POLITIQUE DE PROTECTION DE VOS DONNEES A CARACTERE PERSONNEL

This policy is intended to describe the conditions under which the management company CA Indosuez Wealth (Asset Management) and its subsidiaries, hereinafter "Indosuez Asset Management", is required to collect and process, as part of its activities, the personal data of all data subjects, particularly investors and users of this website.

PERSONAL DATA


As part of its activities, Indosuez Asset Management is required to process, in an automated or non-automated manner, the personal data of natural persons: existing and potential investors, users of this website (when they complete the online form made available on this website) and any other natural person (such as representatives, executives, etc.); all of these people are hereinafter individually referred to as the “Data Subject”.

The personal data relating to Data Subjects that Indosuez Asset Management collects or processes, in its capacity as data controller, are needed to satisfy its legal and regulatory obligations, to enable the implementation of precontractual measures or contracts to which the Data Subject is party and/or the pursuit of Indosuez Asset Management’s legitimate interests, in accordance with the rights of the Data Subject. When such data are collected for other purposes, Indosuez Asset Management obtains the Data Subject’s consent beforehand.

As this more specifically concerns Data Subjects who are investors, Indosuez Asset Management uses their personal data in order to provide investment services, comply with regulatory obligations by virtue of the law applicable to investment funds under management and to the management company, and to enable the effective management of the investments made in these funds.

Without certain information concerning an investor necessary to perform a service, Indosuez Asset Management will not be able to offer this investor the opportunity to benefit from the service for which these data are required.


Purposes of processing personal data

The personal data of Data Subjects may be subject to processing, mainly for the purposes set out below.

By clicking on each of the elements below, the Data Subject may access detailed information on the use of their personal data, concerning both the purposes of the processing and the legal basis enabling Indosuez Asset Management to process their data and any transfers thereof to non-EU countries.


- La gestion des canaux de communication
- L’Audit Interne
- Les Moyens Généraux
- La gestion de la sécurité et du contrôle des systèmes d’information et de communication
- La gestion du Risque Opérationnel et Audit
- L’organisation et le pilotage du système de production comptable
- Les activités du Contrôle Permanent
- La gestion, la production financière, le reporting, l’organisation et le développement de la société de gestion
- La gestion des relations avec les tiers
- La Conformité et prévention de la fraude
- La Sécurité Financière
- La Distribution
- L’activité Administration Centrale
- L’activité d’Agent de Transfert
- L’activité d’Agent Payeur
- L’activité de Banque Dépositaire
- Le suivi du portefeuille des fonds


Retention of personal data

These personal data are processed and stored for the period necessary to fulfil the intended purpose and for a period not to exceed the duration of the contractual relationship or the business relationship plus the time needed to liquidate and consolidate rights, periods of limitation and exhaustion of remedies.

To meets its legal obligations or respond to requests from regulatory and administrative authorities, as well as for the purposes of historic, statistical or scientific research, Indosuez Asset Management may archive data under the terms set forth by applicable regulations.


Rights of the Data Subject

At all times, the Data Subject shall have the following rights, under the conditions provided for in the applicable regulations:

· the right to access their personal data;

· the right to have inaccurate or incomplete data concerning them corrected;

· the right to object, on legitimate grounds, to the processing of their data;

· the right to request the deletion of their data when they are no longer necessary for the purposes for which they were collected or processed or when the Data Subject withdraws their consent (when the processing of the data in question requires such consent);

· the right to request the limitation of the processing of their personal data;

· the right to request the portability of the data entrusted to our institution based on the Data Subject’s consent or in order to execute a contract: for the Data Subject, this right consists of receiving their data in a digital format.

At any time and without providing a reason, the Data Subject may also object to the use of their data for commercial prospecting purposes, including “profiling”: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements (art. 4, para. 4 of Regulation (EU) 2016/679 of 27 April 2016). When it is related to this purpose, by Indosuez Asset Management or by third parties, or when the processing has consent as its legal basis, the Data Subject may withdraw their consent, by writing a letter to CA Indosuez Wealth (Asset Management), 31-33 avenue Pasteur, L-2311 Luxembourg. Postage costs will be reimbursed on simple request from the Data Subject.

The Data Subject may exercise their rights by contacting the Data Protection Officer, whose contact details are set out below in the “Data Protection Officer” section. In support of their request, the Data Subject may use the form for the exercise of rights below (link on…).

The Data Subject is informed that by exercising a number of the aforementioned rights, Indosuez Asset Management may be prevented from providing them, as the case may be, with certain products or services.


Data Protection Officer (DPO)

Indosuez Asset Management has appointed a DPO (Data Protection Officer), whom the Data Subject may contact at the following address: dataprotectionofficer@ca-indosuez-am.com or at the postal address: CA Indosuez Wealth (Asset Management), 31-33 avenue Pasteur, L-2311 Luxembourg.

By contacting the DPO, the Data Subject may access detailed information on their rights and the use of their personal data, particularly with regard to the purposes of the processing, the legal bases allowing Indosuez Asset Management to process their data, their retention periods, their recipients, and, if appropriate, the transfers of such data to a non-EU country as well as the implemented safeguards.


Complaints to the Authorities

In the event of a dispute, the Data Subject may make a complaint to the National Data Protection Commission (CNPD), whose contact details are available on the website accessible from the following link: https://cnpd.public.lu


Transfer of personal data

The personal data collected by Indosuez Asset Management in accordance with the agreed purposes may, in the course of various operations, be transferred to a country that is or is not a member of the European Union. In the case of a transfer to a non-EU country not approved as suitable by the European authorities, safeguards ensuring the protection and security of such data are put in place.

The Data Subject is informed that their personal data are subject to computerised processing within Crédit Agricole Group entities, particularly CA Indosuez Wealth (Europe) and CA Private Banking Services in Switzerland, a country providing an adequate level of protection under Decision 2000/518/EC issued by the European Commission on 26 July 2000. It is specified for all intents and purposes that the transfer of this data to Switzerland has no effect on the storage of investors’ assets.


Professional secrecy

The operations and personal data of Data Subjects are covered by professional secrecy, to which Indosuez Asset Management is bound, in accordance with its legal and regulatory obligations.

However, to fulfil these obligations, Indosuez Asset Management may be required to provide information concerning Data Subjects who are investors to the judicial or legally authorised administrative authorities.

Finally, the Data Subject expressly authorises Indosuez Asset Management to inform them by e-mail of any information concerning them that may be covered by professional secrecy.


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