Privacy policy for personal data

Effective May 25, 2018

RAIZERS has updated its privacy policy relating to Personal Data (hereinafter, the " Privacy Policy ") in order to inform the public of the means implemented to protect the privacy of persons who visit the RAIZERS Platform (hereinafter, the " Internet Users "), or register (hereinafter, the " Users ") with a view to using the services offered on the Platform, or any other natural person who may provide RAIZERS with information or Personal Data.

1 - Person in charge of the processing of Personal Data

The data controller is the company that defines for what purpose and how your Personal Data is used:

RAIZERS SA, domiciled at 5, rue des Alpes, 1201 Geneva, Switzerland, hereinafter referred to as " RAIZERS ".

2 - Nature of the data collected

The data collected on the RAIZERS Platform are those that allow RAIZERS to identify Users directly or indirectly in order to provide the various services offered by the RAIZERS Platform.

This may include personal data such as last name, first name, email address, postal address, telephone number, date of birth, gender or connection data such as IP address and navigation data such as cookies. Data must also be provided by Users for the purpose of paying a subscription or refund (IBAN, BIC, identity of the bank account holder, title account holder).

The Personal Data provided by the Users when registering on the RAIZERS Platform are stored in the SalesForce CRM, as well as the Personal Data provided by the Users when subscribing to an operation presented on the RAIZERS Platform.

3 - Purpose of the processing

The Personal Data will be used for the following purposes

• Execution of the contract between RAIZERS and the User (see the General Conditions of Use):
  • To register and identify an Internet user or the User and/or to verify the conformity of their use of the RAIZERS Platform;
  • To protect the RAIZERS Platform and/or the User / an Internet user;
  • Ensure proper processing of the Subscription;
  • Development of statistics and tests.
• Legitimate objective: the Personal Data collected may be necessary to pursue a legitimate objective such as all forms of communication with Internet users within the framework of the services offered on the RAIZERS Platform, it being specified that if an Internet user no longer wishes to receive communications, he or she may inform RAIZERS, which will unsubscribe him or her from all communications.
• Legal obligation in the context of the activity of a Participatory Investment Advisor :
  • Know Your Customer Process;
  • Abuse and Fraud Prevention;
  • Respond to the request of an administrative or judicial authority;
  • Comply with its obligations regarding the prevention of money laundering and terrorist financing;

The User expressly consents to the transfer of his or her Personal Data between the different companies of the RAIZERS group.

In addition, for the purposes of operating the RAIZERS Platform, Personal Data is automatically collected by RAIZERS through cookies and other tracers. This is particularly the case for the IP address, the date and time of access to the RAIZERS Platform, the URL visited, the site of origin, the type of browser and the operating system. Thus, RAIZERS reserves the right to use the IP address of the User or of another Internet user in cooperation with his Internet service provider.

4 - Time of collection

The data collected by RAIZERS is freely communicated by the User.

Personal data is collected when using the RAIZERS Platform, in particular when the User :

• Create an account on the RAIZERS Platform;
• Navigate the pages of the RAIZERS Platform;
• Enters into a contract and/or fills out a subscription form;
• Send a request to RAIZERS via the contact form.

5 - Consent

The Privacy Policy is systematically brought to the attention of Users when they register on the RAIZERS Platform. Indeed, the creation of an account implies the express, full and complete acceptance by the User of this Privacy Policy.

IMPORTANT : NOTE TO THE INTERNET USERS

BROWSING THE RAIZERS PLATFORM AFTER THE PUBLICATION OF THIS PRIVACY POLICY CONSTITUTES ACCEPTANCE OF IT WITHOUT RESERVATION.

If the User wishes to withdraw his consent to the processing of his data, he may send a request to RAIZERS in the manner described in Article 8 below.

6 - Recipients of personal data

The recipient of the personal data collected on the RAIZERS Platform is primarily RAIZERS.

Other recipients may have access to personal data, such as service providers or subcontractors of RAIZERS. The list of recipients can be consulted at any time upon request by Users.

The Personal Data transmitted may, in the course of various operations, be transferred to a country within or outside the European Union.

In the event of a change of control of RAIZERS, an acquisition, a bankruptcy proceeding or a sale of RAIZERS' assets, the data collected by RAIZERS may be transferred to third parties.

7 - Shelf life

To ensure the proper processing of financial transactions, your personal data must be kept and updated regularly throughout the time you are a party to an investment.

In order to meet legal and/or regulatory obligations and/or to respond to requests from authorities authorized to make such requests, your personal data will be retained for the following periods in accordance with your situation:

• For a period of 10 years beyond the date of the transaction for all equity investments;
• For a period of 5 years beyond the repayment date for any loan investment; and
• For a period of 5 years in all other cases after the contractual relationship has been terminated

8 - Right of access and rectification

The User must update the information concerning him/her on his/her Individualized Space. To delete his Individualized Space, the User may send an e-mail with his user name and password to RAIZERS. The User may at any time exercise his rights concerning the collection and processing of his Personal Data:

• Right of access to Personal Data: to access the information that has been provided to Raizers ;
• Right to rectification of Personal Data: to request the correction of any errors, outdated information or omissions in the information that has been provided to Raizers;
• Right to withdraw consent: request that certain information provided by Raizers not be used for future processing or transfers;
• Right to the portability of Personal Data: to request that Raizers send to a third party service the information that has been provided to Raizers within the limits of the legal reasons that justified the collection and processing of this data;
• Right to the deletion of Personal Data: to request the deletion of information that has been provided to Raizers within the limits of the legal reasons that justified the collection of this data.

However, the User acknowledges that the processing carried out before the revocation of the said consent remains perfectly valid.

The User also has the right to object, without giving any reason, to RAIZERS profiling his or her data in the context of sending content or communications for commercial prospecting purposes. However, in accordance with Article 12.6 of the GDPR, for the exercise of these rights, RAIZERS, as the data controller, reserves the right to request proof of identity from the applicant. The Personal Data allowing the User's identity to be proven will subsequently be deleted once the request has been processed.

It is specified that in case of deletion of the User's account, the Personal Data recorded in the Salesforce CRM are automatically anonymized.

The User may exercise these rights by sending an email to [email protected] or to one of the following postal addresses

For Internet users residing in France:

RAIZERS SAS

130 rue de Courcelles - 75017 Paris

For Internet users residing in any other country:

RAIZERS SA

Rue des Alpes 5

1201 Geneva, Switzerland

9 - Response time

RAIZERS undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time, which may not exceed one (1) month from receipt of your request.

10 - Violation of Personal Data

In the event of a breach of Personal Data (Article 34 of the RGPD), Raizers undertakes to inform, in addition to the CNIL, the Users concerned (i.e. the owners of the Personal Data) as soon as possible, if these present a high risk for the rights and freedoms.