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Personal data confidentiality policy
The purpose of this confidentiality policy is to inform you of the methods and means used by PERGAM to collect your data, as well as the means available to you to assert your rights with regard to your personal data.
Personal data is any information relating to a natural person who can be identified directly or indirectly. The data controller is the company that determines for what purposes and by what means your personal data will be collected.
In order to carry out its activity, PERGAM has access to certain personal data of its clients and contractual partners. In carrying out this data collection, PERGAM has the capacity of data controller. PERGAM is committed to protecting your personal data in accordance with French and European regulations on personal data.
Identity of the data controller and collection of personal data
Personal data collected on the PERGAM website are processed by: PERGAM, Société par Actions Simplifiée (a French Simplified Joint Stock Company), registered in the Trade and Companies Register of Narbonne under the number: 438 328 973, with its registered office located at 5 Rue des Anciens Moulins 11100 BAGES and with its principal place of business located at 28, rue Bayard 75008 PARIS.
For the purposes of our activity we collect and process the following personal data:
- The information you give us
As part of our contractual or business relationship, it is necessary for us to collect and process your personal data, including your name, gender, postal address, personal or business e-mail address, personal or business telephone number, financial information, photograph, identity documents (including your passport or ID card), occupation, marital status and information about your dependants or successors.
- The information we collect about you
PERGAM owns and operates the site (https://www.pergam.net)
Each time you visit our site, we automatically collect the following information: technical information, including the Internet Protocol ("IP") address used to connect your computer to the Internet, your user ID, the type and version of browser you are using, your time zone setting, and information about your visits, including the full sequence (URL) of requests or clicks made on this site (including date and time); the products, services or questions you have viewed or searched for, page response times, download errors, time spent on each page, information about interactions between pages (scrolling, clicking, mouse pointing) and methods used to leave a page.
- Information from other sources
We may receive information about you when you use the website we operate or any of the services we provide. We work closely with third parties (banks, financial institutions, business partners, legal and other advisors, technical contractors) who may provide us with information about you.
Purposes and legal basis of the data processing
We may ask for your permission to collect and process your personal data on certain occasions, in particular, as indicated above, when it is necessary to provide you with information on products, services or events that may be of interest to you and in the context of our regulatory obligations in terms of KYC (Know Your Customer and Prospects - AMF position No. 2013-02 and 2007-21 Articles 314-4 to 9 - 314-44 to 54 of the General Regulations of the AMF).
We process your personal data when it is necessary to conclude a contract with you. This is particularly the case for performing your management mandate or providing you with investment advice, verifying your identity or providing you with additional services in connection with the contractual services.
We process your personal data when required by law. This is the case when we receive a request from a judicial or government authority. We use your personal data to verify commercial and legal information about our customers, prospects and counterparties. The purpose is to assess your activities and circumstances in relation to the investments and services we provide or may provide to you, as required by financial services regulation.
We monitor the use of our internet site and use your personal data to better control, improve and protect our services and internet site, both online and offline, from any risk of malicious attack.
We monitor our clients' accounts and financial transactions to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime in accordance with applicable law. We will use your personal data in connection with legal claims, to ensure compliance, to comply with applicable regulations or for investigations, if necessary (we may also disclose this information in connection with legal proceedings or litigation).
Disclosure of your personal data
In the course of our business we may share your personal data with trusted third parties such as: Legal advisors, financial institutions (e.g. banks, depositaries, account holders), professional experts, suppliers and service providers, and technical subcontractors for the sole purpose of performing a contract concluded with them.
We take all necessary steps to ensure that our service providers and counterparties protect your personal data and are aware of their data security obligations.
Where and how your personal data is stored
PERGAM and its subsidiaries or affiliates store your personal data in data centres located solely in countries of the European Union.
In order to adequately protect your personal data, PERGAM has put in place a tracking system (Tags) on the processing files, which PERGAM performs using personal data. We take the necessary steps to protect your personal data against the risk of loss or destruction.
Although we make every effort to protect your personal data, we cannot guarantee the security of personal data that you transmit to us via external messaging services.
Any transmission is made under your responsibility. Once your personal data is received by our services, strict procedures and high security features are put in place to prevent unauthorised access.
Cookies
By using the site, you agree to the placement of cookies on your computer. Cookies are small data files sent to the Internet browser you are using by the website you are visiting. The main purpose of cookies is to make it easier for you to navigate a website by remembering your user preferences, for example, or to improve the user experience.
Cookies used on the PERGAM website are automatically deleted when the user closes the browser. These cookies are essential in order to be able to browse the site and take full advantage of its features such as access to certain secure internet pages. Without these cookies, some of the services you may request cannot be provided.
Performance cookies are used to collect information about how visitors use the site, such as which pages are visited most often or whether error messages appear on certain pages. All information collected through these cookies is anonymous, and is collected solely for the purpose of developing and tracking traffic patterns on the site in order to improve the way it operates.
Google Analytics: the cookies placed by Google Analytics are used for analysis purposes only and do not allow for individual tracking of users. For more information on how Google Analytics collects and uses these data and the rights associated with the use of these cookies, please see their privacy policy. However, if you do not want Google Analytics to collect Personal Data from you, you can download and install the Google Analytics Opt-out Browser Add-on.
Your rights
You have a number of rights regarding the use of your personal data. We must respond to your request within one month. If your request is particularly complex, we have an additional two months to provide you with an answer.
• Access:
You have the right to request a copy of the personal data we hold concerning you. The copies requested are free of charge, but you may be charged for any additional copies or if the request is clearly unfounded or excessive. Please note that there are exceptions to this right. You may be denied access to your personal data if, for example, making it available to you involves disclosing the personal data of a third party, or if we are prohibited by law from disclosing such information. You have the right to consult your personal data. Please contact us using the contact details below to access them.
• Accuracy:
We endeavour to keep your personal data up to date and to ensure its accuracy and completeness. We invite you to contact us using the contact details below to report any inaccurate personal data or changes so that we can update your personal data.
• Objections:
In some cases, you also have the right to object to the processing of your personal data and to ask us to block or limit the processing or to erase your personal data. If you would like us to stop using your personal data, please contact us using the details below.
• Portability:
You have the right to request that part of your personal data be transferred to you or to another data controller in a commonly used and machine-readable format.
• Complaints:
If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the competent supervisory authority (in France, the CNIL: www.cnil.fr).
To exercise your rights, you can contact Pergam's Data Protection Officer (DPO) by e-mail or post, indicating your name, first name, contact details and providing a copy of your identity document: Data Protection Officer (Délégué à la Protection des données) postal address: PERGAM – 28 rue Bayard – 75008 Paris - email address: DPO@pergam.net
Please note that there are exceptions to these rights if, for example, we are legally required to continue processing your personal data.
As a reminder, in France, pursuant to Article 40-1 of the French Data Protection Law No. 78-16 of 6 January 1978, as amended by the Law 2018-493 of 20 June 2018, you also have the right to give instructions concerning the management of your personal data after your death.
When we ask you for personal data, we will endeavour to make it clear whether this is necessary to provide you with the relevant products and services or whether it is optional.
How long we retain your personal data
We will retain your personal data for as long as we consider it necessary or desirable to achieve our business objectives or to comply with applicable law, to satisfy applicable audit requirements, to meet regulatory obligations or to enforce the decisions of competent courts.
Personal data will be stored in accordance with our data retention policy. The duration of retention is variable and depends on the nature of the data and the purposes for which it is retained. In most cases, they will be kept for a minimum of five (5) years from the date of last use.
Changes to our privacy policy
Any subsequent changes to our Policy will be posted on our website. When necessary, you will be informed by e-mail. Please check the site regularly for any updates or changes to our Policy.
In the case of a contradiction between several versions of PERGAM's privacy policy, the most recent version shall prevail .
Updated: 04/10/2022
