What is the purpose of this Policy?

We attach great importance to the protection and confidentiality of your personal data, which represent for us a guarantee of seriousness and trust.

The Data Privacy Policy specifically reflects our commitment to enforce compliance with applicable data protection rules and, in particular, those of the General Data Protection Regulation (“GDPR”).

In particular, the Privacy Policy aims to inform you about how and why we process your data in connection with the services we provide.

Who is this Privacy Policy for?

The Privacy Policy applies to you, regardless of where you live, if you are at least 15 years old, whether you are a customer, applicant for a position with Reach Capital, or visitor to the www.reach-capital.com site.

Why do we process your data?

As part of the services offered, we may need to process your personal data for the following reasons and purposes:

• To browse our website www.reach-capital.com, pay for and benefit from our services and so that we can respond to your requests (e.g., requests for information, complaints, etc.) on the basis of our terms and conditions of sale, our terms and conditions of use, and our legitimate interest in providing you with the best possible service.
• To stay informed of our latest offers and events by email based on our legitimate interest in building customer loyalty and prospecting for potential new customers.
• To follow us and comment on our publications on social networks on the basis of the general terms of use of the social network concerned (e.g. Facebook) and our legitimate interest in having a dedicated page on social networks.
• To apply for a position at Reach Capital based on discussions we have with you during the recruitment process and our legitimate interest in recruiting and selecting candidates.
• To ensure and enhance the security and quality of our services on a day-to-day basis (e.g. statistics, data security, etc.) based on our legal obligations, our terms and conditions and our legitimate interest in ensuring the proper functioning of our services.
• Finally, we may also install “Cookies” on your terminal. For more information on the use of “Cookies”, we invite you to consult our “Cookies Policy”.

Your data is collected directly from you when you log on to our website and use our services.

We undertake to process your data only for the purposes described above.In addition, we guarantee that none of your data will ever be sold to a partner or third party. However, when you voluntarily post content on the pages we publish on social networks, you acknowledge that you are fully responsible for any personal information you may transmit, regardless of the nature and origin of the information provided.

What data do we process and for how long?

We have summarized the categories of personal data we collect and their respective retention periods.

If you wish to obtain further details on the retention periods applicable to your data, you can contact us at: [email protected].

• Professional identification data (e.g. last name, first name, position, company, etc.) and contact information (e.g. professional email address, Linkedin, etc.) kept for the duration of the provision of the service, plus the legal limitation periods, which are generally 5 years.

• Data for commercial prospecting, and marketing purposes (e.g.: email address, etc.) kept for a maximum of 3 years from the last contact we had with you.
• When there is a confusion between the name of your structure and your personal name (e.g.: auto-entrepreneur, VSE, etc.), economic and financial data (e.g.: bank account number, verification code, etc.) kept for the time necessary for the transaction and the management of invoicing and payments, to which are added the legal prescription periods, which are generally from 5 to 10 years.
• Data indicated in the CV and cover letter kept for the duration of the recruitment process and for 2 years from the date of your application.
• Connection data (e.g. logs, IP address, etc.) kept for 1 year.
• Cookies which are generally kept for a maximum of 13 months. For more details on how we use your cookies, you can consult our cookie policy, which can be accessed at any time on our website.

Upon expiration of the retention periods summarized above, we delete all of your personal data to ensure your privacy for future years.

The deletion of your personal data is irreversible and we will no longer be able to communicate them to you after this period. At most, we can only keep anonymous data for statistical purposes.

Please also note that in the event of litigation, we are required to retain all of your data for the duration of the processing of the case even after the expiration of the retention periods described above.

What rights do you have to control the use of your data?

The applicable data protection regulations give you specific rights that you can exercise, at any time and free of charge, to control how we use your data.

• Right of access and copy of your personal data as long as this request is not in contradiction with business secrecy, confidentiality, or the secrecy of correspondence.
• Right to rectify personal data that are incorrect, outdated or incomplete.
• Right to object to the processing of your personal data carried out for commercial prospecting purposes.
• Right to request deletion (“right to be forgotten”) of your personal data that is not essential for the proper functioning of our services.
• The right to restriction of processing your personal data, which allows you to freeze the use of your data in the event of a dispute over the lawfulness of a processing operation.
• The right to give instructions on the fate of your personal data in the event of your death. You can give instructions directly by you or through a trusted third party or a beneficiary.
• The right to your personal data portability which allows you to transfer some of your personal data from one information system to another.

In order for a request to be processed, it must be made directly by you at [email protected]. Any request that is not made in this way cannot be processed.

Requests cannot be made by anyone other than you. Therefore, we may ask you to provide proof of identity if there is any doubt about the identity of the applicant.

We will respond to your request as soon as possible, but no later than three months from receipt of the request, in case the request is technically complex or if we receive many requests at the same time.

Please note that we may always refuse to respond to any excessive or unfounded request, especially if it is repetitive.

Who can access your data?

We will only share your data with persons duly authorized to use it to implement our services. This may include our staff in charge of service implementation, accounting, marketing or even security of our premises.

How do we protect your data?

We implement all technical and organizational means required to guarantee the security of your data on a daily basis and, in particular, to fight against any risk of destruction, loss, alteration, or disclosure of your data that would not be authorized (e.g.: training, access control, password, antivirus, “https”, etc).

Can your data be transferred outside the European Union?

Unless strictly necessary and on an exceptional basis, we never transfer your data outside the European Union and your data is always hosted in European soil. In addition, we make every effort to hire only service providers who host your data within the European Union.

Should our service providers nevertheless transfer your personal data outside the European Union, we take great care to ensure that they implement appropriate safeguards to ensure the confidentiality and protection of your data.

Who can you contact for more information?

Our Data Protection Officer (“DPO”) is always available to explain in more detail how we process your data and to answer your questions on the subject at [email protected].

How can you contact the CNIL?

You may at any time contact the French data protection supervisory authority (the “Commission nationale de l’informatique et des libertés” or “CNIL”) at the following address CNIL Complaints Department, 3 place de Fontenoy – TSA 80751, 75334 Paris Cedex 07 or by telephone at 01.53.73.22.22.

Can the policy be changed?

We may change our privacy policy at any time to accommodate new legal requirements as well as new processing that we may implement in the future. You will, of course, be notified of any changes to this policy.

Published on 24/11/2022

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