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Private Policy

1. Newsletter registration data

Your email address is processed by SAS Aquiti Gestion as data controller. Your email address is collected for the sole purpose of sending you our newsletter.

By subscribing to the newsletter, you consent to its processing by SAS Aquiti Gestion within the framework defined in this section. You retain the possibility of withdrawing your consent by clicking on the “unsubscribe” link appearing on each newsletter you receive.
The recipients of your email address are SAS Aquiti Gestion and its subcontractors involved in the management of the website.

Your email address is retained until you request its deletion from SAS Aquiti Gestion or in accordance with regulatory time limits.
You may also exercise your rights (access, rectification, opposition, deletion, limitation and portability) by contacting us at the following addresses:
- By email:SG@aquiti.fr
- By post: 11 Rue des Gamins, Bâtiment B, 7e étage, 33800 BORDEAUX, FRANCE.
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You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), notably on its websitewww.cnil.fr.

2. Contact form data

The personal data collected is processed by SAS Aquiti Gestion as data controller.
The information required by Aquiti Gestion to process and manage your request for information is marked with an asterisk (*) or equivalent. In their absence, SAS Aquiti Gestion will not be able to process your request. Your personal data is collected for the sole purpose of responding to your request for information. By writing to us via the contact form, you consent to the processing of your data by SAS Aquiti Gestion within the framework defined in this section.
The recipients of your e-mail address are SAS Aquiti Gestion and its subcontractors involved in the management of the website.
Your e-mail address will be kept for as long as you have not requested SAS Aquiti Gestion to delete it, or for as long as required by law.

You may also exercise your rights (access, rectification, opposition, deletion, limitation and portability) by contacting us at the following addresses:
- By email : SG@aquiti.fr
- By post : 11 Rue des Gamins, Bâtiment B, 7e étage, 33800 BORDEAUX, FRANCE.
To exercise these rights, you will be asked to provide proof of identity.

You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), notably on its website:

www.cnil.fr.

3. Data collection and processing by Aquiti Gestion

Aquiti Gestion collects and processes data in line with applicable regulations, in particular with the General Data Protection Regulation (n°2016/679).

Aquiti Gestion respects the principle of data minimization, namely that only personal data that is adequate, relevant and limited to what is strictly necessary to achieve the purpose for which it was collected is processed.

Aquiti Gestion is also committed to keeping personal data accurate and up to date.

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a. Collecte des données

Aquiti Gestion directly or indirectly collects certain personal data:

1. Data collection : we collect and process the following data according to the contract we have with you or the advice you have requested:
- Identification data (first name, last name, date of birth, KYC documentation including valid ID);
- Contact data (telephone number, e-mail address, postal address);
- Professional data (your position, experience, knowledge of financial instruments);
- Economic and financial data (financial situation and assets);
- Tax data (tax domicile or other tax information);
- Data shared during your interactions with Aquiti Gestion.
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2. Indirect collection : We may collect data indirectly in order to comply with a legal or regulatory obligation, or to check or enrich our databases.
We collect data from the following sources:

- Publications and databases made accessible by official authorities (e.g. INPI Database, Infogreffe, Journal Officiel, etc.);
- Files that AQUITI Gestion is required to consult under specific regulatory conditions (e.g. Asset Freeze List, Sanctions, etc.);
- Websites or social network pages containing information that you have made public.
Aquiti Gestion does not collect, either directly or indirectly, so-called sensitive data.

b. Justification for data collection

We use all or part of the personal data of data subjects for the purposes described below and on the following basis:

1. Execute the contract between us (or between you and Aquiti Gestion):

‍We process personal data in order to provide the products, services and/or advice to which a customer has subscribed or a prospect wishes to subscribe. The processing is carried out because it is necessary for the performance of the contract, or for the performance of pre-contractual measures taken at the customer's request (pre-contractual measures such as the provision of advice, a proposal, a simulation).
2. Meeting our legal and regulatory obligations :
As an asset management company, our business is strictly governed by a complex and demanding regulatory environment. We use your personal data to comply with the various legal and regulatory obligations to which we are subject, including :
- Banking and financial regulations, under which we detect abnormal transactions, monitor them and report any risks they may entail;
- Responses to official requests from duly authorized supervisory or judicial authorities;
- The fight against money laundering and the financing of terrorism, the fight against FATCA-CRS tax evasion, etc. ;
- The management and processing of complaints or requests for information from our customers or prospects.

More generally, we may invoke a “legitimate interest” in processing your data, in particular when we are faced with situations that could present risks for our business. Our legitimate interest may also be linked to the management of our activity as a company (general accounting, invoicing, balance sheet management, reporting, statistical studies and satisfaction surveys, management of people on our sites), to the management of our customer relations or for our auditing activities.These processing operations are implemented taking into account your interests and fundamental rights. As such, they are accompanied by measures and guarantees to ensure a balance between the protection of your interests and rights and the pursuit of our legitimate interests.

c. Recipients outside the European Union

Your data may be used by WEBFLOW, Aquiti Gestion's service provider for the creation and management of this website. WEBFLOW processes data outside the European Union.

Your data may be used by software/solutions such as Airtable, Notion and Sharepoint, whose head offices are located outside the European Union.
Aquiti Gestion has put in place the appropriate guarantees to ensure the protection of this personal data.

Aquiti Gestion remains at your entire disposal for further information.

d. Your rights

You can exercise your rights (access, rectification, opposition, deletion, limitation and portability) by contacting us at the following addresses:

- By email : SG@aquiti.fr
- By post : 11 Rue des Gamins, Bâtiment B, 7e étage, 33800 BORDEAUX, FRANCE.
To exercise these rights, you will be asked to provide proof of identity.
You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), notably on its websitewww.cnil.fr.

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Cookie policy

A cookie is a file placed on your computer by your browser to facilitate your browsing and provide you with a better user experience. Please note that browsing the SAS Aquiti Gestion website may result in cookies being placed on your computer.
SAS Aquiti Gestion uses cookies which are only necessary for the operation of the site. They enable the user to use the site's main functions. Without these cookies, the user would not be able to use the site or enjoy a pleasant experience. Due to their essential nature, the Commission Nationale de l'Informatique et des Libertés (CNIL) considers that they may be exempted from the requirement to obtain your consent.

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DISCLAIMER : This site is an information site whose objective is to present the portfolio management activity of SAS Aquiti Gestion and the main characteristics of the funds it manages or advises. Investors in the funds managed or advised by the management company Aquiti Gestion are exclusively professional clients or equivalents within the meaning of the MIFID Directive. This site is not a transactional site and its pages do not constitute, under any circumstances, promotional material, a solicitation, advice, or an offer to buy/sell financial instruments. The figures cited on the site's pages pertain to past years. Past performance is not indicative of future performance. All the information presented on the site's pages comes from sources considered reliable. However, Aquiti Gestion cannot, under any circumstances, be held responsible for any direct or indirect loss resulting from the use of the information contained herein by anyone. All the information on the site can be modified without prior notice from SAS Aquiti Gestion. The data published on this site is the exclusive property of their holders and cannot be reproduced, in whole or in part, without the prior authorization of SAS Aquiti Gestion.
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