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Privacy Policy

General provisions

This Privacy Policy is a part of the Legal Terms and Conditions of the Website www.carmignac.com (the “Website”) and applies to any User of the Website. This Privacy Policy defines treatment of personal information that Carmignac collects when the User accesses to and uses the Website.

Collection of user’s personal information

By using the Website and providing any personal information, the User consents to the collection and use of the data in accordance with this Privacy Policy.

Navigation on the Website is possible without providing any Personal Data about yourself. However, in order to access some parts of our websites, such as to download certain documents, or in connection with another specific purpose, we may need to collect Personal Data from you. Providing Personal Data to us in these events is voluntary. If you do not provide Personal Data to us, then you will not be able to benefit from the respective functionality offered by our websites, such as communication or downloading of documents.

Personal data processed by Carmignac

"Personal data" includes any information making it possible to directly identify (e.g. first name, surname) or indirectly identify (e.g. combination of data) an individual.

The personal data that Carmignac processes may include:

  • identification data, e.g. name, address, telephone number, e-mail address, work contact details;

  • personal details, e.g. date of birth, country of birth;

  • work information, e.g. job and work history, position, power of representation;

  • information transmitted, e.g. by cookies and similar technologies on websites and in e-mails.

Purposes and legal bases of personal data processing

Carmignac collects and processes personal data with the purposes (hereinafter the "Purposes") and according to the legal bases set out in this document.

Generally, Carmignac bases its processing on: - the pursuit of Carmignac’s legitimate interests; - Carmignac’s obligation to comply with statutory or regulatory provisions.; - Your conscent.

The purposes, for which your Personal Data is collected, are described below, along with a brief description of how your Personal Data may be handled in each case.

Communicate with CARMIGNAC.

We will follow up on comments and other requests that you submit to us through our website, such as online queries, business related inquiries, or registering your attendance at an event. This may include using your Personal Data to call you back by telephone or communicating with you via email.

Direct marketing and promotion.

Direct marketing and/or promotional efforts by or on behalf of CARMIGNAC may include providing you with specific information that you have requested online, providing more general information about other CARMIGNAC offerings. When we collect Personal Data for direct marketing or promotional purposes, however, we generally offer appropriate choices regarding the use of your Personal Data.

Maintaining the Website and conducting customer satisfaction surveys.

We will use your Personal Data in order to maintain and improve our website. We may also use your Personal Data in order to conduct customer satisfaction surveys.

Compiling aggregate statistics regarding the use of the website.

When providing Personal Data on this website, you acknowledge that you have the necessary authorisation and consent to disclose Personal Data to be used by CARMIGNAC as described in this Policy

Profiling and automated decision-making

Carmignac may evaluate certain of your characteristics based on personal data processed automatically (profiling) so that, in particular, Carmignac can send to you customised offers and advice or information about Carmignac’s products and services. However, we do not generally use automated decision-making in connection with the Business Relationship and/or Data Subjects. If we need to do so, we will comply with the applicable statutory and regulatory requirements

Sharing your personal data with third parties

If necessary or useful to achieve our Purposes, Carmignac reserves the right to disclose personal data or to make personal data accessible to the following recipients, provided this is legally or otherwise authorised or required:

  • public/government authorities, courts, relevant authorities (e.g. financial supervisory authorities) or financial market actors (e.g. third-party or central depositories, brokers, stock markets and registers);

  • CARMIGNAC Group entities or third-party Data Processors who process personal data on Carmignac behalf and/or to whom Carmignac entrusts some of Carmignac’s activities (outsourcing);

  • auditors or legal advisers.

CARMIGNAC’s practice is to require such third parties to handle Personal Data in accordance with CARMIGNAC’s commitments in terms of personal data processing, confidentiality and security.

Legal disclosures

CARMIGNAC may disclose your Personal Data in urgent circumstances to protect personal safety, the public or CARMIGNAC’s websites. It is also possible that we may be required by law to disclose your Personal Data pursuant to judicial or other government subpoenas, warrants, or orders, potentially, in any country where we do business.

Transfers of your data outside the EEA

In the event of transfers of your data outside the EEA, this transfer will take place on the basis of a decision rendered by the European Commission, when the latter has recognized that the country to which your data will be transferred ensures a level of protection equivalent to that existing in the EEA.

In the event that your data is transferred to a country whose level of protection of your data has not been recognized as adequate by the European Commission, Carmignac will put in place one of the following guarantee to ensure the protection of your personal data: Standard contractual clauses approved by the European Commission.

In this context, CARMIGNAC will verify the appropriate protection measures that could be applied by its service providers to the data - such as encryption or tokenization.

Cookies

Cookies are small pieces of data that a website sends to your computer’s web browser while you are navigating through it. They have many different purposes, but mainly, cookies enable you to navigate between pages easily, to remember your preferences, and eventually to improve the user experience. These cookies may then be stored on your machine to identify your computer.

Cookies can be “session” or “persistent” cookies: a session cookie is a cookie that is automatically deleted when the user closes the browser, whereas a persistent cookie is a cookie that remains stored in the user’s terminal device until it reaches a defined expiration date.

Cookies used on the Website have a maximum lifetime of 12 months.

1. Types of cookies

1.1 Strictly necessary cookies

These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies, services you have asked for cannot be provided.

These cookies allow a website to remember choices you make and provide enhanced, more personal features. These cookies cannot track your browsing activity on other websites.

They do not gather any information that could be used for advertising.

1.2 Performance cookies (“User experience Improvement”)

These cookies are used to collect information about how visitors use a website, for instance which pages they go to more often, and if they get error messages from web pages. All information collected by means of these cookies is anonymised, aggregated and only used to develop and track traffic patterns and the volume of use of the Website and to improve how the Website works. This information is for CARMIGNAC’s exclusive use and is not shared with any third party or connected to any other information.

Performance cookies can be analytical cookies. These cookies are used to store the URL address of previously visited web pages, thus making it possible to track the browsing of users coming from both outside and inside the Site. When you click on a Carmignac advertising link form a third-party website, a cookie may be placed on your computer in order to save it and to allow us to measure the audience of our advertisings and to ensure that they are effectively used

1.3 Targeting cookies (“Personalized offers”)

These cookies are used to deliver advertisements that are targeted to be relevant to you, limit the number of times you see an advertisement, and help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information.

1.4 Social media cookies (“Social media”)

The purpose of theses cookies is to make the Site more user-friendly and interactive, by allowing you to interact with social networks (Facebook, Twitter, LinkedIn, etc.).

These cookies can, in particular, process data related to the number of contents shared through social networks, the fact that you have an account on a social media, the monitoring of your browsing on different sites, etc. These features are based on third-parties applications integrated into our site. The social network providing such an application button is likely to identify you using this button, even if you did not use this button when you visited our site. Indeed, this type of application button can allow the social network concerned to follow your browsing on your site, simply because your account on the social network concerned was activated on our terminal (open session) during your browsing on our site.

We invite you to consult the privacy policies of these social networks in order to be aware of the purposes of use, in particular advertising, of the browsing information that they can collect using these

application buttons. These protection policies must in particular allow you to exercise your choices with these social networks, in particular by setting up your user account for each of these networks. The use and storage of these cookies is possible with your consent.

2. Use of cookies

CARMIGNAC may use Personal Data collected from our cookies to identify user behaviour and to serve content and information about our products based on your profile.

Information from cookies placed via our advertisements on third-party websites can collect Personal Data.

Here is a list of the main cookies we use on our website:

Google Analytics: cookies set by Google analytics are used for web analytical purpose, but are not used to track individual users. For further information on how Google Analytics collects and uses information on our behalf and the right to use such cookies, please refer to the Google Analytics products and services privacy statement. If you object to your Personal Data being collected by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on.

Pardot: cookies set by Pardot are used to track users on our website. Visits are tracked for known users only. Unknown users are recorded as anonymous users. Please refer to Pardot privacy policy for any further information on their use and your rights related to the use of such cookies.

HotJar: We use Hotjar to better understand our users’ needs and to optimize this service and experience. Hotjar uses cookies to collect data on our users’ behaviour and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither HotJar nor Carmignac will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

Numberly: The cookies placed by Numberly are used to track your activity on the Site and to send you personalized content.

Wistia: We use Wistia to host our videos on the website. We only capture viewing data form anonymized videos.

LinkedIn Adds: We use LinkedIn Adds to obtain anonymized data on the demographics of our visitors (age, function)

Facebook Connect: We use Facebook Connect to access the performance of our advertising campaigns on Facebook network.

3. Other non-cookie technologies

CARMIGNAC also enables the use of technologies that perform functions similar to cookies such as web beacons or other technologies that may be included in marketing e-mail messages or newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor website activity.

4. How to accept or refuse cookies

If you do not want to receive cookies from our website, you may set your browser to refuse cookies or to notify you when you receive a cookie, which you may then accept or refuse upon such notice.

You can use the cookie configuration panel, located at the bottom of the page «Privacy settings » in order to choose your preferences.

You can also generally set your browser to turn off cookies. To understand how to do this, please consult your browser’s “Tools” section, or any other similar heading.

We recommend that you leave the cookies active. If you block, turn off or otherwise reject our cookies, some web pages may not display properly or you will not be able to use any website services that require you to sign in.

If you object to have cookies placed on your machine, you need to disable them. In order to do so, please follow the relevant instructions depending on your browser:

Your rights

Subject to the local legislation on data protection, you have the right:

  • to request access to the personal data we hold and to receive a copy of it;

  • where applicable, to request correction of inaccurate personal data;

  • where applicable, to request the erasure of personal data when its Processing is no longer necessary to achieve the Purposes, or is not or is no longer lawful for other reasons, subject however, to the applicable data retention periods (see section “retention period” below);

  • where applicable, to request the limitation of the processing of your personal data;

  • where applicable, to object to the Processing of personal data, in which case Carmignac will no longer process the personal data, unless Carmignac has overriding legitimate reasons for doing so (e.g. the establishment, exercise or defence of legal claims);

  • if you have given your consent to the processing of your personal data, to withdraw your consent at any time

  • to request the portability of your data, ie the return of your personal data that you have provided to us or where technically possible, the transfer of these personal data to a third party;

  • to file a complaint with Carmignac Data Protection Officer (see section “Contact” hereunder) in connection with the Processing of personal data and, in the absence of a satisfactory answer, to file a complaint in connection with the Processing of said data with the relevant data protection authority.

Data security and integrity

CARMIGNAC uses various technological and procedural security measures in order to protect the Personal Data we collect, use or transfer from loss, misuse, alteration or destruction. However, due to the open and unsecured character of the Internet, CARMIGNAC cannot be responsible for the security of transmissions of the Personal Data over the Internet.

Retention period

In principle, Carmignac retains personal data for as long as Carmignac needs in order to achieve the Purposes. Similarly, Carmignac will delete or anonymise personal data (or will take equivalent measures) when they are no longer necessary to achieve the Purposes, subject however (i) to statutory or regulatory requirements applicable to the retention of Personal Data for a longer period; or (ii) in order to establish, exercise and/or defend real or potential claims in the context of legal action, investigations or similar procedures, including legal holds which we may require in order to protect relevant information.

Third-party websites

CARMIGNAC websites may provide links to third-party websites. CARMIGNAC does not make any representations or warranties with respect to such third-party websites. You should be aware that the owners and operators of such third-party websites might collect, use or transfer Personal Data under different terms and conditions than CARMIGNAC. Upon linking to a third-party website, you should inform yourself of the privacy policies of such third-party websites

CONTACT

For any question you may have about the use of your personal data, please send an email to dpo@carmignac.com