Preamble
The Smart Lenders Asset Management company, authorized and regulated by the Autorité des Marchés Financiers (AMF) under the number GP-17000031 is committed to respecting the confidentiality of your data and your privacy and takes care to protect your personal data.
This privacy policy aims to provide you with detailed information on how Smart Lenders Asset Management collects, protects and retains your personal data, as well as the reasons for its use and sharing. This policy also aims to inform you of your rights regarding the collection and processing of your personal data and how to exercise your rights.
Please note that this policy may change in the light of regulatory developments and we reserve the right to modify this Privacy Policy at any time.
What personal data is collected ?
Through our Site you may have an opportunity to send us information, such as through the « contact us » pages or any other area where you may send e-mails, request information or any query. By choosing to participate in these, you might provide us with some personal data.
Such personal data include:
- for natural persons: the name, date of birth, place of birth, address (including postal and/or email address), nationality, passport number or identity card number, citizenship, tax identifiers, tax status, banking details, invested amount in the Fund or by the Fund, the holding company (if any) through which the natural person acts, as well as the personal data of the beneficial owner(s) (if other than the natural person);
- for legal persons: the name, date of birth, place of birth, address (including postal and/or email address), nationality, passport number or identity card number and citizenship of the employee(s), director(s), trustee(s), agent(s), auditor(s), legal and/or tax adviser(s) and generally any other person acting on behalf of the legal person, as well as the personal data of the beneficial owner(s) (if other than the natural person),
In addition, details of your visits to our Site including (but not limited to) IP address, cookies, traffic data, location data, weblogs and other information related to what pages are accessed and when may be collected. If you are accessing sections of our Site that are password protected or have entered the Site through a link in an email, our Site will identify you as an individual and may collect data including information about the pages you visit, the documents you download or other information to enhance and personalise your future interaction with our Site.
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.
How do we use your personal data ?
Smart Lenders Asset Management will retain and process your personal data only when this is necessary to achieve our commercial or business objectives and to comply with our regulatory obligations such as the General Data Protection Regulation ((EU) 2016/679) (« GDPR ») and any implementing legislation (« Data Protection Legislation »).
Your personal data can be used in the context (i) know-your-customer processes, anti-money laundering and counter terrorist financing, and (ii) the suitability and appropriateness assessment of the proposed product (including personal data in regards to the knowledge, experience, skills, investment objectives, financial situation, risk tolerance and the ability to bear losses).
We may also use your information to:
respond to queries from you or provide information that you request from us; ensure that content from our Site is presented in the most effective manner for you and for your computer; provide you with information about our products and services; send you promotional materials, newsletters and other communications; provide you with invitations to events, promotions, surveys and market research or other marketing correspondence; respond to your inquiries; verify your information; operate, evaluate and improve our business (developing our products and services, improving our communications, performing auditing or accounting functions); protect against any unlawful activity and prevent fraud; carry out our obligations arising from any contracts entered into between you and us; comply with any legal requirements and our Policies; allow you to participate in interactive features of our service when you choose to do so; notify you about changes to our business, products or services; or any other internal purposes that we believe to be necessary.
Smart Lenders Asset Management will always ensure its business interest does not override your rights and freedoms as an individual.
We are legally required to hold some types of information to fulfil our statutory and regulatory obligations. These obligations include regulations made by the Autorité des Marchés Financiers (AMF) by whom we are authorised and regulated by in France
Internet browsing and Cookies
Cookies are small text files sent from websites that you visit. They are recorded on your device (smartphone, tablet, PC, etc.) and enable data to be temporarily or permanently stored. They inform the website that you are visiting about the date of your last visit and your display preferences (e.g., number of articles per page, etc.).
We will collect cookies in compliance with the GDPR. We will collect cookies for compliance reasons; and may collect further cookies to enhance your Site and customer experience. You can always change your approach at any time.
You can prevent cookies (or their equivalent) from being saved by selecting the relevant option in your browser (or any other media interface used, i.e., smartphone, tablet, etc.).
Moreover, please note that, as with the majority of online services, we automatically collect certain data and information about you and/or your computer or electronic device using « cookies » each time you visit any of our Websites. This information includes:
- the IP address automatically assigned to your computer when using the Internet;
- 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.
How long is my personal data stored?
Smart Lenders Asset Management will keep your information confidential and only use it within Smart Lenders Asset Management, and only transfer it to third parties in the manner described in the below section labelled “Use of third parties”, unless we are under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.
Do we share your personal data with third parties?
Your personal data is used exclusively by Smart Lenders Asset Management and will not be sold or exchanged with third parties. It may however be communicated in certain cases, namely
– To judicial or financial authorities, state agencies or public bodies upon their request and within the limits of what is authorised by the regulations;
– To service providers in the context of a contractual relationship (custodians, distributors, etc.).
Our Site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies or the treatment of your personal data by any third parties. Please check these policies before you submit any personal data to these websites.
What safeguards we have in place
Smart Lenders Asset Management has security measures in place to protect the loss, misuse and alteration of the information under our control. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavour to use appropriate security measures, including systems security, backups, business recovery and breach notification procedures, monitoring and testing procedures.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site and accordingly any transmission is at your own risk. However, once we have received your information, we will use all appropriate procedures and security measures to try to prevent unauthorised access to or disclosure of your personal data.
What rights you have with regards to your personal data we process ?
In accordance with the provisions of Regulation 2016/679, the so-called General Data Protection Regulation (RGPD), you have the following rights with regard to your data:
- Right of and rectification: you can access your personal data and request a copy of the information held by us about you. You have the right to correct any inaccuracies in the details we hold about you – if you change your email address or notice any other information we hold is inaccurate or out of date, please contact us. You have the right to obtain without undue delay the rectification of any inaccurate personal data concerning you.
- Right to cancellation
- Right to object and restrict processing : you can change your marketing preferences or restrict any specific uses of your personal data at any time by contacting us. We will inform you if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by contacting us directly.
- Right to portability : you can ask for your information to be transferred to another organisation or to yourself. Where such requests are manifestly unfounded or excessive, we will inform you and we may charge a reasonable fee or refuse to respond to such a request.
Please be aware that even if you object, we will be allowed to continue processing if it is necessary for the performance of a contract signed with you, for the public interest or for the legitimate interests of Smart Lenders Asset Management.
What if I have further questions about the privacy policy ?
If you have any questions about this Privacy Policy or doubts about the processing of your data by Smart Lenders Asset Management, you can contact the Data Protection Officer by email at dpo@smartlenders-am.com or by sending a letter to Smart Lenders Asset Management – Data Protection Officer – 109, boulevard Haussmann – 75008 PARIS.
Complaints
If you believe your personal data has been processed by Smart Lenders Asset Management in a way that does not comply with the GDPR, you have the right to lodge a complaint with us directly or with the CNIL, whose contact details can be found at the following Internet address: http://www.cnil.fr
What legislation applies to this privacy policy?
This Privacy Policy is governed by French law, in particular the French Data Protection Act No. 78-17 of 6 January 1978, as amended and the recommendations of the CNIL the GDPR.
