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PRIVACY POLICY

 

Last update : 15 octobre 2024

 

I. PREAMBLE

 

This Privacy Policy is designed to provide transparency about how we collect and process your personal data. Your privacy is important to us, and we are committed to safeguarding your information in accordance with the European Regulation (Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016) on the Protection of Personal Data “RGPD” resulting in a framework for the collection and use of personal data. It outlines how we collect, use, store, and share your information when you engage with our services, access our website, or communicate with us. This policy also includes our Cookies Policy, explaining how we use cookies and similar technologies on our website.

By using our services or visiting our website, you agree to the terms set forth in this Privacy Policy.

 

1. INFORMATION WE COLLECT

We may collect personal information about you in several ways, including:

 

• Personal Data You Provide: when you contact us, sign up for services, or engage in transactions with us, you may provide personal information such as:

  • Contact information (last name, first name, address, e-mail, telephone, etc.)

  • Identification documents (identity card, passport, date of birth, place of birth, etc.)

  • Financial and tax information (tax number, country of tax residence, wealth status, income, debts, information about your assets, etc.)

  • Education and employment status (occupation, educational background, employer, salary) 

  • Banking information (information about your bank account). 

 

• Information Automatically Collected: When you visit our website, we may automatically collect:

  • IP address

  • Browser type and version

  • Operating system

  • Website usage data (such as pages visited, time spent on the website)

• Third-Party Information: We may receive information from third-party sources, such as partners or public databases, in compliance with legal and regulatory obligations.

 

 

2. HOW WE USE YOUR INFORMATION

This information is processed on the basis of Article 6 (1) c/ of the RGPD and falls under the legal and regulatory obligations to which the company is bound in its capacity as a management company approved by the Autorité des Marchés Financiers. 

 

We use your personal data for the following purposes:

• To provide, manage, support the investment services you request from us

• To manage and improve he business relationship administratively and to assist you in entering the relationship

• To comply with applicable laws, regulations, and legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements.

• To contact you about your account, inform you of changes to our policies, or provide investment updates.

• To maintain the security of our website, services, and operations.

• To evaluate your eligibility for the products marketed, to send you our specific questionnaires (investor quality, suitability test), to verify your identity, to record the accounting operations related to your investments, to manage the controls related to the fight against money laundering, to manage, prevent and detect possible fraud

• To market our products during a subscription or commercial solicitations subject to obtaining your consent. 

 

This information is collected for the purpose of creating a business relationship within the framework of the subscription to our investment products and is necessary: 

• to comply with the legislation governing the marketing of funds managed by the management company; 

• to manage the administrative relationship. 

 

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3. LEGAL BASIS FOR PROCESSING

We process your personal data based on one or more of the following legal grounds:

• Performance of a contract

• Compliance with legal obligations

• Legitimate interests of Ceres Industrie, such as improving services

• Your consent (for marketing communications, where required)

 

4. SHARING YOUR INFORMATION

We may share your personal data with:

• Service Providers: Third-party service providers who assist us in operating our business, such as IT providers, payment processors, and compliance services.

• Legal and Regulatory Authorities: When required by law or to protect our rights and interests.

• Business Partners: In limited cases, we may share information with business partners for joint ventures or similar activities.

We will never sell your personal information to third parties.

 

This sharing of information is inherent to the subscription of financial instruments issued by an alternative investment fund. It allows us to provide the services you have requested, but also to comply with the legislation in force and the rules of compliance governing asset management. 

 

5. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, loss, or misuse. However, no system can be completely secure, so we cannot guarantee the security of your data.

 

6. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. When we no longer need to retain your personal data, we will securely delete or anonymize it.

 

7. YOUR RIGHTS

You have the following rights concerning your personal data:

• Access: Request a copy of your personal data.

• Correction: Correct any inaccurate or incomplete information.

• Deletion: Request the deletion of your personal data when it is no longer necessary.

• Restriction: Restrict the processing of your personal data in certain circumstances.

• Objection: Object to the processing of your personal data based on legitimate interests or for direct marketing purposes.

• Portability: Receive a copy of your data in a structured, machine-readable format.

• To exercise any of these rights, please contact us at: 

• vcantero@ceresindustries.co.uk

• or by mail addressed to : Investor Relations, Ceres Industrie, 51 rue Gay-Lussac - 75005 Paris 

 

8. INTERNATIONAL DATA TRANSFERS

If your personal data is transferred outside the country where you reside, we will ensure that appropriate safeguards are in place to protect your information, such as using standard contractual clauses approved by the relevant regulatory authority.

 

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The revised policy will be posted on our website with the effective date at the top. We encourage you to review this policy periodically to stay informed about how we protect your information.

 

 

10. COOKIES POLICY

 

What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They allow us to recognize your device and store preferences to enhance your experience on our site.

 

Types of Cookies We Use:

• Essential Cookies: These cookies are necessary for the proper functioning of our website, such as enabling you to navigate between pages or access secure areas.

• Performance Cookies: These cookies help us understand how visitors use our site by collecting information about page views, time spent on the site, and other metrics.

• Functionality Cookies: These cookies allow us to remember your preferences and customize your experience, such as language selection.

 

Managing Cookies:

You can control or delete cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website and limit your ability to use certain features.

 

 

11. CONTACT US

If you have any questions or concerns regarding this Privacy Policy or our handling of your personal data, please contact us at:

• vcantero@ceresindustries.co.uk

• or by mail addressed to : Investor Relations, Ceres Industrie, 51 rue Gay-Lussac - 75005 Paris 

You alos have the right to file a complaint with the CNIL or any other competent control authority.