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PERSONAL DATA PROTECTION POLICY

Exoé attaches great importance to the protection and confidentiality of the privacy of its customers and more particularly of their personal data. In this context, this Personal Data Protection Policy will allow you to understand what personal data we collect and what we do with it, as well as how you can protect your privacy in the context of the services we provide.

  1. WHO IS RESPONSIBLE FOR DATA PROCESSING?

Exoé, a French simplified joint-stock company, duly authorized to act as an investment service provider, with a share capital of €529,650, headquartered at 6, rue de Lisbonne, 75008 Paris, France, registered with the Paris Trade and Companies Registry under the number 492 940 499.

2. WHAT TYPE OF DATA EXOÉ COLLECT ABOUT YOU ?

As part of the subscription to Exoé services and during the provision of these services, Exoé collects the following categories of data:

  • Identification data: first name, last name, professional postal and email address, professional telephone number, customer ID, etc.

  • Service data: transactions processed, funds managed, restrictions, etc.

  • Usage data: services subscribed, products used, consumption, communications, geolocation, etc.

  • Relationship monitoring data: support requests, correspondence, etc.

3. HOW DOES EXOÉ USE YOUR DATA ?​

Exoé uses your data for the purposes of contract execution and management. This includes the management of your account and the contractual relationship, the installation, maintenance, supply and management of the subscribed service or ordered product, the delivery of assistance and the processing of your requests, the invoicing of the service or product, management of complaints and disputes, also through third parties. This data is kept for the time necessary to manage the contract and/or for the legal duration. Without this data, Exoé would not be able to carry out the services to which you or the legal entity of which you are the beneficiary or user have subscribed. Exoé may also use your data when it has a legitimate interest. Your data will allow Exoé to evaluate and improve its services and develop new ones, as well as to carry out loyalty, prospecting, survey and promotion actions. Unless you object, you may receive, by post and telephone, offers from Exoé or its commercial partners, as well as emails for services similar to those offered by Exoé. With your express agreement, Exoé may communicate to you by email commercial information for services not similar to those already provided. Finally, your data may also be used to guarantee the security of the network and to prevent possible fraud or in the context of mergers, sales of assets or transfers of all or part of its activity, by transferring your personal data to the or to third parties involved in the transaction as part of the transaction. This data will be kept for the time necessary to achieve these purposes and for a maximum period of five years from the end of the contractual relationship. Exoé may also use your data in order to comply with its legal obligations (including laws relating to conflicts of interest, laws on money laundering and provisions concerning late or non-payment) and/or to respond to requests from public and governmental authorities.

4. HOW CAN YOU MANAGE THE COLLECTION AND USE OF YOUR DATA?

You can at any time access your data, rectify it, request its deletion, object to processing for legitimate reasons due to your particular situation or even exercise your right to the portability of your data, by sending a letter and providing proof of your identity to: Exoé – GDPR Service – 6 rue de Lisbonne 75008 Paris. You can contact our department dedicated to the Protection of Personal Data at any time at: contact@exoe.fr. The data that Exoé needs for the purpose for which they were collected, necessary to comply with a legal obligation and/or to establish, exercise or defend legal rights cannot, however, be deleted. By contacting Mr. Frédéric Varenne, Personal Data Protection Officer, you can also define directives relating to the fate of your personal data after your death. In the event of a complaint to which Exoé has not given you a satisfactory response, you can contact the National Commission for Information Technology and Liberties (CNIL) in charge of compliance with obligations regarding personal data.

5. HOW DOES EXOÉ ENSURE THE SECURITY OF YOUR DATA ?

Exoé implements the necessary actions to protect the personal data it processes. Your data is processed electronically and/or manually and, in any case, in a manner that ensures their security, protection, and confidentiality with respect to their sensitivity level, through administrative, technical, and physical measures to prevent loss, theft, use, disclosure, or unauthorized modification.

6. WHO CAN HAVE ACCESS TO YOUR PERSONAL DATA?

Your personal data is processed by Exoé, the group companies and its subcontractors and partners, for the purposes of managing the contract and carrying out the services that you have requested or authorized. Your data may also be transferred to third party service providers who provide services or support and advice to Exoé. On request, they may also be transferred to persons and authorities whose right of access to personal data is recognized by law, regulations or provisions emanating from authorities authorized by law. Exoé's subcontractors and partners may be located outside the European Union. When this subcontractor or partner is located in a country which has not been recognized as ensuring an adequate level of protection, Exoé requires it to comply with its security and confidentiality requirements for your personal data and not to process your data only for the purposes it has determined. Such subcontractors and partners will have previously signed the Standard Contractual Clauses of the European Commission.

7. EVOLUTION OF THE PRIVACY POLICY

This Privacy Policy is subject to change, particularly due to legislative and regulatory developments.

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