Politique de confidentialité
Nous (également désignés par « Nous », « Notre » ou « Nos ») nous engageons à protéger vos Données Personnelles et votre vie privée.
La présente Politique de Confidentialité vous informe des modalités selon lesquelles nous collectons et stockons les informations que vous fournissez via le site https://sillonpatrimecto.com (le Sillon Patrimecto).
Les principes suivants seront respectés :
We want you to make informed decisions about how your Personal Data is used and processed. We use various methods to provide you with relevant information and will share specific details with you when appropriate. We're happy to answer any questions you have about applicable legal limitations.
1. Le périmètre ?
This policy describes the personal data Sillon Patrimecto collects about individuals, and how that data is processed, shared with third parties, and secured.
This policy applies to information relating to an identified or identifiable individual. An identifiable individual is one who can be identified directly or through a combination of additional information we hold or are able to obtain.
"Processing" refers to any activity involving the use or collection of personal data, including its management, structuring, and storage.
Our services are intended for a general audience and are not designed for use by individuals under the age of 18. We do not knowingly collect personal data from individuals under 18 or permit them to use our services. If we become aware that such data has been collected, we will delete it promptly.
2. What personal data do we hold about you?
When you access our services, channels, or website, we collect personal data. In some cases, we may ask you to provide it directly. In others, we collect it by analysing how you use our services or channels, or by receiving it from our third-party partners.
3. You are not required to share any personal information with the company, and there are no consequences for choosing not to do so.
You are not required to provide personal data. However, choosing not to may prevent us from delivering the Services or granting you access to the website.
4. What types of personal data do we collect? When you visit our website, we collect the following personal data about you:
This includes your online activity log, traffic data (such as your IP address, access date, and access time), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal data we receive directly from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal data you provide directly to third-party platforms to facilitate transactions: this includes your full name, address, phone number, and email address.
5. Legal Basis and Grounds for Processing Personal Data
Vos données personnelles sont traitées par la Société aux fins décrites dans cette section, conformément à la base juridique applicable.
Sans base juridique valable, la Société ne peut pas utiliser vos données personnelles. Les fondements juridiques sur lesquels la Société peut s'appuyer pour traiter vos données personnelles :
- You have provided consent for your personal data to be processed for one or more specific purposes. This applies when you submit personal data through the Site for us to share with a third-party trading platform.
- The Company or a third party may need to process your personal data to pursue its legitimate interests — for example, to improve our Services or enforce legal rights.
- Processing is required to comply with a legal obligation.
Reach out to us by email for details on the processing carried out to protect legitimate interests.
Below is a list of the purposes and legal bases under which we may use the personal data you provide to us.
Périmètre, Fondement juridique
1. At your request, we may collect your personal data and share it with third-party companies to facilitate access to digital trading.
You have consented to the processing of your personal data for one or more specified purposes.
2. To address your requests, questions, or concerns, we require certain personal data to assist you with any inquiries you may have about the Services.
The Company's legitimate interests, or those of a third party, must be addressed.
3. Personal Data is processed in accordance with applicable legal requirements to meet any legal, administrative, judicial, or regulatory obligations.
To meet legal obligations, processing of your information is required.
4. We may use personal data to improve our Services. This includes crash reports and malfunction data collected in connection with the Services.
Processing in the legitimate interests of the Company or a third party requires this data.
5. To prevent fraud and misuse of our Services
Processing is required to serve the legitimate interests of the Company or a third party.
6. Performing and managing activities required to deliver our Services — including back-office functions, business development, strategic decision-making, and oversight mechanisms.
Processing is required to serve the legitimate interests of the Company or a third party.
7. For analytical purposes, including statistical analysis, we apply a range of analytical techniques to support decision-making across various matters.
To address the legitimate interests of the Company or those of a third party.
8. To protect our rights, interests, and assets — as well as those of third parties — we may process personal data to establish or defend legal claims, in accordance with all applicable laws, regulations, agreements, terms, and policies.
To address the legitimate interests of the Company or a third party.
6. Sharing Personal Data with Third Parties
We may also share Personal Data with third-party service providers that support our operations, including hosting and storage providers, IP address information services, and user experience analytics platforms.
At your request, we may disclose specific Personal Data to third-party trading platforms. In such cases, we will transmit the Personal Data you provide to the relevant trading platforms. Your Personal Data will be subject to their privacy policies and may be shared with multiple trading platforms.
We may share Personal Data with affiliated entities or business partners to support the development and improvement of the products and services we offer.
Where necessary to protect the rights or assets of third parties, we are authorized to disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data with potential investors, acquirers, or lenders of the Company or any entity within our corporate group in connection with any such transaction — including the transfer or sale of Company or group assets — or in the context of any merger, restructuring, consolidation, or insolvency involving the Company or any group entity.
7. Cookies and Third-Party Services
We may use third-party services, such as advertising networks or analytics providers, on our website. These third parties may also use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit the website. They collect information about your browsing preferences and habits to improve your user experience, remember your settings, and present products and services relevant to you. Cookies are also used for statistical and analytical purposes.
Some cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a set period after your browser is closed. Persistent cookies allow the website to recognize you as a returning user and enable you to resume your session when you return.
Types de cookies :
They may be used by us according to their purpose:
1. Essential cookies only
These cookies are required to give you access to the features you've requested and to allow you to navigate our website. They enable us to deliver the information, products, and services you've asked for.
They are also necessary for your device to download and stream data, allowing you to browse the site, use its features, and return to pages you've previously visited.
Cookies collect personal data — such as your username and last login date — to verify your session. They are automatically deleted when you close your browser (session cookies).
2. Cookies fonctionnels
Cookies remember you between visits, storing your settings and preferences for a seamless experience.
Cookies collect personal data — such as your username and last login date — to verify your session. They are automatically deleted when you close your browser (session cookies).
3. Cookies de performance
Cookies are used to collect statistical data on site performance and support ongoing improvements, including website analytics.
Cookies store anonymous data that is not linked to any identified or identifiable individual. Some cookies are deleted when you close your browser; others have no set expiry date.
Cookies Blocked or Disabled
To block or delete cookies, you'll need to update your browser settings. Links below will guide you through the process for some of the most widely used browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that some or all website features and functionality may not work as expected in this case.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. How We Retain Your Personal Data
We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable laws, regulations, and regulatory requirements.
We share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We conduct regular reviews of the personal data we hold to confirm it remains necessary to retain.
9. Transfers of Personal Information to a Third Country or International Organization
Your personal data may be transferred to other countries or international organizations outside your country of residence. The Company takes all necessary measures to protect your personal data and to ensure that users can exercise their rights and access effective legal remedies.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).
- Transfers to a third country or international organization that the European Commission has determined provides an adequate level of protection for personal data transferred to it, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is carried out under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
- This transfer was carried out in accordance with the standard contractual clauses for data protection adopted by the European Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission are available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
The Company can provide information on the security measures it implements to protect your Personal Data transferred to third countries or international organizations. Send an email to: info@sillonpatrimecto.com
10. Personal Data Security
We have implemented appropriate organizational and technical measures to protect Personal Data, including against accidental or unlawful destruction, loss, or alteration. We cannot guarantee absolute security of your Personal Data, nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, Personal Data disclosed due to transmission errors, unauthorized third-party access, or other causes beyond our reasonable control. Where required by legal or other obligations beyond our control, we may be required to disclose Personal Data to third parties, such as public authorities. We have no control over the level of security those third parties apply to your Personal Data in such circumstances. Personal Data cannot be transmitted over the Internet with absolute security. We cannot guarantee the security of Personal Data you transmit to us via the Internet.
11. Links to Third-Party Websites
Our website contains links to third-party sites and applications. These are not under our supervision, and we are not responsible for how they collect or process personal data. This Policy does not apply to any actions taken through those sites or applications.
Before accessing or using any third-party site or application, we recommend reviewing its privacy policy. Share your personal data with third parties only where necessary and with care.
12. Changes to This Policy
Before accessing any third-party website or application, review its privacy policy carefully. We also recommend sharing only the personal data necessary for your interaction with that third party.
13. Your rights regarding your personal information
You have the right to request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete any Personal Data we no longer need. You may also restrict the scope of processing applied to your Personal Data.
If you reside in the EEA, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise any of these rights, send an email to the address listed below.
Right of Access
We can verify the accuracy of Personal Data we process about you. Where applicable, you may access your Personal Data.
We will provide one electronic copy of your Personal Data currently being processed. A reasonable fee may apply for additional copies. Data will be provided in electronic format upon request.
The right of access must not prejudice the rights and freedoms of others. If a request would harm another person's rights or freedoms, we may refuse or limit the scope of our response.
Right of Rectification
We will correct inaccurate Personal Data. You may require that incomplete Personal Data be completed, taking into account the purpose of the processing.
Right to Erasure
The following grounds apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis exists for processing; (c) you object, on grounds relating to your particular situation, to processing of your Personal Data based on our legitimate interests or those of a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation applicable to us.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defence of legal claims.
Restriction of Processing
If you question the accuracy of your Personal Data, you may request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, to protect the rights of another individual, or for reasons of substantial public interest within the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and is based on your consent or a contract to which you are party, you have the right to access the Personal Data you have provided to us.
You may request that your Personal Data be transmitted directly by us to another controller, where technically feasible. Exercising your right to data portability does not affect your rights under the right to erasure. The right to data portability must not prejudice the rights and freedoms of others.
Right to Object
You have the right at any time to object to the processing of your Personal Data where that processing is based on our legitimate interests or those of a third party. This right is not limited to objecting to profiling based solely on those legitimate interests. Where we can demonstrate compelling legitimate grounds for the processing that override your rights, freedoms, or interests, or where processing is necessary for the establishment, exercise, or defence of legal claims, we may continue that processing.
You have the right at any time to object to the processing of your Personal Data for direct marketing purposes.
Right to Withdraw Consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out on the basis of your consent prior to that withdrawal.
You have the right to lodge a complaint with the competent supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals with regard to the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights in relation to your Personal Data, as set out in Section 13 of this agreement.
We will respond to requests made under the rights described in Section 13 within one month of receipt. This period may be extended by up to two months where necessary, depending on the nature and volume of requests. We will notify you of any extension and the reasons for it within one month of receiving your request.
Unless otherwise provided under Section 13, information provided in response to requests under Section 13 will be supplied free of charge. Where a request is unfounded or excessive, including due to repetition, we may charge a reasonable fee to cover the administrative costs of providing the information or carrying out the requested action. We may also decline to act on the request.
Where we have reasonable doubt as to the identity of the person submitting a request, we may ask for additional information to confirm identity.