This policy is aimed at describing the conditions under which CFM Indoseuz Wealth Management, a Monegasque public limited company with share capital of €34,953,000, whose registered office is located in Monaco at 11 bd Albert 1er, registered with the R.C.I under number 56 S 00341 (hereafter known as the "Bank") may collect and process, in the course of its activities, the personal data or information of any data subject, particularly its clients and users of this Site.
In light of the entry into force on 25 May 2018 of Regulation (EU) 2016/679 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, the Bank has chosen to extend this strengthened data protection standard.
In this context, we would like to inform you of the methods used by the Bank to process your personal data.
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In the course of its activities and the Client’s use of its services, including its online banking website and/or mobile apps, the Bank may process, whether automatically or not, personal data of natural persons: existing and potential clients, 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 Bank collects or processes, acting as processing manager, is necessary for it to meet its professional, 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 Bank's legitimate interests, while respecting the rights of the Data Subject. When such data is collected for other purposes, the Bank must first obtain the consent of the Data Subject.
With regard to Data Subjects who are clients, the Bank uses 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 or an operation, the Bank will not be able to provide him or her the benefit of the service or carry out the operation for which that data had been required.
Purposes of personal data processing
The personal data of Data Subjects may be processed, primarily for the purposes mentioned above.
The Data Subject can, by clicking on the link below, access detailed information on how his or her personal data is used, both with respect to the purposes of the processing and the legal bases that enable the Bank to process his or her data, and how that data may be transferred to non-member states of the European Union and/or states not ensuring an adequate level of protection.
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
Storing personal data
This 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 the 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 Bank may 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 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, by the Bank or by third parties, or when the processing is legally based on consent, withdraw his or her consent, by writing a letter to CFM Indosuez Wealth Management, Data Protection Officer, 11 avenue Albert 1er, 98000 Monaco. Postage fees shall be reimbursed upon request by the Data Subject.
The Data Subject may exercise his or her rights by contacting the Data Protection Officer, whose contact information appears below in the section entitled "Data Protection Officers".
In support of his or her request, the Data Subject may use the rights exercise form by clicking on the link below:
The Data Subject is informed that exercising some of the aforementioned rights may prevent the Bank from providing him or her with certain products or services in some cases.
Data Protection Officer (DPO)
The Bank has designated a Data Protection Officer, whom the Data Subject may contact at the following address: CFM Indosuez Wealth Management, Data Protection Officer, 11 boulevard Albert 1er, 98000 Monaco and/or at the following email address: email@example.com
Complaints to Authorities
The data Subject may, in the event of a dispute, file a complaint with the President of the CCIN (Commission de contrôle des informations nominatives) or the CNIL (Commission nationale de l’informatique et des libertés) whose contact information is accessible from the following links: http://ccin.mc and http://www.cnil.fr.
Transferring personal data
Personal data collected by the Bank in accordance with the agreed purposes may, during various operations, be transferred to a third-party country. Whenever it is transferred to a third-party country that is not a member state of the European Union and/or has not received adequate protection and is not on the list established by the CCIN, guarantees are put in place to ensure the protection and security of that data.
The Data Subject is hereby informed that his or her personal data is being processed by AZQORE SA, a subsidiary of CA Indosuez Wealth (Group) in Switzerland, a country that has received an adequacy decision from the European Commission and ensures an adequate level of protection. It is specified for whatever purpose it may serve that the transfer of that data to Switzerland has no effect on the custody of clients' assets or the conducting of transactions concerning them, which are carried out in Monaco by the Bank's own teams.
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 Banking Secrecy".
Professional Banking Secrecy
The transactions and personal data of Data Subjects are covered by professional secrecy, to which the Bank is bound in accordance with its legal and regulatory obligations.
However, in order to meet its legal, regulatory and professional obligations, the Bank may be required to disclose information regarding those Data Subjects who are clients to legally authorised judicial or administrative authorities, as well as to service providers or any duly authorised person, provided that the execution of the operations requested or the provision of services justifies such disclosure.
Consequently, each Data Subject who is a client expressly authorises the Bank to share data about him or her and update that data with the following third parties:
Finally, the Data Subject expressly authorises the Bank 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 sent to the Data Subject upon simple request by him or her to the Bank, via the Data Protection Officer.