Last update: 25 May 2018
La Française Group and its companies (collectively “the Group”, “we” or “our”) are committed to respect the confidentiality of your data and your privacy. We take care to protect your personal information. You should read the following information carefully to find out how we collect and use your personal information and the options available to you in connection with their use.
For the purposes of this privacy and cookies policy, (the “Privacy and Cookies Policy”), the data controller is La Française Group, a company registered on the Paris Trade and Companies Register under number 480 871 490 and which has its registered office at 128 Boulevard Raspail, 75006 Paris.
This Privacy and Cookies Policy applies to the products and services offered by the Group (“the Products and Services”) and presented on our website www.la-francaise.com (the Website) and more specifically to:
- personal data collected on the subscription forms available on the websites of Group companies linked to the Website;
- personal data collected through the contact form;
- personal data collected through a request for information;
- personal data which may be collected when you enter into a commercial or investment relationship with a company in the Group.
This Privacy and Cookies Policy applies whether you are a “Visitor” (which means you are simply looking at the Products and Services) or a “User” (which means that you have registered with the Website).
The Privacy and Cookies Policy governs the use of the Website however you access it.
By accessing or using the Website and providing us with information via the Site, you accept this Privacy Protection and Cookies Policy. We recommend that you regularly check the Policy as we often update and modify it.
In the event of any inconsistency between this policy and the French version, the French version shall prevail.
1. Personal data collected
Data which do not reveal your identity
You can visit our Website without providing us with any information which identifies you.
Each time you visit our Website we, like most online services, automatically collect certain data and information about you and/or your computer that do not identify you. This information includes:
- The type of internet browser you use;
- The type of operating system and device you use to access the Website;
- Your Internet service provider’s domain name;
- The web page from which you come;
- The country where you live and your language;
- The pages and options that you visit and access on our Website.
When you access, visit and/or use our Website we can, therefore, follow your visit and collect certain data about your use of the Products and Services and your activities on the Website, as described below in the “cookies” section.
In certain cases, in particular when you register or request information, you may be asked to provide personal data, such as your surname, first name, email address and telephone number (“Personal Data”).
When you contact us or ask for information by email, post or text message, we collect the Personal Data that you voluntarily decide to disclose to us.
However, if you do not wish to disclose your Personal Data, some of the services and/or options available on the Website and/or linked to our offer of Products and Services may be unavailable to you.
We also collect Personal Data when the Website allows you to register on “My Account” or “My Extranet”: you will be asked to disclose Personal Data such as your surname, first name, email address, postal address and telephone number. We may also obtain Personal Data via your internet browser, such as your IP Address, which is a number that is automatically assigned to your computer when you use the internet.
We may also obtain information about you from other sources. For example, we may ask a third party supplier or collector to provide us with additional information about our existing clients (adding data or “data appending”), particularly information you have provided on the Website.
2. How we use your personal data?
Personal Data are disclosed to us through the Website, either with your consent (request for information or documents) or on the basis of a contract (subscription form or registration on the Website to benefit from the Products and |Services). We may use the Personal Data you disclose to us via the Website for the purpose of:
- Managing your subscription to various Products and Services;
- Supplying you with various Products and Services;
- Improving our client management;
- Creating access to “Your Account” or “My Extranet” when the Website allows you to do so.
- Providing you with documents you have requested (newsletters etc.) and inviting you to events;
- Answering your questions;
- Customising our offer of Products and Services and improving your browsing experience on the Website, by making it more effective and efficient;
- Complying with requirements on us to know our Users in connection with the offer of investment products, particularly requirements related to money laundering (nationality, name, address, date of birth etc.) under Articles L.561-5 and L.561-23 of the French Monetary and Financial Code.
- Defining the profile of the User as investor: their objectives, tolerance of risk and level of understanding of investment;
- Identifying and managing conflicts of interest in accordance with Article L.533-10 of the Monetary and Financial Code and Articles 318-12 et seq of the General Regulation of the Autorité des Marchés Financiers (the French financial markets regulator);
- Generally complying with the Group’s legal, regulatory accounting and tax obligations;
- Informing you about Products and Services which are new or similar to those from which you already benefit and which could be of interest to you;
- Processing requests and complaints related to the Website, initiated by you and/or a third party, which concern you.
3. How we keep your personal data?
Personal Data used in connection with use of the Website
We store these Personal Data only for as long as is necessary for the purpose for which we process them and in any event for the period necessary to comply with a legal or regulatory requirement.
Personal data used to send you information
Your Personal Data will be kept for as long as your subscription is live. You can bring this to an end at any time by unsubscribing, using the link shown. In any event, if you do not make contact for three years, your Personal Data will be erased.
Personal data used to send marketing offers
Your Personal Data will be kept for as long as you agree to receive our marketing offers. You can bring this to an end at any time by unsubscribing, using the link shown. In any event, if you do not make contact for three years, your Personal Data will be erased.
Personal Data used in connection with a commercial or investment relationship
We store these Personal Data only for as long as is necessary for the purpose for which we process them, that is throughout our contractual relationship and in any event for the period necessary to comply with a legal or regulatory requirement.
4. How we share your personal data?
Transfer outside the European Union
When the processing of your Personal Data involves transfer outside the European Union, they will be transferred to countries listed by the European Commission as providing sufficient protection for data and/or covered by appropriate guarantees based on standard contract clauses, in accordance with models published by the European Commission and/or certified as meeting a recognised standard.
When sharing of Personal Data involves transfer to the United States, recipients will have Privacy Shield certification.
The Group’s companies
We may share your Personal Data with companies in the Group. For further information on the companies in the Group, please go to our Regulatory Information.
As part of the conduct of our business, we may transfer your Personal Data to service providers outside the Group. These service providers use Personal Data only to enable us to provide you with Products and Services. As examples, these service providers may supply IT services, be our logistics or marketing partners, our website host, or support us in data management, email distribution or analysis of information. We disclose to our service providers only the Personal Data they need to provide their services and we work with them to ensure that your Personal Data are respected and protected.
We never disclose any personal Data to these companies for their own marketing or commercial needs. However, we may disclose your Personal Data to our commercial partners only in order to provide you with our Products and Services or other products and services which may be of interest to you.
We may need to disclose Personal Data in response to a request from a regulatory authority, such as the tax authorities or CNIL (the French data protection authority), and/or a court (in response to a judgment, a court order or injunction) on request or if the law requires us to do so, or in order to protect our interests, our property and/or our security and/or those of a third party.
We may also share Personal Data with companies assisting in the fight against fraud and investigating fraud.
We may also disclose your Personal Data as part of the fight against money laundering and terrorist financing, with the implementation of monitoring of contracts and/or transactions which could lead to the drawing up of a suspicious activity report or the freezing of assets.
Unless otherwise provided in this Privacy and Cookies Policy or with your prior permission, we will not sell, market or lend Personal Data to other companies in the normal course of business. However, in the event of any restructuring of the group’s companies (acquisition, merger or partial transfer of assets) your Personal Data may be disclosed to another company, but the disclosure will then be subject to the Privacy and Cookies Policy in force.
5. How do I know if my personal data is kept safe?
We have a variety of security measures to prevent the loss, misappropriation or misuse of the Personal Data that you have disclosed on the Website. In order to guarantee the security of the data you disclose online during transmission, we use encryption, authentication, and flow analysis and we carry out security audits on the hosting environments.
6. Cookies: What they are and how we use them?
A cookie is a text file placed on the device you are using to access the internet (computer, mobile phone, tablet etc.) when you use a browser to visit a website.
We place a unique identifier in the cookie and use the cookie to connect your computer to the information that we store in our database.
- It contains data which allow you to be identified:
- The name of the server which placed it;
- A unique numeric identifier;
- Possibly, an expiry date.
- Suggest offers in line with the Visitor’s profile;
- Make it easier to share information (especially on social networks);
- Save login settings for a better website experience and, in general, to optimise the way the Website is displayed;
- Collect statistical information.
Cookies do not contain any Personal Data and do not allow access to your computer.
Your consent to the placing of Cookies lasts for 13 months. At the end of this period, we will again ask for your consent.
When you first visit our Website, an information banner will be displayed at the foot of the page. In continuing to browse the Website or after clicking on “I accept” you are agreeing that the Group may place cookies on your device (cookies related to targeted advertising, certain audience measurement cookies and social networking cookies including those generated by their sharing buttons when they collect personal data).
Each internet browser offers different settings for the management of cookies. They are generally shown in the browser’s help menu. If you use a browser or version different to those listed, we suggest you use the browser’s “Help” menu. Firefox, Chrome, Internet Explorer, Safari and Opera.
However, if you decide to refuse session or functionality cookies, many of the options offered on the Website will not be available to you. The Group cannot be held liable if Website functions are adversely affected by your chosen settings.
7. How links from the website to sites other than those of the Group can affect you?
The Group may offer links to the websites of other companies with which it has a relationship.
We may place these “hyperlinks” to other websites and applications operated by third parties on our Website. The only purpose of these links is to make browsing easier for you and to provide you with the fullest possible information. We have no control over these websites and applications. They are separate from the Group and have their own privacy policies. La Française Group cannot, therefore, be held liable under any circumstances, in particular for the accuracy, relevance, availability or reliability of the information and services offered on these websites, or the respect for copyright, legality or decency of the content of these third party websites and applications accessible through our Website. We encourage you to review the terms and conditions and privacy policies of any third party websites and applications before using them. You should note that our Privacy and Cookies Policy ceases to apply when you leave our Website.
Moreover, La Française Group is not responsible for any hyperlinks to its Website which may be embedded in third party websites, even if the Group has authorised the publisher of the third party site to place such a link.
Finally, the Group generally prohibits anyone from placing a hyperlink to one or more pages of its Website without its express prior consent.
8. How to refuse and/or unsubscribe from emails or sms messages or transmission of your personal data to service providers?
If you no longer wish to receive emails from the Group informing you of events, new Products or Services, similar Products or Services, or containing other marketing communications, you only have to click on the “unsubscribe” link at the foot of every email and follow the steps set out there.
If you no longer wish to receive SMS messages, you can text “STOP” to the number shown if this option is available. Otherwise, you should contact your usual adviser
9. How to access, update or delete the information in "my account" and/or "my extranet"?
You can log in to “Your Account” or “My Extranet” when the Website allows you to do so. After you have logged in, you can change your profile and update your Personal Data. It is your responsibility to protect your log in details (particularly your username and passwords) and, as set out in the General Terms and Conditions, you are responsible for any activity on the Website using your log in details.
10. Your rights regarding your personal data
Under the legal and regulatory framework applicable to the protection of personal data and privacy, particularly the GDPR, current French legislation and the recommendations of any independent public authority established by a Member State of the European Union responsible for controlling this legal and regulatory framework, you have a right to access, rectify, object to or erase your Personal Data or limit its processing, and a right to its portability.
You also have a right to give instructions about what should be done with your Personal Data after your death.
You may write to La Française Group about this at any time, at the following address: La Française Group - Data Protection Officer – 128, Boulevard Raspail - 75006 PARIS, or by email at email@example.com.
If you wish to make a complaint, you may choose to contact the CNIL.
11. What to do if you have further questions about the Privacy and Cookies Policy?
If you have any questions or concerns about this Privacy and Cookies Policy, you can email the Data Protection Officer at firstname.lastname@example.org or write to La Française Group Data Protection Officer – 128, Boulevard Raspail - 75006 PARIS.
12. What legislation applies to this Privacy and Cookies Policy?
This Privacy and Cookies Policy is governed by French law and, with effect from 25 May 2018, by the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”). Please note that this policy may change in the light of regulatory modifications.