sent third party cookies through our websites and theirprivacy policy:●Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Privacy policy: https://policies.google.com/privacy●

Linkedin Corp., 1000 West Maude Avenue, Sunnyvale, CA, 94085, USA

Privacy policy: https://www.linkedin.com/legal/privacy-policy●Facebook, Inc., 1601 Willow Road Menlo Park, CA 94025, USA

Privacy policy: https://www.facebook.com/about/privacy/C) What cookie do we use and why ?
(i) Necessary cookies
Necessary cookies allow you to navigate on our website and access to all our services. Your
consent is not required to store this type of cookie on your device.
(ii) Analytics cookies
Analytics cookies are used to collect data that allows us to understand how users interact
with our website. These insights allow us both to improve content and to build better featuresthat improve the user's experience.
(iii) Advertisement cookies
This type of cookie will collect data on your navigation and behavior to display to you
advertisement based on topics that interest you. Your consent is always required for thestorage of these cookies.
D) How can you accept or refuse cookies?

When visiting our website, you can set your cookies preferences to:●●●

Accept all cookies, orRefuse all non-necessary cookies, orAccept cookies of your selection.

Setting your preferences may impact you access to services provided by our website. We
decline any responsibility over the consequence of your refusal to the storage of cookies.
Your preferences can be set:●●
●By clicking on the buttons on the cookie banner displayed at your first visit on ourwebsite ;By setting your choice with our Cookie Consent Manager;
By setting your browser :Internet Explorer:
https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-0
43d-7c16-ede5947fc64d
Firefox:https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox
Safari:https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
Chrome:https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
11. YOUR RIGHTS
You have the right to obtain information about and access your personal data collected wecollect, subject to applicable legal provisions. You also have the right to have your personal
data rectified, erased or have the processing of it restricted. Furthermore, you have the rightto data portability and to issue instructions on how your data is to be treated after your death.
You can also object to the processing of your personal data, subject to legal provisions. If theprocessing of your data is based on your consent, you also have the right to withdraw yourconsent at any moment.
We remind you that your personal data are process in order answer your demands or toallow you to participate to one of our programs. Without these data, we may not be able toanswer your demand and your participation may be hindered or impossible.
In the event that you wish to exercise any of your above rights, please contact us directly:
By sending an email to dpo@inco-group.co.

By writing a mail to the INCO entity you have been in contact with (see art. 2 for theaddress).
In case of reasonable doubts concerning your identity, you may be asked to provide a copyof an official piece of identification, such as an ID card or passport. All requests will receive a
response as swiftly as possible.
If you are not satisfied with the way we process your personal data, you have the right tointroduce a complain before the competent data protection authority.