SEVEN WEALTH MANAGEMENT attaches great importance to privacy and protecting your personal data. SEVEN WEALTH MANAGEMENT is subject to applicable data protection rules, in particular General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (https://www.cnil.fr/fr/reglement-europeen-protection-donnees) and its national implementing measures, on a subsidiary basis. This document reflects and describes our policy on the matter, and describes the terms on which SEVEN WEALTH MANAGEMENT, as data controller, collects and uses your personal data in accordance with the company’s data protection principles and the means that you have to manage this use and exercise your rights.
Personal data: any information about an identified or identifiable natural person (e.g. : name, address, date of birth, contract references, telephone number, photograph, IP address, etc.).
Processing: any operation or set of operations which is performed upon personal data, whether or not by automatic means: collection, recording, organisation, storage, alteration, alignment, retrieval, consultation, extraction, use, or otherwise making available, joining, combination, blocking, erasure or destruction of such personal data.
Seven Capital Management Authorised by the
AMF: N° GP06000045 / CSSF SICAV regulated in Luxembourg
39 Rue Marbeuf
75008 Paris – France
+33 1 42 33 04 50
Identity and contact details of the data controller at SEVEN WEALTH MANAGEMENT: JOHANN SCHWIMANN
The personal data collected and processed by SEVEN WEALTH MANAGEMENT is used in accordance with the data minimisation principle, limiting the collection of personal data to the purposes set out below:
Enabling SEVEN WEALTH MANAGEMENT to fulfil its duty to advise in accordance with article L.132-27-1 of the French Insurance Code and, more generally, comply with applicable legal, regulatory and administrative provisions;
Enabling compliance with regulatory requirements to prevent money laundering and terrorist financing;
Enabling client relations management;
Enabling the coordination of SEVEN WEALTH MANAGEMENT’s work.
The mandatory or optional nature of the personal data requested and any consequences of a failure to reply are indicated when the data is collected.
In the event of processing for purposes other than those referred to above, SEVEN WEALTH MANAGEMENT will specify these purposes and obtain your prior consent if regulations require it to do so.
This data is accessible only to authorised staff of SEVEN WEALTH MANAGEMENT, and will only be disclosed to third parties (business partners and/or data processors) for administration and management purposes, or to meet our legal and regulatory obligations. We take appropriate measures to ensure that our data processors process your personal data in accordance with the relevant data protection legislation. These measures notably include the signature of an agreement specifying exactly how data is to be processed and requiring data processors, inter alia, to process your personal data only on our instruction, not to hire a secondary data processor without our agreement, to take appropriate technical and organisational measures to guarantee the security of your data, to ensure that persons authorised to access the data are subject to a duty of confidentiality, to return and/or destroy your data at the end of their assignment or contract, to submit to audits, and to help us follow up on your requests to exercise rights held in relation to your personal data.
If you would like more information on the guarantees provided by SEVEN WEALTH MANAGEMENT regarding the transfer of personal data outside the EEA, please contact our Data Protection Officer, JOHANN SCHWIMANN, by email to firstname.lastname@example.org or post at SEVEN WEALTH MANAGEMENT – 39 rue Marbeuf - 75008 Paris.
Regulations require us to guarantee a certain level of security and confidentiality for your personal data. In this regard, we consider that all data about you is confidential data covered by the professional secrecy rules by which we are bound. This data may be passed on, used or retained according to the security framework described below. SEVEN WEALTH MANAGEMENT implements and maintains a series of security measures in its computing environments to secure the data stored on its IT systems.
SEVEN WEALTH MANAGEMENT ensures that its data processors and service providers implement and maintain a security system in accordance with the GDPR in particular. If we notice an incident that has an impact on personal data then, depending on the regulatory framework in question, we will notify the Commission Nationale Informatique et Libertés (CNIL) as soon as possible, and inform the data subjects.
We have drawn up a data storage policy to ensure that your personal data is kept only for as long as is needed given the purposes for which it is processed. To determine this length of time, we consider the different purposes for which the data is collected, the data subjects, and compliance with the laws, regulations and industry standards to which we are subject. It must be no longer than is strictly needed for data to be processed properly.
In accordance with the relevant data protection legislation, you have the right to access, correct and delete your personal data, the right to object to or restrict the processing of your personal data, the right to data portability, and the right to issue instructions on the use of your personal data after your death.
|Right to be informed||You have the right to obtain clear, transparent and comprehensible information on the way in which we use your personal data and on the exercise of your rights.|
|The rights of access and rectification||You may ask to access your personal data and to rectify it if it is inaccurate or incomplete.|
|Right to erasure
(“right to be forgotten”)
|You have to right to have your personal data erased. However, the right to erasure (or “right to be forgotten”) is not absolute and is subject to certain conditions. We may therefore keep your personal data to the extent permitted by law, and in particular when its processing is necessary for compliance with a legal obligation incumbent on SEVEN WEALTH MANAGEMENT, or for the establishment, exercise or defence of legal claims.|
|Right to restrict the processing of data||You have the right to restrict the processing of your data in certain circumstances. In this scenario, except in relation to its storage, data may only be processed with your consent, or for the establishment, exercise or defence of legal claims.|
|Right to data portability||In certain circumstances, you have the right to receive personal data that you have provided to SEVEN WEALTH MANAGEMENT in a structured, commonly used, machine-readable format, and to transfer it to another data controller.|
|Right to object to processing||You have the right to object to certain types of processing (except where SEVEN WEALTH MANAGEMENT’s processing meets a legal requirement) for legitimate reasons.|
|Right to withdraw consent||If you have given your consent to processing of your personal data, you have the right to withdraw it at any time.|
|Right to give instructions over the use of your data after your death||You may give instructions regarding the storage, deletion and communication of your personal data after your death. These instructions are general or specific. General instructions are registered with a trusted third party. Specific instructions are registered with the data controller.|
Please send any requests concerning the exercise of your rights by email to email@example.com or by post to SEVEN WEALTH MANAGEMENT – 39 Rue Marbeuf – 75008 Paris – France
You may also file a complaint with the relevant supervisory authority. In the case of France, this is CNIL – Commission Nationale de l’Informatique et des Libertés – We may amend this Personal Data Policy to bring it in line with changes in our practices, or to clarify them, and to ensure compliance with regulations. https://www.cnil.fr
We may amend this Personal Data Policy to bring it in line with changes in our practices, or to clarify them, and to ensure compliance with regulations.
Version updated on 15 July 2021