Confidentiality Policy

As part of its business operations, DORVAL ASSET MANAGEMENT may be required to process your personal data. DORVAL ASSET MANAGEMENT is committed to protecting personal data and safeguarding the privacy of its website visitors.

With this in mind, DORVAL ASSET MANAGEMENT pledges to process personal data in accordance with applicable legislation and regulation i.e. Regulation (EU) 2016/679 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, and the French data protection act (Loi Informatique et Libertés) of 6 January 1978, amended on 20 June 2018.

This Confidentiality Policy describes how DORVAL ASSET MANAGEMENT collects and processes your personal data when you visit its website www.dorval-am.com.

If you require further information to answer your questions, please contact the Data Protection Officer (DPO) at DORVAL ASSET MANAGEMENT at the following address:

dpo@dorval-am.com

1. WHAT ARE PERSONAL DATA?

Personal data mean any information relating to an identified or identifiable natural person (known as the data subject).

The data subjects for the DORVAL-AM.COM website are visitors to the site.

Personal data covered by this Confidentiality Policy mean all data relating to these subjects, where they are identified or identifiable, for example via their computer’s IP address.

Personal data processing is governed by specific legislative and regulatory provisions.

2. WHAT PERSONAL DATA ARE COLLECTED, FOR WHAT PURPOSES AND ON WHAT LEGAL GROUNDS?

DORVAL ASSET MANAGEMENT collects your personal data in the following circumstances:

2.1 WHEN YOU BROWSE THE DORVAL-AM.COM WEBSITE

When you browse the DORVAL-AM.COM website, DORVAL ASSET MANAGEMENT collects the following data via its servers:

  • Your terminal’s IP and/or MAC address;
  • Your terminal type;
  • Your web browsing software version.

These data are collected and processed for the purposes of ensuring correct display of the DORVAL-AM.COM website on your terminal. This processing is based on the necessity of its implementation for the performance of a contract to which the visitor is party i.e. the terms of use for the DORVAL-AM.COM website.

2.2 WHEN YOU USE FORMS ON THE DORVAL-AM.COM WEBSITE

When you use a form, DORVAL ASSET MANAGEMENT collects the following data via the form:

 

Contact form

  • Your title, first name and surname: Mandatory
  • Your email address: Mandatory
  • Phone number: Optional (to contact you to provide answers to your questions where necessary)
  • Your company: Optional
  • Your status: Mandatory
  • Object and description of your request: Mandatory

These data are collected and processed for the purposes of ensuring that DORVAL ASSET MANAGEMENT can receive and process your request and provide you with an answer where appropriate. This information may be used for the purposes of direct marketing, as well as managing your requests regarding your rights to access, query, rectify, object on legitimate grounds and to object to direct marketing. This processing is based on your consent.

 

Newsletter:

  • Your email address; Mandatory

These data are collected and processed for the purposes of ensuring that DORVAL ASSET MANAGEMENT can manage your subscription to our newsletter and send you the newsletter periodically where appropriate. This information may be used for the purposes of direct marketing, as well as managing your requests regarding your rights to access, query, rectify, object on legitimate grounds and to object to direct marketing. This processing is based on your consent.

 

Failure to provide this mandatory information will mean that your request cannot be processed.

If you enter data in the message field that may be considered as ‘sensitive data’ under applicable regulation, you explicitly agree when you click on the button to submit the form to DORVAL ASSET MANAGEMENT receiving and processing these data to reply to your request.

It is understood that DORVAL ASSET MANAGEMENT does not in any circumstances require or encourage website visitors to provide so-called ‘sensitive data’ in the contact form.

3. WHO IS IN CHARGE OF PERSONAL DATA PROCESSING AND HOW CAN THEY BE CONTACTED?

DORVAL ASSET MANAGEMENT is in charge of this data processing, a company listed on the Paris Trade and Companies Register under number 391 392 768, and with its head office located at 1 RUE DE GRAMONT, 75002, PARIS, FRANCE. DORVAL ASSET MANAGEMENT is accredited as an asset management company by the A.M.F. (Autorité des Marchés Financiers, French financial markets authority) under number GP 93-08.

For any questions on this Confidentiality Policy, personal data processing and any general matters related to personal data protection and privacy at DORVAL ASSET MANAGEMENT, you can contact the Data Protection Officer at DORVAL ASSET MANAGEMENT at dpo@dorval-am.com

4. WHO ARE DATA SHARED WITH?

Personal data collected and processed as set out in article 2 above are used by the relevant departments at DORVAL ASSET MANAGEMENT and its processors, who are committed to complying with regulation on processing the personal data to which they have access.

All members of DORVAL ASSET MANAGEMENT’s staff are subject to confidentiality requirements across all businesses carried out.

5. HOW LONG ARE DATA KEPT?

Personal data collected and listed in article 2 above are kept by DORVAL ASSET MANAGEMENT for such times as you are an ‘active’ client and for a period of 3 years from your latest activity. Data are then filed with limited access for an additional period of 2 years authorized by law (disputes, guarantees) and are then erased.

Data on your web browsing will be held for a maximum of 13 months.

6. DOES THE DORVAL-AM.COM WEBSITE USE COOKIES AND OTHER SIMILAR TECHNOLOGIES?

7. YOUR RIGHTS

In accordance with applicable personal data legislation and regulation, you have the following rights on your personal data processing.

You may exercise these rights by contacting the Data Protection Officer at DORVAL ASSET MANAGEMENT at the following address: DPO Dorval Asset Management, 1 rue de Gramont, 75002, Paris, France or by email at dpo@dorval-am.com

7.1 RIGHT OF ACCESS

You may access your personal data processed by DORVAL ASSET MANAGEMENT. In the event that it receives a request, DORVAL ASSET MANAGEMENT will provide you with a copy of your personal data, as well as information on how DORVAL ASSET MANAGEMENT processes your personal data i.e. purposes of processing, categories of recipients, length of time personal data is stored, etc.

7.2 RIGHT TO RECTIFICATION

You may request the rectification of your personal data if they are inaccurate, incomplete or obsolete.

7.3 RIGHT TO ERASURE

You may request the erasure of your personal data in the following circumstances:

  • If the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • If you withdraw consent to personal data processing, on condition that your prior consent was the legal grounds for their collection and processing and where there is no other legal ground for the processing;
  • If you oppose data processing and DORVAL ASSET MANAGEMENT has no overriding legitimate grounds for the processing;
  • If the personal data have been unlawfully processed;
  • If your personal data have to be erased for DORVAL ASSET MANAGEMENT to comply with a legal obligation to which it is subject;
  • If you were a minor at the time that your personal data were collected. In this case and on condition that you are a minor at the time of the request, holders of parental authority may also request the erasure of your personal data by DORVAL ASSET MANAGEMENT.

7.4 RIGHT TO OBJECT

On legitimate grounds relating to your particular situation, you may object to the processing of your personal data where your personal data are processed on the grounds of the necessity to process them for the performance of a task carried out for reasons of public interest or in the legitimate interests of DORVAL ASSET MANAGEMENT or a third party.

You may also object at any time to the processing of your personal data for direct marketing purposes, with no obligation to provide the reason.

7.5 RIGHT TO RESTRICTION OF PROCESSING

You may request the restriction of the processing of your personal data in the following circumstances:

If you contest the accuracy of the personal data, for a period enabling DORVAL ASSET MANAGEMENT to verify the accuracy of the personal data;

If the processing of your personal data is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

If you wish DORVAL ASSET MANAGEMENT to keep your personal data for the establishment, exercise or defense of your legal claims or ;

If you have objected to personal data processing pending the verification of other overriding legitimate grounds by DORVAL ASSET MANAGEMENT to continue processing.

DORVAL ASSET MANAGEMENT will then stop processing the data in question and will store them for the appropriate length of time.

 

7.6 RIGHT TO SET INSTRUCTIONS FOR PERSONAL DATA FOLLOWING DEATH

You may give DORVAL ASSET MANAGEMENT your instructions on your personal data processing in the event of your death.

7.7 RIGHT TO WITHDRAWAL OF CONSENT

For all processing, among those listed in article 2 above, with your consent as the legal grounds, you have the right to withdraw consent at any time, without having to justify your decision to DORVAL ASSET MANAGEMENT.

7.8 RIGHT TO LODGE A COMPLAINT WITH THE SUPERVISORY AUTHORITY

You have the right to lodge a complaint on your personal data processing by DORVAL ASSET MANAGEMENT with the competent supervisory authority.

In France, this supervisory authority is the Commission Nationale de l’Informatique et des Libertés. For further information on this body and how to contact it, please visit the website www.cnil.fr.

8. MODIFICATION TO THIS CONFIDENTIALITY POLICY

This Confidentiality Policy was last updated on March 25, 2021.

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