The ALLINVEST Group attaches great importance to protecting your privacy. That is why we have adopted common principles within the ALLINVEST Group’s Privacy Policy, which is available on the www.all-invest.com website (“We”).
ALLINVEST is the trademark of all the activities of the financial company INVEST & ASSOCIES, SARL whose registered office is located at 73 boulevard Haussmann, 75008 PARIS, France. INVEST & ASSOCIES includes Invest Securities, Invest Corporate Finance, Sully Patrimoine Gestion and Sully Assurances, which are the entities responsible for processing your personal data.
The purpose of this document is to inform you of how we use and protect your personal data, as well as the reasons why we process such data.
It applies uniformly to all ALLINVEST products and services, with it being understood that additional information may be provided if necessary when you purchase a particular product or service.
1. WHAT PERSONAL DATA DO WE PROCESS?
We only collect and use personal data that we need in the course of our activity to offer you customised and quality products and services.
We may be required to collect various types of personal data from you, including:
- identification and contact information (surname, first name, place and date of birth, photo, passport and identity card numbers, postal and email address, telephone number, sex, age or signature), proof of address (utility bills, etc.);
- identification and authentication data, especially when using online services (technical logs, computer traces, information about the security and use of the terminal, IP address, etc.);
- tax data (tax number, tax status, country of residence);
- family situation (marital status, matrimonial regime, number of children);
- information about training and employment (level of study, employment, name of employer, remuneration, etc.);
- banking, financial and transactional data (data on transactions including transfer information, investor profile, the value of your assets, etc.);
- data on your habits and preferences: data related to the use of the products and services purchased in relation to banking, financial and transactional data;
- data on interactions with us: on our premises (contact reports), on our websites, on our applications, on our pages, on social networks, during interviews and phone calls.
The data we use may be collected directly from you or obtained from the following sources, in order to verify or enrich our databases:
- publications/databases made available by the official authorities (Official Journal);
- our client companies or service providers;
- third parties such as business intelligence or anti-fraud agencies, in accordance with data protection regulations;
- websites/social media pages containing information that you have made public and databases made public by third parties.
2. SPECIAL CASES OF DATA COLLECTION, INCLUDING INDIRECT COLLECTION
We may collect information about you even if you are not a customer of the ALLINVEST Group.
The following list (non-exhaustive) shows examples of personal data collected by ALLINVEST from non-customers, such as:
- prospective customers, guarantors, agents, business introducers;
- legal representatives, corporate officers and authorised persons of a corporate entity of the ALLINVEST Group;
- beneficial owners and shareholders of a corporate entity of the ALLINVEST Group;
- contractors or beneficiaries in transactions made in relation with a customer of the ALLINVEST Group;
- employees of our service providers.
3. WHY AND ON WHAT PROCESSING BASIS DO WE USE YOUR PERSONAL DATA?
a. To comply with our legal and regulatory obligations
We use your personal data to fulfil various legal and regulatory requirements, including:
- the fight against money laundering and terrorist financing;
- compliance with the applicable legislation on international sanctions and embargoes;
- the fight against tax fraud, compliance with tax audit and reporting obligations;
- compliance with banking and financial regulations, which require us to: assess your financial solvency;
- prevent unpaid bills;
- fulfil our duty of advice, for example on life insurance;
- monitor and report risks to which the institution may be exposed;
- responses to formal requests from duly authorised public or judicial authorities.
b. To execute a contract with you or provide you with pre-contractual information
We use your personal data to conclude and execute our contracts including to:
- provide you with information about our products and services;
- assist you in subscription requests;
- purchase products and services distributed by ALLINVEST;
- as part of customer relationship management, including: management and performance of products and services such as advisory management or mandated management;
- assess your needs and knowledge, for example in life insurance or securities;
- the security of the services you use.
c. To serve our legitimate interests
We use your personal data to develop and expand our products and services, optimise our risk management and defend our interests in court, including for the purposes of:
- evidence of transactions or operations;
- IT management, including infrastructure management (such as exchange platforms) and business continuity including the safety of people;
- fraud and abuse prevention (security measures, monitoring unusual transactions, etc.);
- recovery;
- recording phone calls;
- customisation of commercial offers: by improving the quality of banking, financial or insurance products or services; offering products or services that match your situation and profile as defined by us.
These commercial proposals may be carried out through:
- segmenting prospective customers and customers;
- the transmission of your data to another ALLINVEST Group company, particularly if you are – or are likely to become – a customer of this other company;
- adapting the offer of products or services to products or services you already own or use and the data we hold (for example, we can identify that you hold securities eligible for PEA-PME but no PEA-PME tax envelope);
- monitoring transactions to identify those that seem unusual (for example, a significant amount deposited into your securities account).
d. To respect your choice when we ask for your consent to specific processing
In some cases, consent is needed to process your data, for example:
- when the purposes described above give rise to an automated decision-making producing legal effects concerning you or affecting you significantly, we will inform you separately of the underlying reason, as well as the importance and expected consequences of this processing;
- if we carry out processing for purposes other than those described in section 3, we will inform you and we will ask for your consent if necessary.
4. TO WHAT CATEGORIES OF ENTITIES MAY YOUR PERSONAL DATA BE DISCLOSED?
In order to fulfil the aforementioned purposes, we may be required to disclose your personal data only to:
- entities in the ALLINVEST Group,
- service providers and subcontractors carrying out services on our behalf,
- independent agents, intermediaries or brokers,
- commercial and banking partners,
- financial, judicial or state agencies, public organisations upon request and within the limits of the regulations,
- some regulated professions such as lawyers, notaries and auditors.
5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep your personal data for the longest period of time necessary to comply with the applicable legal and regulatory provisions or another period given the operational constraints such as proper account management, effective customer relationship management and responses to legal or regulatory requests.
With regard to customers, most of the information is kept for the duration of the contractual relationship and for 10 years after the end of the contractual relationship.
With regard to prospective customers, the information is kept for 3 years after collection or our last contact with you.
6. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
In accordance with the applicable regulations, you have various rights, namely:
- Right to access: you can obtain information about the processing of your personal data and a copy of this personal data.
- Right to rectification: if you believe that your personal data is inaccurate or incomplete, you can request that this personal data be modified accordingly.
- Right to erasure: you may request the deletion of your personal data within the limits of what is allowed by the regulations.
- Right to restrict processing: you can request the limitation of the processing of your personal data.
- Right to object: you can object to the processing of your personal data, for reasons related to your specific situation. You have the absolute right to object to the processing of your personal data for the purposes of commercial prospecting, including profiling related to such prospecting.
- Right to data portability: when this right is applicable, you have the right for the personal data that you have provided to be returned or, where technically possible, to be transferred to a third party;
- Right to set guidelines regarding the storage, deletion or disclosure of your personal data, which become applicable after your death.
- Right to withdraw your consent: if you have consented to the processing of your personal data, you have the right to withdraw your consent at any time.
You can exercise the rights listed above:
- by writing a letter to Invest & Associés – DPO, 73 boulevard Haussmann, 75008 Paris, France
- by sending an email to: dpo@all-invest.com
In accordance with the applicable regulations, you are entitled to lodge a complaint with the competent supervisory authority such as the CNIL (National Commission for Data Processing and Freedoms) in France.
7. HOW CAN YOU CONTACT US?
If you have any questions about the use of your personal data covered by this document, you can contact our Data Protection Officer by writing a letter to: Invest & Associés – DPO, 73 boulevard Haussmann, 75008 Paris, France, or by sending an email to: dpo@all-invest.com