The Armen site is produced by Armen SAS, a “Société par action simplifiée” with a capital of 13 166 863 euros, whose registered office is located at 6, Place de la Madeleine – 75008 Paris France, registered in the Paris Trade and Companies Register under the identification number 915 298 566.

Email : contact@armen.eu

Armen has been approved by the Autorité des marchés financiers on 07/09/2022 as a portfolio management company under the number GP-202222. Intracommunity VAT number: FR 19915298566

Name of the publication director of the website: Dominique Gaillard

Editorial managers : Marie-Claire Martin, Armelle de Selancy

Web development: Futur Parfait

The website www.armen.eu is hosted on a Microsoft cloud platform (Azure), in the Microsoft “France Central” hosting center located in France.

Service provider: MICROSOFT France – Simplified joint stock company

Head office: 39 quai du president Roosevelt – 92130 Issy-les-Moulineaux

Share capital: 4 240 000 €

SIRET: 32773318400516

SIREN: 327733184

Intra-community VAT number: FR95327733184

The images of the lighthouse are taken from the video “Le Phare d’AR-MEN” (“The AR-MEN Lighthouse”) produced by drone by Guillaume Leysenne. Other sea and miscellaneous images are from the Unsplash photo library.

The use of any document from www.armen.eu webpage is only permitted for information and personal use. Reuse, reproduction, transcription or alteration of any part of this website, for other aims, is strictly forbidden, without the following society’s prior written permission to: Armen

Armen reserves the right to fully or partially alter, cancel, suspend, or interrupt, at anytime, for any reason, and at its own discretion, access to website, including to its content, functionalities, or availability hours, without prior notice.

Armen (a portfolio management company approved by the Autorité des marchés financiers on September 7, 2022 under number GP-202222) attaches the greatest importance to collecting and processing your personal data with the utmost care in compliance with the applicable legal framework, in particular law no. 78-17 of January 6, 1978 on data processing, data files and individual liberties, as amended in particular by the European General Data Protection Regulation (GDPR).

The purpose of this privacy policy is to detail the purposes and methods by which Armen collects and processes your personal data when you visit the www.armen.eu website and to remind you of the rights you have to the processing and control of your personal data.

 

Definitions

“Personal data” refers to any information relating to a natural person that is likely to identify him or her, either directly or indirectly. For example, name, e-mail address, telephone number, social security number, IP address, computer connection identifier, etc., constitute personal data, regardless of whether this information is confidential or public.

“Processing” of personal data refers to any operation involving personal data, regardless of the process used. Thus, the recording, storing, modifying, organizing, combining with other data, transmitting, etc. of personal data constitutes the processing of data.

“Data controller” refers to the person, in this case Armen, who determines the purposes and means of the processing activity, i.e. the objective of processing and the way in which processing is carried out.

 

Object

The purpose of this confidentiality policy is to inform you, as a user of the www.armen.eu website (the “Site”), about the way in which Armen – as the data controller – collects and processes personal data that you may transmit to us when consulting and using the Site.

 

Nature of the personal data collected and purposes of the processing of your personal data

The nature and type of personal data collected by Armen depend in particular on your use of the Site and are detailed below according to the purposes of processing defined by Armen. When consulting and using the Site, Armen does not collect “sensitive” personal data, i.e. data relating to your ethnicity, religion, political or philosophical beliefs or sexual orientation. In any case, Armen applies the principle of data minimization and therefore only collects personal data that is strictly necessary. All personal data processing carried out by Armen when you use the Site is justified by different purposes, depending on the services you receive, each of which is legally justified by a valid legal basis.

In the context of consultation and use of the Site, the purposes for which your personal data is collected and processed include the following:

• Responding to requests sent via the contact form: the Site offers a contact tab which, when used, triggers the processing of your personal data for the purpose of following up your requests. Armen’s legitimate interest, when processing personal data in the context of requests submitted by users of the Site, is the proper management of relations between Armen and said users. This processing, which only takes place when a user submits a request, concerns the following personal data:
  • Identification data: surname, first name
  • Contact details: telephone number, email address
  • Message content
• Responding to subscription requests for the Armen newsletter: Armen shall collect and retain the contact email address, first name and surname of any user of the site intending to subscribe to its newsletter in order to manage subscription requests. This processing will only be carried out with your prior consent, which constitutes the legal basis for this processing.
• Ensuring the development and proper operation of the Site: In order to provide you with a high-performance Site in line with user expectations, Armen may analyze your interactions when consulting the Site and process various browsing information (date, time, Internet address, pages consulted) resulting from cookies which, in particular, make it possible to memorize your consultations, record your preferences and benefit from statistical measurements of the users of the Site. The legal basis for this processing is Armen’s legitimate interest in understanding how users of the Site consult and navigate the Site and in improving the Site’s performance where necessary.

You can find out more about cookie management in our dedicated cookie use policy, which can be consulted below.

 

Recipient of your personal data

The transmission of your personal data is always carried out in compliance with the regulations in force and only if it is necessary for the purposes identified above.

In this respect, the persons to whom Armen may disclose your personal data are :

• The suppliers and service providers that Armen uses to operate the Site in connection with the processing purposes listed above;
• The staff or corporate officers of any entity of the Armen Group, in particular in the context of responding to requests sent via the contact form, depending on the nature of the requests and the skills required to respond to them, which may be located in another entity of the Armen Group;
• Any public, administrative, governmental authority or competent court, in France or abroad, requesting access to your personal data insofar as such disclosure is required by applicable laws or regulations.

 

Transfer of data outside the European Economic Area

The entities of the Armen Group and the suppliers and service providers of Armen to operate the Site may be located outside the European Economic Area. In this respect, certain entities of the Armen Group are located in the United Kingdom, the United States and Singapore.

Given that it is then possible that the regulations in force in these jurisdictions are not equivalent to those applicable within the European Economic Area, Armen implements all appropriate measures to ensure an adequate level of protection of personal data, including the implementation of contractual clauses that the European Commission considers to provide a sufficient level of protection.

 

Storage of your personal data

Armen retains your personal data for as long as it is necessary for the purposes for which it was collected and in accordance with legal, regulatory, accounting, reporting or internal policy requirements. The length of time we keep your personal data depends on the purpose for which it was collected. When your data is collected and processed in the context of requests submitted via the Site’s contact form, Armen will not retain the personal data thus processed beyond a period of five (5) years from the last contact initiated by the Site user. When Armen collects and processes your personal data as part of your subscription to its newsletter, this data is kept until the date on which you decide to end your subscription. Lastly, personal data collected and processed in connection with the development of the Site will be kept only for the time required to complete development operations.

 

Your rights and obligations as a user of the Site

As a user of the Site, the regulations in force guarantee you various rights in relation to the processing of your personal data, in particular:

• A right of access which enables the user to obtain from Armen confirmation as to whether or not personal data concerning him or her is processed, when it is processed, access to the said data, the purposes of the processing of the said data, the categories of personal data concerned, the recipients of the said data and the retention period that the said data will be kept, where possible.
• The right to ask Armen to rectify any personal data collected that is inaccurate or to complete any personal data that is incomplete, including by providing a supplementary declaration.
• The right to obtain from Armen the deletion of personal data as soon as possible, in particular when the data is no longer necessary for the purposes for which it was collected or in the event of the withdrawal of consent when the latter served as the legal basis for data processing.
• The right to restrict the processing of personal data relating to the user, in particular when the accuracy of the data is contested by the user, for the period allowing Armen to verify the accuracy of the data or when Armen no longer needs the personal data for the purposes of processing but the data is still necessary for the user to establish, exercise or defend legal claims. In such cases, the data may no longer be processed except with the user’s consent, but the data may be retained.
• Each user has the right to receive the personal data concerning him or her that he or she has provided to Armen, in a structured, commonly used and machine-readable format, and has the right to transmit such data to another data controller without Armen’s hindrance, where the processing is based on consent and carried out using automated processes.
• The right to object to the processing of personal data at any time, for reasons relating to his or her particular situation.
• The right to lodge a complaint with a supervisory authority.

In order to allow fair and accurate processing of personal data, users of the Site undertake to provide Armen with valid information and will inform Armen in the event that the information shared becomes obsolete or inaccurate.

In addition, in the event that a user provides Armen with personal data relating to another natural person, the user will be obliged to transmit this privacy policy to the person concerned and to declare and guarantee to Armen that this privacy policy has been transmitted to the third party prior to the sharing of such information and, insofar as applicable, that the third party has consented to the processing of its data.

 

Contact and complaints

In the event of any questions in connection with this privacy policy or the processing of your personal data, including for the exercise of the rights listed in the previous section, users of the Site may contact Armen at the following address:

Armen
Data Protection
6, place de la Madeleine 75008 Paris

Or send an e-mail to dataprivacy@armen.eu

In connection with the exercise of their rights by users of the Site and in accordance with applicable regulations, Armen may require the payment of reasonable fees taking into account the administrative costs incurred in providing the information, making the communications or taking the measures requested.

Each user of the Site also has the right to lodge a complaint with a competent authority for the protection of personal data in the country where he or she lives or works, or in the country where he or she believes that a problem relating to the processing of his or her personal data has occurred. In France, the competent authority is the Commission Nationale de l’Informatique et des Libertés (CNIL).

Armen undertakes, where necessary, to notify violations of personal data to the CNIL as soon as possible and, if possible, no later than 72 hours after becoming aware of them (or in a staggered manner if it is not possible to provide all the information at the same time), unless the violation in question is not likely to give rise to a risk to the rights and freedoms of individuals. In such cases, the notification must, at the very least :

• describe the nature of the personal data breach, including, if possible, the categories and approximate number of persons affected by the breach and the categories and approximate number of personal data records affected;
• provide the name and contact details of a point of contact from which further information can be obtained;
• describe the likely consequences of the personal data breach; and
• describe the measures taken or proposed to be taken by Armen to remedy the personal data breach, including, where appropriate, measures to mitigate any negative consequences.

In the event of a high risk to the rights and freedoms of an individual, Armen will also notify the users of the Site concerned.

A « cookie » is a text file kept in the memory and hard drive of your computer when you are accessing a web page. Cookies are used to facilitate the smooth functioning of websites, in particular by providing information to the owners of the websites or third parties. For example, they allow to analyze and record visitors’ technological preferences and to offer tailormade services.

When you will first access this website, you will be informed that cookies may be installed on your device if you agree thereto and you will be invited to accept or decline the use of cookies depending on identified purposes.

Depending on the choice made on your first connection or if you are using functionalities of your browser preventing the use of cookies, it is possible that you cannot benefit from all the functionalities offered by this website and that we cannot notably keep record of your choices and preferences. Armen declines any responsibility in this respect.

In the event cookies would be used to collect your personal data, such data would be treated and kept in accordance with the confidentiality policy available above.

This website may include links to other websites which are external to Armen including by the presence of hyperlinks. Armen declines any responsibility with respect to the contents of such external websites over which it has no control. Such links do not constitute, in any event, approval or partnership between Armen and those websites, which are subject to their own terms of use and data protection policies.

This website, as well as any document from or extracted from the website, includes confidential information which is protected by applicable intellectual property rights and whose use is authorized for information purposes only and for a private and personal use in the context of the management of your investment in the funds managed by Armen. Any use, reproduction, transcript, modification that could be performed for any other purpose is expressly prohibited without any prior written request addressed to Armen.

It is also prohibited to copy, amend, create any derivative work, reverse the design or assembly or by any other means seek to find the source code, sell, allocate, sub-license and transfer in any manner the software or any rights relating to the software being used in relation to the website, notably in order to gain a non-authorized access to the services and to access the website by any other means than the interface being provided by Armen.

Thus, in the absence of the contrary, the intellectual property rights over the documents included on the website and each of the elements designed for this website are Armen’s exclusive property and Armen does not grant any license, nor any other rights than the right to consult the website.

ARMEN tries its best to guarantee the accuracy and updating of the information posted on this website, and reserve right to correct its content, anytime, without prior notice. Users are warned that they are responsible for seeking information through other means, for example by phoning our office. We therefore accept no responsibility: for any imprecision, inaccuracy or omission dealing with information posted on this website; for any damage resulting from fraudulent intrusion of user, having resulted in an alteration of information available on the webpage.

External websites, with hyperlinks to this webpage are not controlled by ARMEN, which therefore accepts no responsibility for their content.These hyperlinks are in no way equivalent to approbation or partnership with ARMEN, these external websites being subjected to theirownterms and conditions, and their own privacy policies.

The products, brand names, signatures and brand images mentioned on his webpage are owned by their respective companies.