PERSONAL DATA PROTECTION POLICY

This personal data protection policy aims to inform all external stakeholders of the management company about the processing of personal data carried out by Exane Asset Management (hereinafter “EAM”), its commitments regarding the protection of individuals’ privacy, as well as the rights individuals have in relation to this data.

Scope

This policy applies to any processing involving personal data implemented by EAM.

Basis and purpose of collecting personal data

EAM collects and processes personal data in the following cases:

• As part of the performance of a contract binding EAM to a partner;
• Based on EAM’s legitimate interest (for example, prospecting and managing the commercial relationship with clients);
• To comply with legal and regulatory obligations (such as identification and verification of identity for anti-money laundering and counter-terrorism financing purposes, recording telephone lines and monitoring electronic communications for compliance, handling complaints and litigation, etc.).

Collection and use of personal data

EAM may collect and process personal data that directly or indirectly identifies an individual (such as first name, last name, email address, professional contact details, company, position, etc.). This data may be analyzed and shared with the relevant departments as part of the company’s activities.

How do we collect your personal data?

Access to personal data

EAM may be required to disclose your data to the following categories of recipients:

• Authorized members of our staff and any individual or legal entity authorized by EAM to process personal data;
• Where applicable, the competent courts, arbitrators, and mediators;
• Supervisory and regulatory authorities, as well as any public bodies authorized to receive such information;
• The centralizers, transfer agents, and statutory auditors of our funds (OPC);
• Control-related services such as statutory auditors and external auditors, as well as internal control departments.

These recipients may be located outside France.

Retention period of personal data

We retain your personal data for no longer than is necessary for the purposes for which it is processed.
The retention periods we apply are summarized in the table below:

• Commercial prospecting: 3 years from the date on which the data is collected by the data controller, or from the last contact initiated by the prospect.
• Contracts: 10 years after the contract’s expiry or termination date.
• Regulatory data: 5 to 10 years.
• Anti–money laundering and counter‑terrorist financing: 5 years from the end of the relationship with the data subject.

Processes Security

EAM implements appropriate physical, IT, and organizational measures to ensure the security and confidentiality of personal data, in particular to protect it from any loss, destruction, accidental or unintentional alteration, or any unauthorized access
 

Data subject rights

The processing of personal data concerning you may be subject to the exercise of your rights of access, rectification, erasure, restriction, portability, and objection to the use of your personal data, under the conditions set out by the applicable regulations, in particular by the European Regulation 2016/679 (GDPR).

Data subjects have the right to access their personal data, as well as the right to request that any inaccurate, incomplete, or outdated data be rectified, updated, or deleted. They may also request that the use of their personal data be restricted and may object to the processing of their personal data, subject to the continuation of the subscribed services and/or the maintenance of the business relationship.

Data subjects may also object, without having to justify their request, to the use of their personal data for direct marketing purposes or to their disclosure to third parties for such purposes.
To exercise these rights, you must write to the address indicated in the ‘Contact’ section below.

Contact

This policy is reviewed regularly and may be amended at any time. EAM reserves the right to revise its terms and conditions.
For more information, please contact us at dpo@exaneam.com