General Data Protection Regulation
Personal data protection and cookie management
Pulsim places great importance on the protection of your personal data and privacy and takes steps to ensure the confidentiality and security of your personal data.
We ask you to carefully read the information below to find out how we collect and use your personal data and the options available to you relating to use of your personal data.
All operations on your personal data are performed in accordance with laws and regulations in force, including in particular the Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “Regulation”), and any domestic laws applicable to data protection.
For the purpose of this personal data protection and cookie management policy (hereinafter the “Policy”), the data controller is:
PULSIM,a simplified joint-stock company, with capital of EUR 10,000, registered on Paris Trade and Companies Register under number 884 976 283, having its registered office at 11 Avenue Delcassé, 75008 Paris.
The Policy applies to the services offered by Pulsim provided on the Website on which you are browsing and, in particular, to personal data collected:
- When you make a contact request;
- When you enter into a commercial or investment relationship with Pulsim and/or one of our advisors.
The Policy governs use of the Website however you access it. By accessing the Website, using the Website and providing us with information via the Website, you agree to application of the Policy, without prejudice to the choices made available to you herein and pursuant to applicable laws and regulations.
If you disagree with the terms and conditions of the Policy, you are free not to provide your data. However, you are informed that you are required to disclose some of your data - where applicable marked by an asterisk - to access some services and, if you do not provide such data, some functionalities may be altered.
CONTENTS:
1. WHAT PERSONAL DATA IS COLLECTED?
2. HOW IS MY PERSONAL DATA USED?
3. HOW IS MY PERSONAL DATA STORED?
4. HOW IS MY PERSONAL DATA SHARED?
5. HOW DO I KNOW IF MY DATA IS STORED SAFELY?
6. WHAT ARE COOKIES? WHAT DO THEY DO?
7. HOW CAN I MANAGE COOKIES?
8. WHAT ARE MY RIGHTS RELATING TO MY PERSONAL DATA?
1. WHAT PERSONAL DATA IS COLLECTED?
Data that cannot be used to identify you directly:
You can visit our Website without providing us with any information that can be used to identify you directly.
Like most online services, every time you visit our Website, we automatically collect some data and information concerning you and/or your computer or electronic device without it being possible to identify you directly from such data and information.
This information mainly includes:
- The type of Internet browser that you are using;
- The type of operating system and infrastructure that you are using to access the Website;
- The domain name of your Internet service provider;
- The Internet page from which you came;
- Your country of residence and your language;
- The pages and options that you visit and access on our Website.
When you access, visit and/or use our Website, we can consequently track your visit and collect data relating to your use and your activity on the Website as described in the section on “Cookies”.
2. HOW IS MY PERSONAL DATA USED?
Personal Data is provided to us on the Website based on a legal basis: your consent (request for information or documentation).
We may use Personal Data that you provide via the Website to:
- Reply to your questions;
- Comply with Know Your Customer obligations in the scope of offering investment products and, in particular, requirements relating to money laundering (citizenship, name, address, date of birth, etc.) in accordance with Articles L.561-5 and L.561-23 of the French Monetary and Financial Code;
- Identify and manage conflicts of interest in accordance with Article L.533-10 of the French Monetary and Financial Code and Article 318-12 et seq. of the AMF (French Stock Market Authority) General Regulation;
- More generally, compliance with Pulsim’s legal, regulatory, accounting and tax obligations;
- Provide you with information on new Products and Services and similar products and services to those you already enjoy and may possibly be of interest to you;
- Process requests and complaints relating to the Website made by you and/or third parties concerning you.
3. HOW IS MY PERSONAL DATA STORED?
Personal Data used when visiting the Website:
We store Personal Data for a limited period that is necessary for the purpose for which it is processed and in any event for the period required for compliance with a legal or regulatory obligation.
Personal Data used in the scope of a commercial or investment relationship:
We store Personal Data for a limited period that is necessary for the purpose for which it is processed, i.e., throughout the term of our contractual relationship and in any event for the period required for compliance with a legal or regulatory obligation.
4. HOW IS MY PERSONAL DATA SHARED?
Transfers to countries outside the European Union/EEA:
When processing your Personal Data involves a transfer outside the European Union/EEA, the transfer may take place to countries listed by the European Commission as providing an adequate level of data protection and/or governed by appropriate guarantees and based on standard contractual clauses, in accordance with the models published by the European Commission and/or that have obtained recognised certification.
When Personal Data sharing involves a transfer to the United States, the transfer may take place to recipients that have been granted Privacy Shield certification.
For more information on Personal Data transfers to countries outside the European Union/EEA, please go to the section "WHAT TO DO IF I HAVE OTHER QUESTIONS ON THE CONFIDENTIALITY PROTECTION AND COOKIE POLICY?” below.
Service Providers:
In the scope of our business activities, we may be required to transfer your Personal Data to service providers that are not affiliated to Pulsim. These service providers use Personal Data solely for the purpose of enabling us to provide the Products and Services or operate Website. For example, these service providers may be IT service providers, logistics and marketing partners, our web host or service providers which help us manage data, distribute email and analyse information. We only disclose Personal Data to our service providers on a need-to-know basis to provide their services and work with them in order to respect and protect your Personal Data.
We may also be required to transfer your Personal Data to companies for which we perform services but solely in order to fulfil our contractual obligations towards them and in accordance with applicable law.
We do not disclose any Personal Data to companies for their own marketing or commercial purposes. However, we may disclose your Personal Data to our commercial partners solely for the purpose of supplying the Products or Services or similar products or services that may possibly be of interest to you.
Legal Obligations:
We may be required to disclose Personal Data at the request of an administrative authority (tax authority, CNIL (French Data Protection Authority) and/or judicial authority (response to a judgment, order, injunction issued by a court), on request or where required by law, in order to protect our rights, property and/or security and/or that of third parties.
We may share Personal Data with companies helping to combat fraud and carry out investigations in this respect.
We may also disclose your Personal Data in the scope of the fight against money laundering and terrorist financing, by implementing monitoring systems for contracts and/or transactions for the purpose of drawing up suspicious transaction reports or introducing asset freezing measures.
Unless otherwise stipulated in this Confidentiality Protection and Cookie Policy or subject to your prior consent, we do not sell, market or lease Personal Data to other companies in the normal course of our business activities.
5. HOW DO I KNOW IF MY DATA IS STORED SECURELY?
We have implemented a range of security measures aimed at preventing loss, misappropriation and misuse of your Personal Data that you have provided to us. To ensure the security of data that you provide to us online during transmission, we use authentication and flow analysis tools, and carry out security controls on hosting environments.
6. WHAT ARE COOKIES? WHAT DO THEY DO?
A cookie is a small text file placed on the device (computer, mobile phone, tablet, etc.) that you use to access the Internet (when you visit a website via your browser). We store a unique identifier in the cookie and use the cookie to link your computer to the information we store in our database.
It contains data that can be used to identify you:
- The name of the server that placed it;
- An identifier in the form of a unique number;
- In some cases, an expiry date.
Cookies may be used on your computer or mobile device for different periods of time. Some cookies may be"session cookies",meaning they only exist when your browser is open and are automatically deleted when you close your browser or exit the application. Other cookies are "permanent cookies",meaning they stay after your browser or application is closed, and can be used by websites and applications to recognise your computer when you return to your browser or application.
Some of the cookies we use are permanent cookies. When your consent to permanent cookies is required, your cookie consent is valid for 13 months.
At the end of this period, we will ask for your consent again.
We use cookies to:
- Enhance your browsing experience by customising page content based on your user journey and what interests you when you are browsing;
- Facilitate information sharing (in particular on social networks);
- Collect statistical data.
Cookies placed by the owner of a Website (by us) are called "internal cookies".
Cookies placed by parties other than the owner of a Website are called "third-party cookies". Third-party cookies enable third-party functions or functionalities to be offered on or via a website (for example, advertising, interactive content and analytics). Third-party cookie partners that set these third-party cookies can recognise your computer when you visit the Website in question and when you visit other Websites.
Cookies are not the only way of recognising or tracking website visitors. We may use other similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear GIFs”). These are tiny graphics files that contain a unique identifier that enables us to recognise when someone has visited the Website. In many cases, these technologies rely on cookies to function properly so they will not work correctly if you reject cookies.
7. HOW CAN I MANAGE COOKIES?
When you first visit our Website, a cookie banner will appear at the bottom of the page. By continuing to browse the Website or by clicking on “I agree”, you agree that Pulsim may place cookies on your computer or device (targeting/advertising cookies, audience measurement cookies, social media cookies that are mainly created via share buttons when they collect personal data).
The cookie banner will be displayed up until you start browsing, i.e., up until you visit another page or click on another item on the Website. You can change your browser settings at any time to accept or reject cookies, or change your cookie settings. Several options are available to you:
- Accept all cookies,
- Be notified when a cookie is saved,
- Or systematically reject all cookies.
You can choose to accept or reject all or some cookies, with the exception of browser cookies that are necessary for the Website to function.
Rejecting other cookies (audience measurement, customisation, advertising cookies) will not prevent you from accessing the Website although the services and sections may not work properly and you may not enjoy an optimal user experience.
Types of cookies:
- Strictly necessary cookies :browser cookies that help to improve the performance of the Website. These cookies do not require prior notification or consent of the User to be placed on the User’s terminal.
- Audience measurement cookies :audience measurement cookies help us to compile statistics and collect information on the number of visitors to the Website and the pages that they visited (sections and content viewed, user journey) enabling us to make the Website more interesting and user-friendly. These cookies do not require prior notification or consent of the User to be placed on the User’s terminal.
You can reject cookies by changing your browser settings: every Internet browser has different settings to manage cookies.
In general, they are described in every browser’s Help section. If you use a different browser type or version than listed below, please go to the “Help” section on your browser: Firefox, Chrome, Internet Explorer, Safari and Opera.
However, if you decide to reject session or functionality cookies, you may not be able to access many options offered by the Website. In this respect, Pulsim shall not be held liable if the Website does not work properly as a result of the settings you have chosen.
Lastly, if you have disabled one or more cookies, we can continue to use the data collected by these cookies before you disabled them. However, we will no longer collect data via the cookie that you have rejected.
8. WHAT ARE MY RIGHTS RELATING TO MY PERSONAL DATA?
In accordance with Regulation (EU) 2016/679 on the protection of personal data, you have a right to request from the Data Controller access to and rectification or deletion of your personal data (right to be forgotten) or restriction of processing concerning your personal data as well as the right to data portability.
You have the right to object, on grounds relating to your particular situation, to processing of your personal data.
For data that is not marked as mandatory that you have agreed to disclose and consent to processing, you have right to withdraw your consent at any time: the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You have the same right under the same conditions over data that is not marked as mandatory when such data is collected and you have given consent to the processing for other purposes than performance of the contract to which you are a party or in order to take steps at your request prior to entering into a contract.
Such data shall continue to be processed solely for performance of the contract or in the other cases stipulated or authorised by law.
You may also have additional rights laid down by the domestic law applicable to you, such as defining your instructions on storage, deletion and disclosure of your personal data after your death.
You can exercise your rights by sending a letter to:
Pulsim – DPO – 11 Avenue Delcassé – 75008 Paris or by email at the following address: xalvarez@pulsim.fr