GDPR

Charter for the protection of personal data

The purpose of this charter (hereinafter, the "Charter") is to determine the rules relating to the collection and processing of personal data carried out by Financière Ora in accordance with the requirements of European Regulation n° 2016/679 of 27 April 2016, relating to the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter the "GDPR"), and Law no. 78-17 of 6 January 1978 on information technology, files, and freedoms in its amended version.

This Charter is likely to evolve according to the legal and regulatory context, as well as the decisions and recommendations established by the CNIL in this area. The current version of the Charter is available at any time on the Financière Ora website, at the address www.financiere-ora.fr.

Who is responsible for processing your personal data?

The controller of your personal data, is the company:

Financière Ora
6 avenue d’Eylau
75116 Paris

On what occasions is your personal data collected?

Your personal data may be collected by Financière Ora in the context of relationships such as setting up a management mandate, a life insurance contract, contacts established during professional meetings or partnerships, financial investment advice, job interviews, application management etc.

Financière Ora undertakes to comply with the principles of protection of personal data by design and by default as required by the GDPR; as well as the principle of minimizing the collection of personal data, thus only collecting relevant information, adequate, sufficient and strictly necessary for the purposes for which the personal data are processed.

On what legal grounds are your personal data collected?

Financière Ora processes your personal data on several legal bases, and more particularly on the basis of:

  • The execution of an agreement that you wish to entrust to Financière Ora, or any other contract if applicable;

  • The expression of a free, specific, informed and unequivocal consent on your part to the processing of your personal data (for example your subscription to our newsletter);

  • Compliance with the legal and regulatory obligations imposed on Financière Ora (for example in the fight against money laundering and terrorist financing, compliance with regulations imposed by the Autorité des Marchés Financiers, the Prudential Control and Resolution Authority, and other possibly applicable regulations); and

  • When the legitimate interests of Financière Ora are such as to justify the processing of your personal data (such as the exercise or defense of a legal claim by Financière Ora, in case of debt recovery, liability claims, etc.).

Why is your personal data collected?

The personal data processed by Financière Ora are collected for specific, explicit and legitimate purposes.

Financière Ora collects your personal data in particular for the purpose of:

  • Manage and respond to requests addressed to Financière Ora by email and through the online contact form;

  • Manage applications sent to Financière Ora and monitor recruitment processes;

  • Send you information regarding the regulatory and financial activity and news of Financière Ora;

  • Comply with the legal and regulatory obligations incumbent on Financière Ora in the context of its activities;

Who are the recipients of your personal data?

The personal data collected and processed by Financière Ora being confidential by nature, they will only be communicated to the persons referred to in the list belowbelow; without prejudice to their possible transmission to the bodies responsible for a control or inspection mission in accordance with the applicable regulations (notably the Autorité des Marchés Financiers, and the Autorité de Contrôle Prudentiel et de Résolution):

  • Personnel of Financière Ora within the limits of their respective responsibilities (including without limitation associates, employees, temporary workers, apprentices, interns);

  • External service providers and subcontractors to which Financière Ora may call for the performance of specific services (namely, in particular, independent agents, intermediaries or brokers, account holding institutions, auditors, lawyers, etc.). Financière Ora ensures that this access is made in the respect of confidentiality intrinsically attached to your personal data, and this within the strict limits of information necessary for the accomplishment of the tasks entrusted to them;

  • Administrative, financial and judicial authorities, public bodies with which Financière Ora collaborates (AMF, ACPR, etc.);

  • Financière Ora shall previously ensure that each person likely to have access to such personal data is subject to strict confidentiality obligations (and depending on the cases of professional secrecy, bank secrecy, legal or contractual obligation of confidentiality).

Some of the personal data processed by Financière Ora are transferred outside the European Union to several subcontractors. Financière Ora ensured prior to the implementation of this transfer that it met appropriate guarantees, and was carried out within a contractual framework ensuring the security of your data (notably through the adoption of standard contractual clauses as recommended by the European Commission).

How long is your personal data kept?

Financière Ora retains your personal data for the period strictly necessary to fulfill the purposes for which they are processed, and applies in particular the following retention periods:

  • Personal data of Financière Ora clients: the time of the contractual relationship, then archiving until the applicable limitation period runs out;

  • Personal data of the partners of Financière Ora: the time of the contractual relationship, then archiving until the applicable limitation period runs out;

  • Personal data of Financière Ora prospects: three years from the last contact originating from the prospect or from the collection of data;

  • Personal data of candidates: the time necessary to process the application, then in case of a negative outcome, three years from the last contact (if no agreement of the person concerned for a longer retention period).


How does Financière Ora ensure the security of your personal data?


In order to ensure that your personal data is not damaged, destroyed or disclosed to unauthorized third parties, Financière Ora ensures that each person accessing personal data is duly authorized to access it, and is bound by a strict obligation of confidentiality.

Moreover, Financière Ora has implemented technical and organizational measures to ensure the security of personal data for the duration of their processing and storage (such as obtaining contractual guarantees with subcontractors accessing and processing personal data on behalf of Financière Ora, securing access to premises and servers hosting Financière Ora’s data, securing the computer system and its access methods, encryption of data exchanged with its subcontractors by an SSL certificate.

In accordance with the GDPR, and if despite all precautions taken, Financière Ora becomes aware of a personal data breach, Financière Ora then undertakes to communicate this breach to the National Commission for Informatics and Freedoms (the CNIL), and when required by the applicable regulations for data subjects, in particular in case of high risk to their rights and freedoms.

What are your rights regarding your personal data?

In accordance with the provisions of the GDPR, and subject to the limits imposed by the applicable regulations, you have the following rights:

  • A right to information on the processing of your personal data
    Financière Ora will make its best efforts to inform you of the existence or not of personal data processing concerning you as well as of the conditions for implementing such processing in the most concise, transparent and easily accessible manner possible.

  • A right of access, rectification and erasure of your personal data ("right to be forgotten")
    You have the right to obtain an electronic copy of your personal data processed by Financière Ora (for any additional copies, Financière Ora is entitled to demand the payment of a reasonable fee based on the administrative costs incurred).


In the event that the personal data concerning you processed by Financière Ora is incomplete, outdated or non-compliant, you have the right to request rectification as soon as possible.

Finally, and subject to the exceptions provided for by the applicable regulations, you have the right to request at any time the erasure of personal data concerning you when they are processed by Financière Ora, in particular (without this list being exhaustive) :

  • when these are no longer necessary in view of the purpose for which they were collected and processed;

  • when you wish to withdraw your consent to the processing of this data and there is no other basis justifying its processing;

  • when you consider that these should be erased given a legal obligation.

Un droit à la portabilité de vos données personnelles
You have the right to obtain the communication of your personal data processed by Financière Ora in a structured and commonly used format in order to transmit them to the person of your choice.

Provided that this is technically feasible, your personal data may be directly transferred by Financière Ora to the controller you indicate.

The right to obtain a restriction on the processing of your personal data
In the event that (i) you contest the accuracy of your personal data as it is processed by Financière Ora, (ii) when Financière Ora no longer needs the personal data, but you still need them for the determination, the exercise or defence of a legal claim, or (ii) where you object to the processing of your personal data which is based on the legitimate interest of Financière Ora; the processing of your data will then be limited during the examination of your request.


Furthermore, if you do not wish for Financière Ora to process your personal data, without however, that they are erased, you have the right to request the limitation of their processing.

A right to withdraw consent to the processing of your personal data
If the processing of your personal data by Financière Ora is based solely on your consent, you have the possibility to withdraw this at any time, so that your personal data are no longer processed by Financière Ora.


For example, if you no longer wish to be a recipient of newsletters or other information related to the activity of Financière Ora, you have the possibility to unsubscribe directly via the link located within each of our newsletters.


Your attention is however drawn to the fact that the withdrawal of your consent will only be valid for the future and will not call into question the lawfulness of the processing carried out until then.

A right to lodge a complaint with a supervisory authority
If, despite all the care taken by Financière Ora to respect the confidentiality of your personal data and your related rights, you consider that these are not respected, you then have the right to file a complaint with a competent authority, namely, the CNIL.

A right to decide the fate of your personal data after your death
You have the right to organize the fate of your personal data after your death, through the communication of directives that Financière Ora undertakes to respect.

These directives may concern in particular the erasure and storage of such personal data, through the designation of a trusted digital third party responsible for ensuring their proper execution.

With whom to exercise your rights?

In order to exercise the rights detailed above, we invite you to contact the Personal Data Protection Officer (the "DPO") of Financière Ora, accompanied by your request with a copy of your identity document at the following address:

DPO Financière Ora
6 avenue d’Eylau
75 116 PARIS
Or:
contact@financiere-ora.fr

Your request will be replied to as soon as possible, and at the latest within one month from receipt of your request. If necessary, and especially in case of complexity of the request or receipt of too many requests, Financière Ora may extend this period by two months, and will then inform you of this decision as well as the reasons for this extension within one month of receipt of your request.