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Data Protection Policy

Last updated: April 21, 2022

Data confidentiality is a critical issue to which Fincome is highly committed, implementing high standards of privacy and cybersecurity to ensure the respect and protection of your privacy.

This data protection policy informs you of the commitments and practical measures taken by Fincome to ensure the confidentiality of your personal data.

1. DATA CONTROLLER

As the data controller, C&G Partners, a Simplified Joint-Stock Company registered with the Paris Trade and Companies Register under number 901 210 054 and headquartered at 619 Rue Marcel Paul, 94500 Champigny-sur-Marne, France, is responsible for collecting and processing your personal data.

2. PERSONAL DATA COLLECTED AND PROCESSED BY FINCOME

Fincome may collect and process the following types of personal data:

  • Contact data: such as email address, phone number, etc.
  • Identification data: such as name, surname, etc.
  • Connection data: including IP address, browser type and version, operating system, other installed software, mobile platform, technical identifiers, error reports, and execution data.
  • Strictly necessary cookies: Fincome uses cookies to ensure the proper functioning of the website and enhance user experience.

3. PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Fincome ensures that only data strictly necessary for the purpose it serves is collected and processed. Fincome collects and processes your personal data for various purposes, based on the legal grounds detailed below:

  • Contract execution or pre-contractual measures: Personal data is collected and processed to establish and fulfill contracts and manage the business relationship for purposes such as:some text
    • Subscription to Fincome services and execution of General Terms of Use (GTU);
    • Business relationship management.
  • Legitimate interests: Personal data is collected and processed to protect our legitimate interests for purposes such as:some text
    • Fraud prevention;
    • Personalization of our offers;
    • Improving website navigation;
    • Managing cookies not requiring consent.
  • Compliance with legal and regulatory obligations: Personal data is collected and processed to comply with applicable regulations, notably in banking and finance, for purposes such as:some text
    • Identification, identity verification, and Know Your Customer (KYC) under Anti-Money Laundering and Counter-Terrorist Financing regulations;
    • Resolving disputes and enforcing contracts.
  • Consent: For specific activities, such as marketing and cookies, your consent is obtained prior to processing your personal data. This consent can be withdrawn at any time.

4. RECIPIENTS OF PERSONAL DATA

Depending on the purposes mentioned in this policy, Fincome may share your personal data with:

  • Authorized Fincome employees and managers, solely at the express request of clients who wish to do so. Fincome holds only client contact data, such as phone numbers and email addresses, which are never shared outside Fincome. Employees with access to personal data are bound by strict confidentiality obligations.
  • Service providers acting as processors for services related to Fincome, such as email service providers.
  • Competent authorities, where applicable, such as public authorities, regulatory bodies, or organizations involved in anti-money laundering and counter-terrorist financing.

5. DATA RETENTION PERIOD

The retention periods for your personal data are limited and proportionate to the purposes for which they were collected.

Purpose
Storage period
Customer data management
Data is retained primarily for the duration of the contractual relationship and for ten (10) years following its conclusion.
Prospective client data management
Data is retained for three (3) years from its collection or our last contact with the prospect.
Anti-money laundering and counter-terrorist financing obligations
Data is retained for the entire duration of the contractual relationship, after which only necessary data for potential pre-litigation or litigation purposes is archived until the statutory limitation period is reached.
Accounting management
Data is retained for ten (10) years per Article 123-22 of the French Commercial Code.
Cookies
Data retention does not exceed 13 months.

6. TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Your personal data is stored and processed within the European Union. No data transfers outside the EEA are planned. Should it be necessary, contractual mechanisms and binding legal processes will be implemented to legally transfer personal data outside the EEA.

7. YOUR RIGHTS

Under applicable regulations, you have rights regarding your personal data, including:

  • Right of access: Obtain information on the data we hold about you and the processing carried out.
  • Right to rectification: Modify or correct your data.
  • Right to erasure: Request the deletion of your data under certain conditions (legal or regulatory obligations or legitimate reasons may require us to retain your data).
  • Right to restriction and objection: Request restriction or oppose data processing under certain conditions (we may continue processing if we have a legitimate reason).
  • Right to portability: Request data in electronic form and/or ask us to transmit this data to a third party, where technically feasible.

You may exercise these rights and contact our data protection service by:

  • Email: privacy@fincome.co
  • Postal address: C&G Partners, 619 Rue Marcel Paul, 94500 Champigny-sur-Marne, France.

For requests to exercise your rights, we may ask for official identification to verify your identity. We aim to respond promptly, within a maximum of one (1) month. However, this period may be extended by two (2) months for complex requests or based on the volume of requests. You will be informed of such an extension and its reasons within one (1) month of receiving your request.

You may also file a complaint with the French Data Protection Authority (CNIL) at www.cnil.fr.

8. DATA SECURITY

Fincome ensures the security of your personal data by implementing physical, technical, and organizational measures to ensure data confidentiality, integrity, and availability. All Fincome employees and partners are held to strict standards regarding personal data security.

9. MODIFICATION

We will regularly update this privacy policy. Any changes will be posted on this page with an updated revision date.