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P E R S O N A L   D A T A
 

Personal data processing policy

This personal data processing Policy, adopted pursuant to Regulation (EU) 2016/679 of the Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (RGPD), applies to any user of the website. It provides transparent information about the collection and possible use of personal data by Horae Technology, when connecting to and using its website.

General principles

Users can freely visit this website and consult information about the organisation and services offered by Horae Technology without having to provide personal data. However, some information is only available upon request, via a contact form. The communication of personal data in this context is voluntary.

By filling in the online form, users can contact Horae Technology. Consequently, the company will keep the data collected in order to adapt to the request expressed by the user and provide the appropriate response. The personal data collected via the form may also be used to improve and update the website. It may also contribute to the improvement of Horae Technology’s services.

By using the site and providing personal information, you consent to the collection and use of data in accordance with this privacy Policy.

Horae Technology may entrust external service providers with the task of collecting and processing personal data on its behalf. In this situation, the service providers are required to comply with the commitments contained in this privacy Policy.

For further information, you can contact our Data Protection Officer (DPO) by email at:

dpo@horae-technology.com.

Rights of access, rectification, limitation and portability

The users have the right to oppose access, to rectify and to delete their data, as stipulated by the 1978 Data Protection Act and maintained by the EU Regulation 2016/679, known as the « RGPD ». This regulation also strengthens the rights of individuals and gives them new data processing capabilities.

In particular, the user has the following new rights:

  • Right to limit processing (Art. 18 of the RGPD): the user may obtain the limitation of processing when he/she has objected to the processing, when he/she disputes the accuracy of the data or when he/she considers that the processing is unlawful.

  • Right of portability (Art. 20 of the RGPD): the user has the right to receive the personal data that he/she has communicated to Horae Technology and can also ask Horae Technology to transmit this data to another data controller.

  • Right to object (Art. 21 of the RGPD): The user has the right to object on legitimate grounds to the processing of their personal data as well as the right to object to the processing of their data for the purpose of prospecting.

  • Right to be informed about the purposes of the processing (see above) and about the identity of the controller (Art. 13 of the GDPR).

  • Right to withdraw consent at any time, without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.

 

To exercise their rights, the user is invited to contact the investment management company according to the procedures defined on the « Contact » page of this site.

 

In accordance with the legislation protecting personal information, the right to access to personal data is a personal right that can only be exercised by the person concerned for their own information.

The user acknowledges that he/she is authorised to produce the personal information concerned.

Security

Horae Technology has taken the appropriate organisational and technical measures to ensure a level of security appropriate to the risk and to ensure that the servers hosting the personal data processed prevent, as far as possible:

  • unauthorised access to or modification of such data

  • the improper use or disclosure of such data

  • the unlawful destruction or accidental loss of such data

In this respect, Horae Technology's employees who have access to this data are subject to a strict obligation of confidentiality. However, Horae Technology shall not be liable for any misappropriation of such data by a third party despite the security measures adopted, except in the event that Horae Technology has been informed of such a security breach and has not taken any action to try to remedy it.

Complaints about the processing of personal data

The user is informed that he/she has the right to lodge a complaint with the CNIL in accordance with Art. 77 of the RGPD if he/she considers that the processing of their personal data constitutes a breach of the RGPD.

Recipients

Horae Technology may need to send your data to the following categories of recipients

(non-exhaustive list):

  • Authorised members of our staff and any natural or legal person allowed by Horae Technology to process personal data

  • Courts, arbitrators and mediators, if applicable

  • Relevant ministries, supervisory and control authorities, and all public bodies authorised to receive the data

  • Processing agents, transfer agents, statutory auditors of Horae Technology's mutual funds

  • Services responsible for control, such as statutory auditors and internal control services as well as external auditing departments or service providers

  • Settlement systems

These recipients may be located outside France.

Data transfers outside the European Union

The laws of non-EU countries relating to personal data may not be as comprehensive as the laws applicable in the French Republic and in the EU. However, if Horae Technology uses service providers in non-EU countries, it requires them to apply EU-level standards of protection to your personal data. Typically, Horae Technology achieve this by using standard data protection clauses approved and published by the European Commission for this purpose. More generally, Horae Technology will only transfer your personal data to non-EU countries using methods authorised by French data protection law.

Duration of retention of personal data

Your data is not retained by Horae Technology longer than is necessary for the purpose of the service concerned, which may include any time required to respond to any customer request or complaint made after the end of the user’s business relationship with Horae Technology.

Use of cookies

Horae Technology draws your attention to the fact that certain information concerning the Internet user may be recorded by our servers (browser used, IP address, etc.). In addition, the connection to our web server may cause a small amount of data to be sent to your browser and stored on your computer’s hard drive. These are cookies that record information relating to your computer’s navigation on our site (the pages you have consulted, the date and time of the consultation, etc.) that we can read during your subsequent visits.

Your browser contains a function that allows you to refuse cookies (details on the CNIL website). This will not prevent you from connecting to our site but may delay the loading of pages.

Links to other sites

This site contains links to other websites belonging to third parties over which Horae Technology has no control and for which it cannot be held responsible.

Horae Technology cannot be held liable for the processing of personal data, practices and content of sites belonging to third parties and whose access by the users is at their own risk.

Horae Technology invites users to study the processing of personal data, applied to the site belonging to third parties and to verify also thow personal data is processed, when users click or interact with a link leading to a website belonging to third parties.

Modification

Horae Technology reserves the right to update and modify the provisions of its personal data processing policy as required and without notice. Any changes will be posted on the Horae Technology's website.