Privacy Policy

1. Who are we?

The protection of your personal data is a priority for Diversicap. This Privacy Policy explains how we process your personal data when you use the website [https://www.diversicap.com] (the "Website") and our services.

The data controller is Diversicap SAS, a French simplified joint-stock company (SAS) with a share capital of €1,000, registered with the Trade and Companies Register of Paris under number [TODO: RCS number], whose registered office is located at 21 rue Monsieur, 75007 Paris, France, hereinafter referred to as "we", "us" or "our".

We act in compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 – "GDPR") and applicable French data protection law.

2. What data do we collect?

"Personal data" means any information that identifies you directly or indirectly. We may collect the following categories of data:

• Identification data: first name, last name, email address, phone number, postal address, nationality, date and place of birth, etc.
• Financial and wealth data: information relating to your financial situation, tax residency, income and wealth, where required by regulation.
• KYC / identification documents: copy of your ID document, proof of address, and any information required for anti-money laundering and counter-terrorist financing (AML/CFT) obligations.
• Login and technical data: IP address, connection logs, browser type, operating system, device identifiers, etc.
• Usage data: history of your actions on the Website, pages visited, products viewed, subscriptions and investments made, amounts invested, payment methods used.
• Contact data: all information you choose to provide when contacting us (forms, email, chat, etc.).

3. On what legal bases and for what purposes do we use your data?

We process your data on the following legal bases and for the following purposes:

• Performance of a contract: creating and managing your Account, providing the Services, processing your investments, giving you access to your Dashboard, and managing our relationship with you.
• Compliance with legal and regulatory obligations: obligations relating to financial markets, AML/CFT, tax and accounting rules, and regulatory reporting.
• Legitimate interests: improving the Website and user experience, ensuring the security of the platform, preventing fraud, and conducting limited business development with existing clients.
• Your consent: sending newsletters and marketing communications where required by law, placing non-essential cookies, etc. You can withdraw your consent at any time.

4. How long do we keep your data?

We keep your data only for as long as necessary to achieve the purposes described above and to comply with our legal obligations, for example:

• Account and contractual data: for the duration of the contractual relationship, then archived for the applicable limitation period.
• KYC / AML/CFT data: for the statutory retention period required by law (typically several years after the end of the relationship).
• Prospecting and marketing data: up to 3 years after the last contact or until you withdraw your consent or object to such processing.

5. Who can access your data?

Access to your personal data is limited to:

• our internal teams (support, operations, compliance, IT, etc.);
• our service providers and subcontractors (hosting providers, payment institutions, KYC providers, electronic signature providers, email and CRM tools, analytics tools, etc.);
• public or judicial authorities, where this is necessary to comply with our legal obligations or to protect our rights.

6. Are your data transferred outside the European Union?

Your data may be hosted or processed outside the European Union, for example where some of our service providers are located in third countries.

In such cases, we ensure that appropriate safeguards are in place, in accordance with the GDPR, such as adequacy decisions by the European Commission, standard contractual clauses, or equivalent mechanisms.

7. What are your rights?

Under applicable data protection law, and subject to certain conditions, you have the following rights:

• right of access to your personal data;
• right to rectification of inaccurate or incomplete data;
• right to erasure ("right to be forgotten") in certain cases;
• right to restriction of processing;
• right to object to processing, in particular for marketing purposes;
• right to data portability, for data you have provided to us;
• right to withdraw your consent at any time where processing is based on consent;
• right to define guidelines regarding the fate of your data after your death (where this is provided by applicable law).

8. How do we protect your data?

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction (access controls, encryption, logging, internal policies, etc.).

However, no system is completely secure. You are also responsible for keeping your login details confidential and must inform us immediately if you suspect any unauthorised access to your Account.

9. Cookies

We use cookies and similar technologies to operate the Website, measure its audience, improve your experience and, where applicable, provide personalised content.

For more information on how we use cookies and how you can manage your preferences, please refer to our Cookie Policy available on the Website.

10. Contact and Changes to this Policy

If you have any questions about this Privacy Policy or about how we process your personal data, you can contact us at:

We may update this Privacy Policy from time to time, in particular to reflect changes in law, regulation, our services or our internal practices. The date of the latest version will always appear at the top of this page.