Whilst a visit to this website does not imply an obligation on the part of the USER to provide information about themselves, in the event they do provide personal information, any such personal data collected via this website will be used solely for the purposes, in the way, and with the limitations and rights, as contained in the prevailing Personal Data Protection legislation. To this effect and in compliance with Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, we hereby proceed to inform you how ETHIFINANCE SAS (henceforth, ETHIFINANCE) may handle the processing of the above-mentioned personal data.
2. Identification of the Data Controller
Entity: ETHIFINANCE SAS
Address: 20 boulevard Eugène Deruelle, 69003 Lyon, France
Email Address: firstname.lastname@example.org
Data Protection Officer: email@example.com
3. Purpose and Legitimacy of the processing of your personal data
Consent and authorization needed for every data purpose will be obtained through the different data collection forms in the website as well as through the contracts signed with the USER.
Such consent may be withdrawn at any point for commercial and promotional purposes which are unnecessary for the procurement and provision of services. Please, notify the company by sending an email to the following address: firstname.lastname@example.org.
In the event that a contract is signed with a legal entity, the consent granted by the authorized signatories will be considered both in their own name and in the name of the legal entity they represent, allowing them to refuse at all times communications through the communication channels of ETHIFINANCE.
Answering the questions and data required to establish their relationship with ETHIFINANCE is completely optional. ETHIFINANCE is not obliged to request the USER’s consent for the collection of their data as part of a contractual or pre-contractual commercial relationship, such data being necessary for the maintenance and fulfillment of such contract. Likewise, if the USER refuses to facilitate the requested personal data, the agreement’s validity would be withdrawn as such data are needed for the above-mentioned purposes.
The procurement of the explicit consent shall not be necessary in the event of a legitimate interest by both parties to answer requests for information, suggestions or enquiries, as well as to contact the USER when the USER requested such contact.
5. Retention period
Your personal information will be kept by ETHIFINANCE for communication purposes for the duration of the business relationship; or as long as your interest in the current policy remains; or for the duration until forfeiture or limitation of rights in relation with the present agreement; or until you withdraw your consent; or for the duration of 5 years after your last communication with ETHIFINANCE as well as for the time derived from any claim we receive from official entities in compliance with applicable regulations; all of the above without prejudice to your right to erase or to object to the processing of your personal data.
6. Legal grounds for processing of personal data
All the data ETHIFINANCE has requested is mandatory. Therefore, failure to provide any of the requested information may prevent us from providing the services offered in the ETHIFINANCE website.
With regard to commercial communications about our products / services, the legal basis is the consent requested in every data processing form, which the USER will provide of his/her own free will, expressly and unequivocally. In regard to commercial communications by electronic means - based on an existing contractual agreement - the legal basis is the legitimate interest of ETHIFINANCE for the development and maintenance of commercial relationships.
7. Communication or assignment of data and international data transfer
ETHIFINANCE will communicate your personal data to those public entities with competence in the matter provided that we are legally obliged to do so.
However, in the event of a need to communicate the USER’s personal data to third parties for new purposes, this communication will only be done after ETHIFINANCE receives the USER’s prior consent in the legally required manner.
Depending on whether the service is hired through our website or another kind of contract, the personal data may be communicated to third parties in those cases where it is needed in order to provide the service, with the sole purpose of managing the hired service.
ETHIFINANCE will not conduct any international transfer of the USER’s personal data. Personal data may only be transferred to companies within the ETHIFINANCE group in the European Union or in third countries where an equivalent level of protection of personal data is ensured according to the European Commission.
8. Applicable rights
Under certain circumstances, the USER may exercise the rights granted in data protection regulations in regards to his/her personal data.
In particular, the USER has a right to:
- Request access to his/her data, given that any person has a right to receive confirmation as to whether his or her personal data has been processed and, if applicable, has the right to access their personal data, the purpose of the processing and the categories of personal data being processed.
- Request a correction to the personal data, that is, request the amendment and/or modification of those data that are inaccurate.
- Request the deletion of the data when such data is no longer needed for the original purpose it was collected for; or because the consent on which the processing is based has been withdrawn; or because the above-mentioned data has been processed in a violation of ETHIFINANCE’S legal obligations; or because it needs to be deleted in compliance with a legal obligation established in EU or EU Member State regulations.
- However, please note that it is possible that ETHIFINANCE might not be able to meet the USER’s request for the deletion of data due to specific legal reasons, which would be communicated to the USER if applicable.
- Refuse the processing of the personal data: under certain circumstances and for reasons related to the USER’s particular situation, the USER may refuse the processing of his/her data. In that case, ETHIFINANCE will interrupt the processing of the data except in the event of legitimate reasons or for the legitimate interest of its customers (third parties) or in defense against potential complaints.
- Request a limitation of the processing of the personal data. The USER may request such limitation if and when:
- He/she is made aware of an inaccuracy in the personal data during a period of time that allows ETHIFINANCE to verify such accuracy.
- The USER considers that the processing is illegal, and does not wish to delete the personal data but instead wish to limit their use.
- ETHIFINANCE does not need the personal data for the purpose such data were collected for, but either one of the parties needs them to prepare their defense against a claim.
- In those cases where the concerned party has opposed the data processing in the period of time ETHIFINANCE verified if the legitimate reasons for the data processing prevail over the individual’s legitimate reasons.
- In these cases, we will only keep the data for the exercise of defense rights against claims.
- Request/receive the personal data (transferability) the USER has provided in a structured format and transfer them to another data controller indicated by the USER, should certain criteria be met.
- Withdraw the consent granted by the USER at any point. The exercise of this right, however, will not affect the legality of any processing that has taken place prior to the above-mentioned withdrawal. Such withdrawal of consent may prevent ETHIFINANCE from being able to provide certain products or services. Should this be the case, the USER will be notified at the time of the withdrawal.
How the USER can exercise his/her rights with ETHIFINANCE:
The USER may send a written communication to ETHIFINANCE SAS, 20 boulevard Eugène Deruelle, 69003 Lyon, France, or write an email aimed at email@example.com.
In the case that a person is not a USER of our website but his/her contact information is accessible in public domain sources and may be used by ETHIFINANCE as part of their commercial information products, that person may also obtain any information needed about the processing of his/her data and his/her rights on the matter by communicating with the Data Protection Officer at the following email address: firstname.lastname@example.org
The USER may also be granted the possibility to withdraw his/her consent at any time or refuse our mailing of commercial communications about our services by contacting the Data Protection Officer at email@example.com
The USER is exempt from paying any fee to exercise any of the rights mentioned in this section and ETHIFINANCE will cover any cost involved in the necessary response to and actions needed to attend the USER’s claim.
Information needed to respond to the exercise of the USER’s rights:
The USER must include his/her forename, surname, copy of his/her ID, an address for notifications, and an exact statement of the right his/she wishes to exercise. Alternatively, the USER may send an email to firstname.lastname@example.org or contact the ETHIFINANCE Data Protection Officer at email@example.com
Deadline for consideration and response:
ETHIFINANCE tries to respond to all legitimate requests within a month after the request has been received. On occasions, it might take ETHIFINANCE over a month when the request is especially complex or if it is part of a series of requests. In those cases, the USER will be notified and updated in due time.
Filing a complaint to the Supervisory Authority:
In accordance with the applicable data protection legislation, the USER has a right to file a complaint, claim or allegation at any given time to the National Committee for Information Technology and Liberties - CNIL (https://www.cnil.fr).
Notwithstanding, ETHIFINANCE would like the opportunity to address any concerns before any claim is put before the CNIL. Therefore, ETHIFINANCE is at your disposal as a first point of contact.
9. Data Sources
In all cases, website USERS’ personal data processed by ETHIFINANCE come from the concerned party him/herself.
In cases where the USER has facilitated third parties’ contact information, the USER shall guarantee that such information concerns individuals over the age of 18 years and that the information is accurate and truthful. The USER undertakes to communicate the terms of this clause to the concerned third parties and to inform them prior to the data communication about all the information contained in it as well as the processing, purposes, transfers, and potential exercise of rights. In the event of failure on the part of the USER to communicate the above-mentioned information to the third party, the USER will indemnify and grant damages to ETHIFINANCE for any damage, prejudice or legal expense or sanction arising directly or indirectly from the failure to communicate the terms this clause and the required information by the USER to the individual third party.
10. Additional information
In all cases, the USER guarantees the truthfulness, accuracy, validity, authenticity and legitimacy of the provided personal data and commits to update them periodically.
Likewise, the USER certifies that he/she is 18 years of age or older.
When providing the requested data, the USER guarantees such data is true, exact and complete. The USER shall inform ETHIFINANCE of any need for modification of the above-mentioned personal data to ensure the proper management and quality of our services, especially contact information such as address, email, phone number, etc.
ETHIFINANCE complies with the legally required security levels for the protection of personal data and resorts to all available technical means and takes all the required precautionary measures made available with current technology so as to avoid the loss, misuse, alteration, unauthorised use, or theft of the personal data.
The USER is guaranteed confidentiality according to our confidentiality policy. ETHIFINANCE’s employees, as well as all parties involved in the processing of the data on behalf of ETHIFINANCE, observe their confidentiality obligation. Without limiting the foregoing, the USER is aware of the possibility that the security of communications over networks may not be invulnerable.
ETHIFINANCE SAS © 2022
This document has been drafted and is owned by ETHIFINANCE SAS (henceforth, ETHFINANCE).
This document is for internal and personal use only and shall not be reproduced, published or redistributed, in part or in its whole, without the written authorization of ETHIFINANCE.
The USER will be solely responsible for any and all the consequences that shall result from any breach of this prohibition, as well as from the safeguarding of the received information.