The Client is informed of the regulations regarding marketing communications, the Law of 21 June 2014 on Confidence in the Digital Economy, the French Data Protection Act of 6 August 2004, and the General Data Protection Regulation (GDPR: No. 2016-679).
1 – Definitions
Client: any professional or natural person with legal capacity under Articles 1123 et seq. of the French Civil Code, or any legal entity, visiting the Site subject to these general conditions.
Services: www.carminecapital.com provides Clients with investment banking services specialising in business sales, acquisitions and fundraising dedicated to SMEs.
Content: All elements constituting the information present on the Site, including texts, images and videos.
Client Information: All personal data that may be held by www.carminecapital.com for account management, client relationship management, and analytical or statistical purposes.
User: Any internet user connecting to and using the aforementioned Site.
Personal Information: “Information that allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies” (Article 4 of Law No. 78-17 of 6 January 1978).
The terms “personal data”, “data subject”, “processor” and “sensitive data” have the meanings defined by the GDPR (No. 2016-679).
2 – Data Controllers
For Personal Data collected during the creation of the User’s personal account and while browsing the Site, the data controller is: Anne-Laure Beuriot.
As the controller of the data it collects, www.carminecapital.com undertakes to comply with applicable legal provisions. It is the Client’s responsibility to determine the purposes of its own data processing, provide prospects and clients with complete information upon collecting their consent, and maintain a processing register that reflects reality.
Whenever www.carminecapital.com processes Personal Data, it takes all reasonable measures to ensure their accuracy and relevance with regard to the purposes for which they are processed.
3 – Purpose of Data Collection
www.carminecapital.com may process all or part of the following data:
• to enable browsing on the Site and to manage and track services ordered by the user: connection data, usage data, browsing history
• to prevent and combat computer fraud (spamming, hacking): hardware used for browsing, IP address, password (hashed)
• to improve navigation on the Site: connection and usage data
• to conduct communication campaigns (newsletter): name, surname, email address
• to manage client relations (online ordering or payment, product delivery): name, surname, company, postal address, email, telephone number, banking details via the secure payment platform
www.carminecapital.com does not sell your personal data. They are used strictly as needed or for statistical and analytical purposes.
4 – Rights of Access, Rectification and Objection
In accordance with current European regulations, Users of www.carminecapital.com have the following rights:
• right of access (Article 15 GDPR) and rectification (Article 16 GDPR), updating and completeness
• right to block or erase personal data (Article 17 GDPR) when they are inaccurate, incomplete, ambiguous, outdated, or when their collection, use or storage is prohibited
• right to withdraw consent at any time (Article 13-2c GDPR)
• right to restrict processing (Article 18 GDPR)
• right to object to processing (Article 21 GDPR)
• right to data portability of data provided by the User, when the processing is automated and based on consent or a contract (Article 20 GDPR)
• right to define instructions regarding the fate of their data after death and to indicate whether www.carminecapital.com may disclose such data to a third party they have previously designated
Once www.carminecapital.com is informed of a User’s death and in the absence of instructions, the company undertakes to delete the data unless retention is necessary for evidentiary purposes or to fulfil a legal obligation.
If the User wishes to know how www.carminecapital.com uses their Personal Data, request rectification, or object to processing, they may contact Carmine Capital in writing at:
Carmine Capital
42 rue Vignon – 75009 PARIS
or by email at info@carminecapital.com
In such cases, the User must specify the Personal Data they wish to have corrected, updated or deleted and must identify themselves with a copy of an identity document (ID card or passport).
Requests for deletion of Personal Data will be subject to legal obligations imposed on www.carminecapital.com, particularly regarding document retention or archiving. Users may also file a complaint with the relevant supervisory authorities, including the CNIL (https://www.cnil.fr/fr/plaintes).
5 – Non-Disclosure of Personal Data
www.carminecapital.com undertakes not to process, host or transfer Client Information to a country outside the European Union or deemed “non adequate” by the European Commission without informing the client in advance. However, www.carminecapital.com remains free to choose its technical and commercial processors, provided they offer sufficient guarantees regarding GDPR requirements.
www.carminecapital.com commits to taking all necessary precautions to preserve the security of Information and to ensure it is not disclosed to unauthorised persons. If an incident affecting the integrity or confidentiality of Client Information is discovered, www.carminecapital.com will inform the Client as soon as possible and detail the corrective measures taken. www.carminecapital.com does not collect any “sensitive data”.
Personal Data may be processed by subsidiaries or subcontractors (service providers) strictly for the purposes outlined in this policy.
Within the limits of their responsibilities, the primary individuals who may access Users’ data are customer service agents.
6 – Types of Data Collected
For users of the Site www.carminecapital.com, the following data are collected as necessary for service operation and client relationship management and are retained for a maximum of 36 months after the end of the contractual relationship:
Name, surname, address, email, telephone number
www.carminecapital.com also collects information to enhance user experience and provide contextualised guidance:
• browsing cookies (IP address)
• anonymised browsing data for statistical purposes (Google Analytics)
These data are stored for a maximum of 13 months.
7 – Cookies
A “cookie” is a small data file sent to the User’s browser and stored on the User’s device (computer, smartphone, etc.) (hereinafter “Cookies”). This file includes information such as the User’s domain name, internet provider, operating system, and date and time of access. Cookies cannot damage the User’s device.
www.carminecapital.com may process information about the User’s visit, such as pages viewed and searches performed. These elements help improve Site content and User navigation.
Since Cookies help improve navigation or the services provided, the User may configure their browser to allow them to accept or refuse cookies, either systematically or depending on the sender. The User may also configure the browser to be prompted before a cookie is stored.
The User is informed that refusing Cookies may limit access to certain functionalities of the Site. This may also occur if www.carminecapital.com or its providers cannot identify the browser type, language settings or display preferences, or the country from which the connection originates.
www.carminecapital.com declines all liability for any degraded functionality of the Site resulting from the User’s refusal of Cookies or from the inability to store or consult Cookies necessary for Site operation.
Cookie preferences depend on each browser’s configuration, accessible via the help menu.
At any time, the User can adjust their Cookie preferences. www.carminecapital.com may also use external providers to help collect and process data described in this section.
By clicking on social media icons (Twitter, Facebook, LinkedIn, Google Plus) appearing on the Site and continuing to browse, the User accepts that these social networks may deposit cookies on their device.
These cookies are only deposited if the User consents. Consent may be withdrawn at any time.
