Personal Data

PREAMBLE

The La Française Group and its affiliate companies (collectively referred to in this document as “the Group”, “we”, “us” or “our”) are committed to respecting the confidentiality of your data and your privacy and take care to protect your personal data (hereinafter referred to as “Personal Data”).

Please read the following carefully to understand how we collect and use your Personal Information and the options available to you for its use.

This Privacy Policy applies to all processing of Personal Information by the Group in connection with its products and services (the “Products and Services”).

Your Personal Data may be collected from you directly or indirectly via a third party.

PART I: GENERAL

This Privacy Policy (Part I) applies whether you are a “Visitor” to a Site (which means that you are simply browsing the Products and Services offered online), a “User” (which means that you are registered on the Site) or a “Customer” (which means that you have subscribed to the Group’s product or service offerings).

We recommend that you consult this Privacy Policy regularly as we update and modify it regularly.

1/ WHAT DATA IS COLLECTED ABOUT YOU?

Personal Data that you provide directly to us

We may collect Personal Information directly from you:

– via subscription forms

– when requesting contact

– when requesting documentation

– and when you enter a commercial, contractual or investment relationship with a Group company.

For more information on the type of Personal Data collected, please read Part 2 of this Policy.

If you do not wish to provide such Personal Data, some of the services and/or options available on the Site and/or related to our Products and Services offering may not be available.

In addition, please note that, like most online services, each time you visit one of our Sites, we automatically collect certain data and information about you and/or your computer or electronic device using “cookies:

– the IP address automatically assigned to your computer when you use the Internet

– the type of internet browser you are using

– the type of operating system and device you use to access the Site; and

– the domain name of your Internet service provider

– the web page you came from

– your country of residence and language.

– the pages and options you visit and access on our Site.

When you access, visit and/or use one of our Sites, we may therefore track your visit and collect certain data about your use of the Products and Services and your activity on the Site. To learn more about our use of cookies, please read our Cookie Policy, available at https://www.newalpha.com/donnees-a-caractere-personnel/

Personal Data we collect from third parties

We may obtain Personal Information about you from partners of the Group.

For example, we may collect Personal Information from:

– Banks or financial advisers who distribute our Products and Services.

– Property managers in charge of monitoring tenants, etc.

2/ HOW IS YOUR PERSONAL DATA USED?

We process your Personal Data on the following legal bases: your consent (request for information or documentation), a contract (subscription form, registration to benefit from the Products and Services), compliance with applicable laws, or when we pursue a legitimate interest. We believe that the risk associated with the Personal Data we process based on our legitimate interests is not excessive or overly intrusive. We have put in place measures to protect your rights by applying appropriate retention periods and ensuring appropriate security controls.

For more information on the purpose of the processing carried out, please read Part 2 of this Policy.

3/ HOW LONG IS YOUR PERSONAL DATA STORED?

We store your Personal Data for a limited period necessary for the purpose for which we process it and in any event for the period necessary to comply with a legal or regulatory obligation.

Personal Data used to send you documentation:

Your Personal Data will be kept for as long as your subscription is active. You may terminate your subscription at any time by unsubscribing in the link that will be provided in the email sending you the documentation. In any event, if there is no contact from you for a period of three years, your Personal Data will be deleted.

Personal Data used to send you commercial offers:

Your Personal Information will be kept for as long as you agree to receive our commercial offers. You can refuse them at any time by unsubscribing in the link that will be indicated in the e-mail sending you a commercial offer. In any event, if there is no contact from you for a period of three years, your Personal Data will be deleted.

Personal Data used in connection with a commercial, contractual or investment relationship

We store Personal Data for a limited period as is necessary for the purpose for which we process it, i.e., for the duration of our contractual relationship and in any event for the period of time necessary to comply with a legal or regulatory obligation.

For further information on the retention periods of Personal Data, please refer to section 11 “WHAT TO DO IF YOU HAVE ANY OTHER QUESTIONS REGARDING THE PRIVACY POLICY”.

4/ HOW IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

When the processing of your Personal Data involves a transfer outside the European Union/EEA, this is done to countries listed by the European Commission as providing sufficient data protection and/or with appropriate safeguards based on the standard contractual clauses published by the European Commission and/or having obtained a recognized certification.

Where the sharing of such Personal Data involves a transfer outside the EU, such transfer is made to recipients who provide all the required safeguards.

For more information on transfers of Personal Data outside the European Union/EEA, please refer to the section “WHAT TO DO IF YOU HAVE ANY OTHER QUESTIONS REGARDING THE PRIVACY POLICY”.

5/ HOW IS YOUR PERSONAL DATA SHARED?

Group companies

We may share your Personal Data with companies within the Group. For more information about the companies in the Group, please visit https://www.newalpha.com/informations-reglementaires/

Service Providers

During our business, we may transfer your Personal Data to service providers not affiliated with the Group who act as subcontractors. These service providers use Personal Data to enable us to provide the Products and Services, to make the Site available or to assist us in the management of our business.

For example, these service providers may include IT service providers, logistics and marketing partners, our hosting provider or service providers who assist us with data management, email distribution, information analysis, but also banks, investment advisors, tax advisors, auditors, lawyers, or other external professional advisors.

We only provide our service providers with the Personal Information they need to provide their services and work with them to respect and protect your Personal Information.

We may also transfer your Personal Data to companies for whom we provide services but only to fulfil our contractual obligations to them and in accordance with applicable law.

We do not provide any Personal Data to companies for their own marketing or commercial purposes. However, we may disclose your Personal Data to our business partners solely for the purpose of providing you with the Products or Services or similar products or services that may be of interest to you.

Legal Obligations

We may be required to disclose Personal Information at the request of an administrative authority (tax authorities, CNIL etc.), and/or judicial authority (in response to a judgment, order, court injunction), upon request or if required by law, to protect our rights, property and/or safety and/or those of third parties.

We may share Personal Data with companies that assist in the fight against and investigation of fraud.

We may also share your Personal Data in the context of the fight against money laundering and terrorist financing, including the monitoring of contracts and/or transactions which may lead to the drafting of a suspicious transaction report or an asset freeze.

Other

Except as otherwise provided in this Privacy Policy or with your prior consent, we will not sell, trade, or lend Personal Data to other companies in the normal course of business.

However, in the context of a possible reorganization of the companies making up the Group (acquisition, merger, partial transfer of assets or other such transaction) your Personal Data may be communicated to another company, but such communication will then be subject to the applicable Privacy Policy.

6/ ARE OUR PRODUCTS AND SERVICES TARGETED AT MINORS?

Our Products and Services are not targeted or intended for children. By using one of the Group’s Sites, you certify that you are over 15 years of age, otherwise please do not use a Group Site without prior parental consent.

7/ HOW DO YOU KNOW THAT YOUR PERSONAL DATA IS KEPT SECURE?

We have a variety of security measures in place to prevent the loss, misuse, or misappropriation of the Personal Information you have provided to us.

To ensure the security of the data you provide online during transmission, we use encryption, authentication, flow analysis and security controls on the hosting environments.

8/ HOW CAN THE LINKS ON THE WEBSITE TO OTHER SITES AFFECT YOU?

Each Site may contain various hypertext links to other Group Sites.

In addition, each Site may contain hypertext links to other websites and applications operated by companies outside the Group. The sole purpose of these links is to facilitate your navigation and to provide you with the most complete information possible. We have no control over these websites and applications, which are independent of the Group and have separate privacy policies. Consequently, the Group cannot be held liable for any reason whatsoever, in particular about the accuracy, relevance, availability, reliability of the information and products and services offered on these sites, the respect of copyright, legality or decency of the material contained in these third-party websites and applications accessible via our Site. We therefore encourage you to review the terms and conditions and privacy policies of any third-party websites and applications before using them. When you leave our Site, please be aware that our Privacy Policy no longer applies.

Furthermore, the Group is not responsible for hyperlinks to its own Sites that third party websites may include on their own sites even if the Group has authorized the third-party publisher of such site to place such a link.

Finally, and more generally, the Group prohibits any person from placing a hypertext link to one or more pages of its Sites without its prior express authorization.

9/ HOW CAN YOU REFUSE/UNSUBSCRIBE FROM RECEIVING EMAILS AND SMS?

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 commercial communications, simply click on the “Unsubscribe” link at the bottom of each email and follow the procedure indicated.

If you no longer wish to receive SMS messages, you can send “STOP” to the number indicated if the option is available, otherwise contact your usual contact person.

10/ WHAT ARE YOUR RIGHTS CONCERNING YOUR PERSONAL DATA?

In application of the legal and regulatory framework applicable to the protection of personal data and privacy, you have the right to access, rectify, oppose, delete, limit the processing of your Personal Data, as well as the right to portability of your Personal Data, unless otherwise provided by law.

These rights are not absolute and each of these rights is subject to certain conditions in accordance with French law (by Law 78-17 of 6 January 1978 relating to data processing, files and freedoms, as amended, but also any legislation applicable to the Group in relation to banking and financial matters), the recommendations of the CNIL, as well as the General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”)

Similarly, if we have collected and processed your Personal Data with your consent, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing based on the consent made prior to the withdrawal of consent.

You also have the right to set out instructions on what to do with your Personal Data after your death.

In this respect, you may contact the La Française Group at any time by writing to the following address La Française Group – Data Protection Officer – 128, boulevard Raspail – 75006 PARIS, or by email at dpo@la-francaise.com.

Before assessing your request, we may ask you for additional information to identify you. If you do not provide the requested information and we are therefore unable to identify you, we may refuse to process your request.

Finally, you have the right to lodge a complaint about the collection and use of your Personal Data with your local data protection supervisory authority (for France, this is the CNIL: www.cnil.fr).

11/ WHAT IF YOU HAVE FURTHER QUESTIONS ABOUT THE PRIVACY POLICY?

If you have any questions or doubts about this Privacy Policy, you can contact the Data Protection Officer by email at dpo@la-francaise.com or by sending a letter to La Française Group – Data Protection Officer – 128, boulevard Raspail – 75006 PARIS.

12/ WHAT LEGISLATION APPLIES TO THIS PRIVACY POLICY?

This Privacy Policy is governed by French law, by Law 78-17 of 6 January 1978 on information technology, files and freedoms, as amended, the recommendations of the CNIL and the RGPD.

Please note that this policy may change to consider regulatory developments.

PART II: SPECIFIC PRODUCTS AND SERVICES

More specifically, depending on the Group entity concerned, the Products and Services in question and the Site you use, the data collected, the purposes of processing and the legal basis may be different. For more information on how your Personal Data is processed, please refer to the tables below according to the sector of activity concerned.

The entity in charge of processing is NEW ALPHA ASSET MANAGEMENT, a company registered in the Paris Trade and Companies Register under the number 450 500 012 and whose registered office is at 128 boulevard Raspail, 75006 Paris.

You will find below the list of Personal Data that we collect from you, the purposes and the legal basis used for each processing.