TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (also known as "We", "Us", or "Our") are committed to protecting your personal data and privacy. This Privacy Policy outlines how we collect and store the information you provide through our website Novione Patrimoines (the "Website").
We believe you should have the information needed to make informed decisions about how your Personal Data is used and processed. We use various methods to keep you informed about relevant details. When we determine that specific information would be helpful, we'll provide it at the right time. We're happy to answer any questions you may have about legal limitations affecting your data.
1. The Scope
This policy outlines the types of personal data the Company collects from individuals and how it processes, shares, and protects that information.
1.2 This Policy applies to information related to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified or determined through a combination of information we hold or can access.
The Policy defines "processing" as any activity involving the use or collection of Personal Data, including its management, organization, and storage.
Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect information from minors or permit them to use our services. If we become aware that we've collected information about a child, we will delete it promptly.
2. What Personal Data Do We Have on You
When you access our website and services, we collect your Personal Data. In some cases, we may also request additional information from you.
In other instances, we collect your Personal Data by analyzing your use of our Services and service channels, or by receiving information about you from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You're not required to provide us with any personal data. However, in certain circumstances, failing to supply us with personal data may prevent us from delivering our services or may limit your access to the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log and data about your traffic, including:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
4.2 The information you collect is not considered private information and cannot be used to identify you personally.
4.3 Personal Data we receive from you: any personal data you voluntarily provide to us when you connect with a third-party online trading platform through us.
4.4 Personal information you provide directly to third-party platforms to enable trading: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 Your personal data is processed by the company for the purposes outlined in this section, and in accordance with the applicable legal basis.
5.2 Without a legal basis, the Company cannot process your Personal Data. The legal grounds that enable the Company to process your Personal Data are as follows:
- You have consented to the processing of your personal data for one or more reasons. This occurs when you submit personal information through the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may require processing to fulfil their legitimate interests. For example, this may be necessary to improve our services or defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact us via email for more information about the processing steps we take to protect legitimate interests.
5.4 Below is a list of reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
To share your personal information with third parties upon your request for access to digital trading
If you ask, we may collect Personal Data from you to forward to third-party companies.
You have consented to the processing of your personal data for one or more purposes.
2. To respond to your inquiries and concerns
We need your Personal Data to address any questions you may have about our Services.
We need to process personal information to protect the legitimate interests of the Company or a third party.
We process your personal data to comply with applicable legal, administrative, and judicial requirements.
To ensure compliance with legal obligations, processing is required.
4. To Enhance Our Services
We may use your Personal Data to improve our Services. This includes, for example, crash reports and malfunction data we collect related to the Services.
We need to process personal information to protect the legitimate interests of the Company or a third party.
5. To stop fraud and misuse of Our Services.
We need to process personal information to protect the legitimate interests of the Company or a third party.
6. To perform and manage actions that align with the requirements of Our Services
Such activities include back-office functions, business development activities, strategic decision-making, oversight mechanisms, and related administrative tasks.
We need to process personal information to protect the legitimate interests of the Company or a third party.
7. To conduct analysis, such as statistical analysis
We use various analytical techniques, including statistical methods, to inform our decision-making on different matters.
We need to process data to protect the legitimate interests of the Company or a third party.
8. To protect our assets, rights, and interests, as well as those of third parties
We may process Personal Data to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and our terms and policies.
We need to process personal information to protect the legitimate interests of the Company or a third party.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, for purposes including IP address information collection and user experience analysis.
6.2 You can also request that we share your Personal Data with third-party trading platforms. When you do, we'll provide your Personal Data to those platforms. Please note that their use of your information is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
6.3 The Company may share Personal Data with related entities or business partners to obtain the resources needed to enhance and improve its products and services.
6.4 If the Company needs to protect the rights of third parties or safeguard assets, it may disclose Personal Data to regulatory authorities, local government bodies, or other official agencies.
We may also share your Personal Data with potential investors, buyers, or lenders to our Company or other group entities in connection with any transaction, including asset transfers or sales, mergers, restructurings, consolidations, or bankruptcy proceedings involving our Company or any business within the group.
7. Cookies and Services from Third Parties
We may use third-party services, such as advertising and analytics providers, on our website. These companies may also use cookies and other tracking technologies.
7.2 Cookies are small text files stored on your device when you visit our website. We use cookies to collect information about your preferences and browsing habits, helping us improve your experience, remember your settings, and personalize the products and services we offer. Cookies also enable us to gather statistics and analytics data.
7.3 We use two types of cookies on our website. Session cookies are temporary and are deleted from your device when you close your browser. Persistent cookies, on the other hand, remain on your device after you close your browser. We use persistent cookies to recognize you as a returning user and to help you access the website more easily on future visits.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are necessary to access the features you've requested and navigate our website. We use them to deliver the information, products, and services you've asked for.
They're required for your device to download and stream data, allowing you to move through the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect personal data, such as your username and last login date, to confirm you're logged in to the site. They're automatically erased when you close your web browser (session cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognize you each time you visit our site and to save your preferences.
Additional Information
They remain valid until the expiry date and persist even after you close your browser.
The type of cookie
Cookies for performance
Scope
We use cookies to collect performance data and help improve your experience. They also enable us to analyze how our website is being used.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable person. Some cookies are removed when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or remove cookies, you'll need to adjust your browser settings. Below are links to help guide you through the process for some of the most commonly used browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please be aware that certain functions and features of the Website may not operate as expected if this occurs.
Online Tracking Notice: This service does not currently respond to do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or for any longer periods as required or permitted by applicable law, regulations, and directives.
We'll share your information with third-party trading platforms for a period of 12 months. If you consent, we'll continue sharing your data for an additional 12 months.
8.3 We regularly review the Personal Data we retain to ensure it's no longer necessary.
9. International Transfers
9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third-country or to international organizations). The company takes all necessary steps to safeguard the personal data you provide and ensures that data users have the ability to assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for personal data under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
- The transfer was completed in accordance with the standard contractual clauses approved by the EU Commission under Article 46(2)(c) of the GDPR.
9.3 The Company can provide information about the security measures it uses to protect your Personal Data when it's transferred to third-party countries or international organisations. For details, send an email to: support@novione-patrimoines.com
10. Security of Personal Data
We have implemented appropriate organizational and technical safeguards to protect your Personal Data, including measures to prevent accidental or unlawful destruction, loss, or alteration.
10.2 We cannot guarantee that your Personal Data will be protected without error, nor can we be held responsible for any indirect, incidental, or consequential damages resulting from the use or disclosure of your Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorized third-party access, or any other circumstances beyond our control.
10.3 If we're required by law or other circumstances beyond our control to share your Personal Data with third parties—such as public authorities—we may do so. In these situations, we cannot guarantee how third parties will secure your Personal Data.
10.4 Personal data cannot be transmitted over the internet with complete security. The Company cannot guarantee the safety of any personal data you send to us online.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party websites and applications that are not operated or supervised by the Company. We are not responsible for how these third-party sites or apps collect or process your personal data. This Privacy Policy does not apply to your activities on those external platforms.
11.2 When you visit any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use them. We also suggest being cautious about sharing any Personal Data with them.
12. Modifications to This Policy
12.1 This Policy may be updated at any time. If we make changes, we will notify you by posting the updated Policy on our website.
12.2 Additionally, when we make significant changes to this Policy, we will notify you using methods we deem appropriate and will post an announcement on our website.
12.3 Unless otherwise specified, any amendments will take effect upon publication of the revised Policy.
13. Your Rights
13.1 You have the right to request that we verify the accuracy of your Personal Data, correct any inaccuracies, and delete Personal Data that we no longer need to retain. You may also request that we restrict how we process your personal information.
13.2 If you are a resident of the EEA, please refer to this page. You have specific rights regarding the personal data you provide to us. To exercise these rights, please contact us by email at the address below.
13.3 Access rights The Company verifies the accuracy of your Personal Data and ensures it is processed correctly. You have the right to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed at no charge, though a reasonable fee may apply for additional copies. If requested, the data will be made available in electronic format. Your right to access Personal Data must not conflict with the rights and freedoms of others. If granting access would be detrimental to another person's rights or freedoms, the Company may refuse the request or limit its ability to fulfill it.
13.4 Right to rectification The Company may correct inaccurate Personal Data. You have the right to request that any incomplete or inaccurate Personal Data about you be corrected, taking into account the purpose of processing.
13.5 Right to Erasure You may request the deletion of your Personal Data for the following reasons: (a) the Personal Data are no longer necessary for the purpose for which they were collected or processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object at any time, for reasons specific to your situation, to the processing of Personal Data based on legitimate interests pursued by us or by a third party; (d) the Personal Data are being processed unlawfully; or (e) the Personal Data must be deleted to comply with a legal obligation. This right does not apply when processing is necessary (a) to fulfil an obligation required by European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may request that the Company limit its processing. When you request a restriction on processing, your Personal Data will be retained only if you provide consent, or to establish, exercise, or defend legal rights — either your own or those of another individual — or where processing is required for reasons of substantial public interest within the European Union or a Member State.
13.7 Right to data portability If processing is carried out by an automated system and is based on your consent or a contract you are party to, you have the legal right to access your Personal Data held by the Company. You may request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. The exercise of your right to data portability does not affect your rights under the right to erasure. The right to data portability does not prejudice the rights or freedoms of any other person.
13.8 Right to challenge You have the right to object at any time to the processing of your Personal Data when it's based on legitimate interests pursued by the Company or a third party. This right applies regardless of whether the processing involves profiling. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue only if you can show that our interests are outweighed by your rights, freedoms, interests, or the need to establish, exercise, or defend legal claims. Regarding direct marketing, you may object to the processing of your Personal Data at any time.
13.9 Right to refuse consent You may revoke your consent for Us processing Personal Data about you at any time. This will not affect the legality of any processing that relied on your consent before withdrawal. You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by an EU member state to protect the fundamental rights of individuals regarding Personal Data processing within the European Union. EU and member state laws may limit your rights concerning your Personal Data, as outlined in this section 13.
We will provide you with the requested information as per the rights outlined in section 13 of this agreement within one month of receiving your request. This timeframe may be extended to up to two months, depending on the nature and complexity of your request as well as the volume of requests received. We will notify you of any extension within one month of receiving your request and provide the reasons for the delay.
13.11 In accordance with section 13 of the law, we will provide the information you request at no cost. However, if your request is unjustified, excessive, or repetitive, we may charge a reasonable fee to cover our administrative costs. We also reserve the right to decline such requests.
If we have any doubt about the identity of the person submitting your request, we may ask them to provide reasonable means of identification.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Novione Patrimoines 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@novione-patrimoines.com