Privacy Policy

Please note that this is an automatic translation of our original privacy policy which can be found here.

At FINARY, the protection of your personal data is a priority.

When you use the finary.com website (hereinafter the "Site") and/or the Finary application (hereinafter the "Application"), we are required to collect personal data about you.

The purpose of this policy is to inform you about how we process such data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "RGPD").

1. Who is the data controller?

The data controller is FINARY, a simplified joint stock company, registered in the Bobigny Trade and Companies Register under number 892 357 724 and whose registered office is located at 95 avenue du Président Wilson 93100 Montreuil (hereinafter "We").

2. What data do we collect?

Personal data is data that allows an individual to be identified directly or by cross-referencing with other data.

We collect data that falls into the following categories:

Identification data (in particular your surname, first name, email address, telephone number, your mobile identifier (AAID or IDFA));
Data relating to your real estate and other assets such as cryptocurrencies, shares in start-ups, etc.
Connection data (including your IP address, logs);
Economic and financial data (including your bank account details, credit card details);
Data for the purpose of verifying your identity;
Data relating to your professional life.

Mandatory data are indicated when you provide us with your data. They are marked with an asterisk and are necessary to provide you with our services.

3. On what legal grounds, for what purposes and for how long do we keep your personal data?

Goals	Legal basis	Retention periods
Providing you with our services (monitoring and managing your assets, making investment recommendations)	Fulfilment of a contract you have entered into	Your data is kept for the duration of your account. If your account is inactive for 2 years, your personal data will be deleted. In addition, your data may be archived for evidential purposes for a period of 5 years.
Fulfill your order, perform customer management operations related to contracts, orders, invoices, referral programs and customer relationship management	Fulfilment of a contract you have entered into	Personal data is kept for the duration of the contractual relationship. In addition, your data is archived for evidential purposes for a period of 5 years. Your credit card data is kept by our payment service providers until your subscription is terminated. The data relating to your bank cards may be kept in an intermediate archive for a period of thirteen (13) months following the date of debit, for the purpose of proof in the event of a possible challenge to the transaction. This period may be extended to fifteen (15) months in order to take into account the possibility of using deferred payment cards.
Build up a file of customers and prospects	Our legitimate interest in developing and promoting our business	For customers: data is kept for the duration of the commercial relationship. For prospects: the data is kept for a period of 3 years from your last contact.
Send newsletters, solicitations and promotional messages	For customers: our legitimate interest in building customer loyalty and keeping customers informed of our latest news. For prospects: your consent	The data is kept for 3 years after your last contact
Developing statistics	Our legitimate interest in improving our services	Personal data is kept for 2 years.
Delivering personalised advertising	Your consent	Personal data is kept for 90 days from the date of collection.
Responding to your requests for information	Our legitimate interest in responding to your requests	The data is kept for the time necessary to process your request for information and deleted once the request for information has been processed.
To comply with legal obligations applicable to our business (including verifying your identity as part of our legal and regulatory obligations for fraud prevention purposes)	Comply with our legal and regulatory obligations	For invoices: invoices are archived for 10 years. For identity verification data, the data is kept for 2 years.
Managing requests to exercise rights	Comply with our legal and regulatory obligations	If we ask you for proof of identity, we will only keep it for as long as it takes to verify your identity. Once the verification is complete, the proof is deleted. If you exercise your right to object to canvassing: we keep this information for 3 years.

4. Who are the recipients of your data?

Your personal data will be made available to

(i) The staff of our company;

(ii) Our subcontractors: hosting service provider, chat tool, platform analysis and administration service provider, bug management service provider, newsletter sending service provider, our product launch service provider, competitions, our payment service providers, audience measurement service provider;

(iii) The service providers that we use to deliver personalised advertising (Facebook Ads or Apple Search Ads);

(iv) Our bank account aggregation partners: Budget Insight in Europe and Plaid in the US. The latter will process data in accordance with their privacy policy. You can view Budget Insight's privacy policy here and Plaid's here.

(v) Your financial advisors for the purpose of assisting you in your financial management where you have entered into a contract with them. They will act as independent data controllers and will apply their respective privacy policies;

(vi) Where applicable: public and private bodies, exclusively to meet our legal obligations.

Within the framework of the sponsorship, the sponsors are informed that their first and last names will be disclosed to the sponsored party in order to inform him/her of the identity of his/her sponsor. The sponsored parties are informed that their email addresses will be disclosed to the associated sponsor in a partially hidden manner, for the purpose of informing the sponsor of the completion or not of the sponsorship.

5. Is your data likely to be transferred outside the European Union?

Your data is kept and stored for the duration of the processing on the servers of HEROKU and Digital Ocean, both located in the Netherlands.

In the context of the tools we use (see article on recipients regarding our subcontractors), your data may be transferred outside the European Union. The transfer of your data in this context is secured by means of the following tools

either the data is transferred to a country that has been judged to offer an adequate level of protection by a decision of the European Commission;
or we have entered into a specific contract with our subcontractors for the transfer of your data outside the European Union, based on the standard contractual clauses approved by the European Commission;
or we have recourse to the appropriate safeguards provided for by the applicable regulations.

6. What rights do you have in relation to your data?

You have the following rights with regard to your personal data:

Right to information: this is precisely the reason why we have drawn up this policy. This right is provided for in Articles 13 and 14 of the GDPR.
Right of access: you have the right to access all your personal data at any time, in accordance with Article 15 of the GDPR.
Right of rectification: you have the right to rectify your inaccurate, incomplete or outdated personal data at any time in accordance with Article 16 of the GDPR
Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
Right to erasure: you have the right to request that your personal data be erased, and to prohibit any future collection on the grounds set out in Article 17 of the GDPR
Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable texts. (Article 77 of the GDPR)
Right to define directives relating to the conservation, deletion and communication of your personal data after your death, in accordance with Article 40-1 of the French Data Protection Act.
Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to request its transfer to the recipient of your choice.
Right to object: Under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Please note, however, that we may continue to process your personal data despite your objection on legitimate grounds or for the defense of legal claims.

You can exercise these rights by writing to us using the contact details below. We may ask you to provide additional information or documents to prove your identity.

7. Contact point for personal data

Contact email: [email protected]

Contact address: Finary SAS, 95 avenue du Président Wilson, 93100 Montreuil

8. Changes

We may modify this policy at any time, in particular to comply with any regulatory, legal, editorial or technical developments. These changes will apply as of the date the modified version comes into effect. You are therefore invited to consult the latest version of this policy regularly. Nevertheless, we will keep you informed of any significant changes to this privacy policy.

Effective date: 03/01/2022