Data privacy

OREIMA has adopted rules and principles in respect of data protection in the present Personal Data Privacy Notice available on its website Oreima.fr.
The processing of personal data refers to any operation in relation to such data, especially the obtaining, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, deletion or destruction of personal data;
The nature of the data, the purposes of the processing are detailed in this document.
This Data Protection Notice provides OREIMA client with detailed information relating to the protection of its personal data by OREIMA.

OREIMA is responsible for collecting and processing OREIMA client’s personal data in relation to its activities. All OREIMA entities (meaning its mothers companies, its sisters companies or its subsidiaries) comply with Oreima’s corporate rules and in particular this notice, subject to compliance with local regulations.
Oreima entities are all based in the European community
The purpose of this Data Protection Notice is to let OREIMA client know which personal data Oreima uses, how and why Oreima may share such data, how long OREIMA keeps it, what OREIMA client rights are and how OREIMA client can exercise them.

Further information may be provided where necessary when OREIMA client apply for, subscribe or use a specific product or service.

1. PERSONAL DATA USED

OREIMA collects and uses OREIMA client’s personal data to the extent necessary in the framework of its activities and to achieve a high standard of personalised products and services.
OREIMA may collect various types of personal data about OREIMA client, including:

• identification information (e.g. name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, IP address);
• contact information (e.g. postal address and e-mail address, phone number);
• family situation (e.g. marital status, number of children);
• Employment information (employment, employer’s name);
• banking, financial and transactional data (e.g. bank account details, credit card number, money transfers);
• client relationship

OREIMA never asks for personal data described as “sensitive” for example related with racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data or data concerning sex orientation.
OREIMA may find data in relation with OREIMA client or OREIMA client’s organization in diverse databases for example:

• publications/databases made available by official authorities (e.g. the official journal);
• websites/social media pages containing information made public by OREIMA client
• databases made publicly available by third parties.

2. SPECIFIC CASES OF PERSONAL DATA COLLECTION, INCLUDING INDIRECT COLLECTION

In certain circumstances, OREIMA may collect and use personal data of individuals with whom OREIMA has, could have, or used to have a direct relationship such as individual prospects.
OREIMA may also collect information about OREIMA clients whereas OREIMA clients have not direct relationship, for instance when OREIMA client’s employer provide with information about it or OREIMA client’s contact details are provided by one client if OREIMA client are for example:

• Family members;
• Legal representatives (power of attorney);
• Company shareholders;
• Representatives of a legal entity (which may be a client or a vendor);

3. RATIONALE OF OREIMA FOR USING OREIMA CLIENT’S PERSONAL DATA

Oreima uses personal data:
a. To comply with its legal and regulatory obligations

• KYC obligations regarding regulation
• security measures to prevent abuse and fraud;
• prevention of money-laundering and financing of terrorism
• reply to an official request from a duly authorised public or judicial authority.

b. To perform a contract with an OREIMA client or to take steps at OREIMA client request before entering into a contract

OREIMA uses OREIMA client’s personal data to enter into and perform its contracts, including to provide OREIMA client with information regarding products and services and assist OREIMA client and answer its requests, evaluate if OREIMA can offer a product or service and under which conditions;

c. To fulfill its legitimate interest
OREIMA uses OREIMA client’s personal data in order to deploy and develop its products or services, to improve its risk management and potentially as the case may be to defend its legal rights.

4. SHARING PERSONAL DATA

In order to fulfill the aforementioned purposes, OREIMA may disclose OREIMA client’s personal data to:

• Service providers which perform services on OREIMA or Oreima entity behalf;
• Independent agents, intermediaries or brokers banking and commercial partners, with which OREIMA has regular relationship;
• Financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain regulated professionals such as lawyers, notaries or auditors.

5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA

In case of international transfers originating from the European Economic Area (EEA), where the European Commission has recognized a non-EEA country as providing an adequate level of data protection, OREIMA client’s personal data may be transferred on this basis.
For transfers to non-EEA countries whose level of protection has not been recognized by the European Commission, OREIMA will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform the contract with OREIMA client such as when making an international payment) or implement one of the following safeguards to ensure the protection of OREIMA client’s personal data as standard contractual clauses approved by the European Commission;
To obtain a copy of these safeguards or details on where they are available, OREIMA client can send a written request as set out in Section 9.

6. STORAGE OF PERSONAL DATA

Oreima shall store the personal data for a period no longer than is necessary for the purpose for which they are obtained and processed.
For individual prospects, information will be kept for 2 years.

7. RIGHTS TO ACCESS TO AND RECTIFY DATA

In accordance with applicable regulations, OREIMA client has the following rights:

• To access: OREIMA client can obtain information relating to the processing of its personal data, and a copy of such personal data.
• To rectify: where OREIMA client consider that its personal data are inaccurate or incomplete, OREIMA client can require that such personal data be modified accordingly.
• To erase: OREIMA client can require the deletion of its personal data, to the extent permitted by law.
• To restrict: OREIMA client can request the restriction of the processing of its personal data.
• To object: OREIMA client can object to the processing of its personal data. OREIMA client have the absolute right to object to the processing of its personal data for direct marketing purposes.
• To withdraw its consent: where OREIMA client have given its consent for the processing of its personal data, OREIMA client have the right to withdraw its consent at any time.
• To data portability: where legally applicable, OREIMA client has the right to have the personal data provided to Oreima to be returned, or where technically feasible, transferred to a third party.

If OREIMA client wishes to exercise the rights listed above, Oreima client may send a letter to the following address:
Oreima
22 Place de la Madeleine
75008 Paris, France.
Please include a scan/copy of identity card for identification purpose.
In accordance with applicable regulation, in addition to the rights above, OREIMA client are also entitled to lodge a complaint with the competent supervisory authority.

8. DATA PROTECTION NOTICE UPDATE

In a world of constant technological changes, OREIMA may need to regularly update this Data Protection Notice.
OREIMA invites OREIMA client to review the latest version of this notice online and OREIMA will inform OREIMA client of any material changes through OREIMA’s website or through other usual communication channels used by OREIMA.

9. CONTACT

If OREIMA client has any questions relating to the use of its personal data under this Data Protection Notice, he may contact OREIMA’s data protection correspondent:
OREIMA
General Secretary
22 Place de la Madeleine
75008 Paris, France
Or
dataprivacycontact@oreima.fr

who will investigate OREIMA its query.