2020 CCAR Resubmission
Sia Partners understands that your privacy is important to you.
Sia Partners is committed to offering the highest level of security for the services it provides. By ensuring the protection of personal data and by providing simplicity, clarity, and transparency, Sia Partners wishes to treat personal data with respect and exemplarity within the framework of a relationship of trust. Sia Partners' orientations aim to develop its services in an environment that is undergoing accelerated changes both technically and in terms of regulations. Data protection is therefore a priority for Sia Partners. Having integrated the constant evolution of security threats and risks, Sia Partners places security on a daily basis at the heart of its concerns. This policy applies to all Sia Partners offices.
In the course of carrying out its activities, Sia Partners collects and processes some of your personal data. The communication of your data is voluntary and does not constitute a condition of use of the site. This personal data is collected directly from you, or indirectly.
For example, Sia Partners collects information about you:
The data we collect is, for example:
We are vigilant in protecting the privacy of minors. We do not intentionally collect personal data from minors.
We only use personal data if this use is at least based on the legal basis specified below:
We process your data in order to, in particular :
The processing of personal data as part of our assignments:
We may also process personal data as part of the services we provide to our clients, in accordance with our contractual commitments. In this case, the data is processed exclusively within the scope of the assignment. We implement organizational and technical security measures to limit access to data and guarantee the confidentiality of the information processed in the specific context of our services.
Your data is intended for the services of Sia Partners. They may also be transmitted to third parties, such as service providers to whom we entrust the performance of certain activities (not, for example, the management of applications).
Sia Partners may be requested by the authorities to transmit personal data.
Sia Partners shall ensure that it has (including with its partners and service providers) sufficient guarantees with respect to the protection of personal data at each data transfer.
If during navigation Sia Partners provides a link to a third party site, the rules and policies applicable to that site shall apply. Under no circumstances shall Sia Partners be held responsible for the processing of your personal data by a third party site.
As data regulation legislation is not equivalent between countries, Sia Partners has chosen to give priority to hosting and processing data on French territory, or where applicable a European Union country, or to contract with a company complying with the European Commission's Standard Contractual Clauses.
Your data concerned by processing operations are kept in accordance with a set of rules. Sia Partners only processes data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed. This entails, in particular, ensuring that the data retention period is limited to the strict minimum. This retention period is variable and depends on the nature of the data, its purpose and the legal and regulatory aspects to which it is subject.
Sia Partners ensures that the processing of personal data benefits from the highest level of security. Sia Partners guarantees the implementation of "appropriate technical and organisational measures", taken according to the nature of the data, the purposes of the processing and the associated risks. In the event of an incident leading to a violation of personal data, Sia Partners shall notify the incident to the competent supervisory authority and inform, if necessary, the persons concerned as soon as possible.
In accordance with the applicable data protection regulations, you have the following rights:
We bring to your attention the fact that when the law requires it, in the case of compliance with its contractual obligations, public interest, or legitimate interest, Sia Partners reserves the right, exceptionally, not to honor certain request contents (related to a request for deletion, limitation, and opposition).
Furthermore, in the case of requests that are manifestly unfounded or excessive, in particular, due to their repetitive nature, Sia Partners may either :
However, it shall be incumbent upon Sia Partners to demonstrate the manifestly unfounded or excessive nature of such requests.
You may exercise your rights by enclosing a copy of an identity document with your application, either :
Sia Partners shall have a period of one month to reply to you. In the event of a complex request or a large number of requests, this period may be extended to three months. If necessary, Sia Partners will inform you.
If, despite all the attention that Sia Partners pays to the processing of your data, you find that Sia Partners does not satisfy your request, you may file a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés): www.cnil.fr ; 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
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