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Data protection · GDPR

Privacy Policy

Preamble

FINRARE's commitment
to protecting your data

This privacy policy describes how FINRARE collects, uses, stores and protects the personal data of users of finrare.com, in accordance with the General Data Protection Regulation (GDPR – EU Regulation 2016/679) and applicable French data protection law.

We are committed to ensuring that the collection and processing of your data is carried out in a lawful, fair and transparent manner, in full respect of your privacy.

01

Data controller

The data controller responsible for your personal data is:

Company FINRARE
Legal representative Mr Benjamin GIRARD, Managing Director
Registered office 52 Rue Danton, 92500 Rueil-Malmaison, France
Company registration 838 466 829 R.C.S. Nanterre
Contact contact@finrare.com

02

Personal data collected

FINRARE only collects data that is strictly necessary for the purposes described in this policy. The data collected is as follows:

Contact form First name, last name, business email address, company name, area of interest, message content
Browsing data IP address, browser type, pages visited, session duration (via technical cookies only)

We do not collect any sensitive data within the meaning of Article 9 of the GDPR (racial origin, religious beliefs, health data, etc.).

03

Purposes of processing

Your personal data is processed for the following purposes:

Contact management Processing and following up on your information or introduction requests submitted via the contact form
Business relationship Correspondence in the context of advisory assignments, asset disposals or investment advisory services
Website improvement Anonymised analysis of browsing behaviour to improve website performance and content
Legal obligations Compliance with accounting, tax and regulatory obligations applicable to our business

04

Legal basis for processing

Each data processing activity is based on one of the following legal grounds, in accordance with Article 6 of the GDPR:

Consent When you submit the contact form, you consent to your data being processed to respond to your enquiry
Legitimate interest Website improvement, IT security and professional relationship management
Legal obligation Retention of certain data to comply with accounting and tax obligations

05

Data retention periods

Your personal data is retained for no longer than is necessary for the purpose for which it was collected:

Contact data 3 years from the last contact, unless an ongoing contractual relationship exists
Contractual data 10 years from the end of the contractual relationship (accounting and legal obligations)
Browsing data Maximum 13 months (cookie lifespan)

At the end of these periods, your data is securely deleted or anonymised.

06

Recipients of data

Your personal data is intended exclusively for FINRARE's internal staff authorised to process it for the purposes described above.

FINRARE never sells, rents or transfers your data to third parties for commercial purposes. Your data may however be shared with technical service providers to the extent strictly necessary for the performance of their services (hosting, website maintenance), in compliance with the GDPR and under appropriate data processing agreements.

FINRARE may be required to disclose your data to competent authorities upon judicial or administrative request.

07

International data transfers

Personal data collected by FINRARE is hosted in France (OVH SAS, Roubaix) and processed within the European Union. FINRARE does not transfer your data outside the European Economic Area.

In the event that a transfer outside the EU becomes necessary, FINRARE undertakes to implement the appropriate safeguards provided for under the GDPR (standard contractual clauses, adequacy decisions, etc.).

08

Your rights

In accordance with the GDPR, you have the following rights over your personal data:

Right of access
Obtain confirmation that your data is being processed and receive a copy of it.
Right to rectification
Request the correction of inaccurate or incomplete data.
Right to erasure
Request the deletion of your data under the conditions provided for by the GDPR.
Right to restriction
Request the temporary suspension of the processing of your data.
Right to object
Object to the processing of your data on grounds relating to your particular situation.
Right to portability
Receive your data in a structured, machine-readable format.

To exercise any of these rights, send your request by email to contact@finrare.com, stating your name, surname and the nature of your request. FINRARE undertakes to respond within one month of receiving your request.

If you consider that your rights are not being respected, you have the right to lodge a complaint with the French data protection authority: Commission Nationale de l'Informatique et des Libertés (CNIL) — www.cnil.fr — 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France.

09

Data security

FINRARE implements appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, accidental or unlawful alteration or destruction.

These measures include, in particular, encrypted communications (HTTPS protocol), restricted access to data on a need-to-know basis, and secured hosting infrastructure.

In the event of a data breach likely to result in a risk to your rights and freedoms, FINRARE undertakes to notify the competent authority within the timeframe required by the GDPR, and to inform you where appropriate.

10

Cookie management

A cookie is a small text file placed on your device when you visit a website. finrare.com uses only essential technical cookies necessary for the proper functioning of the site (navigation, security). No third-party advertising or tracking cookies are used.

Technical cookies Necessary for site functionality · Max. 13 months · No consent required
Analytics cookies Not used
Advertising cookies Not used

You can configure your browser to refuse or delete cookies at any time. Refusing cookies does not affect your navigation on finrare.com. For more information on cookie management, visit: cnil.fr.

11

Changes to this policy

FINRARE reserves the right to amend this privacy policy at any time, in particular to reflect any legal, regulatory or technical developments. Any changes will be published on this page with an updated revision date.

We encourage you to review this page regularly to stay informed of the current version.

Last updated: May 2025