KEYS ASSET MANAGEMENT GROUP
25B Boulevard Royal
Tel.: 00 352 278 60007
The Keys Asset Management website is a site presenting the products and services offered by Keys Asset Management. The visitor who accesses these web pages acknowledges having had the opportunity to read the legal notices while browsing the website. The Information contained on this website is subject to regular checks and we endeavour to keep it updated without undue delay. However, if, despite all our efforts, errors may have occurred, please accept our sincere apologies. In any case, we invite you to check all data with our team. Moreover, Keys Asset Management reserves the right to modify at any time the content and/or the conditions of use of these web pages and/or withdraw access to these pages at any time.
PERSONAL DATA PROTECTION
1.1. The personal data collected in the “Contact Us” section of the website www.keys-am.com (hereinafter the “Site”) are as follows: your first and last names, your e-mail address, your telephone number and the company in which you conduct your professional business (hereinafter the “Personal Data”).
1.2. The person in charge of processing Personal Data is the Data Protection Officer (DPO), Mr. Jimmy Castillo (email@example.com).
1.3. Personal Data is collected and processed in the strictest confidentiality, in accordance with the provisions of European Law No. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (“General Data Protection Regulation [GDPR]”).
1.4. The processing of Personal Data is based on KEYS Asset Management’s legitimate interest in its business development and is mainly used to send you our newsletter and latest news.
1.5. Personal Data is kept for a three-year period from the date of its collection or, if you are already a client of KEYS Asset Management, from the end of our business relationship. At the end of this period, KEYS Asset Management will contact you to find out if you wish to continue receiving our newsletter and latest news. In the absence of an explicit positive response, your Personal Data will be deleted.
1.6. The Personal Data is only intended for authorised personnel working within the marketing department who are responsible for answering requests for information.
1.7. By writing to firstname.lastname@example.org, you may:
- Exercise a right of access, in order to know your Personal Data as well as the information mentioned in Article 15 of GDPR;
- Request that any of your inaccurate or incomplete Personal Data be corrected;
- Request that your Personal Data be deleted under the conditions provided for in Article 17 of the GDPR;
- Request the limitation of your Personal Data under the conditions provided for in Article 18 of the GDPR;
- File a claim with the CNPD: Luxembourg’s National Commission for Data Protection
You may also object, for reasons relating to your particular situation, to the processing of your Personal Data, by writing to email@example.com or via the “Unsubscribe” link included in the e-mails sent to you by KEYS Asset Management.
For security reasons and to avoid fraudulent requests, KEYS Asset Management reserves the right to ask you for proof of identity to exercise these rights. Such proof will be destroyed within one (1) year of collection.
1.8. KEYS Asset Management uses applications that may host Personal Data outside the European Union (EU) published by companies that have successfully completed the process of self-certification to the EU-US data protection shield (“Privacy shield”) or that have adopted standard contractual clauses that comply with European requirements. A copy of such clauses is stored by KEYS Asset Management and is available for your perusal upon request.
INTELLECTUAL PROPERTY, WARNINGS AND RESTRICTIONS ON WEBSITE ACCESS
The information contained on this website in the form of texts, photographs, illustrations, graphics, plans, is not contractual and may be modified at any time without notice. Keys Asset Management holds the website copyright. This includes: images, texts, photos and all information that can be retrieved from this website. Any reproduction, partial or total representation of this website, by any means whatsoever, is strictly prohibited without the permission of Keys Asset Management. In any case, Keys Asset Management and its principals cannot be held responsible for any possible direct, indirect, technical or special damage that may result.
Any example or simulation of financing is only given as an example and as a reference value and Keys Asset Management does not give any guarantee in terms of result. It is up to the user to check that they meet the legal and fiscal conditions to access financing or tax exemption from any professional of their choice (bank, solicitor, administration, etc.). Access to the funds on the site may be restricted to certain persons or countries. The funds may not be marketed, directly or indirectly, to US persons and/or any entity owned by one or more US persons as defined by the US Foreign Account Tax Compliance Act (FATCA) regulations.
Furthermore, the funds presented on this website may only be subscribed to in jurisdictions in which their marketing and promotion is permitted.
Past performance is not a guide to future performance and is not constant over time.
Personal Data Protection Policy
The personal data collected in the “Contact Us” section of the website www.keys-am.com (hereinafter the « Site ») are essentially your name, first name and e-mail address, telephone number and the company in which you carry out your professional activity (hereinafter the « Personal Data »).
The person in charge of processing the Personal Data is KEYS AM, a simplified joint stock company, with a capital of 300,000 €, registered in the Paris Trade and Companies Register under the number 818520611, whose registered office is located at 24 rue des Capucines, 75002 Paris, represented by its President, Mr Pierre MATTEI and whose Data Protection Officer (DPO) is Mrs Amandine Acquatella (firstname.lastname@example.org).
The Personal Data are collected and processed in the strictest confidence, in accordance with the provisions of Law n°78-17 of 6 January 1978 relating to information technology, files and freedoms (« Loi Informatique et Libertés ») and European Regulation n°2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data (« GDPR »).
1.2. Processing of personal data by Keys AM
Keys AM collects and processes your Personal Data :
- Directly, as part of the management of the website.
- Indirectly, in particular as part of the management of social networks and public relations. This Personal Data may be identification data (surname, first name, telephone number, email address), relative data and data relating to the professional life of the persons concerned. They come in particular from social networks or from our exchanges with various actors (for example, mayors, managers within metropolises, elected officials, association managers, etc.).
This Personal Data is necessary for the management of these activities. If you do not provide this Data or if you refuse to collect it, this may not allow us to carry out our activities and services.
In all cases, we ensure that the Personal Data processed is adequate, relevant and not excessive in relation to the purposes for which it is collected and/or further processed.
The processing purposes listed above are based on the legitimate interest of KEYS AM to operate the website and to ensure its commercial development, to manage public relations with real estate actors and to analyse the reactions of Internet users on social networks.
For some cookies, the processing is based on your consent (see section 1.8).
1.3. Retention Periods
Concerning the management of the website and the management of public relations, the Personal Data are kept for a period of 3 years from their collection or from our last contact or, if you are already a client of KEYS AM, from the end of our commercial relationship. At the end of this period, KEYS AM will contact you to know if you wish to continue to receive our newsletter and our news. In the absence of a positive and explicit answer from you, the Personal Data will be deleted.
Concerning the management of social networks, Personal Data are kept for the time necessary to carry out statistics sent by our social network partners.
Cookies are stored on your terminal for as long as it is necessary to achieve the purposes pursued. In particular :
- Cookies, which may or may not require your consent, are stored on your device for a maximum period of 13 months from the date of their creation;
- The information collected via cookies is kept for 6 months for technical cookies and from 14 to 26 months for audience measurement cookies from the time they are created on your terminal.
- Your choice, consent and/or refusal, concerning cookies is kept for a period of 6 months (after this period, we will ask you again to choose how you wish to manage your cookies on our Site).
Personal Data is intended solely for use by authorised Keys Group personnel working in the departments responsible for processing Personal Data within the scope of their duties (e.g. marketing department, customer service, public affairs department, etc.) and responsible for responding to requests for information.
We also use external service providers acting on our behalf who may have access to your Personal Information (e.g. for IT management, website development, sending communications, etc.).
We only share your Personal Information where such recipients have a legitimate need to access it. In this respect, as some of our IT service providers are located outside the European Economic Area, we ensure that transfers to these service providers are subject to adequate safeguards, including the signing of European Commission standard contractual clauses and appropriate security measures.
1.5. Exercise of data protection rights
You have the possibility, by writing to the following e-mail address: email@example.com to:
- Exercise a right of access, in order to know the Personal Data concerning you as well as the information mentioned in article 15 of the RGPD;
- Request that the Personal Data concerning you, which are inaccurate or incomplete, be rectified in accordance with Article 16 of the GDPR;
- Request that your Personal Data be deleted in accordance with Article 17 of the GDPR;
- Request the limitation of your Personal Data under the conditions provided for in Article 18 of the GDPR.
You also have the possibility to oppose, for reasons relating to your particular situation, the processing of Personal Data concerning you, by writing to the following address firstname.lastname@example.org or via the link “Unsubscribe” mentioned in the e-mails sent to you by KEYS AM.
You can also define directives on the exercise of your rights after your death, as well as designate a person in charge of the exercise of these rights.
You also benefit from the right to file a complaint with a control authority (in France the CNIL) in case of violation of the applicable rules on Data Protection.
For security reasons and to avoid any fraudulent request, KEYS AM reserves the right to ask you for a proof of identity to exercise these rights, which proof will be destroyed at the end of the exercise of your data protection rights.
When consulting the “keys-am.com” website (hereafter referred to as the “site”), certain information relating to your navigation may be recorded in “cookies” files installed on your terminal (computer, tablet, mobile phone or any other device optimised for the Internet).
These cookies are issued by and for the purpose of facilitating your navigation on this Site, for audience measurement purposes.
1.6.1 What is a cookie?
A “cookie” is a series of information, generally small in size and identified by a name, which may be transmitted to the user’s browser by the site or application to which he or she is connected. The browser software stores it on the user’s terminal (computer, tablet, mobile phone or any other internet-enabled device) for a certain period of time, and sends it back to the web server each time the user reconnects. Cookies are, for the most part, used to make a website or application work better and more efficiently. In effect, a website or application can read and query these files, allowing it to recognise the user’s terminal and record important information that will facilitate the use of the site.
1.6.2 What cookies do we use?
- Technical cookies essential to the functioning of the site: these cookies are purely technical and strictly necessary for the proper functioning of our website. As such, they are not subject to consent. You can, however, technically block them by using your browser settings but your experience on the site may be degraded. For example, the cookie allowing the recording of your choices in terms of cookies or cookies allowing you to personalise your user interface.
- Cookies for measuring the site’s audience via “AT Internet” cookies, a web analysis service provided by the Piano Company (“Piano”): The data collected by AT Internet can be accessed at the following link: “Data collected by AT Internet – AT Internet Help“. The information generated by the cookies on the use of the site will be transmitted to an AT Internet server where it will be kept for 14 months (unless the User withdraws his consent, in which case the data collected by these cookies will be deleted). Piano uses this information to measure User interactions on the site and to provide us with statistical reports on these aspects. IP addresses are used to ensure the security of the service and to tell us from which part of the world users come. Piano does not associate the IP address transmitted by the user’s browser software in the context of AT Internet with any other data held by Piano.
1.6.3 User’s choices concerning cookies
When the user connects to the site, a banner aimed at obtaining his/her consent or refusal concerning the deposit of audience measurement and social network cookies on his/her terminal appears. As long as the user has not expressed his choice, this banner will remain visible, in accordance with the Data Protection Regulations. Every six (6) months, we will ask the user to confirm or change their choice (to set, refuse or accept cookies), by making the banner reappear on their terminal.
The user can withdraw his consent at any time and go back on his choice.
The user may also configure his browser software so that cookies are recorded in his terminal or, on the contrary, that they are rejected, either systematically or according to their sender. The user may also configure his browser software so that he is offered the option of accepting or refusing cookies from time to time, before a cookie is likely to be recorded in his terminal.
If the user refuses to accept cookies or deletes them from his or her terminal, the user may no longer be able to benefit from a certain number of functions that are nevertheless necessary to use the site.
In this case, we decline all responsibility for the consequences linked to the degraded functioning of the site resulting from the impossibility of recording or consulting the cookies necessary for their functioning and which the user would have refused or deleted.