Privacy Policy

1. Introduction

 

1.1. Foreword

 

CAPZA is convinced of the importance of a relationship of trust with its various interlocutors and pays particular attention to the protection of your Personal Data.

CAPZA undertakes to Process Personal Data in compliance with all applicable laws and regulations regarding confidentiality and data protection. The offices of CAPZA are located in countries of the European Union in which laws governing the Processing of Personal Data are in force, in particular the Regulation (EU) 2016/676 dated 27 April 2016 (known as “GDPR“).

 

1.2. Definitions

 

The term “CAPZA” refers to CAPZA, the brand name of Atalante SAS, and each of its affiliates, directly or indirectly, including the funds and investment vehicles it manages (but not their portfolio companies).

 

The “Controller” of your Personal Data is CAPZA.

 

References to “you”, “your” or “yours” are to natural persons who use the CAPZA website and/or whose Personal Data is Processed by CAPZA in the course of its Activities.

 

The term “Activity(ies)” refers to any activity usually carried out by CAPZA, i.e. any normal activity of a management company and its funds and investment vehicles.

 

The “Website” is the website of CAPZA available at: https://capza.co

 

“Processing” (or “process”, “process”) is an operation or a set of operations relating to Personal Data, in particular their collection and use by CAPZA within the framework of its Website and/or within the framework of the relationship between CAPZA and you.

 

“Personal Data” is any information relating to a person which, alone or in combination with other sources of information, makes it possible to identify that person. Personal Data does not include anonymized information, i.e., information that cannot be identified with the individual.

 

If you provide CAPZA with Personal Data about another individual, you represent and warrant that this Privacy Policy has been provided to the third party prior to the sharing of such information. To the extent possible, you have obtained the consent of the third party.

 

Sensitive Personal Data, as defined by current regulations, includes information relating to ethnic origin, religious, political or philosophical beliefs, sexual orientation, etc. CAPZA does not Process Sensitive Personal Data in the context of its Website, but such data may be Processed by CAPZA in the context of its Activities.

 

2. Scope of the Privacy Policy

 

2.1. Purpose and Scope of the Privacy Policy

 

In the interest of transparency, CAPZA has drawn up this Privacy Policy in order to inform you about the Processing of your Personal Data when you use the Website or in the course of your business dealings with CAPZA.

The Privacy Policy defines the purposes for which CAPZA Processes Personal Data and the way in which these are protected. It also defines the rights of individuals with regard to the Processing of their Personal Data.

There may be additional terms, conditions and undertakings that also govern how CAPZA collects, uses and discloses your Personal Data and which should be read in conjunction with this Privacy Policy (see in particular our Cookies Policy).

 

2.2. Categories of Personal Data covered by the Privacy Policy

 

CAPZA Processes your Personal Data only for purposes that have a valid legal basis.

 

The nature of the information collected by CAPZA depends on the services provided and its relationship with you in the context of its Activities. The Personal Data Processed by CAPZA can be classified as follows:

 

  • Identification data: full name, date of birth, gender, functions;
  • Contact data: personal address, telephone number, e-mail address;
  • Technical data: data relating to your interactions with the Website (e.g. cookies);
  • Marketing and Communication Data: marketing and communication preferences;
  • Profile data: login, password;
  • Data necessary for the implementation of certain Activities: identification of a financial operator and carrying out financial operations on the assets and liabilities of the funds (e.g. tax number, bank details) or data relating to the management of CAPZA employees (e.g. data relating to sick leave, etc.).

 

CAPZA collects Personal Data about you in various ways, including :

 

  • As a result of your visits to its Website or your connections to one of its online services and;
  • As part of your business relationship with CAPZA for the implementation of its various Activities.

 

2.3. Reference to the Cookies Policy

 

Please see CAPZA’s Cookies Policy.

 

 

3. Purpose and legal basis of the Processing of your Personal Data

 

The Processing of your Personal Data is justified by purposes consistent with the regulations in force and legitimized by valid legal bases.

In any case, CAPZA applies the principle of data minimization, and therefore only collects Personal Data that are strictly necessary.

 

This Privacy Policy describes the main collection and processing operations related to :

 

  • with your use of the Website; and
  • with the various Activities of CAPZA (for more details please consult the contractual conditions governing these operations).

 

 

3.1. Website specificities

 

(i) Follow-up of your answers via the contact form of the Website

 

The CAPZA Website offers a contact tab which, when you use it, Processes your Personal Data for the purpose of following up your requests. The Processing is therefore only carried out when you use the contact form.

 

The Processing concerns the following data:

  • Identification data
  • Contact data
  • Content of the messages

 

The legal basis for this Processing is the legitimate interest of CAPZA to manage its relations with you.

 

(ii) Website Development

 

In order to provide its users with an efficient Website, CAPZA analyses the interactions of its users with the Website.  For this purpose, the Processing of cookies, Personal Data, is necessary.

The Processing therefore only concerns browsing data.

The legal basis for this Processing is the legitimate interest of CAPZA to better understand the use of its Website by its users and improve it accordingly.

For more information on the use of cookies by CAZPA, please refer to the Cookies Policy.

 

(iii) Candidate’s section

 

The Website allows you to apply for a job with CAPZA. In this context, the communication of your Personal Data is a necessary condition for the conclusion of a possible contract, so if you decide not to provide CAPZA with your Personal Data necessarily required, your application will be rejected. In order to process your application CAPZA Processes your Personal Data for two purposes:

 

1.Firstly, CAPZA Processes your Personal Data for the proper implementation of its recruitment process.

 

For this purpose, CAPZA Processes the following Personal Data:

  • Identification data;
  • Contact data;
  • Data relating to your professional life;
  • Content of the application message.

 

The legal basis for this Processing is the legitimate interest of CAPZA, which is to carry out and manage its recruitment activities.

 

2. In addition, if your application is not successful, CAPZA may wish to keep your application file in order to contact you again if a subsequent job offer is likely to match your profile.

 

To this end, CAPZA will inform you of its wish and you will have the possibility to request the deletion of your file. If you do not object to the storage, CAPZA shall Process the aforementioned Personal Data in order to build up and manage its candidates database.

 

At the time of collection of the Personal Data, the legal basis for the Processing is the legitimate interest of CAPZA to carry out and manage its recruitment operations. Subsequently, if CAPZA wishes to keep your application file for more than two (2) years after the last contact on your initiative, your consent, which is then requested by CAPZA, will become the legal basis for the Processing.

 

CAPZA works with the service provider TALEEZ for the management of applications. By applying on the Website, you agree to share your Personal Data with TALEEZ, which acts as a subcontractor. The privacy policy of TALEEZ is available in the application tab of its site.

 

 

4. Recipients of your Personal Data

 

CAPZA may disclose Personal Data in any jurisdiction to:

 

  • Other CAPZA members;
  • Professional advisors (attorneys, consultants, etc.) or independent contractors who provide goods and services to any member of CAPZA (Custodians, banks, computer system providers, marketing service providers, etc.);
  • Any person to whom disclosure is authorized or required by applicable local or foreign laws or regulations.

 

These transmissions of Personal Data are always carried out in compliance with the regulations in force and only if they are necessary.

 

 

5. International Transfers of Personal Data

 

If the operation of its services requires it, CAPZA may have to deal with contacts located outside the country in which you reside or in which services are provided to you or to the organization or entity for which you work.

 

If the contact person of CAPZA is located outside the European Union, it is possible that the regulations in force are not equivalent to those applied within the European Union. In this case, CAPZA guarantees an adequate level of protection of Personal Data by ensuring that the country to which the Personal Data is transferred is considered by the European Commission to provide an adequate level of protection, or by putting in place contractual clauses that the European Commission considers to provide an adequate level of protection.

 

 

6. Retention of Personal Data

 

CAPZA keeps your Personal Data for the time necessary :

 

  • for the purpose for which it was collected;
  • to comply with legal, regulatory, accounting, reporting or internal policy requirements;
  • to exercise or defend legal rights.

 

Thus, the duration of retention depends primarily on the purpose of the Processing and in particular, with regard to the use of the Site, four particular cases of retention of your Personal Data are to be noted:

 

  1. Follow-up of questions via the contact form of the Website: CAPZA will not keep your Personal Data beyond five (5) years after the last contact at your initiative.

 

  1. Development of the Website: Personal Data will be kept by CAPZA for the time necessary to finalize the development of the Website (e.g. optimization of the most consulted pages of the Website).

 

  1. Candidate’s section: the Personal Data necessary for the management of applications are kept at least until the end of the recruitment process, or until the time necessary to verify an unsolicited application. If you do not want your file to be kept, CAPZA will delete it as soon as it is technically possible. If you do not request the deletion of your application file, CAPZA will keep it for two (2) years after the last contact on your initiative. After this period, you will be asked for your explicit consent to keep your file and you will be informed of the planned retention period. By applying on the Website, you agree to share your Personal Data with TALEEZ, which, as a subcontractor, may also retain your Personal Data. TALEEZ’s privacy policy is available in the application tab of its site.

 

 

7. Security of Personal Data

 

CAPZA is committed to ensuring the security of your Personal Data. To this end, CAPZA deploys various technical and management measures to ensure an appropriate level of security.

 

However, the security of data transmitted over the Internet cannot be guaranteed and there is a risk of access and interception. CAPZA makes every effort to protect Personal Data but cannot guarantee the security of data transmitted via channels external to CAPZA.

 

 

8. Your rights and obligations as a data subject

 

The regulations in force confer various rights on the person concerned by the Processing:

 

  • Right of access: allows you to know whether data concerning you are being Processed and to obtain communication of such data in an understandable format. You can also check the accuracy of the data and, if necessary, have them corrected or deleted.
  • Right to object: you can object to your Personal Data being Processed by CAPZA on the basis of legitimate interests, for profiling or canvassing purposes. In any case, you must put forward “reasons related to your particular situation”.
  • Right of correction: allows you to correct/complete inaccurate data about yourself.
  • Right to erasure: allows you to have your Personal Data erased if CAPZA has no legal or regulatory obligation or other valid reason to continue Processing or storing them.
  • Right to restrict Processing: allows you to freeze the use of your Personal Data if you dispute its accuracy or object to the accuracy of its Processing. If you request it, the restriction of Processing takes place while CAPZA verifies or examines your request. CAPZA shall no longer use your Personal Data but may retain it.
  • Right to data portability: allows you to request the retrieval of the data you have provided to CAPZA, for personal use or to transmit them to a third party of your choice.
  • Right to human intervention: allows you to request manual human intervention if you are subject to automated decisions where the decision has a legal or similar effect on you.

 

CAPZA is keen to ensure that your Personal Data is fully protected, you can exercise your rights at any time by using the information indicated in the “Contact” section of this Privacy Policy.

 

Please note that in accordance with the applicable regulations, CAPZA may charge a fee appropriate to the exercise of your rights.

 

In order to enable fair and accurate Processing of your Personal Data, you agree to provide CAPZA with valid information and will inform CAPZA of any instances where the information shared is out of date or inaccurate.

 

 

9. Changes to this Privacy Policy

 

CAPZA reserves the right to modify or amend this Privacy Policy.

 

 

10. Contact – Complaints

 

If you wish to exercise any of your rights, make a complaint about the Processing of your Personal Data, or if you have any questions regarding this Privacy Policy, please contact the Data Protection Officer (DPO) of CAPZA:

 

Valentine Brisac

103 rue de Grenelle – 75007 Paris, France

Phone: +33 (0) 142 600 105 – Mobile phone: +33 (0) 786 658 972

E-mail : vbrisac@capza.co

 

You also have the right to lodge a complaint with a competent authority for the protection of Personal Data in the country where you reside or work, or in the country where you believe that a problem relating to the Processing of your Personal Data has occurred. For France, the competent authority is the CNIL.