PERSONAL DATA PROTECTION AND PRIVACY POLICY

CA Indosuez Wealth (Group)

This policy aims to describe the conditions under which CA Indosuez Wealth (Group), a Société Anonyme under French law with a capital of EUR 2,650,000,000, 12 place des Etats Unis, 92545 Montrouge cedex, France, Id. SIREN: 533 015 939 RCS Nanterre, a holding company of the Indosuez Wealth Management group, ensures the privacy and protection of personal data.

 

I. PRIVACY POLICY -  USE OF THE SITE
 

CA Indosuez Wealth (Group) may collect personal information about Users who access and browse the Website, notably those Users who (i) fill in any of the contact forms on the Website by providing their surname, first names, country of residence, e-mail address, telephone number, as well as their profile (customer, journalist, candidate), etc. and any other information contained in any message or attachment sent to CA Indosuez Wealth (Group), (ii) any information that can be used to identify or contact Users who have accessed or browsed the Website or to manage their requests. Personal information may also be collected when a User subscribes to alerts or newsletters via a specific form.

All personal information may be subject to automated processing. It may be saved in the information systems of CA Indosuez Wealth (Group), its providers or consultants mandated by it for management purposes.

Personal information may be communicated to other Entities of the Indosuez Wealth Management Group, the Website host or to Crédit Agricole Group companies for processing. It may also be communicated to external providers that require said information in order to manage and supply services requested or to maintain or host the Website.

The User’s attention is drawn to the fact that the Website Host is a subsidiary of CA Indosuez Wealth (Group) that is located in Switzerland, a country in which, according to decision 2000/518/EC handed down by the European Commission on July 26, 2000, personal information benefits from the same level of protection as it does in France.

Users who do not wish to allow the transfer of personal information to other third parties or overseas should abstain from using the Website services that require personal information.

The collection, automated processing, saving, and transferring mentioned above are carried out in accordance with the provisions of our Personal Data Protection Policy described below.

This Privacy Policy applies exclusively to the Website. For websites of other entities of the Indosuez Wealth Management group, the User should refer to the privacy policy that applies specifically to them depending on their country and its governing law.

 

II. Cookies
 

The User is informed that, when visiting the Website, certain files ("cookies") may automatically and temporarily be stored in the memory or on the hard drive of their computer in order to facilitate website navigation. The User acknowledges that they have been informed of this practice and authorises CA Indosuez Wealth (Group) to do so. For further information on the use of cookies by CA Indosuez Wealth (Group), the User is advised to visit the Website page devoted to cookies.

If the User does not wish for cookies to be downloaded and stored on their hard drive, they should configure their web browsers and/or devices to refuse cookies before visiting the Website. Where this is the case, certain Website functions may be altered or blocked.

 

III. POLICY FOR PROTECTING YOUR PERSONAL DATA
 

This policy aims to describe the conditions under which CA Indosuez Wealth (Group) may collect and process, in the course of its business, the personal data of any data subject as defined below, particularly clients of the entities of the Indosuez Wealth Management Group (credit institutions, insurance brokers, or other companies) and the users of this website.

The main concepts involved in personal data protection as described in Appendix I.

 

Personal data

In the course of its activities, the Indosuez Wealth Management Group may process, whether automatically or not, personal data of natural persons: existing and potential clients of entities of the Indosuez Wealth Management Group, users of this Site (when they fill out online forms provided to them on this Site) and any other natural person (such as an agent or executive), these people all being individually known below as the "Data Subject".

Personal data regarding Data Subjects which the Indosuez Wealth Management Group processes is necessary for it to meet its legal or regulatory obligations, to enable the execution of pre-contractual measures or contracts to which the Data Subject is a party and/or to pursue the legitimate interests of entities of the Indosuez Wealth Management Group, while respecting the rights of the Data Subject. When collected for other purposes, the entities of the Indosuez Wealth Management Group obtain the consent of the Data Subject in advance.

With regard to Data Subjects who are clients of entities of the Indosuez Wealth Management Group, those entities use their personal data to offer them personalised offers and advice, higher-quality service, and everything they need to help make the best decisions.

In the absence of certain information regarding a client that is needed to perform a service, the entities of the Indosuez Wealth Management Group will not be able to provide him or her the benefit of the service for which that data had been required.

 

Purposes of personal data processing

Entities of the Indosuez Wealth Management Group

The personal data of the Data Subjects may be processed, within entities of the Indosuez Wealth Management Group, primarily for the purposes set out in points 1 to 4 below.

 

The Data Subject can, at the website of each of the entities of the Indosuez Wealth Management Group, access detailed information on how his or her personal data is used, with respect to each of those processing purposes, regarding both the legal bases that enable each entity to process his or her data, and how that data may be transferred to non-member states of the European Union.

 

1-      Onboarding and managing the relationship and account

1.1      Prospecting and overseeing the relationship

1.2      Onboarding and managing the banking relationship and accounts

2-      Offering and managing products and services

2.1      Advisory and wealth engineering activities

2.2      Securities investment and life insurance activities

2.3      Credit activities

2.4      Cash transaction and payment method activities

2.5      Online banking and safe deposit box activities

3-      Logistics management (Safety and Security of people and property, mail and archive management)

4-      Adherence to other legal and regulatory obligations

4.1      Adherence to legal and regulatory obligations with respect to outside authorities

4.2      Adherence to legal and regulatory obligations in response to internal auditing obligations

 

CA Indosuez Wealth (Group)

The CA Indosuez Wealth (Group)'s processing of personal data of clients of entities of the Indosuez Wealth Management Group are focused on items regarding the management of lending activities and adherence to the legal and regulatory obligations in response to internal control obligations, the details of which appear in Appendix II.

 

Storing personal data

Personal data is processed and stored for as long as needed for the intended purpose, and no longer than for a period corresponding to the duration of the contractual or business relationship, plus whatever time is needed for the liquidation and consolidation of rights and for the statutes of limitations and avenues of appeal to lapse.

To meet its legal obligations or respond to requests from Regulators and Administrative Authorities, as well as for the purposes of historical, statistical, or scientific research, the entities of the Indosuez Wealth Management Group archive the data under the conditions set out by applicable regulations.

 

Rights of the Data Subject

The Data Subject, at all times, has the following rights, under the conditions set out by applicable regulations:

  • the right to access his or her personal data;
  • the right to have his or her data rectified if inaccurate or incomplete;
  • the right to object, on legitimate grounds, to the processing of his or her data;
  • the right to request the erasure of his or her data when it is no longer needed for the purposes for which it was collected or processed, or when the Data Subject withdraws consent (when the processing of the data in question requires such consent);
  • the right to request restrictions on the processing of his or her data; and
  • the right to request the portability of the data entrusted to our establishment on the basis of the consent of the Data Subject or for the purposes of performing a contract: for the Data Subject, this right consists of receiving his or her data in digital format.
  • the right to communicate instructions on what to do with his or her data in the event of his or her death (in France only).

The Data Subject may also, at any time and without justification, oppose the use of his or her data for the purposes of commercial prospecting, including profiling when it is linked to that purpose, or, when the processing is legally based on consent, withdraw his or her consent, by writing a letter to the Data Protection Officer (DPO) of the entity in question. Postage fees shall be reimbursed upon request.

The Data Subject may exercise his or her rights by contacting the Data Protection Officer of the entities of the Indosuez Wealth Management Group whose contact information appears in their Personal Data Protection Policy in the section entitled "Data Protection Officer" or, in the case of data processed by CA Indosuez Wealth (Group), its Data Protection Officer whose contact information appears below.

In support of its request, the Data Subject may use the rights exercise form, available by clicking here.

The Data Subject is informed that exercising some of the aforementioned rights may prevent the entities of the Indosuez Wealth Management Group from providing him or her with certain products or services in some cases.

 

Data Protection Officer (DPO)

The entities of the Indosuez Wealth Management Group have designated a Data Protection Officer, whom the Data Subject may contact at the address that appears on their respective website, in their Personal Data Protection Policy.

CA Indosuez Wealth (Group) has designated a Data Protection Officer, whom the Data Subject, with respect to his or her personal data processed by the holding company of the Indosuez Wealth Management Group, may contact at the following address: CA Indosuez Wealth (Group) – à l’attention du Délégué à la Protection des Données (DPO) - 12 place des Etats Unis, 92545 Montrouge cedex, France or at the following email address: DataProtection.indosuezgroup@ca-indosuez.com

 

Complaints to Authorities

The data Subject may, in the event of a dispute, file a complaint with the CNIL, whose contact information appears on the website accessible from the following link http://www.cnil.fr, for processing by CA Indosuez Wealth (Group), or the Authority of the country where each entity of the Indosuez Wealth Management Group mentioned in the Personal Data Protection Policy that appears on its website is located.

 

Transferring personal data

Personal data collected by the entities of the Indosuez Wealth Management Group in accordance with the agreed purposes may, during various operations, be transferred to a country that is or is not a member state of the European Union.Whenever it is transferred to a country that is not a member state of the European Union that has not received an adequacy decision from the European Commission, guarantees are put in place to ensure the protection and security of that data.

The Data Subject is informed that within the Indosuez Wealth Management Group, his or her personal data is subjected to computerized processing at AZQORE in Switzerland, a country that provides an adequate level of protection under the terms of decision 2000/518/EC issued by the European Commission on 26 July 2000. It is specified for whatever purpose it may serve that the transfer of that data to Switzerland has no effect on the custody of the client's assets.

Furthermore, the Data Subject is hereby informed that his or her personal data may be sent to the recipients mentioned below in the section entitled "Professional Secrecy".

 

Information

By contacting the Data Protection Officer of each of the entities of the Indosuez Wealth Management Group (contact information available at the website of each of said entities), the Data Subject may access detailed information on his or her rights and how his or her personal data is being used, in particular with respect to the purposes of processing, the legal bases that enable the entities of the Indosuez Wealth Management Group to process data, its storage periods, its recipients, and, if applicable, its transfer to countries outside the European Union as well as the guarantees implemented.

 

Professional Secrecy

The transactions and personal data of Data Subjects are covered by professional secrecy, to which the entities of the Indosuez Wealth Management Group are bound in accordance with their legal and regulatory obligations.

However, in order to meet those obligations, the entities of the Indosuez Wealth Management Group may be required to disclose information regarding those Data Subjects who are clients of entities of the Indosuez Wealth Management Group to legally authorised judicial or administrative authorities. Thus, for example, some information must be sent to tax authorities.

Furthermore, each Data Subject who is a client of an entity of the Indosuez Wealth Management Group is informed that said entity may share data regarding him or her and their updates with the following third parties:

  • the central body of the Crédit Agricole Group, as defined by the French Monetary and Financial Code, so that said body can meet its legal and regulatory obligations for the benefit of the entire Crédit Agricole Group, notably in relation to prudential disclosures to competent authorities or regulatory bodies;
  • any entity of the Indosuez Wealth Management Group for purposes of legal or regulatory consolidation, risk management, particularly counterparty or compliance risk;
  • any mediators, officers of the court, or ministerial officials in the course of their debt recovery duties, as well as people involved in the transfer or reassignment of debts or contracts;
  • the recipients of funds transfers and their payment service providers, for the purposes of fighting money laundering and terrorism financing, and in accordance with international sanctions and embargo regulations;
  • companies of the Crédit Agricole Group responsible for the management and prevention of operational risk (risk assessment, security and prevention of delinquencies and fraud, combating money laundering, etc.) on behalf of all entities of the Group;
  • any entity of the Crédit Agricole Group in the event of pooled resources or business consortia in order to enable such entities to carry out the purpose of their joining together;
  • subcontractors of the entities of the Indosuez Wealth Management Group, and in particular those which participate in account management and in offering financial, banking, and/or insurance products, and solely for the purpose of the subcontracting work;
  • Crédit Agricole SA or any entity of the Group, and their subcontractors, in the context of setting up computer systems for analysing the data of clients of the Crédit Agricole Group's entities with the aim of creating predictive algorithmic models for the purposes of (i) entering into, managing, and performing contracts regarding financial, banking, and/or insurance products, (ii) improving the services provided to clients and the suitability of the financial, banking, and/or insurance products offered to clients, (iii) creating statistics and actuarial studies and simulations regarding the contracts entered into with the entities of the Indosuez Wealth Management Group and (iv) combating fraud;

Finally, the Data Subject expressly authorises the entities of the Indosuez Wealth Management Group to send him or her, by e-mail, any information about him or her, which may be covered by professional secrecy.

The list of personal data recipients may be communicated to the Data Subject upon simple request to the entities of the Indosuez Wealth Management Group, whose contact info is available on each of their websites.

 

IV. Applicable law and jurisdiction
 

This Personal Data Protection and Privacy Policy is subject to the laws and regulations of each of the countries of the entities of the Indosuez Wealth Management Group. With respect to CA Indosuez Wealth (Group), this policy is subject to French laws and regulations. The Paris Court of Appeals (France) holds jurisdiction in the event of any dispute.

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