Privacy Policy

 

☰ Personal Data Management

We undertakes:

  • to limit collection of personal data to those strictly useful for the sole purpose of the proper performance of the Services and for professional, commercial, business, projects relationship management in the framework of support, service request, request for quotation, subscriptions, online registration, payments, administrative and legal needs, quality improvement, human resources management and still for respect its own legal obligations, especially financial regulation obligations : due diligence, anti-money laundering, anti-terrorism financing, Fatca, CRS, fiscal regulation, data exchange and what applies in that matter
  • do not use the data collected for purposes other than those for which they are collected
  • not to collect and use the data for profiling purposes in order to carry out mass marketing, advertising campaigns or personally targeting the individuals whose information we hold
  • not sell or transfer the information to third parties other than related companies or group members
  • keep personal data for a limited and proportionate period. For example, the data processed for the purpose of managing the relationship between the investor and us (surname, first name, postal address, e-mail, etc.) are kept by the company during the entire duration of the commitment and then following period still for respect our own legal obligations. At the end of this time, they are deleted on all media and backups
  • to treat the personal data of all people in the same way, regardless of the nature, type, level and purpose of the relationship.

 

☰ Information - consent

Information
Whenever we collects or receives personal data, the natural person concerned will be notified with a reminder of his rights and, where appropriate, a request for his consent.

Consent
Most often, and especially when required by regulation (i.e. EU GDPR), an appropriate consent will be requested.

We will also ask you periodically or occasionally to check your data and ask you for update and renew your consent. For example, some time before a deadline or after a period of total inactivity.

 

☰ Rights of access, modification, restrictions, erasure

Access rights
Default common option is done by the link (or sending an e-mail) to contact@vivalys-patrimonia.com with Subject = Personal Data Request

As a investor, customer, supplier, partner, project member, you or some of your employees, maintain regular exchanges with us. You then become a personal login Id for direct and permanent online access to your personal data and, case by case based, other information through our Customer Service Portal. There you have the direct view on your data and more stored in our database. Also you can submit your requests and communicate online directly in a private, secured way with us, inside our IT system.
On a case-by-case basis, at our sole discretion, upon request, you can obtain this access.

In case of a close relationship and if it brings added value, efficiency, at our sole discretion, you and some of your employees can have an IT system User access.

 

Modification rights
Depending on what is concerned, and the access rights available to the natural person, it may either submit a request for modification, express restrictions, or itself directly made certain changes.

 

Erasure rights
Erasure (right to be forget) can be requested at any time. Perfectly legitimate and without having to provide reasons or justification, this request is however the subject of a specific procedure with manual processing because certain information are essential to the provision of services that the natural person wants to continue to benefit and some informations must be retained by us to fulfill its own legal obligations.

To avoid fake requests you will have to confirm your request and to pass a particular identification process. We also may ask you to provide some informations and/or documents.

The full process will be tracked and exchanges recorded. You will become event/action drived automatic notification as follow-up until the final confirmation of the erasure.

When erasure is allowed also in relation to legal obligations for us, ALL the data and informations concerned are deleted.

 

☰ Rights of transfer and portability

Transfer rights
In accordance with the applicable regulations, we will accede to any request for transfer that will be submitted to it within the means available: either at the level of the Customer Services Portal or the IT system User access, otherwise by the link (or sending an e-mail) to contact@vivalys-patrimonia.com with Subject = Personal Data Transfer Request
To avoid fake requests, process will be manual and the same as for Erasure Rights here above item

Portability
We provide data to be transfered in a portable format: text (.csv or .txt), MS Excel (.xls or xlsx), opendoc xml (.odt - .ods).

Case of volumes or on particular request, transfer might be done using or S.H.C. platform and other particular data format can be done (subject to conditions and special quotation).

 

☰ Data breach & right to know

In case of detection of a data breach, or serious potential data breach suspicion, we undertake to communicate as soon as possible and within 72 hours following the confirmation by an analysis of the facts (EU GDPR rule)