Data Privacy Policy

In the course of its operations, Committed Advisors SAS (« CA ») collects and uses personal data.

This Privacy Policy explains the personal data that we might collect from you, the purposes and manner of such personal data processing, and your rights with respect to your personal data.

Below are the situations which may be applicable to you, followed by a summary of the applicable policy applied by Committed Advisors.

I. Investors, potential investors or representatives or shareholders of investors or potential investors in our investment vehicles / Shareholders, representatives or managers of entities involved in business transactions with our investment vehicles

1/ What personal data do we collect?

We collect your name, contact information, personal information, financial information, professional information, bank account details, tax information, identification documents and due diligence forms and checks as required.

2/ What is the purpose and legal basis for such personal data processing?

We need your contact information for the purposes of communicating and transacting with you in relation to your investment or during the course of the transaction.  We may use this information for purposes of entering into a contractual relationship with you. In addition, we may need to verify your identity and to confirm your suitability for purposes of the contemplated investment or transaction. We may also need your information to comply with our own tax legal reporting obligations. The legal basis is that, as a regulated management company, we are subject to anti-money laundering, “know-your-client” procedures, tax, reporting and other regulatory obligations.

 3/ Who do we share personal data with?

Your personal data is only accessible to the relevant personnel within our company, which may include personnel in our affiliated offices outside the UE (United States and Singapore). Your personal data may also be shared with our service providers when required in providing their services. Your personal data will also, if necessary, be shared with tax or regulatory authorities.

4/ How long do we keep such personal data?

We only keep your personal data for as long as is necessary for the purposes set forth above, including additional time as required to comply with our record-keeping and regulatory obligations.

II. Suppliers, service providers, business contacts and their representatives

1/ What personal data do we collect?

We collect your name and contact information. We may also collect bank account details and, in certain cases, professional information (CV, diplomas) and identification documents.

2/ What is the purpose and legal basis for such personal data processing?

We need your contact information for the purposes of corresponding and transacting with you in relation to your provision of goods or services. We may use this information for purposes of entering into a contractual relationship with you. In certain cases, we use the data collected to confirm your identity and/or proper qualification for the services. The legal basis is our legitimate business interest in receiving your services and in some cases, our legal compliance obligations to confirm your identity or suitability as a business partner.

3/ Who do we share personal data with?

Your personal data is only accessible to the relevant personnel within our company, which may include personnel in our affiliated offices outside the UE (United States and Singapore). Your personal data can also be shared with our service providers when required in providing their services. Your personal data will also, if necessary, be shared with tax or regulatory authorities.

4/ How long do we keep such personal data?

We only keep your personal data for as long as our relationship is relevant to our business, including additional time as required to comply with our record-keeping and regulatory obligations.

III. Employees

1/ What personal data do we collect?

We collect your name, contact information, personal information, professional information (CV, diplomas), bank account details, social security information, identification documents, certificate of non-conviction and internal employment-related forms.

2/ What is the purpose and legal basis for such personal data processing?

We need your contact information for the purposes of communicating and transacting with you in relation to your employment with us.  We may use this information for purposes of entering into a contractual relationship with you.  We also need your information to comply with our own tax and legal obligations as an employer. In addition, we need to verify your identity and to confirm your suitability as an employee and we need to comply with our internal procedures. The legal basis is our legitimate business interest in having you as an employee and in complying with our legal, labor and tax obligations. As a regulated management company, we are subject to specific regulations requiring certain internal procedures that apply to employees.

3/ Who do we share personal data with?

Your personal data is only accessible to the relevant personnel within our company, which may include personnel in our affiliated offices outside the UE (United States and Singapore). Your personal data may also be shared with our service providers when required in providing their services, in particular our payroll administrator. Your personal data will also, if necessary, be shared with tax or regulatory authorities.

4/ How long do we keep such personal data?

We only keep your personal data for the duration of your employment and any additional time required to comply with our record-keeping, tax and regulatory obligations.

IV. Job applicants

1/ What personal data do we collect?

We collect (directly or through the use of recruitment service providers) your name, contact information and professional information (CV, cover letter, diplomas etc.). We may also seek third-party references.

2/ What is the purpose and legal basis for such personal data processing?

We need your contact information for the purposes of communicating with you during the application process.  We may use this information for purposes of entering into an employment relationship with you.  We use professional information and references to confirm your suitability for the relevant position. The legal basis for processing your personal data is our legitimate business interest in managing our recruiting process.

3/ Who do we share personal data with?

Your personal data is only accessible to the relevant personnel within our company, which may include personnel in our affiliated offices outside the UE (United States and Singapore). Your personal data may be shared with our service providers when required in providing their services. Your personal data will also, if necessary, be shared with regulatory authorities.

4/ How long do we keep such personal data?

If your application is unsuccessful, we may keep your personal data for a period of 2 years, in order to inform you of future opportunities that may be suitable for you, unless you indicate to us that you do not wish us to do so.


HOW DO WE ENSURE PERSONAL DATA SECURITY?

We are committed to keeping your personal data secure, and have implemented appropriate technical and organizational security measures to protect your personal data from loss, misuse or unauthorized disclosure.

We are implementing internal procedures to ensure compliance with our data policy at all levels of our company and are taking steps to ensure that our service providers are held to the highest standards of legal compliance in this regard.

WHAT ARE YOUR RIGHTS?

You have a right to be informed about the personal data that we process in relation to you. You have a right to access, opposition, rectification, erasure and restriction of such personal data as well as data portability rights and post-mortem rights. 

You may exercise such rights by sending a request in writing at "Please enable JavaScript" or Committed Advisors SAS, 4 rue Galilée, 75116 Paris, France.

If you believe that your rights are not upheld or disagree with our Privacy Policy, you have a right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) at https://www.cnil.fr/en/home.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy was last updated in May, 2018. We reserve the right to update and change it from time to time to reflect any changes in the law or in our internal process of personal data. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal data.