Terms & Conditions
1. Legal Notices
This site is published by
22 boulevard Malesherbes 75008 Paris
AMF authorisation n° GP-202228
A French société par actions simplifiée with a share capital of €285 000
920 121 084 RCS Paris
Editorial Director: Bénédicte de Raphélis Soissan
The content on the website - including logos, trademarks, photos and other original material - should not be reproduced without prior written consent.
The site may include links to other websites as a convenience. We do not make any express or implied warranties with regard to the information, material, products, or service that are contained on or accessible through linked sites.
The Website is subject to French law; the French courts have exclusive jurisdiction in the event of a dispute. An amicable settlement should be sought before any referral to the competent jurisdiction.
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Users can change their Internet browser settings to inform them of the presence of cookies and to block them if they wish. Doing so may break certain functionalities of this website.
To learn more about cookies and how to manage them, visit www.AboutCookies.org.
2. Policy on processing personal data
Registered office: 22 boulevard Malesherbes, 75008 Paris
Information and consent
What purpose will Emblem process the user’s personal data and for how long?
Depending on the User’s requests, the personal data collected will be processed by Emblem in accordance with the following purposes:
- To comply with its legal and regulatory obligations;
- To enter into a contract with you or contact you, at your request, with a view to entering into a contract;
- To communicate regularly on its latest news;
- To invite you to participate in the events it organizes.
- The User’s data will be kept for the period required to fulfil each purpose or until the User opposes or revokes their consent.
What user data will Emblem process?
Emblem and its affiliates may process the following categories of data, depending on the request made by the User:
- Identification data: name, surname(s)
- Contact details: Postal address, mobile telephone number, email address.
- Personal data: date of birth, gender, nationality.
What is the legitimation for the processing of your data?
The data processing required in fulfilment of the aforementioned purposes that require the User’s consent cannot be undertaken without said consent.
Likewise, in the event that the User consent to any of the processing, this will not affect the legality of the processing carried out previously.
To revoke such consent, the User may contact by an email sent to email@example.com, with the Reference “Data Protection”.
To which recipients will the user’s data be disclosed?
The recipients indicated in this section may be located within or outside the European Economic Area, in the latter case international data transfers must be duly legitimated. Suppliers of Emblem for the adequate fulfilment of the legal obligations and/or the purposes previously indicated.
One of the purposes for which Emblem processes the User’s data will be for the sending of information on new financial products, through electronic and/or conventional means, with information concerning products, services, promoting events or relevant news for Users.
Whenever any communication of this type is made, it will be sent solely and exclusively to those Users who have authorized its reception and/or who have not previously expressed their refusal to receive them.
To carry out the foregoing task, Emblem may analyze the data obtained in order to create user profiles that allow a more detailed definition of the products that may be of interest.
In the event that the User wishes to stop receiving from Emblem, he/she may request cancellation of the service by sending an email to the following email address: firstname.lastname@example.org
Exercise of rights
The User may send an email to the address email@example.com, with the Reference “Data Protection”, to:
Revocation of consent granted.
- To obtain confirmation about whether personal data concerning the User is being processed at Emblem.
- To access their personal details.
- To rectify any inaccurate or incomplete data.
- To request the deletion of their personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
- To request the portability of your data.
Emblem will process the User’s data at all times in an absolute confidential way and maintaining the mandatory duty to secrecy with regard to said data, in accordance with the provisions set out in applicable regulations, and to this end adopting the measures of a technical and organizational nature required to guarantee the security of their data and prevent them from being altered, lost, processed or accessed illegally, depending on the state of the technology, the nature of the stored data and the risks to which they are exposed.
3. Regulatory notices
Emblem has implemented and maintains an operational procedure in order to quickly and efficiently process complaints made by its clients. Any information on this procedure for handling complaints may be obtained by sending a written request to the company.
Any complaint may be referred to Emblem, 22 boulevard Malesherbes, 75008 Paris, France.
The management company will acknowledge receipt of the complaint within a maximum of ten working days from the date it was received unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint.
In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman, at the following address: Autorité des marches financiers, Madame Marielle Cohen-Branche, Médiateur de l’AMF, 17 place de la Bourse, 75082 Paris Cedex 02. The AMF mediation request form at the Mediation Charteur is available online at www.amf-france.org.
Prevention and management of conflicts of interest
Emblem has implemented a system of prevention, assessment and management of conflicts of interest.
In accordance with the applicable regulations, Emblem has put in place organisational measures and administrative procedures to detect and manage conflicts of interest that may arise in the course of its activities.
The prevention and management of conflicts of interest within the Management Company are in line with the general principles laid down by the AIFM Directive and its Delegated Regulation, which notably mention the following obligations:
- Establishing a policy for the management of conflicts of interest;
- Detecting potential situations of conflict of interest;
- Keeping a register of proven conflict of interest situations and the management measures implemented
- Informing clients when conflicts of interest have not been resolved.
The conflict of interest management policy is available free of charge at the head office of the management company at 22 boulevard Malesherbes, 75008 Paris and will be provided within 8 days upon request by e-mail or by letter.
The ESG Charter as well as the legal and regulatory information are available on request from Emblem.
Sustainable Risk Finance Disclosure Regulation (2019/2088) (The « Disclosure Regulation »)
Emblem makes the following disclosures in accordance with Articles 3(1), 4(1)(b) and 5(1) of the Disclosure Regulation.
1- Approach to sustainability risk
Sustainability risk refers to environmental, social or corporate governance (“ESG”) event or condition
that, if it occurs, could cause an actual or a potential material negative impact on the value of an
investment of the Fund (the “Sustainability Risks”).
The Management Company’s investment team takes ESG criteria into account in investment
decisions, but not in a preponderant manner (Article 6 of the SFDR Regulation).
2- Consideration of sustainability adverse impacts
Although ESG and sustainability risk is important to Emblem and we take it seriously, we do not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the Disclosure Regulation.
The Management Company has however implemented a series of exclusion-based policies to manage the most severe sustainability risks. Such exclusion policies result in the Management Company limiting investment into prohibited sectors, companies and underlying assets.
This is our current position, which we will keep under review.