Privacy Policy

Last update: October 2022

The purpose of this Audacia privacy policy (hereinafter referred to as the “Privacy Policy”) is to set out the origin and use of personal data collected and processed by Audacia via the website available at the URL address https://www.audacia.fr and the measures taken by Audacia to protect such personal data to the best of its ability.

IDENTITY OF THE DATA CONTROLLER

AUDACIA, a public limited company with share capital of 594,256.75 euros, headquartered at 58 rue d’Hauteville – 75010 Paris, and registered with the Paris Trade and Companies Register under number 492 471 792, represented by Mr. Charles Beigbeder, in his capacity as Chief Executive Officer (hereinafter referred to as “AUDACIA”), publishes the website available at URL https://www.audacia.fr (hereinafter referred to as the “Website”). AUDACIA is registered with the AMF under approval number GP-09000025.

AUDACIA is a management company that manages an investment fund dedicated to quantum technologies. The purpose of the Website is to provide information about AUDACIA’s activities to any interested party, and to enable AUDACIA’s partners and investors to access their personal space.

In the course of its activities, AUDACIA collects and processes certain personal data from its investors, distributors and contacts who browse and consult the Website (hereinafter referred to as “Users”).

AUDACIA therefore acts as the data controller.

PURPOSE OF THE PRIVACY POLICY

AUDACIA is committed to respecting the privacy and protecting the personal data of Users.

In this regard, AUDACIA (and consequently its employees, agents, partners and subcontractors) undertakes to process Users’ personal data in accordance with the provisions of the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “Regulation”). GDPR ), the French Data Protection Act no. 78-17 of January 6, 1978 (hereinafter referred to as the “Data Protection Act”) and the French Data Protection Act (hereinafter referred to as the “Act”). Law no. 78-17 “) (the GDPR and Law n°78-17 are hereinafter collectively referred to as the ” Regulations applicable to Personal Data “) as well as to the stipulations of the Privacy Policy.

The purpose of the Privacy Policy is to inform Users about the use of their personal data when using the Website. It informs them of the origin and use of the information collected, as well as the rights available to Users in application of the Regulations applicable to Personal Data.

The Privacy Policy is therefore important for Users, who are invited to read it carefully.

MODIFICATION OF THE PRIVACY POLICY

AUDACIA may modify the Privacy Policy in order to take into account changes in applicable regulations concerning Personal Data and any other regulations, as well as changes in its practices concerning the processing of personal data and cookies. AUDACIA will inform Users of any substantial changes.

AUDACIA therefore advises you to ensure that you are always aware of the most recent version of the Privacy Policy whenever you interact with AUDACIA by clicking on the “Privacy Policy” link at the bottom of the Website.

PERSONAL DATA COLLECTION

Personal data is information relating to a specific, identified or identifiable natural person. A natural person is identifiable when he or she can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data or an online identifier.

AUDACIA collects and processes Users’ personal data on its own behalf, such data being communicated in particular by the User when :

access his User account via the Website;
navigates on the Website, through the use of cookies or similar technologies;
fills in a contact form on the Website.

Information for which communication to AUDACIA is mandatory is identified as such on any data collection form made available to Users during their use of the Website. Where communication of information is mandatory, AUDACIA will inform Users of the consequences of their failure to respond.

CATEGORY OF PERSONAL DATA

AUDACIA collects and processes personal data in connection with the provision of the Website:

identification data (e.g. surname, first name(s)) ;
Contact data (e.g. telephone, e-mail address, postal address);
data relating to operations carried out via the Website (e.g. history of documents consulted);
connection data (e.g. technical logs, IP addresses).

PURPOSES AND LEGAL BASIS OF PROCESSING

AUDACIA processes Users’ personal data for the following purposes:

User account access management: Users can access their User account by logging on to the Website. This allows the User to access all AUDACIA services and documentation. In addition, the User may modify his/her personal data via his/her User account (the legal basis for this processing is the execution of the contract concluded between AUDACIA and the User, as well as AUDACIA’s legitimate interest);
communication with a User who fills in a contact form on the Website: data transmitted via the contact form may be checked using an automated service for detecting undesirable comments. It is then processed internally by AUDACIA’s customer service department (the legal basis for this processing is AUDACIA’s legitimate interest);
creation of a file of customers and prospects (the legal basis for this processing is AUDACIA’s legitimate interest);
litigation management (the legal basis for this processing is AUDACIA’s legitimate interest);
to meet a legal requirement or in the context of legal proceedings or litigation (the legal basis for this processing is a legal obligation to which AUDACIA is subject or its legitimate interest);
optimizing the Website for User browsing (the legal basis for this processing is AUDACIA’s legitimate interest);
informing Users of any changes affecting the services offered via the Website (the legal basis for this processing is the performance of the contract concluded between AUDACIA and Users and the legitimate interests of Users);
management of requests to exercise the rights listed below (the legal basis for this processing is a legal obligation to which AUDACIA is subject).

RECIPIENTS OF PERSONAL DATA

The data collected is strictly confidential and intended for the use of AUDACIA.

However, some of the User’s personal data may be transmitted, in a secure and temporary manner, to third parties when this is necessary to enable it to meet the aforementioned purposes.

In this context, the categories of recipients likely to receive certain personal data are as follows:

service providers with whom AUDACIA has contracted to operate and maintain the Website (e.g. Website host);
AUDACIA employees in the IT or customer service departments;
financial, judicial or administrative authorities on request and within the limits of what is authorized by the applicable legislation;
certain regulated professionals such as chartered accountants, statutory auditors and lawyers.

AUDACIA ensures that all of its partners, recipients of Users’ personal data, place the protection of personal data at the heart of their mission, make contractual commitments relating to data protection at least equivalent to the Privacy Policy, and undertake to take all measures to ensure the security and confidentiality of personal data.

USER RIGHTS

In accordance with the regulations applicable to Personal Data, Users have a number of rights in respect of their data, which are detailed in greater detail below:

accès : il permet à l’Utilisateur de demander à AUDACIA de confirmer si elle traite ses données et, le cas échéant, l’informer descaractéristiques du traitement, lui permettre d’y accéder et en obtenir une copie ;
rectification : l’Utilisateur peut demander à AUDACIA de rectifier ou compléter ses données si elles sont incorrectes ou incomplètes ;
effacement : il permet à l’Utilisateur d’obtenir la suppression de ses données à caractère personnel. S’agissant du droit à la suppression des données personnelles de l’Utilisateur, ce dernier ne sera pas applicable dans les cas où le traitement est mis en œuvre pour répondre à une obligation légale ;
limitation : il permet à l’Utilisateur de suspendre le traitement de données à caractère personnel dont il fait l’objet tout en conservant les données traitées ;
opposition au traitement de données: il permet à l’Utilisateur de s’opposer au traitement de ses données à caractère personnel pour des motifs liés à sa situation particulière. Le droit d’opposition est absolu s’agissant du traitement mis en œuvre à des fins de prospection commerciale ;
à la portabilité : il permet à l’Utilisateur que les données à caractère personnel qu’il a fournies lui soient restituées ou, lorsque cela est techniquement possible, soient transférées à un tiers. Les informations demandées par l’Utilisateur lui seront fournies sous une forme électronique, sauf demande expresse contraire ;
retirer son consentement : lorsque la base légale du traitement de données à caractère personnel mis en œuvre est le consentement, il permet à l’Utilisateur de retirer son consentement à tout moment.

The User may exercise his rights by sending either a letter to the attention of the Data Protection Officer, AUDACIA, 58 rue d’Hauteville – 75010 Paris, or an e-mail to rgpd@audacia.fr.

Certain requests to exercise rights, such as the right of access, must be accompanied by a photocopy of the User’s identity document bearing his or her signature so that AUDACIA can verify the User’s identity and specify the address to which the reply should be sent.

A reply will then be sent to the User concerned within one (1) month of receipt of the request.

However, AUDACIA reserves the right to refuse requests that are manifestly unfounded or excessive.

The User may also, if he considers it necessary, lodge a complaint with the French Data Protection Authority (www.cnil.fr).

SHELF LIFE

AUDACIA keeps Users’ personal data in an active database for the periods listed below:

for User account data: AUDACIA retains personal data for the duration of the investor’s or distributor’s account. Accounts are considered inactive after two (2) years without activity. Investors and distributors concerned are notified of this measure by e-mail. The accounts of those who have not reacted within six (6) months are deleted;
connection data: stored for one (1) year;
for data communicated via contact requests: the time required to respond to the request;
for data transmitted in order to exercise a right granted by the applicable Personal Data Regulations: the time required to process the request.

However, at the end of the aforementioned periods, the personal data collected and processed may be archived beyond the periods stipulated (i) in the event of legal proceedings in order to establish the reality of the disputed facts; and/or (ii) for the purposes of investigating, establishing and prosecuting criminal offences, with the sole aim of making such data available to the judicial authorities, where necessary.

Once the time limits set out in the Privacy Policy have elapsed, Users’ personal data will be deleted.

TRANSFER OF PERSONAL DATA

Where AUDACIA is required to communicate Users’ personal data to third parties as described above, this may involve sending information outside the European Economic Area.

When the third party concerned is located outside the European Union, or in a country that does not have adequate regulation within the meaning of the RGPD, AUDACIA frames its relationship with this third party by adopting an appropriate contractual arrangement.

COOKIES AND OTHER TRACKERS

AUDACIA uses cookies on the Website to collect information about how Users use the Website.

Cookies are small text files that are stored in the User’s browser or device by websites, applications, online media and advertisements. Cookies help AUDACIA to remember the User when they access the Website, as well as various information about their previous visits.

In accordance with the regulations applicable to cookies, the User is informed of the purpose of the cookies used and of the means available to him/her to object to them.

AUDACIA uses only so-called “tracers strictly necessary for the provision of the service”, which do not require the User’s prior consent as they are essential for the proper technical functioning and day-to-day administration of the Website.

It is not technically possible to deactivate these tracers from the Website.

The User may, however, oppose the use of cookies, exclusively by configuring his browser. In principle, the User can either activate a private browsing function, or simply prohibit or restrict cookies. However, it is possible that cookies may have been stored on the User’s device before the browser was set. In this case, it is advisable to delete the browsing history, again using the browser settings.

AUDACIA uses the following trackers:

COOKIE NAMES	PURPOSE	THIRD PARTY
gstatic.com	Make sites load faster.	Google https://policies.google.com/privacy
ajax.googleapis.com	Allows connection to the Google API to execute JavaScript code.	Google https://policies.google.com/privacy
fonts.googleapis.com	Connects to the Google API to load fonts.	Google https://policies.google.com/privacy

EMBEDDED CONTENT FROM OTHER WEBSITES

Website articles may include embedded content (e.g. videos, images, articles).

Content integrated from other websites behaves in the same way as if the visitor were visiting that other website.

These websites may collect data on the User, use cookies, embed third-party tracking tools, and track the User’s interactions with these embedded contents if the User has a logged-in account on their website.