Confidentiality and cookies

 

Last update: 15 January 2019

The La Française group and the companies within it (referred to collectively in this document as “the Group”, “we” or “our”) are committed to protect your privacy and the confidentiality of your data and we take care to protect your personal data. Please read the following information carefully. It tells you about how we collect and use your personal data 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 Groupe La Française, 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”) on its website which you are browsing (the “Website”) and particularly:
-    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. 

1. Personal data collected

Data that do not allow you to be identified directly

You can visit our website without providing us with any data that allow you to be identified directly.
Like the majority of online services, we automatically collect certain data and information about you and/or your computer or electronic equipment each time you visit our Website, but they do enable you to be identified directly. 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. 

Personal Data 

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?

We obtain your Personal Data on the Website on a legal basis: your consent (request for information or documents), a contract (a subscription form or registration on our Website to benefit from Products and Services), in order to comply with relevant legislation or in pursuit of a legitimate interest. 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/ EEA

When the processing of your Personal data involves a transfer to third countries outside the European Union/ EEA, the transfer is to countries listed by the European Commission as providing sufficient protection for data and/or is covered by appropriate guarantees based on standard contract clauses reflecting models published by the European Commission and/or recognised certification.  
When sharing of Personal Data involves transfer to the United States, recipients will have Privacy Shield certification. 
For more information about the transfer of Personal Data to third countries outside the European Union/ EEA, please refer to the section below: “WHAT SHOULD I DO IF I HAVE MORE QUESTIONS ABOUT PROTECTION OF PRIVACY AND COOKIES?”. 

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 https://www.la-francaise.com/fr/actualites-reglementaires/. 

Service Providers 

As part of the conduct of our business, we may transfer your Personal Data to service providers outside the Group. These service providers use your Personal Data only to enable us to supply you with Products and Services or to make the website available.   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 may also transfer your Personal Data to companies for which we deliver services but only in order to fulfil our contractual obligations to them and in compliance with relevant legislation.
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.

Legal Obligations 

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 Personal Data that you provide to us. 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.

Cookies may be used on your computer or mobile device for different periods. Some are “session cookies” which means that they remain only while your web browser is open and are automatically erased when you close your browser or exit the application. Others are “persistent cookies”, meaning that they stay after your browser or application is closed and may be used on websites and applications to recognise your computer when you subsequently re-open your browser or application.  Some of the cookies we use are persistent. When your consent is required for their use, consent for placing of Cookies is valid for 13 months. At the end of this period, we will again seek your consent. 
We use cookies to:
•    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 placed by the owner of a Website (in this case the La Française Group) are known as “first-party cookies”. Cookies placed by parties other than the owner of a Website are known as “third-party cookies”. Third-party cookies allow the provision of third-party functions or functionalities on or via a Website (such as advertising or interactive or analytic content).    Those who set these third-party cookies are able to recognise your computer both when it visits the Website in question and when it visits other websites. 
Cookies are not the only way that visitors to a website can be recognised or traced. We may from time to time use other, similar technologies, such as tags (sometimes known as “tracking pixels” or “clear gifs”. These are tiny graphic files containing a unique identifier which enables us to recognise when someone has visited the Website. In many cases these technologies depend on cookies to function correctly, so rejection of cookies will obstruct their operation. 

How to manage cookies

When you first visit our Website, an information banner will be displayed at the foot of the page. By continuing to browse the Website after clicking on “I accept”, you consent to the Group placing cookies on your computer or device (cookies linked to targeted advertising operations, certain audience measurement cookies, and social media cookies, generated in particular by sharing buttons when they collect personal data).   
The banner will be displayed until you continue you browsing, i.e. until you go to another page on the Website or click on another item. You can change your internet browser settings at any time to accept, configure or refuse cookies. You will be offered a number of options: to accept cookies, be alerted when a cookie is placed, or refuse all cookies.    
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.
Finally, if you, disable one or more cookies, we can still use information collected by these cookies before they were disabled.   However, we will no longer collect data via the rejected cookie.

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. Consequently, the Group cannot be held liable under any circumstances, in particular in relation to the accuracy, relevance, availability or reliability of information and products and services offered on these websites, their respect for copyright, or the legality or decency of material contained on these third-party websites and applications accessible from 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 Confidentiality and Cookies Policy ceases to apply when you leave our Website.
Moreover, the Group is not responsible for hypertext links to its own Website which may be included in third party websites, even if the Group has authorised the third-party publisher of the website 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. 
Similarly, if we have collected and processed your Personal Data with your consent, you have a right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of processing based on the consent undertaken before it was withdrawn.
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 e mail to dpo@la-francaise.com. 
Finally, you have a right to complain about the collection and use of your Personal Data to the French data protection authority (CNIL). 

11. What to do if you have further questions about the Privacy and Cookies Policy?

If you have any questions or doubts about this privacy and Cookies Policy, you can send an email to the Data Protection Officer at dpo@la-francaise.com or send a letter 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 18 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 developments.