Privacy Policy

HGH may modify this Privacy Policy as needed. This new Privacy Policy has evolved since its last update of 14/12/2023.

HGH reserves the right to modify this Privacy Policy as needed, for example to comply with evolutions in laws, regulations, HGH practices and procedures, or requests by supervisory authorities.

In this case, HGH will inform impacted individuals of material changes in this Privacy Policy. HGH will post new versions on relevant internal and external websites and digital platforms.

HGH is committed to protecting your privacy and personal information. This Privacy Policy informs you of our privacy practices and of how personal information is protected. You should read it before accessing HGH digital content.

HGH strongly supports the fundamental rights to privacy and data protection as well as compliance with national and international privacy laws.

This Privacy Policy describes how HGH processes and protects personal information of individuals who use our websites and other digital platforms as well as in the context of our offline business activities.

HGH has adopted an internal Global Data Privacy Policy which is applicable to all our subsidiaries for the collection, processing, use, dissemination, transfer and storage of personal information. It imposes common rules for all of our subsidiaries of all countries, and aims at ensuring a high level of protection of personal information within HGH.

In the HGH’s privacy policy, we respect and take into account the major principles of EU data protection rules as our Head Offices is located in the European Union.

This Privacy Policy applies to all HGH subsidiaries and digital content, unless a specific privacy notice has been released to supplement it or to replace it. You should check the privacy notices made available to you on each digital platform such as websites or applications.

HGH is a global company, with legal entities, business processes, management organizations, and system infrastructure that cross borders. This Privacy Policy applies to all HGH data processing activities run by our controlled subsidiaries, including product and service offerings and digital content (e.g. event registrations, websites, applications, tutorials, e-trainings, newsletters, advertising, and other communication). It may however be supplemented by a more specific privacy notice/statement/policy or even superseded by another policy, specific to a particular HGH program, product, service, content or entity. It is important that you read the statements made available to you for your full information. For instance, the processing of job candidate applications is governed by the privacy notice posted on our Career Portal.

The data controllers of the data processing activities are the HGH subsidiaries who have determined the data processing means and purposes. They may vary on a case-by-case basis. In many instances, HGH Systèmes Infrarouges SAS, 10 rue Maryse Bastié 91420 Igny – France, HGH’s Head Office, is the data controller of global data processing activities. For information you can contact us at hgh@hgh-infrared.com

This Privacy Policy binds all HGH controlled subsidiaries, and their employees.

We use personal information for various purposes, including to fulfill orders and requests, to manage customer and prospect relationships, conduct surveys, improve our products, services, digital content as well as user journeys, manage user accounts and programs, analyze activities on our digital platforms, run marketing activities, provide user with contextual and relevant information, ensure the security of our activities, protect against fraud, and, more generally, run our business activities.

Our primary goal in collecting information is to provide you with superior service and a smooth, efficient and personalized experience while using our digital content.

HGH collects personal information for the following purposes:

• To fulfill orders of product, services and digital content. We collect this information to deliver your order, to obtain payment, to provide the functionalities of our applications, to communicate with you about the status of your order and for contract management purposes;
• To better address future requests for information and support. We keep record of exchanges including personal information to provide an optimized service on contacting us for support;
• For relationship management purposes which includes communicating about the products, services and digital content including email communications and messaging;
• To conduct surveys and polls. We may collect personal information to complete surveys and contact you for follow-up. We use this information to measure satisfaction, get to know our customers better and improve products, services and digital content;
• To improve our products, services and digital content; for instance, we analyze the use of our applications and websites in order to identify areas and functionalities where users have difficulties, and we improve them;
• To learn about your browsing and searching activity. We collect navigation information when you visit our digital content or click on links for products and services. We collect this information to improve user experience for next, help our websites run more efficiently, to gather broad demographic information to analyze the websites’ activity and performance, and to evaluate the relevance and effectiveness of our advertising to better serve our customers. We may use cookies and other identifiers or similar technologies (referred to hereinafter as “Cookies”) to obtain information on the referring website, type of browser used, the content viewed, as well as the date and time of access to the digital content. You may read our Cookie Notice for more information on our use of Cookies and your options for managing Cookies;
• To run promotional programs and activities: we collect personal information when you join a promotional or reward program or activity. We use this information to administer the program or activity, to send relevant e-mails about the program and activity, notify winners, and make the winners’ list publicly available in accordance with applicable regulations and laws;
• To send you marketing information by mail, phone, text messages, email and electronic communications about promotions, news and new products or services that we think may be of interest to you in compliance with applicable opt-in and opt-out requirements. This can be conducted by HGH, its subsidiaries or selected third-parties acting on our behalf;
• To provide you with certain communications and/or targeted information about our products and services through pop-ups, banners, videos, emails and any other advertising format. Please read our Cookie Notice for more information on the use of Cookies and your options for managing them;
• To create a user profile that we may use for our sales and marketing operations and  to provide  you with personalized content and services, on the basis of  information obtained online from different digital platforms and information we collected about you offline   considering your cookie preferences (see our Cookie Notice). We may also use Cookies to geographically target users.
• To ensure the security of our products, services and digital content, of our activities and of others, for the protection against fraud and the compliance with our terms and conditions and this Privacy Policy. We may also investigate potential breaches; ‘
• To enable or administer our business, such as for quality control and consolidated reporting;
• To support corporate transactions or reorganizations in which HGH is involved;
• For business continuity and disaster recovery;
• To comply with legal obligations to which we are subject. For example, accounting and tax obligations;
• Any other purpose otherwise conveyed to you.

HGH processes various types of personal information including identity and contact related information, professional related information, information about preferences, interactions with us, financial related information, online traffic data and the content you provide to us. In most instances this information is obtained from customers, partners and users. We also purchase lists from marketing agencies and obtain information from our partners, through Cookies and social networks.

Personal information (also called personal data) is any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

The types of personal information we process about you may include:

– Identity and contact related information, such as name, company, email address, phone number, photo, age range, contact addresses;

– Professional information, such as customer type, purchasing authority, purchasing timeframe; acquisition and use of HGH products, services and digital content;

– Information which is specific to the digital platform you use

– Your preferences such as product and service preferences, contact preferences, marketing preferences;

– Your interactions with us such as queries, orders, claims, survey answers;

– Online traffic data such as IP address, device and system identifiers, referring website, type of browser used, consulted content, and location, based either on your IP address or on information transmitted by your mobile device;

– Content that you have provided via online forums or otherwise (see section 6 “Your content” below).

This Privacy Policy does not cover personal information rendered anonymous, that is if individuals are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or labor. If anonymized data becomes identifiable, then this Privacy Policy shall apply.

In most instances we collect personal information directly from users who have a business relationship with us. We may also obtain information through a reseller or a business partner, by purchasing customer lists from marketing agencies, from your online browsing experience, from social networks when you connect with these network’s credentials and through Cookies. You may obtain more precise information on the third-party source (if any) of personal information by contacting us at the email address indicated in section 10.

You may choose to contribute content, including photos or comments, to online forums, applications or other digital platforms operated by HGH. Your content must be harmless. It must respect the law, the rights and interests of others. Need to have obtained consent before sharing someone else’s data. You should apply caution before sharing information in a forum.

The content provided to us must respect the rights and interests of others, including their rights to protection of personal information and privacy. It should not be offensive, disrespectful or be harmful in any way.

Any provision of personal information to HGH about another individual must be compliant with privacy laws, including with notice and consent requirements for the disclosure of that information.

While HGH strives to protect your personal information, providing it online on shared forums is not risk-free. If you post, comment, indicate interest, or share personal information, including photographs, to any forum, social network or blog, please be aware that any personal information you submit can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor HGH have control over. HGH is not responsible for the personal information you choose to submit in these forums. You should apply caution before deciding to share information about yourself or another person.

We share personal information with the HGH subsidiaries and the service providers involved in our activities, with advertising and marketing agencies, with social networks if you use their login credentials, with third-party websites if you register with HGH credentials, competent regulatory bodies and authorities and business successors.

HGH is a global group of companies which works as one. To provide the best service to customers, prospects and users, personal data may be shared amongst personnel working for different entities. It may be the case, for example, for customer relationship management, sales or product support, marketing, product development purposes, improvement of the products, services and digital content, data quality checks, or security, finance, regulatory and compliance purposes.

We resort to service providers to carry out data processing activities and to provide our products, services and online content to you. These service providers include, without limitation, providers of hosting facilities, information systems, advertising and marketing agencies, IT support, security services, financial services, carriers who deliver products, outside accounting firms, lawyers and auditors.

We ensure all service providers working under contract for HGH are compliant with data privacy laws and aligned with HGH guidelines.

We also share the information as follows:

• In connection with the provision of advertising, we may share some limited personal information (e.g. device identifiers, Cookie identifiers) with ad exchanges or agencies that manage advertising on third-party websites and apps on which you may see advertising.
• You may access our digital content and/or register through login credentials of third-party websites (such as LinkedIn). If you do so, we will be able to access some of the information you registered on these social networks, to assist you to pre-fill the registration form for HGH digital content. By using the login credentials of these third-party websites, you may at the same time inform your contacts on these sites that you have created an account with HGH. If you want to know more about the information accessible by your contacts on these sites and how to restrict their communication, we encourage you to read their terms of use and privacy policies.
• HGH may disclose your personal information as necessary to potential buyers and successors in title, to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which HGH participates.
• Where required by law or court orders or to protect our legal rights, we will disclose your personal information to government agencies, regulators and competent authorities.
• In other ways described in this Privacy Policy or to which you have otherwise consented.
• Aggregated with other information, in such a way that your identity cannot reasonably be determined (for example, statistical compilations).
• We will not sell or rent your personal information to a third party without your permission.

HGH complies with widely recognized key data protection principles (fairness, purpose limitation, data quality, data retention, compliance with individuals’ rights, security) and takes reasonable measures for the security of personal information.

HGH respects the privacy rights and interests of individuals. HGH and its subsidiaries observe the following principles when processing personal information:

1. Processing personal information fairly and lawfully;
2. Collecting personal information for specified, legitimate purposes and not processing it further in ways incompatible with those purposes;
3. Collecting personal information which is relevant to and not excessive for the purposes for which it is collected and used. We may render information anonymous when feasible and appropriate, depending on the nature of the data and the risks associated with the intended uses;
4. Maintaining accurate personal information, and where necessary, keeping it up-to-date. We will take reasonable steps to rectify or delete information that is inaccurate or incomplete;
5. Keeping personal information only as long as it is necessary for the purposes for which it was collected and processed;
6. Processing personal information in accordance with individuals’ legal rights;
7. Taking appropriate technical, physical, and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to personal information;
8. When processing sensitive personal information, ensuring appropriate notice and consent or that the processing otherwise complies with applicable law;

HGH and all its subsidiaries must ensure that the above principles are complied with.

HGH and its subsidiaries are committed to taking commercially reasonable technical, physical, and organizational measures to protect personal information against unauthorized access, unlawful processing, accidental loss or damage, and unauthorized destruction. We implement access control measures for our internal systems that hold personal information. Authorized users are given access to such systems through the use of a unique identifier and password. Access to personal information is provided to our staff for the sole purpose of performing their job duties. We sensitize our employees on proper use and handling of personal information. We also require our service providers to maintain compliant security measures. We implement security measures to determine the identity of registered users, so that appropriate rights and restrictions can be enforced for these users. In case of a registered user, we use both log ins and passwords for authentication.

By using our digital content or providing personal information to us, you agree that we may communicate with you electronically or otherwise about related security, privacy, use and administrative activities. In spite of our efforts to implement appropriate security measures, online browsing carries inherent risks and we cannot guarantee that it is risk-free.

You should read the privacy policy of third-party websites and social media and adjust privacy settings as you see fit. Non-HGH websites and platforms are not covered by this Privacy Policy.

HGH digital platforms may provide links to third-party applications, products, services, or websites for the user convenience and information. If you access those links, you will leave the HGH digital platform. HGH does not control those third-party sites or their privacy practices, which may differ from HGH’s practices. We do not endorse or make any representations about third-party sites. The personal information you choose to provide or that is collected by, these third parties are not covered by the HGH Privacy Policy. We encourage you to review the privacy policy of any site you interact with, before allowing the collection and use of your personal information.

We also provide social media links that enable you to share information with your social networks and to interact with HGH on various social media sites. The use of these links may result in the collection or sharing of information about you. We encourage you to review the privacy policies and the privacy settings of the social media sites with which you interact to make sure you understand the information that may be collected, used and shared by those sites and to adjust these settings as you see fit.

HGH will comply with your data protection rights, including your rights to request access to your personal information and to request that it be deleted or amended. You can always opt out of any direct marketing activity performed by HGH.

HGH will comply with your data protection rights, including your rights to access and correct your personal information. You may enquire about the nature of the personal information stored or processed about you by any HGH entity. You will be provided access to your personal information, regardless of the location of the data processing and storage.

You can request access to your personal information and request that it be deleted or amended at any time. To exercise your rights please click here or send an email to hgh@hgh-infrared.com

You always have the right to opt out of our marketing communications. Your prior consent is sought, when required by any applicable law. To opt out of marketing emails, simply use the functionality provided at the bottom of any email we send.

Country-specific sections may supplement this section.

HGH also complies with GDPR- specific requirements, including those relating to legal grounds for processing, cross-border data transfers, automated decision making and profiling, data retention, additional rights, claims and DPO contact details.

11.1 On what legal ground is HGH relying to use personal information?

The use of personal information is necessary, with respect to the purposes mentioned in section 3 above, to, respectively:

– Perform the contract entered into between HGH and you in the context of the use of our products, services or digital content. The performance of the contract includes knowing who you are, and your specialty and interacting with you for its performance. It includes as well addressing your requests for information, support, your job applications, managing your accounts and your enrolment into our programs and ensuring compliance with terms and conditions and with this Privacy Statement.

– Comply with legal obligations to which we are subject. For instance, mandatory tax and accounting obligations or addressing filing obligations and requests by competent regulatory bodies and authorities.

– When it comes to:

o Surveys, some are carried out in our legitimate interest because they are to measure your satisfaction with services you requested from us. For other surveys we will request your consent. You will always be free to respond.

o Providing you with marketing communications and interest-based advertising, these activities carried out by us and by our subsidiaries are in our legitimate interests. We will always provide you a possibility to opt out and where required by applicable law we will seek your prior consent.

o Using location data transmitted by your mobile device, we will seek your prior consent, where required by applicable law.

We may also process your personal information for the purposes of our legitimate interests provided that such processing shall not outweigh your rights and freedoms, in particular to:

– Protect you, us or others from threats (such as security threats or fraud),

– Comply with the laws that are applicable to us around the world,

– Improve our products, services and digital content,

– Perform profiling to provide targeted content and interest-based advertising

– Share information between HGH subsidiaries and service providers as described in section 7,

– Understand and improve our online activities, our business, our customer basis and relationships generally.

– Enable or administer our business, such as for quality control and consolidated reporting

– Manage corporate transactions, such as mergers or acquisitions.

11.2 Will personal information be transferred abroad?

At HGH, a global company, the teams working on fulfilling the data processing purposes may have global or multi-country roles. They can then be located anywhere in the world where HGH operates, including outside the European Union, in countries which do not have equivalent standards for the protection of personal information as the country where you are located. We may also transfer data to service providers located outside of the EU, including in the United States of America. In the event that these data transfers cannot claim an adequacy decision by the European Commission, HGH will ensure that they comply with applicable legal requirements, for example by executing standard contractual clauses or through its Binding Corporate Rules for intragroup transfers as a data controller. To obtain more details on these transfers and, where appropriate, copies of the applicable safeguards implemented, you may contact: hgh@hgh-infrared.com

11.3 Do we build profiles and do we make automated decisions?

We may create user profiles or make automated decisions for the following purposes:

1. To carry out our sales and marketing operations.

Registration information (professional specialization, information on your online activity, topics of discussion with our representatives, etc.) is grouped together in a digital profile within our contact database. It enables to propose content that matches these profiles. This processing is performed on the basis of our legitimate interest. It does not use end to end automated decision.

2. To provide a personalized, unified experience on our digital content when a user interacts with it.

To offer the best user experience on our digital platforms and provide the most relevant information at the time the user interacts with them, the information that is presented is adapted in real time according to what seems to correspond to the user’s interest. This processing uses end to end automated decision. It is performed with the user’s prior consent.

2.1. This processing activity relies on the creation of a user profile in order to understand the user’s centers of interest. This profile is created automatically by aggregating the user’s interactions with digital content (web pages, e-mails, publications on social networks, online portals and applications, etc.). Tracers and “cookies” are used to identify the actions of the same user across sites and contents, specifically the so-called TEAL and TAPID cookies.

The user consents to the creation of this profile by agreeing to the “customization cookies” category. The user may withdraw consent at any time by rejecting this category. The available on our website provides further details on the technologies used and how to configure them.

When the user identifies himself on the sites, the profile thus created can be enriched with information from our contact database. The user’s identity (surname, first name, telephone number, e-mail address, IP address, device identifiers) is rendered illegible and indecipherable in order to prevent the technological partners involved in this processing from identifying the user.

2.2. This activity then relies on the adaptation, according to the user’s profile and last actions, of the content presented to the user:

– On website pages during the visit.

– Through personalized marketing communications via channels such as, but not limited to, e-mail, social networks, SMS, messaging applications, etc.

The proposed marketing content and communication channels are then automatically activated. This automated decision making is based on objective criteria linked to our activities: market segments, countries of activity, interest in certain products and services, frequency of visits, channels previously used, etc.

These automated decisions may impact the user in the following ways:

– The content proposed on the channels does not reflect the exhaustive worldwide offer available; access to the description of certain products or services may appear more complicated.

– The user may receive messages and commercial proposals that other users do not get.

– Other users may receive messages and commercial proposals that the user does not get.

The user consents to this automated decision by agreeing to the “customization cookies” category. They may withdraw their consent at any time by rejecting this category. The Cookies Notice available on our website provides further details on the technologies used and how to configure them.

If you feel that this automated processing has a significant impact on you, you can:

– Deactivate it by rejecting the “customization cookies” category of your web browser as mentioned above.

– Contact an agent of our customer support center at the contact details shown on the websites of your country to obtain information on available offers, products, services and commercial proposals you may be interested in.

11.4 How long will personal information be retained?

We will retain personal information for as long as the information is needed for the purposes set forth in this Privacy Policy and for any additional period that may be required or permitted by law. More precise information is provided in privacy notices applicable to specific digital content. In general data retention periods are determined taking into consideration:

– The duration of our relationship (e.g. contract performance duration, account de-activation, your legitimate need to be recognized when contacted by us)

– Legal requirements for keeping data

– Statute of limitations

For marketing purposes, we keep relevant customer data for three years after the end of our relationship or since the last interaction with us.

11.5 What are your additional rights?

In addition to the rights provided in section 10 above, you may ask us to erase, restrict or port your personal information and object to the use of your personal information. When data processing is based on individual consent, you have the right to withdraw your consent at any time by sending a request to the following email address hgh@hgh-infrared.com. For processing necessary to perform the contract, or based on legitimate interest, we may not be able to accommodate the request to stop the processing, or if we do so, it may mean that you can no longer access the services or the digital content.

11.6 Where to ask questions and file a claim?

Questions or comments about the HGH privacy practices or this Privacy Policy can be addressed to the Data Protection Officer : hgh@hgh-infrared.com HGH, DPO, 10, rue Maryse Bastié 91420 Igny – France.

If you believe that HGH has processed your personal information in violation of applicable law or of this Privacy Policy, you may file a complaint with the Group DPO. You may also contact a supervisory authority. The supervisory authority for HGH is the CNIL in France; you may contact the supervisory authority in your country.

 

Last update : 18/06/2025