BDL Capital Management will afford its professional contacts' personal data the highest level of protection.
In the course of its collective investment fund management, BDL Capital Management gathers personal data from visitors to its www.bdlcm.com website and from contacts met professionally.
The aim of this section is to explain to contacts and website visitors how BDL Capital Management uses the personal data that they may enter on the website or share during professional encounters.
As Data Processor, BDL Capital Management undertakes to comply with EU General Data Protection Regulation 2016/679 of 27 April 2016 (GDPR).
WHO COLLECTS PERSONAL DATA?
The company that collects and processes personal data is:
BDL Capital Management, a Société́ par Actions Simplifiée with share capital of €200,000, entered in the Paris Trade and Companies Register under number 481 094 480, having its registered office at 24 rue du Rocher, 75008 Paris.
WHY DOES BDL CAPITAL MANAGEMENT COLLECT PERSONAL DATA?
BDL Capital Management is authorised to collect and then use visitors' and contacts' personal data only if it has a valid legal basis for doing so. BDL Capital Management must ensure that it has one or more of the following legal justifications:
- a request for information (e.g. to answer or send an information request or to open and manage an account in the user area);
- meeting a legal obligation (e.g. storing invoices);
- where it is in the legitimate interest of BDL Capital Management;
- if the visitor or contact has consented to the data being collected
BDL Capital Management's legitimate interest must not go against the rights and freedoms of visitors and contacts. Examples of legitimate interests mentioned in the GDPR include prevention of fraud, direct marketing, and data sharing within a group of companies.
BDL Capital Management collects and processes the personal data of its visitors and contacts to perform certain treatments listed below.
What is done with personal data?
-Managing investors' account area
- Sending reports
- Managing customer relations (telephone/email/meetings)
- Statistics, analysis, selection and segmentation of clients to get to know our customers better
- Measuring site traffic
- Staff management
- Supplier management
With what justification?
Publishing or giving access to reports (monthly reports, management newsletters and newsflashes on BDL Capital Management funds)
- BDL Capital Management's legitimate interest in monitoring its clients to improve customer service
- BDL Capital Management's legitimate interest
- Client's consent
- HR policy and legal requirements
- Pursuing the corporate object
WHAT RIGHTS ARE HELD OVER DATA?
Which rights can be exercised ?
In accordance with articles 15 to 22 of regulation 2016/679 of 27 April 2016, all natural persons whose data has been collected may exercise the following rights:
- a right to access data
- a right to correct data
- a right to object to the processing of their data, and require the deletion of their data
- a right to object to profiling
- a right to limitation of treatment and a right to the portability of its data,
Clients will be informed promptly if BDL Capital Management identifies a personal data breach that could present a high risk to their rights and freedoms.Clients may also withdraw their consent at any time.
How to exercise them?
These rights may be exercised by contacting BDL Capital Management, which collects the personal data, as follows:
- By post, writing to: BDL Capital Management, FAO the DPO, 24 rue du Rocher, 75008 PARIS
- By email to: firstname.lastname@example.orgThe request must include first name, surname, postal address and email address, as well as proof of identity.
BDL Capital Management will answer within one month of the right being exercised. In certain cases, the complexity of the request or the number of requests received may see this deadline extended by two months. There may be exceptions to these rights in special cases provided for by law. If no answer is received, or the response is deemed unsatisfactory, the person concerned may contact the French data protection authority (CNIL).
When BDL Capital Management detects a personal data breach that could create a high risk for the rights and freedoms of the Customer, the latter will be informed of this violation as soon as possible. The Customer is also entitled to withdraw his consent at any time
WHAT HAPPENS TO DATA AFTER DEATH?
Natural persons may give instructions to be followed after their death, concerning the storage, deletion and disclosure of their personal data in accordance with article 40-1 of act 78-17 of 6 January 1978. Such instructions may be general or specific.
Natural persons may send these instructions in advance to email@example.com.
2. TO WHOM IS DATA PASSED ON?
In exceptional circumstances, your data may be passed on to a BDL Capital Management partner acting as a subcontractor, following BDL Capital Management's instructions. Data may be:- shared with payment institutions (banks)- used to develop and carry out maintenance on BDL Capital Management's website, internal applications and IT system.- used on CRM platforms and to send emails- shared with staff medical establishments
3. IS DATA SENT OUTSIDE THE EU?
For some processes, personal data may be sent to companies located in countries outside the European Union. BDL Capital Management ensures the security of data before it is transferred outside the European Union, in accordance with applicable regulations.
Data may be transferred outside the European Union particularly in the following cases: CRM and emailing.
4. HOW LONG IS DATA KEPT?
BDL Capital Management has established specific rules for the length of time that clients' personal data may be kept. By principle, data is kept for however long is needed to achieve all the aims of its collection.
Unless legally prevented from doing so, BDL Capital Management respects the storage periods recommended by the CNIL.
5. IS DATA COLLECTED ON CHILDREN AGED UNDER 16?
Clients must be at least 16 years old to open an account on the BDL Capital Management website. As BDL Capital Management does not collect data on children under 16, any internet user below the age of 16 must not try to open an account. Financial services are only provided to those classed as capable adults. Data on minors may be collected from BDL Capital Management employees for HR purposes.
6. WHAT ARE THE RULES ON MARKETING?
BDL Capital Management follows the rules set out in directive 2002/58/EC of 12 July 2002, which requires clients' express consent to be obtained before any marketing material is sent electronically. When you open an account on the website, you are expressly asked for your consent to receive reports from BDL Capital Management by email. You are also asked for your consent at business meetings.
BDL Capital Management will not solicit you in any way if you have not given your consent. The only exception to this is when registered site visitors have not given prior consent but may still be informed about funds if they created their profile on the BDL Capital Management website before 25 May 2018, and the purpose of the communications is to report on the funds. Either way, registered visitors may object to receiving this information by taking the following action:
- Not ticking the reports box when creating the account;
- Clicking on the unsubscribe link in any email
- Contacting customer service or the data protection officer.