PRIVACY POLICY
Date of last update: 06/18/2021
INTRODUCTION
Molitor Partners (hereinafter “Molitor Partners”) publishes and administers the site
www.molitor-partners.com (the “Site”).
This Confidentiality Chart specifies the conditions under which Molitor Partners collects and
processes the personal data collected on this Site, in accordance with the regulations in force in
France as set out in Law No. 78-17 of 6 January 1978, known as the “Informatique et Libertés”
law and EU Regulation 2016/679 of April 27, 2016 on the protection of personal data
(hereinafter “GDPR”).
In particular, it is intended to inform people browsing the Site or using the services offered on
it:
- The way in which Molitor Partners collects, uses and shares the personal data that Molitor
Partners collects,
- As part of the provision of its services,
- Information, likely to include personal data, that Molitor Partners collects , as part of your
navigation.
This Confidentiality Chart is accessible:
- In the footer of each page of the Site;
- Via a clickable link under the data collection and consent collection forms;
- By footer of newsletters and offers that we send to you by email.
Any modification or update of this Confidentiality Charter will be duly brought to the attention
of Users registered on the Site.
PROCESSING OF PERSONAL DATA COLLECTED DIRECTLY FROM THE
MEMBER AS PART OF THE PROVISION OF ITS SERVICES
1. Definitions
The term "General Conditions" refers to our General Conditions of Use, accessible on our
website. These govern the use of the Site and the subscription to our Services and form the
contract between us and you.
The term "Personal Data" means any information relating to an identified natural person or
who can be identified, directly or indirectly, by reference to an identification number or to one
or more elements specific to him.
The term "Expertise" designates a web page edited by Molitor Partners and made available
exclusively to Users to whom the link is sent in the form of a hypertext link and on which a
presentation of the Service Providers and their areas of expertise appears. and any other public
information that does not constitute a promotion or marketing of a financial product. Their
content is reserved exclusively for professional or qualified investors within the meaning of the
article as defined in articles D411-1 to D411-4 of the Monetary and Financial Code.
The term "User" refers to any person accessing the Site or registered on the Site and therefore
having an account on it.
The term “Profile” designates the page of the Site allowing each User to manage their Personal
Data. The more comprehensive your Profile, the more you will be able to benefit from the
Services provided on the Site.
The term "Services" refers to the services provided by Molitor Partners via the Site as described
in our General Conditions.
The term "Site" refers to the website accessible at the address www.molitor-partners.com
2. Who is responsible for processing your Personal Data?
The data controller is Molitor Partners, a French “Société Anonyme” company with a share
capital of € 2,000 registered in the Nanterre Trade and Companies Register under number 093
025 765, whose registered office is at 45 Rue Gambetta Boulogne-Billancourt, and represented
by Mr. Sébastien MASSON, its Chairman.
Members may at any time contact the Personal Data Referent of Molitor Partners, Mr. Sébastien
Masson, about all questions relating to the processing of their Personal Data and the exercise
of their rights as described in point 9 below. -after, at the following address:
themolitorteam@molitor-partners.com
3. What Personal Data do we collect?
3.1. Personal data collected
Molitor Partners provides Users with free access to Expertise from previously referenced
Service Providers. As part of this free access, the User consents prior to this access to the
collection by Molitor Partners of the following Personal Data concerning him: Last name, First
name, e-mail address, certificate that the User is over 18 years of age and is a qualified investor.
If the User wishes to benefit from all the features of the Site as well as the Services of Molitor
Partners, the User must register on the Site. In this case, Molitor Partners is required to collect
the following Personal Data concerning:
(i) Identification data: Account creation (mandatory): Title, Last name, First name, E-mail
address, Password, Date of birth.
(ii) Connection data: IP address, Browser type and version, Information system
(iii) Usage data: History of the pages of the site visited, date and time of visit, time spent on the
pages.
You agree to provide up-to-date and valid Personal Data and guarantee that you will not make
any false statements or provide any erroneous information.
3.2. Mandatory and optional nature of the Personal Data collected
3.2.1. Mandatory data
When accessing the publication of an Expertise, you are invited to provide the following
information: certification that the User is well over 18 years of age and that he is a qualified
investor.
When registering and creating your Profile on our Site, you are invited to provide the following
information: Title, Last Name, First Name, Email address, Password, Date of birth.
This Personal Data must be provided to us insofar as it is strictly necessary for your access to
our Services.
The mandatory nature of the information requested is indicated to you during collection. Failure
to provide such Data will prevent you from accessing the Services.
3.2.2. Optional data
The other Personal Data collected is optional. You are therefore free to inform them or not.
However, they allow us to personalize the Services we offer to you and greatly improve your
browsing experience on the Site.
3.3. Data of minors
The Site is not intended to collect Personal Data from minors. The User declares to be over 18
years of age when registering, as specified in the General Conditions.
4. How is your Personal Data collected?
Molitor Partners collects your Personal Data when you provide the following documents:
Form for access to an Expertise sent to the User in the form of a hypertext link;
Registration form on the Site; and
Newsletter subscription form.
5. For what purposes are your Personal Data collected and under what legal basis?
Your Personal Data is collected and processed to fulfill the purposes and by virtue of the legal
bases described below.
5.1. Management of your access to published Expertise and your registration on the Site.
Access to Expertise
The publication of content on the Site and in particular free access to Expertise through a
hypertext link is strictly personal and limited to professional Users selected by Molitor Partners.
Your Personal Data collected prior to access to this content, through the various forms is thus
intended to ensure your identity and also to obtain your agreement on the possibility for Molitor
Partners to continue to contact you subsequently by e-mail in order to offer you its Services
(including access to the publication of new Expertise or to registration on the Site).
The collection of your Personal Data in this context is based on your express and specific
consent.
You have the option to withdraw your consent at any time, (i) by clicking on the unsubscribe
link at the bottom of each of our emails, or (ii) by sending an email to the following address:
themolitorteam@molitor-partners.com
Registration on the Site
The Personal Data collected during registration on the Site by a User is intended to allow the
creation of your member account on the Site, to verify the validity and authenticity of your
identifiers and to allow you to use our Services such as described in our General Conditions.
The collection of your Personal Data in this context is therefore based on the execution of our
General Conditions, which you must read and accept in order to be able to register and access
our Services.
The collection of your Personal Data in this context is based on your express and specific
consent.
You have the option to withdraw your consent at any time, (i) by clicking on the unsubscribe
link at the bottom of each of our emails, or (ii) by sending an email to the following address:
themolitorteam@molitor-partners.com
Molitor Partners newsletter
You can subscribe freely to our newsletter.
The collection of your Personal Data in this context is based on your express and specific
consent.
You have the option to withdraw your consent at any time, (i) by clicking on the unsubscribe
link at the bottom of each of our emails, or (ii) by sending an email to the following address:
themolitorteam@molitor-partners.com
7. Who has access to your personal data?
The Personal Data collected by Molitor Partners are intended only for persons duly authorized
to process Personal Data within Molitor Partners, namely, and depending on the nature of the
processing and the category of Personal Data concerned, the legal representatives of Molitor
Partners and its employees responsible for IT and web development, marketing and sales.
8. How long are your personal data kept by Molitor Partners?
Molitor Partners keeps your personal data, in a form that allows you to be identified, on an
active basis for the time strictly necessary to fulfill the purposes for which they are collected
and processed, namely:
Member data: They are kept for the duration of your Member account and until it is
deleted. A Member account inactive for two years will be deleted, after sending the
Member an alert that has remained unanswered for one week.
Data relating to access to Expertise and to the newsletter: Regarding your consent to
receive new publications of Expertise or our newsletter and your email address provided
as such, we keep them for 3 years from your date. registration or the last contact from
you (unless you unsubscribe, in which case your email address will be deleted
immediately).
Your Personal Data may also be archived involving supervised, limited and justified access,
the time necessary to allow Molitor Partners to assert a legal claim, if necessary, before being
definitively deleted at the end of 2 years.
9. How does Molitor Partners ensure the security and confidentiality of your Personal
Data?
Molitor Partners undertakes to process your Personal Data in a manner:
- Lawful,
- Fair,
- Transparent,
- Proportionate,
- Relevant,
- Within the strict framework of the purposes pursued and announced,
- For the duration necessary for the treatments implemented,
- In a secure way.
Molitor Partners implements and updates the appropriate technical and organizational measures
to ensure the security and confidentiality of your Personal Data by preventing it from being
distorted, damaged or communicated to unauthorized third parties.
10. What are your rights over your Personal Data?
It is possible for you, on simple written request sent to the following address:
themolitorteam@molitor-partners.com to access the Personal Data concerning you, to request
their rectification or limitation, their erasure or their portability, or to require no longer appear
in the Molitor Partners database.
Under the right of access, you are authorized, in accordance with Article 15 of the GDPR, to
question Molitor Partners in order to obtain confirmation that your Personal Data is or is no
longer being processed as well as the communication of information relating to the processing
(in particular its purposes, the categories of Personal Data processed and the recipients to whom
the Personal Data are communicated, the retention period of the Data or the criteria used to
determine this period, your rights over the Data personal data and the right to lodge a complaint
with a supervisory authority).
In accordance with Article 16 of the GDPR, the right of rectification gives you the right to
require Molitor Partners to rectify, complete or update Personal Data concerning you when it
is inaccurate, incomplete, equivocal or out of date.
Under the conditions provided for in Article 17 of the GDPR, you can also request the erasure
of Personal Data concerning you.
You can also request that the processing of your personal data be limited under the conditions
of Article 18 of the GDPR, i.e. that your personal data be kept only for the purposes of:
Checking the accuracy Personal Data which is the subject of a dispute,
To serve you in the context of the establishment, exercise or defense of your legal rights
and this although Molitor Partners no longer uses it ,
Check whether the legitimate reasons pursued by Molitor Partners prevail over yours in
the event that you oppose the processing based on the legitimate interest of Molitor
Partners,
Satisfy your request to limit the use of your data - rather that an erasure - in the event
that the processing of your data is unlawful.
By virtue of your right to portability and in the circumstances provided for in Article 20 of the
GDPR, you can retrieve from Molitor Partners the Personal Data that you have provided to it,
in a structured, commonly used and machine-readable format, at for the purpose of transmitting
them to another controller.
In accordance with Article 21 of the GDPR, you have the possibility to object, at any time, to
the processing of your Personal Data for commercial prospecting purposes.
To exercise your rights of access, rectification, erasure, limitation, portability and opposition
referred to above, all you have to do is send your request, as desired:
- By email to the following address: themolitorteam@molitor-partners.com
- By post to the following address:
Molitor Partners 45 Rue Gambetta - Boulogne-Billancourt.
You can also withdraw your consent and unsubscribe at any time: from our newsletter (i) by
clicking on the unsubscribe link at the bottom of each e-mail, (ii) by sending an e-mail to the
following address: themolitorteam@molitor-partners.com, (iii) or by setting up your Profile.
Molitor Partners will provide the User who exercises one of these rights with information on
the measures taken, as soon as possible and in any event within one (1) month from receipt of
the request. . This period may be extended by two (2) months, given the complexity and number
of requests.
If Molitor Partners does not respond to the request, it will inform the User as soon as possible,
and at the latest within one (1) month from receipt of his request and will indicate the reasons
for his inaction and the possibility of lodging a complaint with the CNIL and of filing a judicial
appeal.
These rights are exercised free of charge. However, in the event of a manifestly unfounded or
excessive request, in particular in view of their repetitive nature, Molitor Partners reserves the
right (i) to require the payment of fees taking into account administrative costs, or (ii) to refuse
to give Following the request.
11. What happens in the event of a breach of your Personal Data?
In the event of a violation of Personal Data, Molitor Partners notifies the violation to the CNIL
as soon as possible, and, if possible seventy-two (72) hours at the latest after becoming aware
of it, unless the violation in question is not likely to create a risk for the rights and freedoms of
Members.
When a Personal Data violation is likely to generate a high risk for the rights and freedoms of
a Member, Molitor Partners informs the Member, in clear and precise terms, as soon as possible,
subject to the exceptions provided for in Article 34 of the GDPR.
Without prejudice to any other administrative or judicial remedy, the User who considers that
the processing of his Personal Data constitutes a violation of the provisions of the legislation in
force may lodge a complaint with the CNIL.
12. Special categories of data
12.1. Adults
It is recalled that the Site is intended exclusively for adults, as Molitor Partners is not intended
to collect Personal Data from minors.
12.2. Sensitive data
Molitor Partners is also not intended to collect so-called sensitive information such as racial or
ethnic origin, sexual orientation, state of health, political opinions, religious or philosophical
convictions or trade union membership, or genetic or biometric data.
Consequently, the User will refrain from sharing on the Site any sensitive data concerning
himself or concerning third parties. Any sharing by the User of sensitive data is done without
the knowledge of Molitor Partners, which undertakes, as soon as it is notified, to delete them
or make their access impossible.
13. Who should you ask your questions to?
For any questions concerning the processing of their Personal Data and the exercise of their
rights, Members can contact our Personal Data Referent, Mr. Sébastien Masson at the following
e-mail address: themolitorteam@molitor-partners.com
