Politique de confidentialité

1. Le périmètre

1.1 This policy explains the types of personal data the Company collects from individuals, and how it processes, shares with third parties, and secures that data.

1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly by cross-referencing additional information that we hold or can access.

1.3 The Policy defines "processing" as any operation that uses or collects Personal Data, including the management, structuring, and storage of Personal Data.

1.4 Our Services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from anyone under the age of 18, nor do we knowingly permit such individuals to use our Services. We will promptly delete any information relating to children that comes to our attention.

2. Quelles données personnelles détenons-nous sur vous

2.1 We collect Personal Data when you access the service and channels or visit our website. In some cases, we may request your Personal Data directly.

2.2 In other cases, we collect your Personal Data by analyzing your use of our Services or service channels, or by receiving your information from our third-party partners.

3. Aucune obligation de divulguer des informations personnelles

3.1 You are not required to provide Us with Personal Data. In certain circumstances, however, withholding your Personal Data may prevent Us from delivering our Services or granting users access to the website.

4. Quelles données personnelles nous collectons

4.2 Les informations que nous collectons ne sont pas des données privées et ne permettent pas de vous identifier.

4.3 Personal data we receive from you: any personal data you choose to provide when you connect to a third-party online trading platform through us.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.

5. Base juridique et finalités du traitement des données personnelles

5.1 The company processes your Personal Data for the purposes described in this section, in accordance with the applicable legal basis.

5.3 For details about the processing necessary to safeguard legitimate interests, contact us by email.

5.4 The grounds and legal bases on which we may rely to use the information you provide are set out below:

6. Transfert des données personnelles à des tiers

6.1 The Company may also disclose Personal Data to third-party companies that provide services to us, including hosting and storage providers, IP address information, and user experience analytics.

6.2 You may also ask us to share certain Personal Data about you with third-party trading platforms. In these cases, we will provide third-party trading platforms with the Personal Data you have given us. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with affiliated entities or business partners. This can give the Company the resources needed to develop and improve the products and services it offers to its clients.

6.4 Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.

6.5 We may also share Personal Data about you with potential investors or buyers, or with lenders of the Company or any other group company, should such a transaction take place (including the transfer or sale of assets belonging to the Company or any other group company) or in connection with any merger, restructuring, consolidation, or insolvency of the Company or any other group company.

7. Cookies et services de tiers

7.1 We may use third-party services, such as advertising networks that display ads on our website or analytics providers. These companies may also use cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve the user experience, remember your settings, and tailor products and services that may interest you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are temporarily stored on your device and last only a short time, until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They help the website recognise you as a returning user and allow you to return to the website.

7.5 Please note that if this occurs, some or all features of the Site may not function as intended.

Online tracking notice: This service does not currently support "do not track" signals.

8. Conservation des données personnelles

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing described in this Policy, or for a longer period where permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for an additional 12 months.

8.3 Nous réexaminons régulièrement les Données Personnelles que nous conservons afin de vérifier qu'elles demeurent nécessaires.

9. Transferts internationaux

9.1 Your personal data may be transferred to other countries, including to third countries or international organizations. The Company takes all necessary measures to protect the personal data you provide and ensures that data users can exercise their rights and access effective legal remedies.

9.3 The Company can provide details of the security measures it applies to protect your personal data transferred to third countries or international organisations. Email: support@sillage-fondaure.com

10. Sécurité des données personnelles

10.1 We maintain appropriate organizational and technical measures to protect Personal Data, including safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee or ensure that the security of your Personal Data will be maintained without error. Nor can we be held liable for any immaterial, incidental, or indirect damages arising from the use or disclosure of Personal Data. This includes, without limitation, any Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other cause beyond our control.

10.3 Where required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. In these situations, we cannot control the level of security applied to your Personal Data by those third parties.

10.4 Personal data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of personal data you transmit to Us via the internet.

11. Liens hypertextes vers des sites web tiers

11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these sites or applications. This Policy does not apply to actions carried out through such sites or applications.

11.2 Before accessing or using any third-party website or application, we recommend reviewing its privacy policy and considering carefully what Personal Data you choose to provide.

12. Modifications de cette politique

12.1 We may update this Policy at any time. When changes are made, we will notify you by publishing the updated Policy on our website.

12.2 In addition, when we make material changes to this Policy, we will notify you through the means we consider appropriate and publish an announcement on our website.

12.3 Unless explicitly stated otherwise, any changes take effect once the revised Policy is published.

13. Vos droits

13.1 You have the right to ask us to verify the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer need. You may also restrict the scope of how your Personal Data is processed.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in connection with your Personal Data. To exercise your rights, send an email to the address below.

13.3 Right of access The Company can verify the accuracy of the Personal Data it processes about you. Where applicable, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically. The right of access to Personal Data must not conflict with the rights and freedoms of others. If a request infringes the rights or freedoms of another person, the Company may decline to act on it or limit its scope.

13.4 Right to rectification The Company may rectify inaccurate Personal Data. You have the right to request the rectification of any incomplete Personal Data concerning you, in light of the purpose of the processing.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation to which the company is subject. This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or the law of a Member State; or (b) to establish, exercise, or defend legal claims.

13.6 Restrictions de traitement Si vous avez des doutes quant à l'exactitude de vos Données personnelles, vous pouvez demander à la Société de limiter le traitement de vos Données personnelles. Une fois le traitement restreint, ces données ne peuvent être conservées que dans les cas suivants : avec votre consentement ; pour établir, exercer ou défendre des droits en justice ; pour défendre les droits d'une autre personne physique ; ou pour un motif d'intérêt public important au sein de l'Union européenne ou d'un État membre.

13.7 Right to data portability Where processing is carried out by automated means and is based on consent or on a contract to which you are a party, you have the legal right to access the Personal Data you have provided to the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data transfer does not adversely affect the rights and freedoms of others.

13.8 Right to object You have the right to object at any time to any processing of your Personal Data based on the legitimate interests pursued by the Company or a third party. This includes profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing the Personal Data, we may continue only if these grounds override your rights, freedoms, or interests, or relate to the exercise, establishment, or defence of legal claims. Regarding direct marketing You have the right, at any time, to object to the processing of your Personal Data.

13.9 Right to withdraw consent You may withdraw your consent to Our processing of your Personal Data at any time. This withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with the authority that supervises you. You may file a claim with a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union. European Union and Member State laws may limit your rights concerning your Personal Data, as set out in this section 13.

13.10 We will provide the information requested under the rights granted to you in Section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two months, depending on the nature and number of requests. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

13.11 Unless prohibited by Article 13 of the Act, the information you request under your rights pursuant to Article 13 will be provided free of charge. Where a request is unfounded or excessive, in particular if it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action. We may also decline to act on the request.

13.12 If we have doubts about the true identity of the person submitting your request, we may ask that person to provide reasonable proof of their identity.