Please read this Richelieu Gestion personal data protection charter carefully.

General information

By subscribing and using the products and services (hereinafter the “Services”) of Richelieu Gestion, and by browsing all website pages supplied and operated by Richelieu Gestion (hereinafter the “Website” or “Site”), you accept all the terms and conditions of this personal data protection charter (hereinafter “the Charter”).

Introduction

Richelieu Gestion, and more generally the holding company Compagnie Financière Richelieu, considers the protection of your personal data (hereinafter “personal data” or “data”) to be of the utmost importance.

This Charter is intended to let you know how we collect, use, process and share your personal data when you use our Services and our Website.

Your personal data is processed in accordance with the applicable laws pertaining to personal data protection and, in particular, with European Regulation No. 679/2016 on the protection of natural persons with regard to the processing of personal data ("GDPR”) and with the French Law No. 78-17 of 6 January 1978, in its current version, relative to information technology, data files and civil liberties (hereinafter the “Regulations”).

These Regulations do not apply to personal data used to identify a natural person directly or indirectly. Such information may be collected, recorded, stored, adapted, transferred, processed and/or used by Richelieu Gestion in accordance with the following provisions.

For the purposes of this document, the terms “We”, “Us” and “our” mean Richelieu Gestion.

Who is the data controller?

The party responsible for using and processing your personal data is Richelieu Gestion, whose headquarters are located at 1-3-5, rue Paul Cézanne – 75008 Paris. Richelieu Gestion determines the purpose and manner of processing your personal data.

Who are the people concerned by this document?

This document is intended for any natural person having direct or indirect dealings with Richelieu Gestion, such as (non-exhaustive list) :

  • Prospect
  • Visitor/User of our website
  • Job applicant
  • Person contacting Richelieu Gestion
  • Proxy
  • Legal representative, corporate officer and person authorised to represent a legal person
  • Beneficial owner of a legal person
  • Originator or beneficiary for transactions related to the products and/or services of Richelieu Gestion.

Richelieu Gestion employees are not concerned by this Charter, since they have received a data protection policy relative to Human Resources.

The Charter is not intended for minors. We understand the importance of protecting data related to minors, especially in a virtual environment. Accordingly, we strive not to collect or store data concerning minors.

We use or are likely to use your personal data in all these cases. If you are one of the persons concerned, we request that you read this document carefully.

What personal data are collected while browsing the Website?

When you browse our website, Richelieu Gestion collects and processes some of your personal data.

Depending on your use of our website, the data we collect may include those listed in the following categories:

Data categories
Types of data
Identification, personal situation and contact information
First and last names, address, place and date of birth, country of residence, telephone number, email address
Profession
CV, schooling, vocational training, distinctions, studies and professional situation, language, hobbies and interests.
Browsing and cookies
Technical logs, IP address, data collected via cookies.

There is no obligation to answer the questions raised by Richelieu Gestion. However, not providing this information may prevent Richelieu Gestion from being able to process your request or may prevent you from using the tool or service.

We may also collect and use personal data provided to us by your employer, your company or a company to which you are connected through an agreement or a relationship between us and your employer or such a company.

What personal data is collected through other means than browsing the website ?

Richelieu Gestion will process different types of personal data, and in particular those listed in the following categories :

Data categories
Types of data
Identification, personal situation and contact information
First and last names, address, telephone number, email address.
Videos and telephone recording
Richelieu Gestion’s premises are protected by cameras. The data collected are processed by Richelieu Gestion for security reasons only. Email and telephone communications are likely to be recorded by Richelieu Gestion.
Profession
CV, schooling, vocational training, distinctions.
Other
All other personal data reasonably related to the conduct of business by Richelieu Gestion.


When we collect or receive your personal data within the framework of our products and/or services, we may also receive information from third parties, such as the counterparties in a transaction, regulatory authorities, etc. This information may include your name, contact details, details about your employment, and any other information relevant to the services we provide to our clients.

What data do we not collect ?

Except in very specific cases where required by regulations, Richelieu Gestion never processes data concerning your racial or ethnic origins, political opinions, philosophical convictions, religion, trade union membership, sex life or sexual orientation, and your genetic data.

What are the purposes and legal grounds for the processing carried out ?

The purpose of data processing corresponds to the aim pursued, the need it fills for the data controller.

The personal data you provide us with are collected and processed by Richelieu Gestion in order mainly to comply with requests expressed via all collection tools and services made available to you, in particular on the website, such as information collection forms, contact pages, submitting a job application or requesting information.

The data collected are processed (i) if you have consented to such processing or (ii) if the processing is based on at least one of the following legal grounds :

  • The processing is necessary to perform a contractual or pre-contractual obligation at your request,
  • The processing arises from the legitimate interest of Richelieu Gestion or a third party, without disregarding your rights,
  • The processing arises from a legal obligation to which Richelieu Gestion is subject.

Furthermore, if information not strictly required to fulfil the aforementioned purposes is collected, it will be done with your prior consent. Where applicable, you may withdraw your consent at any time.

Who do we share your personal data with ?

In order to fulfil the aforementioned purposes, the personal data collected by Richelieu Gestion may be communicated to :

  • any entity within the Group to which Richelieu Gestion belongs (in accordance with Article L. 233-3 of the French Commercial Code), insofar as the data is necessary to perform the sub-contracted services or tasks, or to review and manage records, as well as for marketing purposes and/or other statistical studies,
  • third parties, in particular partners, as well as sub-contractors and/or service providers, with which Richelieu Gestion collaborates and whose involvement is necessary or useful for the processing or to fulfil the aforementioned purposes,
  • official bodies and administrative or legal authorities with the proper authorisation, at their request, insofar as necessary to comply with any applicable laws and regulations, potential buyers, or investors in our company (as a whole or a specific part thereof), and their advisors and financiers, if we have a legitimate interest to do so,
  • their advisors and financiers, if we have a legitimate interest to do so,
  • any recipient requesting the necessary data to identify and contact the person in question, especially in the event of a health crisis, and when such data communication is intended to safeguard the vital interests of the person in question or those of another natural person, insofar as the data are strictly necessary to fulfil this purpose.
To which third countries do we send your personal data?

The personal data thus transmitted in accordance with the agreed purposes may, as part of various transactions, be transferred to a member country of the European Economic Area or to a country whose legislation has been recognised as adequate by the European Commission pursuant to the provisions of Article 25 of European Directive 95/46. These data transfers are carried out under the terms and guarantees necessary to ensure your personal data protection.

How do we protect your personal data?

All necessary precautions are taken to ensure the safety and confidentiality of your personal data, in particular to prevent their loss, alteration, destruction or use by unauthorised third parties. Furthermore, we request that these third parties (referred to above) implement the appropriate technical and organisational security measures with respect to these personal data.

What are your rights ?

In compliance with legal and regulatory provisions, you may exercise the following rights without costs and within a reasonable interval :


Right to access and receive your personal data :
You have the right to inquire about your data in our possession. You may also access any data concerning you.

Right to correct your personal data :
You may request that we correct your personal data at any time, should you realise that they are incomplete or incorrect.

Right to erase your personal data :
You may also request that Richelieu Gestion erase your personal data, in accordance with the reasonable technical means at the disposal of Richelieu Gestion. However, Richelieu Gestion may refuse to undertake such an operation if it is still necessary to process your data, in particular to comply with its legal and contractual obligations, or for evidentiary purposes.

Right to limit the processing of your personal data :
In certain specific cases, you may request to limit the processing of your personal data.

Right to refuse the processing of your personal data :
You may refuse the processing of your personal data in certain specific cases. If that is the case, Richelieu Gestion will no longer process your personal data, unless it proves that there are legitimate and compelling grounds for such processing, which prevail over your interests. You also have an absolute right to refuse the processing of your personal data for direct marketing purposes.

Right to withdraw your consent for the processing of your personal data :
You may withdraw your consent to the processing of your personal data by Richelieu Gestion at any time.

Right to the portability of your personal data :
You have the right to demand that the personal data you communicated to us are forwarded directly to another data controller, as far as technically possible for Richelieu Gestion.


The aforementioned rights may be exercised by contacting the Richelieu Gestion Data Protection Officer at the following address: “Richelieu Gestion, Délégué à la protection des données (DPD) – 1-3-5, rue Paul Cézanne – 75008 Paris” or by email at the following address: protectiondesdonnees.rg@richelieugestion.com. Richelieu Gestion undertakes to respond within the deadline established by regulations.

In the event of a dispute, the user may contact the French National Commission for Data Protection and Liberties (CNIL). To bring the matter before the CNIL, simply send a letter to the following address: A l’attention du président de la CNIL, Commission nationale de l’informatique et des libertés – 3, Place de Fontenoy – TSA 20715 – 75334 PARIS CEDEX 07.

What are the personal data retention periods ?

The personal data retention periods practised by Richelieu Gestion are variable and determined by different criteria, including :

  • the purpose for which Richelieu Gestion uses the data: Richelieu Gestion must retain the data during the period necessary to fulfil the purpose of the processing; and
  • in compliance with legal obligations: the applicable laws and regulations may set a minimum period during which Richelieu Gestion must retain the personal data.
Changes to our personal data protection charter

Richelieu Gestion reserves the right to change this Charter in line with changes made to the various regulations and practices in force. The changes made to our Charter will be published on this page of our website directly. In order to ensure you have the most recent version at all teams, please check the Charter online.

Cookies - Personal data collection through automated means

The use of cookies is a standard practice on the Internet. A cookie is a small text file containing information, which is stored on the hard drive of your device (e.g. computer, tablet or mobile phone) when you access a website using your browser. It is sent by the website server to your browser. The cookie file enables the issuer to identify the device on which it is placed throughout the period of said cookie’s validity or storage.

In order to improve the website’s presentation and to facilitate access to secure areas, a cookie will be placed on your computer. This cookie has the sole purpose of storing information regarding user identification and the user's computer browsing habits on this website.

Users acknowledge that they have been notified of this practice and authorise Richelieu Gestion to employ it. They may prevent the storage of cookies by changing their browser settings. However, the deactivation of cookies may restrict access to personalised services for Richelieu Gestion clients.