Privacy policy

Preamble

The purpose of this privacy policy (the “Policy”) is to inform You about how SYCOMORE CORPORATE FINANCE collects and processes Your Personal Data in connection with Your use of the website www.sycomore-cf.com (hereinafter the “Site”), in accordance with applicable legislation, in particular Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”) and the amended French Data Protection Act of 6 January 1978 (Loi Informatique et Libertés, the “LIL”).

This Policy may be updated, in particular to reflect changes in legislation or regulations. If SYCOMORE CORPORATE FINANCE makes any changes to this Policy, it will notify the Data Subjects.

Article 1 – Definitions

In this Policy, the terms below have the following meanings:

“Personal Data”: means any personal data, as defined in Article 4(1) of the GDPR, relating to the Data Subjects and Processed under this Policy.
“Data Subjects” or “You”: means the persons concerned by the Processing operations carried out by SYCOMORE CORPORATE FINANCE as data controller. Under this Policy, the Data Subjects are the Users.
“Data Controller”: means the person who, alone or jointly with others, determines the purposes and means of the Processing.
“Services”: means the features and services provided by SYCOMORE CORPORATE FINANCE to the User on the Site.
“Processor”: means the person processing Personal Data on behalf of the Data Controller, acting under the authority and on the instructions of the Data Controller.
“Processing/Process”: means any of the operations referred to in Article 4(2) of the GDPR, performed on Personal Data on behalf of and in accordance with the instructions of SYCOMORE CORPORATE FINANCE, in accordance with Article 4(8) of the GDPR.
“Users”: means any natural person who accesses the Site and uses the Services offered.

Article 2 – Identity of the Controller of Your Data

Your Personal Data is collected and processed by SYCOMORE CORPORATE FINANCE, as Data Controller, for the purposes detailed in Article 4 of this Policy.

For any questions, you may contact SYCOMORE CORPORATE FINANCE:

By post at SYCOMORE CORPORATE FINANCE, 26 Avenue des Champs Elysées, 75008 PARIS, France;
By email at rgpd@sycomore-cf.com.

Article 3 – Context of the Processing

In the course of its business and Your use of the Services, SYCOMORE CORPORATE FINANCE collects and processes Personal Data about You. This Personal Data may come directly from You or may have been collected from third parties.

Your Personal Data may be collected and processed by SYCOMORE CORPORATE FINANCE on various occasions, including:

When using the features of the Site;
When contacting SYCOMORE CORPORATE FINANCE.

Article 4 – Purposes and Legal Bases of the Processing

SYCOMORE CORPORATE FINANCE only collects the Personal Data necessary for the explicit and specified purposes set out below.

Purposes	Details of the purposes pursued	Legal bases
Management of contact requests	Handling Your requests for information, following up on requests and job applications	Consent of the Data Subject
Security, administration and proper functioning of the Site	Ensuring the proper functioning and continuous improvement of the Site and its features	Consent of the Data Subject where required. The legitimate interest of SYCOMORE CORPORATE FINANCE in ensuring the best level of performance and quality of the Site, and in preventing fraud and malicious acts. Data Subjects may obtain, on simple request to SYCOMORE CORPORATE FINANCE, information on the balancing of the interests involved.
Management of requests to exercise GDPR rights	Operations necessary to follow up on requests to exercise rights sent by Data Subjects to SYCOMORE CORPORATE FINANCE	Legal obligation of SYCOMORE CORPORATE FINANCE arising from Articles 15 et seq. of the GDPR

SYCOMORE CORPORATE FINANCE will also be authorised to use Your Personal Data in order to comply with any legal or regulatory obligation to which it is subject.

Article 5 – Data Collected

When the Data Subject browses the Site, SYCOMORE CORPORATE FINANCE collects and processes certain Personal Data, including:

For the management of contact requests:

Identity data: surname, first name, email address, telephone number, postal address;
Professional data: CV, qualifications;
Data relating to the use of the Site’s features, including Personal Data provided to SYCOMORE CORPORATE FINANCE when You contact it.

For the security, administration and proper functioning of the Site:

Data collected through cookies and other trackers on the Site, such as pages viewed, browser type, operating system, IP address and device information, and Your mobile operating system (OS).

For the management of requests to exercise GDPR rights:

Identity data: title, surname, first name, address, email address, telephone number, date of birth;
Where applicable, a copy of proof of identity;
Data relating to Your request to exercise Your rights.

The above list is not intended to be exhaustive; its main purpose is to inform You of the categories of Data that SYCOMORE CORPORATE FINANCE may process.

Article 6 – Recipients of the Data

Within the limits of their respective responsibilities and for the purposes set out in Article 4 of this Policy, the main persons who may have access to Your Data are:

Service providers responsible for managing, hosting and developing the Site;
Where applicable, authorised staff of Processors;
Supervisory authorities;
Third parties that may place cookies on Your devices where You consent to this;
Where appropriate, the relevant courts, mediators, statutory auditors, lawyers, judicial officers, etc.

SYCOMORE CORPORATE FINANCE may disclose Personal Data to any third party where there is a legal obligation to do so, or where SYCOMORE CORPORATE FINANCE believes in good faith that this is necessary in order to:

Respond to any claim made against it;
Comply with the requirements of judicial and/or administrative authorities;
Enforce any contract to which the Data Subject is a party;
Protect the vital interests of any natural person;
Perform a task carried out in the public interest.

Article 7 – Retention Period of Personal Data

We only keep Your Personal Data for as long as necessary for the purposes pursued, as summarised in the table below:

Purposes	Retention period
Management of contact requests	Personal Data is kept for the time needed to process Your request and is then stored until You withdraw Your consent, or for 3 years after the end of the business relationship, or for 3 years from the Data Subject’s last contact.
Security, administration and proper functioning of the Site	Cookies and other commercial trackers may be placed on Your device for a maximum of 13 months. Personal Data collected through cookies and trackers is kept for 25 months.
Management of requests to exercise GDPR rights	Personal Data is kept for as long as necessary to process the request, then archived for the applicable criminal limitation period (6 years). Where a copy of an identity document is provided, it may be kept for one (1) year after receipt of the request.

Article 8 – Cookies and Other Trackers

SYCOMORE CORPORATE FINANCE uses cookies (small files stored on Your device) on its Site to identify You, remember Your visits, and obtain audience measurements and statistics for the Site, in particular regarding the pages viewed.

Depending on the purposes, Users may accept, refuse or select the placement of certain types of cookies on their devices.

Article 9 – Transfers Outside the European Union

As a rule, we process Your Personal Data within the European Union.

However, given the nature of our business, and subject to informing You in advance, we may transfer Your Personal Data outside the European Union.

In such cases, SYCOMORE CORPORATE FINANCE will inform You of the measures taken to control these transfers and ensure their compliance.

Article 10 – Your Rights

In accordance with the LIL and the GDPR, you have the following rights:

The right to withdraw your consent at any time (Article 7 of the GDPR);
The right of access (Article 15 of the GDPR);
The right to rectify, update and complete your Personal Data (Article 16 of the GDPR);
The right to erasure of Your Personal Data where it is inaccurate, incomplete, ambiguous or out of date, or where its collection, use, disclosure or retention is prohibited (Article 17 of the GDPR);
The right to restriction of processing of your Data (Article 18 of the GDPR);
The right to object to the processing of your Data (Article 21 of the GDPR);
The right to portability of the Personal Data you have provided to us, where it is subject to automated processing based on Your consent or on a contract (Article 20 of the GDPR);
The right not to be subject to a decision based solely on automated processing (Article 22 of the GDPR); SYCOMORE CORPORATE FINANCE does not carry out any such decision-making;
The right to give instructions on what happens to your Personal Data after your death and to choose for SYCOMORE CORPORATE FINANCE to disclose Your Personal Data to a third party you have previously designated (Article 85 of the LIL).

These rights may be exercised by simple request by email to rgpd@sycomore-cf.com or by post to 26 Avenue des Champs Elysées, 75008 PARIS, France.

You may also lodge a complaint with the supervisory authorities, in particular the CNIL (French Data Protection Authority).

Article 11 – Security of Your Personal Data

SYCOMORE CORPORATE FINANCE takes appropriate technical and organisational measures to ensure the security of the Processing carried out and to protect Your Personal Data against destruction, loss, alteration, misuse and unauthorised access.

To this end, the measures in place include, without limitation:

hosting of the Site with a specialised provider, with daily data backups;
regular updates of the Site and its components, and application of security patches as soon as possible in the event of an alert;
remote monitoring of the Site’s operation;
encryption of exchanges between Your browser and the Site (HTTPS protocol);
access to Personal Data restricted to authorised persons only, by means of personal login credentials.