Updated on July 7, 2019
The Société Internationale du Cuir, a limited company registered in the Paris Company Register under number 348 106 220 and headquartered at 105, rue du Faubourg Saint-Honoré 75373 PARIS Cedex 08, France (hereinafter referred to as “SIC SA”), in its capacity as data controller, places great importance on protecting and respecting your privacy.
The purpose of this document is to inform you of SIC SA’s practices regarding the collection, use and sharing of information you may provide via its website cuirinvest.com (hereinafter referred to as the “Website”).
This privacy policy describes how SIC SA processes the personal data it collects and/or that you provide.
Any processing of your personal data is carried out in accordance with the provisions of the French Data Protection Act of 6 January 1978 amended in 2018 and with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
By using the Website, you agree to this Privacy Policy.
1. Personal data collected
SIC SA may collect and process the following personal data (hereinafter referred to as “Personal Data”):
1.1 Personal data that you transmit directly
Some of the information you transmit by using this Website may serve to identify you (“Personal Data”), in particular when you fill out the contact form in order to contact us. The Personal Data thereby collected is as follows: first name, last name, email address, company, message.
This is also the case when you fill out the project presentation form. The Personal Data collected through this form is as follows: first name, last name, email address, telephone, company information and project description.
1.2 Personal data collected automatically
Every time you visit the Website, SIC SA, in accordance with applicable legislation and with your consent, when applicable, may collect information about the devices you use to access its services or the networks via which you access them, such as your IP addresses, login details, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, clickstream data about how you browse the Website and the various URL pages, the content you access or consult, search terms used, download errors, time spent on certain pages, your device’s advertising ID, interactions with the page and any telephone number used to contact SIC SA. To collect this information, SIC SA uses technology that includes cookies (for more information on this topic, see article 8 below on cookies).
You may exercise the rights described in Article 7 below, subject to proof of your identity and fulfilment of the conditions for exercising said rights.
2. Data storage period
Your Personal Data is stored for the minimum possible period, i.e. the time required to achieve the purpose for which it was collected.
Your Personal Data collected via forms on the Website is deleted no later than 6 months after collection, if such Personal Data is no longer necessary for our relationship and provided that said deletion does not breach statutory requirements for data storage.
The log file is deleted after 7 days, unless said file is necessary to clarify or prove specific breaches detected during the storage period.
3. Use of the data collected
SIC SA uses the Personal Data collected for the following purposes and on the following legal basis:
| Purposes | Legal basis |
|---|---|
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a) To perform agreements concluded between SIC SA and you or between SIC SA and its business partners and to provide you with the requested information and services. |
a) This processing is necessary for fulfilling the respective contractual obligations. |
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b) To send you information about SIC SA's services via e-mail or any other means of communication. |
b) This processing is necessary for fulfilling the respective contractual obligations and/or is carried out with your consent. |
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c) To give you access to SIC SA’s services and allow you to communicate with SIC SA. |
c) This processing is:
and/or
|
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d) To ensure compliance with:
|
d) This processing is:
|
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e) To send you, in accordance with applicable statutory provisions and with your consent where required by law, marketing and promotional messages and information pertaining to the use of SIC SA's services or to suggest and recommend services likely to interest you, including on social networks or third-party sites. |
e) This processing is based on your consent and/or SIC SA's legitimate interest in providing you with relevant information. |
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f) To inform you of changes in SIC SA’s services. |
f) This processing is necessary for the purposes of:
|
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g) To manage the Website and carry out internal technical operations to resolve problems or perform data analysis, tests, research, analyses, studies, surveys etc. |
g) This processing is based on SIC SA's legitimate interest in ensuring its Website’s security and improving its characteristics. |
4. Sharing of data with third parties
SIC SA may share information about you, in particular Personal Data, with:
- its partners in the management of the investment fund
- subcontractors SIC SA uses for technical services, and suppliers of analytical solutions.
SIC SA only shares your Personal Data with the abovementioned third parties in the following cases:
- when using a service provider for the performance of any agreement between you and SIC SA or in order to provide or improve its services
- when using search engine and analytics solution providers to improve and optimize its Website and/or mobile application
- when you specifically request it (for example, when you use social networks for user authentication)
- when SIC SA has a statutory obligation to do so and in particular to:
- respond to any claim against SIC SA
- comply with any judicial request
- enforce any agreement, such as this Privacy Policy.
We hereby warrant that said third parties, all of whom are located within the European Union, process personal data in accordance with our instructions and with a protection level equivalent to that required by the abovementioned regulations.
5. Targeted promotional information and emails
In accordance with applicable legislation and with your consent where required, SIC SA may use your Personal Data for information purposes, to send you invitations to events or other information that may be of interest to you and to display targeted messages on social media or third-party websites.
With regard to promotional emails, you may withdraw your consent at any time by:
- clicking on the unsubscribe link provided in each message sent by SIC SA
- contacting SIC SA in accordance with the procedure described in Article 11 below.
6. Data transfer
SIC SA stores your Personal Data within the European Union.
However, if some of your Personal Data were to be transferred to Third Countries for which the European Commission has not adopted an adequacy decision (to ensure an adequate level of protection), SIC SA will ensure that this transfer is carried out in compliance with the applicable regulations and with the guarantee of a sufficient level of protection of the privacy and fundamental rights of individuals (in particular by using the European Commission's standard contractual clauses).
7. Your rights to your personal data
You have the right to receive a copy of your Personal Data held by SIC SA (“right of access”).
You may request the erasure of your Personal Data and the rectification of erroneous or obsolete Personal Data (“right to erasure” and “right to rectification”).
SIC SA may retain certain information about you when required by law or when it has a legitimate reason to do so.
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your Personal Data for marketing purposes (direct marketing) (“right to object”).
You have the right to restrict the processing of your Personal Data (“right to restriction”).
This right applies only in certain limited cases, namely:
- when you contest the accuracy of your Personal Data during the period enabling SIC SA to verify the accuracy thereof
- when the processing by SIC SA is unlawful and you demand the restriction of the use of your Personal Data rather than its erasure
- SIC SA no longer needs the Personal Data for the purposes of processing, but you still require it to establish, exercise or defend legal claims
- when you exercise your right to object, pending verification of whether SIC SA’s legitimate grounds prevail over your own.
You have the right to lodge a complaint with the competent supervisory authority (in France, the Commission Nationale de l’Informatique et des Libertés (CNIL – www.cnil.fr), 3 Place de Fontenoy, 75334 PARIS CEDEX 07, Telephone: +33 (0)1 53 73 22 22) or to obtain compensation from the competent courts if you deem that the processing of your Personal Data constitutes a breach of the abovementioned regulations.
You have the “right to data portability”, including
- the right to receive the Personal Data you provided to SIC SA in a structured, commonly used and machine-readable format.
You also have the right to give instructions regarding what should happen to your Personal Data after your death.
To exercise these rights, you may contact SIC SA using the procedure described in Article 11 below.
8. Cookies
Cookies are small files installed on your computer.
A cookie does not allow SIC SA to identify you, but it does record information about your computer's browsing of the Website and that SIC SA may consult on your subsequent visits in order to facilitate browsing, optimize login and track the Website's audience.
- Google Analytics audience metrics cookie
- Matomo audience metrics cookie
- OVH session management cookie (while connected to the Website)
You may block the use of cookies or withdraw your consent to the use thereof at any time
- by adjusting your internet browser settings.
However, by blocking cookies, some or all parts of the Website may become unavailable.
For more information, you may contact SIC SA using the procedure described in Article 11 below.
9. Changes to the privacy policy
SIC SA may make changes to this privacy policy.
When necessary, SIC SA will inform you and/or seek your consent.
SIC SA recommends that you consult this page regularly to check for any changes or updates to its privacy policy.
The modification or update will take effect on the date indicated at the top of the page.
By continuing to browse the Site after that date, you agree to any changes or updates to the Privacy Policy.
11. Contact
For any question relating to this privacy policy or for any request regarding your Personal Data, please contact SIC SA by:
- sending an email to: contact
sicgroup.com - using the contact form on this Website
- writing to us at the following address: 105, rue du Faubourg Saint-Honoré - 75373 PARIS Cedex 08 - France