Cookies Policy

Table of Contents

1. Introduction

2. Definitions

3. Cookies Policy

   • 3.1. Type of Cookies and Trackers

   • 3.2. Type of Personal Data Collected

   • 3.3. Use of Cookies 3.4. Management of Consent 3.5. Setting Up of Cookies on Browsers

4. Policy Changes and Contacts 4.1. Cookies Policy Changes 4.2. Contact Information

1. Introduction

This policy describes:

• How cookies are used on our websites and how they can enhance your user experience.

• How EthiFinance SAS (hereinafter referred to as “EthiFinance” or the “Company”) collects, uses, and discloses your personal information when you interact with our website and other sites we operate.

• How to exercise your rights with respect to your personal information, and how to contact us regarding our privacy practices.

EthiFinance attaches great importance to the respect for privacy and undertakes to process your data in accordance with the provisions of:

• The General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the “GDPR.”

• The French Act No. 78-17 of 6 January 1978 as amended relating to data processing.

• The Data Protection Act (Bundesdatenschutzgesetz).

• The German Telecommunications and Telemedia Data Protection Act (Telekommunikation-Telemedien-Datenschutzgesetz), which define the conditions under which Personal Data may be processed.

Please refer to our Privacy Policy for more information on how we collect, process, and store Personal Data in line with these provisions. [add hyperlink]

EthiFinance SAS with a share capital of €228 020, whose registered office is located at 20 boulevard Eugène Deruelle – 69003 Lyon (France), registered in the Lyon Trade and Companies Register under number 478 661 481.

2. Definitions

• Cookies: Small files placed on your computer, mobile device, or any other device by a website, containing the details of your Browse history on that website, among its many uses.

• Company: (referred to as either “EthiFinance”, “the Company”, “We”, “Us” or “Our” in this policy) refers to EthiFinance SAS. For the purposes of the GDPR (General Data Protection Regulation), the Company is the Data Controller.

• Data Controller: For the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of Personal Data Processing.

• Personal Data: Any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. Any information collected on the Websites that directly or indirectly identifies You is considered to be Personal Data and will be processed in accordance with this policy.

• Websites: Refer to EthiFinance’s websites, accessible from the following hyperlinks:

  • Home

  • https://www.label-fntr.ethifinance.com

  • https://www.report-for-issuers.ethifinance.com

  • https://www.esg-ratings.ethifinance.com

  • https://www.app.esg-ratings.ethifinance.com

  • https://www.publications.spreadresearch.com

• Users: (referred to as either “You”, “Your”, “Data Subject” in this policy) means the individual accessing or using the Websites, or the company, or other legal entity on behalf of which such individual is accessing or using the Websites, as applicable.

• Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. Cookies Policy

3.1. Type of Cookies and Trackers

Cookies are data placed on your computer or cell phone. They are distinguished by their unique identifiers, associated with your computers or phones. They can facilitate an easier user experience on your favorite sites, since they remember your actions and preferences. This way, you do not have to fill in your Browse preferences each time you use the site, such as location, font, or language.

Cookies are stored in your computer’s RAM (random access memory).

On the Website, we may set different types of cookies:

• Necessary Cookies: Cookies necessary for the operation of the Websites. They allow you to use the main features of the Websites and in particular to record information between two visits on the same device and to record session connection identifiers. They do not require your prior consent because these cookies are essential to the proper functioning of the site and are therefore pre-marked as “necessary” in the cookie banner that appears when you access our Websites. If you refuse to accept these cookies on your terminal or browser (via the “deny” function), or if you delete the cookies stored on your terminal, you will be informed that your navigation and experience on the Site may be limited; however, your use of the site will not be automatically blocked.

• Preference Cookies: Preference cookies enable the Websites to remember the information that changes the way the Websites behave or look, like your preferred language or the region that you are in.

Management of Cookies: When you first visit the Websites, a banner informs you of the presence of these cookies and invites you to indicate your choice prior to continuation. The cookies requiring your consent in accordance with the regulations are deposited only if you accept them as set out in paragraph “Management of Consent”. You can at any time inform yourself and configure the cookies to accept or refuse them by going to the Cookie management page at the bottom of each page of the site or by configuring your browser in accordance with paragraph “Setting Up of Cookies on Browsers” below.

3.2. Type of Personal Data Collected

All Personal Data relating to a terminal, at a given moment, that can be collected relate to, in particular:

• The date, time, and duration of connection of a terminal to the Websites;

• The Internet Protocol (IP) address of the page from which the terminal accesses the Websites;

• The type of HTTP User-Agent (technical description of the web browser, operating system, device) of the terminal (e.g., Windows, MacOs, Linux, Unix, etc.);

• The type and version of the browser software used by the terminal (Internet Explorer, Firefox, Safari, Chrome, Opera, etc.);

• The brand and model of the mobile device or tablet;

• The characteristics of the content consulted and downloaded (HRRP Referrer).

3.3. Use of Cookies

The entities depositing cookies on the Websites are EthiFinance and third-parties acting for EthiFinance as processors and partners, i.e. the technical service providers who process your navigation data on behalf of EthiFinance.

Here below the list of all cookies deposited by EthiFinance:

If you would like more information about these third-party cookies and trackers and the way in which you can configure them, we recommend that you visit the websites of these partners and read their cookie policy.

• WordPress download manager: www.wpdownloadmanager.com

• Complianz: www.complianz.io

3.4. Management of Consent

The deposit of Preference Cookies requires your prior consent. This consent is requested through the banner that appears when you first browse the site. You can choose to accept the deposit of cookies for all the purposes listed, refuse them all, or customize your choice on a per cookie/per purpose basis by opting out.

To the extent that this restricts your use of the site, we will notify you of this at the time of your selection. You can withdraw your consent at any time by going to the pop-up tool at the bottom right of each page of the site.

3.5. Setting Up of Cookies on Browsers

In addition to the consent management of the cookies (see paragraph 3.4 above), you have the choice to set your browser to accept or reject all cookies, to delete cookies periodically, or to see when a cookie is issued, how long it remains valid, and what it contains, and to refuse to store it on your hard drive.

You can choose to block or disable cookies at any time by adjusting the internet browser settings on your computer, tablet, or mobile device in accordance with the instructions established by your internet browser provider and listed on the Websites mentioned below:

• On Internet Explorer: Open the “Tools” menu, then select “Internet Options”; click on the “Privacy” tab and then the “Advanced” tab; choose the desired level or follow the link below: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

• On Microsoft Edge: Open the “Settings and more” menu, then select “Settings”; click on “Privacy, search and services” choose the desired level or follow the link below: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

• On Mozilla Firefox: Open the “Tools” menu, then select “Options”; click on the “Privacy” tab and choose the desired options or follow this link: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy/cookies

• On Mac/iPhone/iPad Safari: Choose “Safari > Preferences” then click on “Security”; In the “Accept Cookies” section choose the desired options or follow this link: https://support.apple.com/en-us/HT201265

• On Google Chrome: Open the configuration menu (wrench logo), then select “Options”; click on “Advanced Options” then in the “Privacy” section, click on “Content Settings”, and choose the desired options or follow the following link: https://support.google.com/chrome/answer/95647?hl=en

You can also type “cookies” in the “help” section of your browser to access instructions for setting cookies.

4. Policy Changes and Contacts

4.1. Cookies Policy Changes

EthiFinance reserves the right to modify this cookies policy at any time to comply with any changes in applicable legislations, EthiFinance’s data protection strategy or internal risk exposure. By continuing to use any of our sites, you agree that the terms of the cookies policy as of the effective date will apply to the information collected.

This cookies policy is available in several languages but only the English version is legally binding.

4.2. Contact Information

Questions or comments about this cookies policy or our data collection and processing practices can be emailed to dpo@ethifinance.com.