Protectingyour data.

Depending on the context of your relationship with the firm, JR CONSEIL may collect the following categories of data:

• Identification data: title, surname, first name, date of birth, family and marital status;
• Contact data: postal address, email address, phone numbers;
• Professional data: profession, status, business ownership where applicable;
• Wealth and financial data: composition of wealth, income, expenses, investment objectives, to the strict extent necessary for the advisory engagement;
• Browsing data: anonymised technical information relating to your visit to the website (where applicable, via audience measurement tools).

Only data strictly necessary for the purpose pursued is collected (data minimisation principle).

Your data is processed for the following purposes:

• Responding to your enquiries submitted via the contact form or any other channel;
• Carrying out the wealth advisory engagement and drawing up recommendations suited to your situation;
• Monitoring the client relationship over time;
• Complying with legal and regulatory obligations (anti-money laundering, tax obligations, contractual retention);
• Improving the functioning and security of the website.

Your data is not subject to any wholly automated decision or to profiling for commercial purposes.

Each processing activity rests on one of the legal bases set out in Article 6 of the GDPR:

• Performance of a contract or pre-contractual measures, for the advisory engagement and responding to your enquiries;
• Compliance with a legal obligation, for processing required by regulation (anti-money laundering and counter-terrorist financing, tax and reporting obligations);
• Your consent, for processing that requires it (contact form, non-essential audience measurement cookies);
• The firm's legitimate interest, for website security and the improvement of its services.

Your data is processed by Olivier Raso and, where applicable, by authorised staff of the firm. It is never sold, rented or exchanged for commercial purposes.

It may be disclosed, to the strict extent necessary for implementing the solutions you have taken out, to the following recipients:

• Contractual partners (insurance companies, asset management firms, banking institutions);
• Partner professionals working on your file (notaries, lawyers, accountants), with your agreement;
• The firm's technical service providers (hosting, email), bound by a duty of confidentiality;
• Administrative or judicial authorities, where required by law.

Your data is retained for the period strictly necessary for the purposes for which it was collected:

• Contact enquiries with no follow-up: retained for up to three years from the last contact;
• Client data: retained for the entire duration of the contractual relationship, then archived in accordance with the applicable statutory limitation periods;
• Anti-money laundering obligations: retained for five years from the end of the business relationship, in accordance with the French Monetary and Financial Code;
• Accounting and contractual documents: retained for ten years in accordance with legal obligations.

You have the following rights:

• Right of access — obtain confirmation that your data is being processed and receive a copy of it;
• Right to rectification — have inaccurate or incomplete data corrected;
• Right to erasure — request the deletion of your data, subject to legal retention obligations;
• Right to restriction of processing in certain cases provided for by law;
• Right to object to processing on grounds relating to your particular situation;
• Right to data portability — retrieve your data in a structured, machine-readable format;
• Right to set directives concerning the fate of your data after your death.

A cookie is a small file placed on your device when you visit the website. The JR CONSEIL website uses only:

• Strictly necessary cookies for the proper functioning of the website, which do not require your consent;
• Where applicable, anonymised audience measurement cookies, intended to understand website traffic, set only after your consent has been obtained.

No advertising or commercial profiling cookie is used. You may configure your browser at any time to refuse cookies or be notified when they are set.

JR CONSEIL implements appropriate technical and organisational measures to preserve the security, confidentiality and integrity of your data, and to protect it against any destruction, loss, alteration or unauthorised access. Access to data is strictly limited to authorised individuals, bound by a duty of confidentiality.

Your data is hosted and processed within the European Union. In the event that a service provider were to process data outside the European Union, JR CONSEIL ensures that appropriate safeguards (European Commission standard contractual clauses, adequacy decision) govern such transfer in accordance with the GDPR.

If, after contacting us, you believe that your rights are not being respected, you have the right to lodge a complaint with the French Data Protection Authority (CNIL) — 3, place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France — www.cnil.fr.