Privacy policy Shareholders and Subscription warrant holders

Privacy policy for shareholders and subscription warrant holders

This Privacy Policy describes all the data processing that we may carry out as part of management of our shareholders. For complete information on the nature of the processing we carry out, and also on your rights and how to exercise them, please consult the information contained in Volta Medical's General Personal Protection Policy.

What categories of personal data are we likely to collect and process in our capacity as Data Controller?

In the context of managing our shareholder, the personal data we are likely to collect and process includes the following:

Identification data: First and last names, date and place of birth, personal or business address, nationality (where applicable), role
Economic and financial data: Shareholder account number, order number, data relating to share transactions, observations, data relating to shares issued (specifically, number, type, price, total, percentage of shares issued), number of subscription warrants or founder's share warrants allocated with date of allocation, period of validity, date, location, and signature of the warrant to exercise rights or the simplified agreement.
Data relating to shareholder agreements, minutes of decisions and general meetings, attendance fees paid/allocated, attendance sheets, declarations of absence of forfeiture.
Statistical data on the number of shares.

In addition to identification data concerning shareholders or holders of share subscription warrants, the data may include data relating to agents, delegated representatives, and staff of French or foreign authorities (first and last names, position, reporting department, signature, date of signature, professional contact details).

What do we use this data for? What are our purposes?

As part of the management of our shareholders, data is processed so that you and we can execute the documentation necessary to exercise your corporate rights and for the execution of corporate rights themselves, along with the management of formalities relating to company operations. Data is also processed for fundraising and due diligence purposes.

What is the legal basis of our processing?

Depending of the sub-purpose of processing, the legal basis of the processing will be:

performing a contract in force between us, or implementing pre-contractual measures taken at your request.
fulfilling our legal obligations relating to shareholders
or our legitimate interest in the monitoring and management of our shareholder base as well as the preparation of statistics on this matter.

How long do we keep your data?

The retention periods of your data depend on the intended sub-purpose:

when the legal basis is the contract: Data is retained for the duration of the contractual relationship, after which it is securely archived for 5 years.
when the legal basis is the legitimate interest of Volta Medical: Data is retained for the time strictly necessary to fulfill the secondary purpose in question. The data is then permanently deleted from every medium.

Who are the data recipients?

The data is intended to be used by Volta Medical's authorized departments and only if this is necessary for them to fulfill their assigned tasks. The data may also be communicated (i) to third parties (who are not data processors, such as legal counsel, auditors and/or consultants, prospective investors and their respective advisors) and/or (ii) to data processors (for example: data room providers). This communication may take place on a controller-to-controller, controller-to-processor or joint-controller basis.

Are the collection and processing of your data mandatory?

When you decide to become a shareholder of our company or to benefit from share subscription warrants, the collection and processing of your data is mandatory. Failure to provide this data would make it impossible for you to hold shares in our company.

How do we collect your data?

We collect data directly from you.

Do we transfer your Data outside the EU ?

We may carry out data transfers to a country outside of the European Union in the framework of our operations. In this case, we will take all appropriate measures to ensure compliance with applicable regulations within the European Union. You may obtain a copy of these safeguards from our Data Protection Officer, whose contact details are specified in the “Contact” section of Volta Medical’s General Data Protection Policy.