When you use the Finary site (the "Site"), we may collect personal information about you. The purpose of this charter is to inform you about the ways in which we process this data.
Responsible for processing Finary SAS Registration in progress Head office: 95 avenue du Président Wilson, 93100 Montreuil, France (hereinafter: "We" or "Us")
What is the purpose of the data collected? Your data is processed for one or more of the following purposes:
- Track and manage your assets
- Make investment recommendations to you
- To provide you with our services
- Follow the relationship with our customers
- Build a file of customers and prospects
- Responding to your requests for information
- Send newsletters, solicitations and promotional messages
- Develop statistics
- Manage unpaid invoices and any litigation on our services
- Respect our legal and regulatory obligations
- Verify your identity in the context of our legal and regulatory obligations for the purpose of fighting fraud.
What is the legal basis for the processing? The execution of the contract you have concluded with us Consent when you agree to receive our newsletters Our legitimate interest in developing and promoting our business Comply with the legal and regulatory obligations to which we may be subject
What personal data do we collect? Personal data is data that identifies an individual. We collect data in the following categories:
- Identification data (e.g. name, surname, email address, telephone number)*.
- Data relating to your real estate assets as well as to other assets such as crypto-currencies, start-ups, etc.
- Connection data (e.g. IP address, logs)
- Economic and financial data (e.g. GNI)
- Data to verify your identity
- Data relating to your professional life
- Mandatory information is indicated* when you provide us with your data. They are necessary to provide you with our services.
- Who are the recipients of the data?
- How long is the data kept?
Data collected to provide our services, monitor customer relations and carry out canvassing with our customers: Duration of the business relationship and 3 years beyond for prospecting purposes, then 2 years in intermediate archiving for evidentiary purposes Data collected for prospecting purposes: 3 years from data collection or last contact with the prospect Data required for evidentiary purposes Duration of the legal statute of limitations (generally 5 years) If you exercise your rights If we ask you for proof of identity: we keep it only for the time necessary to verify your identity. If you exercise your right of opposition to receive canvassing: we keep this information for 3 years.
- Is your data likely to be transferred outside the European Union?
We inform you that your data is kept and stored for the duration of its conservation on the servers of the company Heroku and the company Digital Ocean, both located in the Netherlands. However, your data may be transferred outside the European Union in the context of the tools we use and our relations with our subcontractors (see article "Who are the data recipients?"). This transfer is secured using the following tools:
- Either these data are transferred to a country that has been deemed to offer an adequate level of protection by a decision of the European Commission;
- Either we have concluded a specific contract with our processors governing the transfer of your data outside the European Union, on the basis of the standard contractual clauses between a data controller and a processor approved by the European Commission.
- What rights do you have over your data?
You have the following rights regarding your personal data:
- Right to information: This is precisely why we have drafted this charter.
- Right of access: You have the right to access all your personal data at any time.
- Right of rectification: You have the right to rectify at any time your inaccurate, incomplete or obsolete personal data.
- Right to limitation: You have the right to obtain the limitation of the processing of your personal data in certain cases defined in art.18 of the RGPD.
- Right to forget : You have the right to demand that your personal data be deleted and to prohibit any future collection.
- Right to file a complaint with a competent control authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable texts.
- Right to set guidelines for the storage, deletion and disclosure of your personal data after your death.
- Right to Portability: You have the right to receive the personal data you have provided us with in a standard machine-readable format and to require its transfer to the recipient of your choice.
- Right to object: You have the right to object to the processing of your personal data. Please note, however, that we may continue to process them despite this opposition, for legitimate reasons or the defense of legal rights.
You may exercise these rights by writing to us at the contact information below. We may ask you on this occasion to provide us with additional information or documents to prove your identity.
- Contact point for personal data
Contact email: firstname.lastname@example.org Contact address: Finary SAS, 95 avenue du Président Wilson, 93100 Montreuil, France.
We may amend this policy at any time. These changes will apply on the effective date of the amended version. You are therefore invited to consult the latest version of this charter on a regular basis.
Entry into force : 01/08/2020