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PRIVACY POLICY

 

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to natural persons whose personal data is processed by CGPH SAS, with its registered office at 6 Madeleine, 6 Place de la Madeleine, 75008 Paris (hereinafter referred to as "CGPH").

For any questions or complaints regarding this Privacy Policy, you may contact us at complaints@cgph.info.

CGPH complies with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (GDPR), and ensures the confidentiality and security of your personal data.

References to “we” or “us” in this Privacy Policy refer to CGPH and its group companies. References to “you” or “your” refer to clients, prospective clients, affiliates, agents, beneficial owners, and other representatives.

2. CATEGORIES OF PERSONAL DATA

CGPH may collect and process the following categories of personal data:

  • Personal Identification Details: Name, civil status, identity documents, nationality, place and date of birth, signature.

  • Professional Information: Email address, phone number, postal address, job title.

  • Legal and Corporate Data: Information related to power of attorney, board membership, or representation of corporate clients.

  • Special Categories of Data: Information collected for compliance purposes, such as politically exposed person (PEP) status, beneficial owner information, certificates of incorporation, and publicly available records (e.g., news articles).

3. LEGAL BASIS FOR PROCESSING PERSONAL DATA

CGPH processes your personal data for the following purposes and on the following legal bases:

  • Contractual Obligations: To provide agreed-upon services (e.g., client management, conflict checks).

  • Legitimate Interests: To enhance our services, respond to inquiries, create anonymous statistics, assess financial capabilities, or support internal platforms (e.g., whistleblowing tools).

  • Legal and Regulatory Compliance: To conduct due diligence, comply with international sanctions, handle regulatory requests, and maintain insider lists.

  • Consent for Marketing Purposes: We may use your personal data for marketing purposes, such as sending promotional emails. By accepting this Privacy Policy, you agree to receive such communications. You may withdraw your consent at any time by contacting us at complaints@cgph.info.

4. DATA RETENTION POLICY

Your personal data is retained only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws:

  • Accounting Data: Up to 10 years after the end of the contractual relationship.

  • KYC and Supporting Documents: Up to 10 years after the relationship ends.

  • Video Surveillance Data: Stored for up to 1 month from the recording date.

  • Whistleblowing Reports: Stored for up to 2 months after analysis or until the resolution of administrative or judicial proceedings.

5. DATA SHARING WITHIN THE CGPH GROUP AND THIRD PARTIES

Your personal data may be shared within the CGPH Group to provide you with a seamless experience and access to the group’s full range of services.

We may also share your data with trusted third-party providers, including but not limited to:

  • Marketing Platforms: Google, Google Analytics, Facebook, Mailchimp.

  • Payment Platforms: PayPal, Stripe.

  • Customer Relationship Management: HubSpot (secured by two-factor authentication).

These third parties process data on our behalf under strict confidentiality and data protection agreements. We do not transfer your personal data outside of the European Economic Area (EEA).

6. DATA SECURITY MEASURES

We take data security seriously and have implemented reasonable measures to ensure the safety of your personal data. This includes:

  • Two-Factor Authentication: We use HubSpot with two-factor authentication to protect your data.

  • Access Controls: Access to personal data is limited to authorized personnel only, and all data is handled in a secure manner to prevent unauthorized access, alteration, disclosure, or destruction.

7. DATA SUBJECTS’ RIGHTS

You have the following rights regarding your personal data:

  • Access: Request a copy of the personal data we hold about you.

  • Rectification: Request corrections to inaccurate or incomplete data.

  • Erasure: Request deletion of data, where legally applicable.

  • Restriction: Request limitations on how your data is processed.

  • Portability: Receive your data in a structured format or request its transfer to another entity.

  • Objection: Object to data processing for direct marketing purposes, including profiling related to such marketing.

  • Post-Mortem Directives: Provide instructions on the handling of your data after your death.

To exercise these rights, please contact us at complaints@cgph.info. We may request additional information to verify your identity before processing your request.

8. DATA PROCESSING FOR MARKETING PURPOSES

CGPH uses your personal data for email marketing campaigns and analytics, including:

  • Sending newsletters, updates, and promotional offers.

  • Personalizing marketing content based on preferences or behavior.

  • Profiling: We may use profiling techniques to better understand your interests and to send you relevant content.

You can opt out of marketing communications at any time by clicking the "unsubscribe" link in our emails or contacting us at complaints@cgph.info.

9. AMENDMENTS TO THIS PRIVACY POLICY

We may amend this Privacy Policy to reflect updates to our practices or legal requirements. The revised version will indicate the effective date and will be published on our website.

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