This privacy policy describes how Software Club SAS, with headquarters located at 55, rue de la Boétie, 75008, Paris, France, and registered in the Paris Trade and Company Register under the number 893 636 340 R.C.S Paris (“Software Club”, “we”, “us” or “our”), collects, uses, shares, and protects personal information (“Data”). It also tells you about the rights and choices you have with respect to your Data, and how you can reach us to get answers to your questions.

This privacy policy covers the Data that Software Club obtains about you in various contexts, including when you visit our website (“Website”), download, and use our application (“Application”) or software (together “Services”), communicate with us, or participate in any of our programs or events. When we use the term “Data” we are referring to information that identifies, relates to, describes or can be associated with you.

Our Website may include links to third party websites and/or applications. Please note that we have no control over the privacy practices of websites or applications that we do not own.

1. Collected Data

We only collect Data that is strictly necessary for the purpose for which it is processed. The communication and processing of the Data requested is essential for the supply of the Services and/or to comply with our legal and regulatory requirements.
We collect the following data directly from you, whether by telephone, mail, internet, or via mobile application:

• contact information such as name, email address, mailing address, phone number;
• unique identifiers such as username, account number, password;

The communication of your Data is voluntary. However, if you do not provide some or all of the information requested, we may not be able to provide you with all or part of the Services.

We may be required to process Data obtained from third parties, in particular in order to satisfy our regulatory obligations. In addition to Data we collect from you directly, we may also obtain information about you from other sources, including third parties, business partners, our corporate affiliates, social networks, that provide services on our behalf, or publicly available sources.

We also automatically collect some information on your type of browser and the connection equipment used (computer, mobile device) for the purposes of administering its systems, fighting fraud, maintaining the quality of Services and providing general statistics concerning their use. This information may include the type of device you use, operating system, the device identifier, your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our Website or Application, the pages you accessed on our Website or Applications, and other available information.

2. Use of Data

The processing carried out responds to an explicit, legitimate and determined purpose, which is based on the execution of the Services, the respect of a legal or regulatory obligation or our legitimate interest.

Their purpose is:
a. Regarding the measures taken at your request within the framework of the Services:

• to provide you with the Services;
• to facilitate our relationship (communications, statements…); and
• all other services related to the Services and included in the Terms of Business.

b. Regarding the measures taken in accordance with your consent:

• commercial prospecting;
• newsletters.

c. Regarding the measures taken in accordance with our legitimate interest to secure and develop our activity:

• to improve the Services provided to you (taking care of customers and prospects, managing complaints, managing our customer portfolio);
• securing our business and cash flow (managing the business of our entities, monitoring our premises for security purposes, managing IT incidents, fighting fraud, managing litigation, recovering unpaid receivables and mobilising our receivables as collateral);
• to improve communication between us (reporting).

d. To meet legal and regulatory obligations for judicial/legal purposes (e.g. responding to requests from the administrative and judicial authorities, the fight against market abuse and insider trading) and to justify our regulatory requirements (e.g. recording of information relating to our Investment Recommendations).

3. Data security and Data storage

We maintain reasonable and appropriate physical, electronic and procedural safeguards designed to protect your Data.
In general, your Data are kept for a period that does not exceed the duration necessary for the purposes for which they were collected. In particular, when you use our Services, your Data are stored for as long as you use our Services. In some cases, we may keep certain Data about you even if you delete your account, as required by law.

4. Processing and sharing your Data

We may disclose Data in the following circumstances:

• Corporate affiliates: we may share personal information with our corporate affiliates, including our parent company, sister companies and subsidiaries
• Service Providers: we share certain personal information with third parties that perform services to support our core business functions and internal operations;
• Social Media Platforms and Networks: our Website have features such as plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third party;
• Legal Process. We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.

5. Cookies

A cookie is a text file that may be stored in a dedicated space on the hard drive of your device (computer, tablet, smartphone, etc.) when you consult an online service through your browser. This file allows its sender to identify the terminal in which it is stored and thus to track your activity, and to remember information, such as your preferences or information you have previously entered in the forms on the website, during the period of validity or registration of the cookie. Some cookies are essential for the use of the website, others allow to optimize and personalize the contents displayed, and others finally, to display advertisements.

In order to facilitate the use of our Website, we use cookies for technical and statistical purposes.

During your first visit to our Website, a banner informs you of the use of cookies and invites you to indicate your choice. Non-technical cookies are stored only if you accept them. You can at any time inform yourself and set your cookies to accept or refuse them. Your first visit to our website will generate a pop-up alerting you to this privacy policy and on which you will be able to indicate your preference either globally for the site, or service by service by clicking on each category of cookies to activate or deactivate their use. To allow optimal navigation on our Website, it is recommended that you keep the different categories of cookies activated. In addition, you can also restrict or block these cookies by accessing your browser settings.

6. Rights relating to your Data

In accordance with the General Data Protection Regulation (n° 2016/679), you have the right to access, rectify, erase, limit processing, portability of your Data and to define the fate of your Data after your death. These rights may be exercised under the conditions and within the limits set by the regulations in force. It is specified that the exercise of some of these rights may lead to the impossibility for us to supply the Services on a case-by-case basis.

You may also at any time and at no cost, without having to justify your request, oppose the use of Data for commercial prospecting purposes.

You may exercise your rights and contact the personal data protection officer by sending an e-mail to the following address privacypolicy@softwareclub.io or by post at our address.

You have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), the supervisory authority in charge of compliance with obligations in terms of personal data.

7. Contact Us

If you have any questions about our privacy, you can contact our DPO by mail or e-mail:

Software Club
55, rue de la Boétie, 75008, Paris, France
privacypolicy@softwareclub.io

8. Change to this policy

We may revise this privacy policy from time to time. We will notify you of changes by posting the effective date of the latest version at the top of this privacy policy.

This privacy policy was updated on May 12th 2022.

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