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Last update: 01/04/2020 

Preamble 

The La Française Group and the companies within it (referred to collectively in this document as “the Group”) are committed to protecting your privacy and the confidentiality of your data and we take care to protect your personal data (hereinafter “Personal Data”). Please read the following information carefully. It tells you about how we collect and use your Personal Data and the options available to you in connection with its use. 

This Privacy Policy is applicable to all instances of processing of Personal Data implemented by the Group, in the framework of its offer for products and services (hereinafter referred to as the “Products and Services”). 

Your Personal Data may be collected from you directly or indirectly, via a third party. Moreover, they may be collected by paper forms or any websites of the Group as follows (hereinafter referred to as the “Websites”): 

This Privacy Policy includes a first section (Part 1) concerning the general terms and conditions for collection and processing of Personal Data; and a second section (Part 2) concerning the specificities of the collection and processing of Personal Data in line with the entity of the Group who is the data controller, for the Products and Services concerned and Website used.

PART 1: MISCELLANEOUS 

This Privacy Policy (Part 1) is applicable regardless of whether you are a “Visitor” to a Website (which means you are simply consulting Products and Services offered online), a “User” (which means you have registered on the Website), or a Client (which means you have taken out offers for Group products or services). 

We recommend that you regularly check this Policy as we often update and modify it. 

1/ WHAT PERSONAL DATA IS COLLECTED? 

Personal Data which you send to us directly 

We are able to collect Personal Data directly from you: 

  • via subscription forms; 
  • at the time of any contact request;  
  • when making a request for documentation; and 
  • when you enter into a commercial or investment relationship with a company in the Group. 

For further information as to the type of Personal Data collected, please read Part 2 of this Policy. 

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. 

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. 

When you access, visit and/or use any of our Websites we can, therefore, follow your visit and collect certain data about your use of the Products and Services and your activities on the Website. To find out more about how we use cookies, please read our Cookies Policy, available at the following address: https://www.lfis.com/en/cookies.html

Personal Data we collected from third parties 

We may also obtain Personal Data about you from Group partners. 

For instance, we are able to collect Personal Data directly from: 

  • Banks or financial advisors distributing our Products and Services; 
  • Administrators of assets responsible for supervising tenants, etc. 

2/ HOW WE USE YOUR PERSONAL DATA 

We process your Personal Data on the following legal bases: your consent (request for information or documents), a contract (a subscription form or registration to benefit from Products and Services), in order to comply with relevant legislation or in pursuit of a legitimate interest. We believe that the risk related to the Personal Data that it processes on the basis of its legitimate interest is not excessive or too intrusive. We have, notably, implemented measures to protect your rights by applying appropriate retention periods and ensuring appropriate security controls. 

For further information as to the purpose of processing undertaken, please read Part 2 of this Policy. 

3/ HOW LONG IS MY PERSONAL DATA STORED? 

We store this Personal Data only for as long as is necessary for the purpose for which we process it and in any event for the period necessary to comply with a legal or regulatory requirement. 

Personal data used to send you information 

Your Personal Data will be kept for as long as your subscription is live. You can bring this to an end at any time by unsubscribing, using the link in the email sending you necessary documentation. In any event, if you do not make contact for three years, your Personal Data will be erased. 

Personal data used to send marketing offers 

Your Personal Data will be kept for as long as you agree to receive our marketing offers. You can refuse these at any time by unsubscribing, using the link in the email sending you a commercial offer. In any event, if you do not make contact for three years, your Personal Data will be erased. 

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

We store this Personal Data only for as long as is necessary for the purpose for which we process them, that is throughout our contractual relationship, and in any event for the period necessary to comply with a legal or regulatory requirement. 

For further information concerning the term of storage of Personal Data, please refer to the section entitled ‎12 “WHAT TO DO IF I HAVE ANY FURTHER QUESTIONS CONCERNING THE PRIVACY POLICY?”. 

4/ HOW IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE OF THE EU?

When the processing of your Personal Data involves a transfer to third countries outside the European Union/EEA, the transfer is to countries listed by the European Commission as providing sufficient protection for data and/or is covered by appropriate guarantees based on standard contract clauses published by the European Commission and/or recognised certification. 

When sharing of Personal Data involves transfer to the United States, recipients will have Privacy Shield certification. 

For more information about the transfer of Personal Data to third countries outside the European Union/ EEA, please refer to the section below “WHAT TO DO IF YOU HAVE FURTHER QUESTIONS ABOUT THE PRIVACY AND COOKIES POLICY”. 

5/ HOW DO WE SHARE YOUR PERSONAL DATA? 

The Group’s companies 

We may share your Personal Data with companies in the Group. For further information on the companies in the Group, please go to https://www.la-francaise.com/en/legal-notice/

Service Providers 

As part of the conduct of our business, we may transfer your Personal Data to service providers outside the Group who act as sub-contractors. These service providers use Personal Data with a view to allowing us to provide the Products and Services, to provide access to the Website or to assist us in the framework of business management. 

For instance, these service providers may be IT partners, logistical and marketing partners, our host or service providers who assist us in data management, distribution of emails, analysis of information but also property managers, asset administrators, real-estate agencies, banks, investment advisors, tax advisors, auditors, lawyers or other external professional advisors. 

We disclose to our service providers only the Personal Data they need to provide their services and we work with them to ensure that your Personal Data are respected and protected. 

We may also transfer your Personal Data to companies for which we deliver services but only in order to fulfil our contractual obligations to them and in compliance with relevant legislation. 

We never disclose any personal Data to these companies for their own marketing or commercial needs. However, we may disclose your Personal Data to our commercial partners only in order to provide you with our Products and Services or other products and services which may be of interest to you. 

Legal Obligations 

We may need to disclose personal data in response to a request from a regulatory authority, such as the tax authorities or CNIL (the French data protection authority), etc., and/or a court (in response to a judgement, a court order or injunction) on request or if the law requires us to do so, or in order to protect our interests, our property and/or our security and/or those of a third party. 

We may also share Personal Data with companies assisting in the fight against fraud and investigating fraud. 

We may also disclose your Personal Data as part of the fight against money laundering and terrorist financing, with the implementation of monitoring of contracts and/or transactions which could lead to the drawing up of a suspicious activity report or the freezing of assets. 

Others 

Notwithstanding any provision to the contrary in this Privacy and Cookies Policy or with your prior permission, we will not sell, market or lend Personal Data to other companies in the normal course of business.  

However, in the event of any restructuring of the Group’s companies (acquisition, merger or partial transfer of assets or other activity of this sort) your Personal Data may be disclosed to another company, but the disclosure will then be subject to the Privacy and Cookies Policy in force. 

6/ ARE OUR PRODUCTS AND SERVICES INTENDED FOR CHILDREN? 

Our Products and Services are not intended for use by children. By using any of the Websites of the Group, you confirm that you are over 15 years old, failing which you cannot use a Group Website without prior parental consent. 

7/ HOW DO I KNOW IF MY PERSONAL DATA IS KEPT SAFE? 

We have a variety of security measures to prevent the loss, misappropriation or misuse of Personal Data that you provide to us. In order to guarantee the security of the data you disclose online during transmission, we use encryption, authentication, and flow analysis and we carry out security audits on the hosting environments. 

8/ HOW LINKS FROM THE WEBSITE TO SITES OTHER THAN THOSE OF THE GROUP CAN AFFECT YOU? 

Each Website may include various hypertext links towards other Group Websites. 

Moreover, each Website may contain hypertext links leading to other websites and applications exploited by companies who are not part of the Group. The only purpose of these links is to make browsing easier for you and to provide you with the fullest possible information. We have no control over these websites and applications. They are separate from the Group and have their own privacy policies. Consequently, the Group cannot be held liable under any circumstances, in particular in relation to the accuracy, relevance, availability or reliability of information and products and services offered on these websites, their respect for copyright, or the legality or decency of material contained on these third party websites and applications accessible from our Website. We encourage you to review the terms and conditions and privacy policies of any third party websites and applications before using them. You should note that our Confidentiality and Cookies Policy ceases to apply when you leave our Website. 

Moreover, the Group is not responsible for hypertext links to its own Website which may be included in third party websites, even if the Group has authorised the third party publisher of the website to place such a link. 

Finally, the Group generally prohibits anyone from placing a hyperlink to one or more pages of its Website without its express prior consent. 

9/ HOW CAN I REFUSE/UNSUBSCRIBE FROM 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 marketing communications, you only have to click on the “unsubscribe” link at the foot of every email and follow the steps set out there. 

If you no longer wish to receive SMS messages, you can text “STOP” to the number shown if this option is available. Otherwise, you should contact your usual adviser 

10/ WHEN BROWSING ON A WEBSITE, HOW CAN I ACCESS, UPDATE OR DELETE THE INFORMATION IN “MY ACCOUNT” AND/OR “MY EXTRANET”? 

You can log in to “Your Account” or “My Extranet” when the Website allows you to do so. After you have logged in, you can change your profile and update your Personal Data. It is your responsibility to protect your log in details (particularly your username and passwords) and, as set out in the General Terms and Conditions, you are responsible for any activity on the Website using your log in details. 

11/ YOUR RIGHTS REGARDING YOUR PERSONAL DATA 

Under the legal and regulatory framework applicable to the protection of Personal Data and privacy, you have a right to access, rectify, object to or erase your Personal Data or limit its processing, as well as a right to its portability, unless provided otherwise by law.  

These rights are not absolute and each of these rights is subject to certain conditions in accordance with French law (in particular the French Data Protection Act No. 78-17 of 6 January 1978, as amended, but also any legislation applicable to the Group's banking and finance), the recommendations of the CNIL and 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 a right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of processing based on the consent undertaken before it was withdrawn. 

You also have a right to give instructions about what should be done with your Personal Data after your death. 

You may write to La Française Group about this at any time, at the following address: Groupe La Française - Data Protection Officer – 128, boulevard Raspail - 75006 PARIS, or by email to dpo@la-francaise.com

Before evaluating 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 respond to your request. 

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

12/ WHAT TO DO IF YOU HAVE FURTHER QUESTIONS ABOUT THE PRIVACY AND COOKIES POLICY? 

If you have any questions or doubts about this privacy and Cookies Policy, you can send an email to the Data Protection Officer atdpo@la-francaise.com or send a letter to La Française Group - Data  Protection Officer – 128, Boulevard Raspail - 75006 PARIS. 

13/ 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, as well as the GDPR. Please note that this policy may change in the light of regulatory developments. 

Part 2: SPECIFIC PRODUCTS AND SERVICES 

More particularly, depending on the Group entity concerned, the Produces and Services in question and the Website that you use, the data collected, and purposes of processing and legal basis may differ. For further information about the terms and conditions of processing your Personal Data, please refer to the below table in line with the business sector concerned. 

1/ La Française Group 

The Data Controller is LA FRANCAISE Group, a company entered on the Paris Trade and Companies Register under number 480 871 490 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
CLIENTS Websites and Social Networks (cookies and trackings) Supervision of advertising campaigns and social network prospection   Supervision of statistics concerning consultation of our websites Your consent  
Telephone registration of conversations (track recorded) Ensuring that services offered to clients comply with our regulatory obligations Performance of our legal obligations 
Client claims (surname, forename, email address) Processing customer claims, mediation with regulators, quality control of supervision of client relations Performance of a contract that we concluded with you 
    SERVICE PROVIDERS Contact and supervision file (Surname, forename, email, KIBS, and all documents required by the contact file with the partner to fulfil legal obligations) Contact Our legitimate interests  
Supervision of relations  Performance of our legal obligations 
 Contractualisation Performance of a contract that we concluded with you 
Disputes  Performance of a contract that we concluded with you 

2/ Real-estate 

The Data Controller is LA FRANCAISE REAL ESTATE MANAGERS, a company entered on the Paris Trade and Companies Register under number 399 922 699 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
TENANTS (LEGAL ENTITIES or NATURAL PERSONS) Natural persons: Civil status of tenants, data of birth of tenants, address, bank details, financial documents required in the framework of analysis of the tenant application file (pay slip, tax form, employment contract, real-estate where applicable), bank details.   In the event of any dispute with tenants: knowledge of the financial situation of the tenant.  Legal entities: KBIS, balance sheet, profit and loss account, identity document of representatives of the legal entity and all documents required for due diligence Tenant analysis Our legitimate interests  
Supervision of rental management by asset administrators  Performance of a contract that we concluded with you 
Dispute management  Performance of a contract that we concluded with you 
Sale of real estate assets to third parties  Our legitimate interests  
Reporting to SCPI partners Performance of a contract that we concluded with you 
LCB/FT and corruption diligence  Performance of our legal obligations 
Tax declarations  Performance of our legal obligations  
Mandates with real-estate agents  Our legitimate interests 
    CREDIT-LESSORS Civil status of credit-lessors, financial and family circumstances which justifies the desire to enter into a life annuity agreement, bank details, details of heirs, elements required for supervision of the file after acceptance. Purchase from private individuals  Our legitimate interests  
Supervision of credit lease file  Performance of a contract that we concluded with you 
Management of life annuity Performance of a contract that we concluded with you 
Sale of assets Our legitimate interests 
  BUYERS/ 
SELLERS 
Investment file / Uninvestment from real-estate (Civil status of buyers, sellers, all documents required for the file for analysis of acceptance of an offer, origin of funds) Purchase/sale of real-estate for real-estate fleets managed by the property manager  Contact Performance of a legal obligation (LCB/FT diligence)  Our legitimate interests 
Mandates with real-estate agents Our legitimate interests 
  SCPI CLIENTS Civil status, address, bank details, marital status, origin of funds, funding, acquisition of shares  Purchase/sale of shares in an SCPI  LCB/FT diligences  Notices convening General Meetings of SCPIs Performance of a contract that we concluded with you  Performance of a legal obligation (LCB/FT diligence)  Performance of a contract that we concluded with you

3/ Distribution 

The Data Controller is LA FRANCAISE AM FINANCE SERVICES, a company entered on the Paris Trade and Companies Register under number 326 817 467 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences   KYC Performance of our legal obligations 
Establishing audience measurement Your consent 
Register of SCPI processing Performance of a contract that we concluded with you 
Payment of SCPI dividends Performance of a contract that we concluded with you 
Processing IFU and tax declarations  Performance of a contract that we concluded with you 
Notices convening General Meetings of SCPIs Performance of a contract that we concluded with you 
  PROSPECTIVE CLIENTS Clients - natural persons: Surname, forename, email addresses during the first phase of exchange. During the second phase, if the interest concerns a financial instrument: Civil status, email, tax, marital status, residence, telephone number, address, national ID card, passport, proof of address, guardianship power, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: Surname, forename, email addresses during the first phase of exchange. During the second phase, KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Our legitimate interests 
Management of contacts with prospective clients Your consent 
DISTRIBUTORS Surname, forename, email, KIBS, and all documents required by the contact file with the partner to fulfil legal obligations  KYP (knowledge of the partner) Performance of our legal obligations 
Convention management (sales, supervision of provided clients) Performance of a contract that we concluded with you 

4/ Securities 

The Data Controller is LA FRANCAISE ASSET MANAGEMENT, a company entered on the Paris Trade and Companies Register under number 314 024 019 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Your consent 
KYC Performance of our legal obligations 
Management and supervision of customer relations  Performance of a contract that we concluded with you 
  PROSPECTIVE CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Our legitimate interests  
Management of contacts with prospective clients Your consent  

5/ Private Equity 

The Data Controller is NEW ALPHA ASSET MANAGEMENT, a company entered on the Paris Trade and Companies Register under number 450 500 012 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Your consent 
KYC Performance of our legal obligations 
Management and supervision of customer relations  Performance of a contract that we concluded with you 
  PROSPECTIVE CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Our legitimate interests  
Management of contacts with prospective clients Your consent  

6/ LFIS 

The Data Controller is LFIS, a company entered on the Paris Trade and Companies Register under number 752 897 850 and having its registered office at 128 boulevard Raspail, 75006 Paris. 

Below is a list of Personal Data that we collect from you, as well as the purposes and legal basis used for each form of processing. 

Category of data subjects Type of Personal Data Processing purpose Legal basis for data processing 
CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Your consent 
KYC Performance of our legal obligations 
Management and supervision of customer relations Performance of a contract that we concluded with you 
  PROSPECTIVE CLIENTS Clients - natural persons: Civil status, email, tax, marital status, residence, IBAN, telephone number, address, national ID card, passport, proof of address, guardianship power, pledge of shares in SCPI, death certificates, any documents required in the framework of LCB/FT diligences, KYC MIF, ...    Clients who are legal entities: KIBS, powers and national ID card of the signatory, balance sheet, profit and loss account and any document required in the framework of LCB/FT diligences Entering into contact with a client and implementation of a KYC Our legitimate interests 
Management of contacts with prospective clients Your consent  
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