Privacy Notice Regarding the Processing of Personal Data by Pasqal Holding

4.1.1. If you are a job applicant

1. For what purpose do we process your data ?

We process your data to carry out our recruitment process.

2. What are the legal grounds for the processing we carry out?

We do so within the framework of our legitimate interest in recruiting the profiles necessary for the operations of Pasqal Holding.

3. What data do we process?

As part of our recruitment process, we collect the following data:

• Identification data: last name, first name, title; 
• Contact information: address, phone number, email address; 
• Professional information: company, position; 
• Information submitted with job applications; 
• Information you do not enter directly: IP addresses, HTTP protocol elements, website browsing habits, cookies.

4. How do we collect your data?

We collect it directly from you, either through your resume or our applicant tracking system.

5. With whom do we share your data?

Your data is intended for use in connection with Pasqal’s services. It may also be shared with third parties, such as service providers to whom we outsource certain activities (for example, application management). 

Pasqal may be required to disclose personal data to the competent authorities. 

Pasqal ensures that it has sufficient safeguards (including from its partners and service providers) regarding the protection of personal data for each data transfer

6. How long do we retain your data ?

If you are not hired, we will retain your resume for up to two years after the recruitment process ends. If you are hired, you will be subject to the policies applicable to employees of Pasqal Holding.

4.1.2. When you are registered on the Pasqal Community

1. For what purposes do we process your data?

We process your data to establish and maintain the quantum-focused discussion community.

2. What are the legal grounds for the processing we carry out?

We do so within the framework of our legitimate interest in facilitating exchanges among quantum technology stakeholders.

3. What data do we process?

As part of our recruitment process, we collect the following data:

• Identification data: last name, first name, title; 
• Contact information: email address; 
• Professional information: company, position, area of expertise; 
• Information you do not enter directly: IP addresses, HTTP protocol elements, website browsing habits, cookies.

4. How do we collect your data?

We collect it directly from you when you register.

5. With whom do we share your data?

Your data is intended for use within the defined scope of the platform. It may also be shared with third parties, such as service providers to whom we outsource certain activities (for example, platform maintenance). 

Pasqal may be required to disclose personal data to the competent authorities. 

Pasqal ensures that it has sufficient safeguards (including from its partners and service providers) regarding the protection of personal data for each data transfer

6. How long do we retain your data?

You have control over your account and can decide whether to delete it or not. 

4.2. If you are a business contact

4.2.1. If you are a prospect

1. For what purposes do we process your data?

We process your data to promote the products and services of Pasqal Holding, and to:

• Respond to your requests for information; 
• Publish your comments;  
• Manage your requests to register for conferences and events, as well as operations related to the organization and conduct of such events; 
• Distribute newsletters, articles, information, and alerts; 
• Inform you about our products and services that may be of interest to you; 
• Improve the quality of our service; 
• Distribute B2B commercial offers. 

2. What are the legal grounds for the processing we perform?

We process your data based on Pasqal Holding’s legitimate interest in promoting its products and services, as well as your consent to receive information from us or participate in events we organize.

3. What data do we process?

To carry out the processing described above, we may need to process the following data:

• Identification data: last name, first name, title; 
• Contact information: address, phone number, email address; 
• Professional information: company, job title; 
• Images and audio: photos and videos taken during events organized by Pasqal Holding;
• Information you do not enter directly: IP addresses, HTTP protocol elements, website browsing habits, cookies. For more information, please visit or our page dedicated to cookies at https://www.pasqal.com/cookie-policy/.

4. How do we collect your data?

We collect it directly from you through various channels:

• When you browse our websites, including their mobile versions; 
• When you submit a contact form to us; 
• When you register for conferences or events we organize in France or abroad; 
• When you subscribe to our newsletters, marketing alerts, or other information; 
• When you request to download a research document published on our website.

5. Who do we share your data with?

Your data is intended for use in connection with the services provided by Pasqal Holding. It may also be shared with third parties, such as service providers to whom we outsource certain activities.

Pasqal Holding may be required to disclose personal data to the competent authorities. 

Pasqal ensures that it has adequate safeguards (including from its partners and service providers) regarding the protection of personal data for each data transfer.

6. How long do we retain your data?

Unless a contract is subsequently concluded, we retain your data for up to two years after the last contact. 

Images and audio recordings collected during events organized by Pasqal may be retained for up to 5 years from the date they were captured.

4.2.2. When you are a customer

1. For what purposes do we process your data?

Your data is processed in order to: 

• Provide the service requested from Pasqal;
• Maintain the business relationship;
• Manage billing for the services ordered;
• Carry out corporate transactions (including mergers, acquisitions, and divestitures);
• Manage your registration requests for conferences and events, as well as operations related to the organization and conduct of such events;
• Prevention, detection, and investigation of fraud or other breaches of business ethics;
• Managing disputes and litigation and handling any reports submitted or arising from Pasqal Holding’s whistleblowing system;
• Comply with our legal and regulatory obligations;
• Conducting internal or external audits.

2. What are the legal grounds for the processing we perform?

The management of the business relationship and associated processing activities are based on the performance of the contract or pre-contractual measures.

The management of the commercial relationship and the protection of our interests are based on our legitimate interest.

Finally, processing related to alert management, fraud prevention, or compliance with any other legal obligation is based on compliance with the relevant legal obligations.

3. What data do we process?

To carry out the processing described above, we may need to process the following data:

• Identification data: last name, first name, title; 
• Contact information: address, phone number, email address; 
• Professional information: company, job title; 
• Images and audio: photos and videos taken during events organized by Pasqal Holding;
• IT data: data related to the prevention of fraud or other breaches of business ethics.

4. How do we collect your data?

Data is collected either directly from you when establishing a business relationship, or indirectly through our tools designed to combat breaches of business ethics.

5. With whom do we share your data?

Your data is intended for use in connection with Pasqal Holding’s services. It may also be shared with third parties, such as service providers to whom we outsource certain activities.

Pasqal Holding may be required to disclose personal data to the competent authorities. 

Pasqal Holding ensures that it has sufficient safeguards (including from its partners and service providers) regarding the protection of personal data for each data transfer.

6. How long do we retain your data?

Contractual data is retained for five years from the termination of the contract.

Billing data is retained for ten years from the date of issuance.

Data related to the prevention of breaches of business ethics is retained for ten years from the date of the report.

Images and audio recordings collected during events organized by Pasqal Holding may be retained for up to five years from the date they were captured.

In the event of an actual or potential dispute (e.g., if we need this personal data to establish or defend legally valid claims), the associated data will be extracted and stored in a separate environment until all legal remedies have been exhausted.

4.2.3. When you are a supplier

1. For what purposes do we process your data?

Your data is processed in order to: 

• Track the service ordered by Pasqal Holding;
• Monitor the business relationship;
• Manage billing for services ordered;
• Prevention, detection, and investigation of fraud or other breaches of business ethics;
• Managing disputes and litigation and handling any reports submitted or arising from Pasqal Holding’s whistleblowing system;
• Comply with our legal and regulatory obligations;
• Conducting internal or external audits.

2. What are the legal grounds for the processing we perform?

The management of the business relationship and associated processing activities are based on the performance of the contract or pre-contractual measures.

The protection of our interests is based on our legitimate interest.

Finally, processing related to alert management, fraud prevention, or compliance with any other legal obligation is based on compliance with the relevant legal obligations.

3. What data do we process?

To carry out the processing described above, we may need to process the following data:

• Identification data: last name, first name, title; 
• Contact information: address, phone number, email address; 
• Professional information: company, job title; 
• IT data: data related to the prevention of fraud or other breaches of business ethics.

4. How do we collect your data?

Data is collected either directly from you when establishing the business relationship, or indirectly through our tools designed to combat breaches of business ethics.

5. With whom do we share your data?

6. How long do we retain your data?

Contractual data is retained for five years from the termination of the contract.

Billing data is retained for ten years from the date of issuance.

Data related to the prevention of breaches of business ethics is retained for ten years from the date of the report.

In the context of an actual or potential dispute (e.g., if we need this personal data to establish or defend legally valid claims), the associated data will be extracted and stored in a separate environment until all legal remedies have been exhausted.

4.3 If you are a supervisory authority

1. For what purposes do we process your data?

Due to their duties, supervisory authorities may instruct their agents to contact Pasqal Holding, whether for an exchange of information, an investigation, or to conduct an audit. If you are one of these agents, your data may be processed in connection with such audits and any follow-up actions resulting from them.

2. What are the legal bases for the processing we carry out?

The processing described is carried out in accordance with the legal and regulatory obligations applicable to Pasqal Holding, such as the French Data Protection Act, the GDPR, the Labor Code, etc.

3. What data do we process?

The categories of data processed are, in whole or in part, as follows:

• Identification data (e.g., last name, first name);
• Professional data (e.g., job title, work email address).

4. How do we collect your data?

Your data was collected directly from you when you contacted us, or indirectly, either through our Advisors or through the staff of the relevant supervisory authority.

5. With whom do we share your data?

As part of this processing, your data may be disclosed to the following categories of recipients:

• Pasqal Holding’s processors carrying out all or part of the processing described;
• Certain suppliers (e.g., external consultants);
• Public entities to which regulations grant a right of access;
• Entities within the Holding Company that have a legitimate need to know.

6. How long do we retain your data?

The retention periods for your data are:

• Primarily in the email system used; this data is deleted within 90 days of the employee’s departure from the workforce; 
• In our records for a maximum of ten years from the end of the procedure.

4.4. Anyone accessing the premises of Pasqal Holding (Video Surveillance)

1. For what purposes do we process your data?

Pasqal Holding has installed video surveillance in its premises to ensure the safety of its staff and property. The footage recorded by this system is not used for the purpose of monitoring staff or tracking work hours.

2. What is the legal basis for the processing we perform?

The legal basis for the processing is legitimate interest.

3. What data do we process?

Only images, no audio is recorded.

4. How do we collect your data?

Directly via cameras.

5. With whom do we share your data?

In the event of an incident, the images may be viewed by authorized personnel of Pasqal Holding (currently, two individuals in General Services) and by law enforcement. Company personnel responsible for equipment maintenance may also access the images for this purpose only.

6. How long do we retain your data?

The footage is retained for one month.

In the event of an incident involving the safety of persons or property, however, the video surveillance footage may be extracted from the system. It is then stored on a separate medium for the duration of the proceedings related to that incident and is accessible only to authorized personnel in this context.

5. Exercising our rights

As a data subject, you have the following rights:

1. To obtain a copy of your Personal Data as well as information on how Personal Data is processed and the legal basis for such processing (right of access);
2. To correct inaccurate Personal Data (including the right to complete incomplete Personal Data);
3. To erase your Personal Data (right to be forgotten);
4. Restrict the processing of your Personal Data when:
   • Its accuracy is contested;The processing is unlawful but you object to the erasure of your Personal Data;We no longer need your Personal Data but it is still necessary for the establishment, exercise, or defense of legal claims;

5. Request the portability of your Personal Data in a machine-readable format to a third party (or to you) if our processing is based on your consent or on the performance of a contract entered into with you;

6. Provide general or specific instructions regarding the processing and use of your Personal Data after your death;

7. Withdraw your consent to the processing of your Personal Data (if such processing is based on your consent) without affecting the lawfulness of processing based on consent prior to its withdrawal;

8. Object to the processing of your Personal Data for marketing purposes. We also remind you of the option to register for free on the Bloctel do-not-call list; 

9. Obtain or review a copy of the appropriate measures taken to transfer your Personal Data to a third country or to an international organization.

These rights may be exercised at any time and free of charge by sending an email to the following address: privacy@pasqal.com or a signed letter to the Data Protection Officer, Pasqal Holding, Immeuble le Phoenix, 24 Av. Emile Baudot, 91120 Palaiseau. Please note that these addresses are dedicated to handling requests to exercise rights and questions related to the protection of personal data. Requests unrelated to this subject will not be processed and will not be answered.

To do so, your request must include the following information:

1. If you are a current or former customer: 

• The specific reason for the request;
• Your first and last name(s);
• Your customer reference

2. If you are a prospective customer:

• The specific reason for your request;
• Your first and last name(s);
• If you were contacted by our services: the phone number or email address through which you were contacted;
• If you have initiated a subscription: the phone number or email address you provided.  

3. If you are a supplier or an agent of a supervisory authority:

• The specific reason for the request;
• Your first and last name(s);
• The circumstances under which we may have collected your data (e.g., contractual relationships, audit, etc.)

A copy of an identification document (e.g., ID card, passport) may also be requested if necessary, in case of doubt regarding your identity as the requester.

You must also specify the address (email or postal) where you wish to receive the response.

The file related to a request to exercise rights is retained for six months in the active database, then for five years in an intermediate archive database starting from the closure of the request to exercise rights.

You also have the option to access and modify certain Personal Data by logging in directly to your customer account.

If you no longer wish to receive the Pasqal Holding email newsletter, you can click the unsubscribe link at the bottom of each email.

You also have the right to file a complaint with the local data protection supervisory authority: Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07.

6. Transfer of your Personal Data

As part of its activities, Pasqal Holding may need to securely transfer certain data to third parties, including Personal Data, to perform tasks necessary for the fulfilment of your contract and the improvement of its tools.

Any transfer of data by Pasqal Holding to a third country outside the EEA is carried out in accordance with applicable regulations and in a manner that ensures adequate protection of your data. In the absence of an adequacy decision by the European Commission, transfers are carried out in accordance with Article 46 of the GDPR, through standard contractual clauses.

In the event of a potential transfer to the United States, Pasqal Holding will ensure that its partner:

• has subscribed to the “EU-US Data Privacy Framework,” that is, has agreed to self-certify with the U.S. Department of Commerce; or
• has signed the standard contractual clauses based on the European Commission’s model. 

To ensure adequate protection of personal data originating from the EEA that may be transferred to Pasqal Holding entities established outside the EEA, specific agreements including the standard contractual clauses based on the European Commission’s model have been signed.

Finally, Pasqal Holding may also be legally required to disclose your Personal Data to the competent authorities. This applies in the event of legal proceedings or an order from a public authority.

7. Security of your Personal Data