Privacy Policy

In accordance with the regulations in force relating to the protection of personal data, specifically Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, the Law on Data Processing, Data Files and Individual Liberties (LIL) revised by No. 2018-493 of 20 June 2018 amending Law No. 78-17 of 6 January 1978, as well as well as national applicable personal data laws, you will find below the privacy policy.

DEFINITION : WHAT IS A PRIVACY POLICY

The purpose of the privacy policy (hereinafter : “Privacy Policy”) is to provide Internet users with transparent information about the collection and processing of personal data by the data controller via the website.

Personal data collected other than via cookies is explained in the site's privacy policy.

INTRODUCTION

HM.CLAUSE S.A.S., its subsidiaries and affiliates (collectively “HM.CLAUSE” or “we” or “us” or “We”) pay particular attention to the protection of your personal data.

HM.CLAUSE undertakes to ensure that the processing of personal data carried out in the course of its business complies with European Regulation No. 2016/679, known as the General Data Protection Regulation (GDPR), the revised French Data Protection Act (LIL) as well as national applicable personal data laws.

The concept of personal data (‘Personal Data’) refers to any information relating to an identified or identifiable natural person. A person is ‘identifiable’ if he or she can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to that person.

This privacy policy applies to the HM.CLAUSE website https://hmclause.us (hereinafter : “Site”).

WHO COLLECTS PERSONAL DATA

The data controller is HM.CLAUSE S.A.S, based at Rue Louis Saillant, Z.I. La Motte, 26800 PORTES-LES-VALENCE, France, registered under number 435 480 546 represented by Ms. Eugenia RIGAUD , Managing Director.

WHO THIS PRIVACY POLICY IS INTENDED FOR

This Privacy Policy is intended for:

• persons wishing to contact HM.CLAUSE using the dedicated contact form;

• all users of the Site who connect to and browse the Site.

WHAT METHODS OF COLLECTION ARE CONCERNED

This Privacy Policy applies only to the following methods of collection:

• contact form: elements provided by the Internet user

• elements collected automatically via the Internet user's browsing

WHAT DATA IS COLLECTED

Data is collected and processed in accordance with the principle of minimization. Only necessary data is processed by HM.CLAUSE.

The purposes of the various personal data processing operations are as follows: to inform you on our products, company, events, news, commercial contacts per geographic zone and to proceed to your requests.

• Collection method : Personal data collected through the “Contact us” Form

• Data collected : profile (e.g. grower, plant raiser, distributor, etc.), need, First name, Surname, email address, phone number (optional), Company name (optional), region, content of the message if it contains personal data, image if it contains personal data

• Retention Period : Until your unsubscribing or from 3 years after the last contact

• Recipients : Commercial Excellence and Sales Departments

• Legal Basis : Consent

HM.CLAUSE uses the data collected through the “Contact us” Form for the sole purpose of assisting you, and answering your queries

Personal data we automatically collect

HM.CLAUSE may collect information automatically while you Bowse our Site. The types of data that may be collected includes :

Technical Data (Device & Browser)

• Browser type and version (e.g., Chrome 127)

• Operating system (e.g., Windows, iOS, Android)

• Device type (mobile, tablet, desktop)

• Screen resolution

• Preferred language (browser locale)

• Connection type (e.g., Wi-Fi, 4G)

Anonymized Location Data

• Country or region (derived from anonymized IP)

• City (approximate, non-identifiable)

• Time zone

Website Interaction Data

• Pages viewed (page titles, URLs)

• Time spent on page

• Scroll depth

• Clicks (on buttons, links, elements)

• Mouse movements or heatmap zones (Clarity, with anonymization)

• Form interactions (without recording personal input values)

• Video play, pause, or completion events

Session and Visit Data

• Session start and end timestamps

• Session duration

• Number of pages viewed per session

• New vs. returning visitor (via anonymous ID or short-lived session cookie)

• Referrer URL (previous page or source, excluding sensitive data)

Traffic Source & Campaign Data

• Medium/source (e.g., organic search, direct, social)

• Campaign parameters (UTM tags)

• Landing page and exit page

Event Data (Custom Tracking)

• Click on call-to-action buttons

• File downloads

• Outbound link clicks

• Form submissions (only event trigger, no data entered)

Consent & Privacy Settings

• User consent state (accepted, refused, partial)

HM.CLAUSE has implemented a Cookies Policy explaining the use made of cookies and the purpose pursued. HM.CLAUSE encourages you to read our Cookies Policy you can access by Clicking here.

SECURITY AND DATA RECIPIENTS

We take reasonable security measures to protect against the loss, misuse, and unauthorized access, disclosure or alteration of Personal Information under our control.

These measures include the use of appropriate antivirus protection on hosting servers, regular security audits, encryption of data transfers via SSL/TLS certificates, restricted access to personal data through user authentication and role-based permissions, regular updates of our CMS and plugins, daily backups.

Nevertheless, and because of the nature and risks associated with the use of the Internet and its contents, HM.CLAUSE cannot under any circumstances guarantee a total security of your data.

The Site may provide hyperlinks to other websites.

HM.CLAUSE cannot be held responsible for content that it does not publish, as these third-party services are totally independent.

In addition, only people who need to know such information to perform their duties may have access to your personal data, on a “need to know” basis. Thus, the following are likely to have access to your personal data:

• HM.CLAUSE: HM.CLAUSE being part of Limagrain Group, an international group, and may need to communicate your personal information within the Limagrain Group.

• The following companies, as data processor may have access to your personal data :

- DE BUSSAC MULTIMEDIA (design, development and maintenance) : registered office : 44 avenue des Etats-Unis, 63000 Clermont-Ferrant (France)

- BREVO (link between the contact form and the mailbox) : registered office : 2-17 rue Salneuve, 75017 Paris (France)CLEVER CLOUD (cloud hosting) : registered office : 4 rue Voltaire, 44000 Nantes (France)

- AXEPTIO (consent management) : registered office : 15 rue Général Campredon, 34000 Montpellier (France)

• CLARITY, MATOMO, EULERIAN, as analytics tools may have access to your website use.

EXERCISE YOUR RIGHTS

• Right of access: you may request a copy of the data concerning you personally

• Right of rectification: you may amend any data concerning you that is inaccurate

• Right to object: you may object to us processing your data, subject to the conditions set out in Article 21 of the RGPD.

• Right to erasure: you may request that we erase data concerning you; subject to the conditions of article 17 of the RGPD.

• Right to restrict processing: you can temporarily ask us to stop using certain data.

• Right to portability (in some cases): you can ask for your data to be returned to you in a readable format so that you can re-use it

An identity check may be carried out when exercising your rights.

Finally, when a personal data breach likely to give rise to a high risk for your rights and freedoms is detected, you will be informed of this breach as soon as possible.

For any request for information or exercise of your rights regarding the processing of personal data managed by HM.CLAUSE, you can contact the HM.CLAUSE Personal Data Department at the following address : personaldata@hmclause.com or by post at the following address : HM.CLAUSE, Personal Data Referent, Rue Louis Saillant, Z.I. La Motte, 26800 PORTES-LES-VALENCE, France.

If, after contacting us, you feel that your rights with regard to Data Processing, Data Files and Individual Liberties have not been respected or that the access control system does not comply with data protection rules, you may submit a complaint online to the CNIL or by post.

CHANGES TO THE PRIVACY POLICY

HM.CLAUSE may change this Privacy Policy or its practices. If it does, HM.CLAUSE will post the Privacy Policy on the website's home page before the changes take effect, so that you are always aware of what information we collect, how we use it, under what circumstances we disclose it, and, if applicable, with whom we share it.

If, at any time, we decide to use personal information in a manner different from that stated at the time it was collected, we will inform you.

This Privacy Policy may be amended and corrected. Please check it regularly to stay informed of any changes and how they may affect you.

Date of update: 27 May 2026

FOR U.S.A. BASED USERS, THE BELOW PROVISIONS ALSO APPLY (“ USA PRIVACY NOTICE”)

This USA Privacy Notice applies to the Site and personal information collected by and through the Site only for persons located in the United States. It does not apply to any other HM.CLAUSE services or dealings with users or customers, offline or through any other means, nor does it apply to third party websites which may be linked to from the Site.

Use by Minors

The Site is not intended for minors. We do not knowingly collect personal information from minors. If you are a minor, do not use or provide any information on the Site. If we learn that we have collected or received personal information from a minor without verification of parental consent, we will delete that information. If you believe we might have inadvertently collected information from or about a minor, please contact us at personaldata@hmclause.com.

“Do Not Track” Signals Under Your California Privacy Rights

Under the California Online Privacy Protection Act (CalOPPA), we want to inform you that our Site currently does not honor “Do Not Track” or “DNT” browser signals.

Privacy Rights of California Residents

Under the California Consumer Privacy Act of 2018 (the “CCPA”), we may collect certain categories of personal information (described in detail above), including identifiers, personal information described in CCPA §1798.80(e), commercial information, and Internet or other electronic network activity information. We may collect this information from you, directly or indirectly, or from third parties, and may disclose it to third parties, such as our service providers, for the purposes described above. California residents are afforded certain privacy rights. If you are a California resident, subject to certain limitations, you may have the following rights concerning your personal information:

• Right to Know. You have the right to access the specific pieces of personal information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format if you have a password-protected account.

• Right to Deletion. You have the right to request that we delete any of the personal information we have collected or maintain about you.

• Right to Rectification and Correction. You have the right to rectify and correct inaccuracies in your Personal Information.

• Right to Opt-out of Sales of Personal Information. You have a right to opt-out of the “sale” and “sharing” of your personal information, including cross-context behavioral advertising, and to opt-in again at your election.

• Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to opt-out of secondary uses and disclosures of your Sensitive Personal Information.

• Right to Opt-out of Automated Decision-making. You have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.

• Right to Non-Discrimination. You have a right to not be discriminated against in the event you exercise your other rights listed above. If you exercise these rights, HM.CLAUSE will not deny you goods or services, charge you a higher rate, or provide you with lower quality products.

Exercising Your Rights Under the CCPA

You, or an authorized agent, may exercise your rights by submitting a request to personaldata@hmclause.com. The CCPA allows for 1 disclosure request per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request.

We respond to and process requests promptly and within the timeframes required by the CCPA (i.e., 45 days for confirmed requests subject to any necessary extensions). Please note that all requests are subject to proper prior verification before processing, as required by the CCPA.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

To exercise your rights, you may contact us at the personaldata@hmclause.com.

Sale of Personal Information and Universal Opt-out Mechanisms

With respect to the scope of this Privacy Policy, HM.CLAUSE does not “sell” or “share” personal information, as such terms are defined by the CCPA, and has not sold or shared personal information in the preceding 12-months. Because HM.CLAUSE does not sell or share personal information, Universal Opt-out Mechanisms, including Global Privacy Control (GPC), do not apply to our Site.

Your Privacy Rights: California’s Shine the Light Law

HM.CLAUSE has not disclosed in the preceding 12-months personal information to third parties for their own direct marketing purposes, as defined by Cal. Civ. Code § 1798.83.

International Transfer of Your Personal Information

Your Personal Information may be transferred to third countries with different or less privacy protections than your own country. By sharing Personal Information with us, you consent to the transfer of your Personal Information to such third countries.

Date of USA Privacy Policy update: May 27 2026.