Part 01.
Miscellaneous
This Privacy Policy 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 and/or Partner (which means you have entered into a commercial or investment relationship with LFIS).
We recommend that you check this Policy on a regular basis as it may be frequently updated and modified.
1/ What personal data is collected?
Personal Data sent to us directly
We can 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 LFIS
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 have arrived;
- 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.
Personal Data we collect from third parties
We may also obtain Personal Data from LFIS’ partners. For instance, we are able to collect Personal Data directly from:
- Banks or financial advisors distributing our Products and Services;
- Service providers or other intermediaries.
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 LFIS 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 how Personal Data is used, please read Part 2 of this Policy.
3/ How long is my personal data stored?
LFIS will only keep your store Personal Data for as long as necessary given the specific use of the Personal Data and, in all cases, 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 unsubscribe at any time 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 unsubscribe at any time, using the link in the email sending you marketing offers. 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
LFIS will only store this Personal Data for as long as is necessary given the specific use of the Personal Data, that is, throughout your contractual relationship with LFIS, and in all cases, 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 section 12 below.
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.
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?
Service Providers
As part of LFIS’ ordinary business operations, we may transfer your Personal Data to service providers outside LFIS who act as sub-contractors. These service providers use Personal Data in order that LFIS may provide the relevant Products and Services, to facilitate access to the Website or to assist LFIS with management of its business.
For example, 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 asset administrators, banks, investment advisors, tax advisors, auditors, lawyers or other external professional advisors.
We only disclose to our service providers the Personal Data necessary for them to provide their services and we work with them to ensure that your Personal Data is respected and protected.
We may also transfer your Personal Data to companies for which we deliver services but only in order to fulfil contractual obligations and in compliance with relevant legislation. LFIS will not disclose any Personal Data to these companies for their own marketing or commercial needs. We may disclose Personal Data to our commercial partners in order to provide you with information on 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 that of a third party.
We may also share Personal Data with companies assisting in anti-fraud matters and investigations.
We may also disclose your Personal Data as part of anti-money laundering and terrorist financing efforts, through monitoring of contracts and/or transactions which could lead to the creation of a suspicious activity report or the freezing of assets.
Others
Notwithstanding any provision to the contrary in this Privacy Policy and the 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 LFIS (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 Policy 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 LFIS’ Websites, you confirm that you are over 15 years old, failing which you cannot use LFIS Website without prior parental consent.
7/ How do I know that my personal data is kept safe?
We have a variety of security measures to prevent the loss, misappropriation or misuse of Personal Data. 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 LFIS can affect you?
Each Website may include various hypertext links towards other Websites.
Moreover, each Website may contain hypertext links leading to other websites and applications exploited by companies who are not part of LFIS. 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 LFIS and have their own privacy policies. Consequently, LFIS 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 Privacy Policy and Cookies Policy cease to apply when you leave our Website.
Moreover, LFIS is not responsible for hypertext links to its own Website which may be included in third party websites, even if LFIS has authorised the third-party publisher of the website to place such a link.
Finally, LFIS 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?
If you no longer wish to receive emails from LFIS 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 instructions provided, or alternatively send a message to clientservices@lfis.com stating that you no longer want to receive emails from LFIS.
10/ When browsing on a website, how can I access, update or delete the information in “my account”?
Where applicable, you can log in to “Your Account” 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 LFIS'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.
If you have any instructions or questions about the processing of your personal data by LFIS, you may reach our Data Protection Officer (DPO) using the contact information available in provision 12 of this document.
In order to evaluate your request, we may ask for additional information to identify you. If you do not provide the requested information and we are therefore unable to identify you, we may be unable 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 LFIS’ privacy and cookies policy, please email our Data Protection Officer at:
dpo-lfis@lfis.com
or by postal mail at:
LFIS
Responsable de la protection des données
73, rue de vaugirard
75006 PARIS
France
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 104 Boulevard du Montparnasse, 75014 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.