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Privacy policy

Data privacy is essential for Enerfip, and in accordance with the values of transparency that we defend we would like to inform you about how we use your personal data;

We therefore make available to you, in accordance with current regulations, our data processing and protection policy.

Data collection at Enerfip

As part of our activity as a European service provider of crowdfunding services, we collect certain personal data, to which you expressly consent by using the site.

When is your data collected?

We collect information about you when you:

  • visit our platform

  • create an account

  • communicate** with us

We may collect this information only after you have identified yourself on the site or provided us with your identity (at an event for example).

Why do we collect data?

This information is collected for the following purposes:

  • to enable you to access the Services available on the Site,

  • the provision of investment services in accordance with Regulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European providers of crowdfunding services for businesses (order receipt, transmission and placement services);

  • the proposal to open an "EnerJ" account for minors or an Investor account for legal entities,

  • to draw up a declaration of suitability for the investments proposed on the Enerfip website, in accordance with Regulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European providers of crowdfunding services for businesses (order receipt, transmission and securities placement services).

Preserving the confidentiality of your data

The personal data collected is not used for any other purpose and the Company does not market this personal data.

None of the information transmitted by Users when creating their Profile, apart from their user name, is visible to other Users. This information is protected by a user name and password so that only the User has access to his/her personal information.

How long does Enerfip keep your data?

The length of time personal data is kept depends on the purpose of the processing and the circumstances in which it is collected:

  • It is in principle five (5) years due to the regulatory obligations applicable to Enerfip in its capacity as a European provider of crowdfunding services;

  • It may be aligned with the duration of the investors' contractual commitment as a result of their consent to the investor services agreement if this is longer for the purposes of the Fundraising. This second situation arises in the case of an investment. It should be noted that in this case, the five (5) year period does not begin to run until the last repayment made in connection with this investment. However, an intermediate archive may be requested from Enerfip once the last repayment has been made in the context of the last investment held in Enerfip's portfolio.

We use your data to process the financial questionnaire in order to draw up a declaration of suitability and a simulation of your ability to bear losses linked to your investment.

What personal data is collected?

When you are a Registered Investor, we collect and store the information that you provide directly when you create your account:

  • your password

  • your email address.

When you are an Approved or Prospective Investor, we collect and store the information you provide directly when you complete the registration form:

  • your last name

  • your first name

  • your date of birth and place of birth

  • your maiden name

  • your postal address

  • your telephone number

  • your proof of identity and address

  • your answers to the registration questionnaire (financial knowledge, anti-money laundering and financing of terrorism)

  • your tax preferences and options, and

  • the last IP address of your identification*.

This last data is used, in collaboration with our internet service provider, only if we consider it necessary to enforce our GTCUs or to protect our services or our customers, or at the request of the legal authorities.

If you are a legal entity, we also collect your information and proof of identity relating to your legal entity (company registration number, address of the legal entity, articles of association, commercial register extract, declaration of beneficial owners).

We may also collect the data of a valid bank account opened in one of the EU countries where we operate. However, data relating to online payment is processed and stored directly by our banking partner, the investment service provider (see below), and does not pass through Enerfip's servers.

At the same time, we collect and store server logs (IP addresses and pages visited) for a period of 8 days.

Is your information shared?

We do not share information about you in any way other than as described in this Privacy Policy.

However, we may transfer or store certain information about you with third parties (including other EU member states):

  • public authorities in the context of legal obligations

  • project promoters:** After a subscription, the project promoter is required by law to keep and update a register of securities issued. To do this, they need to know the identity of the investors in the fundraising. We therefore send them your surname, first name and tax address so that, in accordance with the law, they can include you in the register of subscribers. In the case of fundraising for projects awarded by the Commission de Régulation de l'Energie, proof of council tax. Your telephone numbers and email address will only be sent to them if Enerfip is wound up or if the contract between the project owner and Enerfip is terminated as a result of serious misconduct on the part of Enerfip. Enerfip is sometimes delegated to keep the register.

  • to our payment service provider (PSP):** Enerfip is legally obliged to use an electronic money institution or an approved payment institution in order to manage your funds securely and to verify your identity as part of the fight against money laundering and terrorist financing (LCB-FT). As a result, we are obliged to pass on your email address, surname, first name, proof of identity, proof of address and IP address to our PSP, which stores them in accordance with the law, as mentioned in their T&Cs, which you can consult here. Your bank details are also stored by our PSP.

  • to the company selected to carry out the extinctive management** (if applicable): In the event that Enerfip disappears, a service provider will be selected to ensure your repayments until all your current investments are extinguished. By default, our PSP will provide this extinctive management

  • Our other third-party service providers:** In order to comply with our regulatory obligations, manage our platform and improve your experience, we use third-party service providers (server management, customer service, emailing, CRM, etc.). These suppliers have all provided us with their confidentiality charter and data protection policy, updated in compliance with the General Data Protection Regulation.

About cookies

What are cookies?

The word itself refers to the "Fortune cookie", the little biscuits with a hidden message. When you surf the internet, each of the sites you visit stores various messages on your browser (Google Chrome, Firefox, Internet Explorer etc.). This information can be used in several ways. For example, to be able to recognise you and not ask you for authentication each time you visit our site. This is an example, but each platform has its own way of using these messages during your browsing

Indispensable cookies

Here are all the cookies that are essential for the platform to function properly and that we use by default (you do not have the option of refusing them):

  • session cookies**, so that you can access and carry out transactions on your passbook and go back and forth on our platform without having to log in again each time you open a new page. For security reasons, these cookies are valid for 8 hours.

  • cookies generated by multimedia playback (tutorial videos or projects for example, to remember the position of the playback head). These cookies are external to Enerfip (used by Youtube in particular and we cannot restrict them from the moment you view a video hosted by a third party).

  • tracker" authentication cookies if you come from partner sites (for example http://crowdlending.fr or https://argent-et-salaire.com/ ) in order to provide you with the service and remuneration associated with the partnership.

The purpose of these cookies is to ensure the normal operation of the site, without any commercial purpose.

Non-essential cookies

Since the European directive known as the "telecoms package" came into force on 25 May 2018, all web platforms are required to inform you of the use of cookies that are not essential to the provision of the service. The use of these cookies can be refused by the Internet user by simply clicking on the yellow icon at the bottom left of a browser page via our non-essential cookies manager provider axeptio.

These include :

  • cookies related to advertising operations

  • social network cookies** generated by sharing buttons

  • audience measurement** cookies

  • behavioural tracking** cookies

User behaviour tracking cookies used for statistical purposes on our website

As Internet users, we're probably just like you in that we don't really like to be tracked in our every move. We wanted to reflect this approach in our use of cookies, so we try to keep our cookie settings as minimalist as possible. However, we do require some cookies in the following cases,

  • in order to provide a better and more efficient service, it is useful for us to collect statistical data on the pages of the site whose ergonomics can be improved, to know the defects of the platform and the effectiveness of certain changes that we make to it

  • in order to measure the effectiveness of certain commercial and marketing actions, it is useful for us to measure the site's audience and the geographical origin of this audience.

To this end, the following third-party cookies can be activated by you:

Matomo (anonymous audience measurement): As of 14 November 2019, we have activated a new audience measurement and geographical location cookie in order to measure the impact of marketing actions carried out on behalf of project sponsors or on our own behalf. It enables us to find out the origin of the traffic, its volume and the location of the traffic (the city at the finest level). If you wish to oppose the tracking of your browsing, click here.

  • Google Ads**: from September 2022, we have activated a new tracker in order to measure the performance of our marketing actions and discover new opportunities for relationship development. This approach allows us to be visible on specific searches by our web users.

Cookie update

  • Crowdlending (2017) A tracker is set up for users of the Crowdlending aggregator.

  • Use cookie (3 October 2019) As of 3 October 2019, we have activated a cookie with the aim of obtaining statistics on the use of our site. It allows us to improve usability and user experience by analysing your preferences and identifying pages where you encounter problems. These statistics are anonymised and processed as a cohort rather than on an individual basis. To do this, we use the Zoho PageSense service, which does not allow us to track your actions outside the enerfip.fr website. We do not use any Google services for this purpose. To put it plainly, this cookie does not enable us to identify your individual behaviour, but simply the behaviour of the average user.

  • Geographical cookie (14 November 2019)** As of 14 November 2019, in order to measure the impact of marketing actions carried out on behalf of project sponsors, we have activated a new cookie. It allows us to find out the origin of the traffic and the location (the city at the finest).

  • Axeptio implementation (29 December 2021)** As of 29 December 2021, non-essential cookies will be managed by our cookie management service provider Axeptio.

What are your rights?

Access rights

You have the right to request information about the personal data we hold about you, including

  • the purposes of the processing; the categories of personal data concerned;

  • the recipients or categories of recipients to whom the personal data has been or will be communicated, in particular (i) the holders of the Project to which the investors have subscribed, (ii) Enerfip's PSP in the context of the monitoring of cash flows linked to the raising of funds, as well as, where applicable, in the event of extinctive management, (iii) certain Enerfip service providers (server manager, customer service management service provider, e-mailing service providers) and (iv) in the event that Enerfip is no longer able to carry out its activities, the European provider of participative financing services that would take over these activities; In addition, and in accordance with applicable national and European regulations, investors' personal data may be transmitted to the public authorities as part of a specific investigation.

  • the identity and contact details of Enerfip in its capacity as data controller, in particular the e-mail address: privacy@enerfip.eu;

  • the period for which personal data will be kept, i.e. five (5) years, due to the regulatory obligations applicable to Enerfip in its capacity as a European provider of participative financing services, or the duration of the contract for the provision of investor services, whichever is greater;

  • the existence of the right to request from the data controller the rectification or erasure of personal data, or a restriction on the processing of personal data relating to the data subject, or the right to object to such processing;

  • the right to lodge a complaint with a supervisory authority;

  • the fact that the requirement to provide personal data to Enerfip is both contractual and regulatory in nature and that Enerfip will not be able to provide the investment services in accordance with Regulation (EU) 2020/1503 of the European Parliament and of the Council of 7 October 2020 on European providers of participatory finance services for entrepreneurs (order reception and transmission and securities placement services), in the absence of the provision of such information ;

  • where personal data is not collected from the data subject, any available information as to its source;

For any additional copies requested, we will ask you to pay the sum of 10 euros based on administrative costs.

You can contact us via confidentialite@enerfip.fr to obtain your personal data.

Right of portability

We store the personal data you send us on a durable medium.

You have the right to obtain a copy of this data, transferred in a structured and common format.

This only concerns the personal data you have sent us.

At your request, we will do our best to ensure the portability of your data to another service provider if you do not have a current project with Enerfip.

In the event of the cessation of our activity, we will make our best efforts, at your request or with your consent, to ensure that personal data is transmitted directly to the structure ensuring the resumption of the Company's activity.

Right of rectification

We regularly update the personal data we collect.

You have the right to request rectification of your personal data if it is inaccurate or incomplete. You can also consult and modify your information at any time in your Enerfip profile.

Your right to rectify or supplement information is without prejudice to your obligation to provide us only with accurate and complete information, and we cannot be held responsible for the consequences of providing inaccurate information, in particular in answers to the financial questionnaire and in signed subscription forms.

Right of deletion

You have the right to request the deletion of any personal data processed by Enerfip at any time

We will process requests for deletion as quickly as possible.

We will accept such requests where the personal data is no longer necessary for the purposes for which it was collected or processed.

We will not accept such requests if you have a current investment, if you have money in your passbook or if the period for which we are required by law to retain personal data has not expired.

Right to object to the processing of data on the basis of a legitimate interest

You have the right to oppose the processing of your personal data on the basis of a legitimate interest.

Enerfip will stop using your personal data; if you are an investor or project holder and an investment or project is still in progress, we will not be able to follow it up, as the data processed is done so to enable the performance of a contract and due to legal and regulatory obligations.

Right of limitation

You have the right to request that Enerfip limit the use of your personal data in the following circumstances:

  • you challenge the accuracy of your personal data, for a period of time that allows us to verify the accuracy of that personal data;

  • the processing is unlawful and you object to the deletion of your personal data and request instead that their use be restricted;

  • We no longer need your personal data for the purposes of processing, but you still require it for the establishment, exercise or defence of legal claims;

  • you objected to the processing during the verification as to whether the legitimate grounds we are pursuing override yours.

Where processing is restricted, we will ensure that personal data is, with the exception of retention, only processed with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or on important Union or Member State public interest grounds.

We will inform you before the processing restriction is lifted.

Exercising your rights

We ensure that your personal data is always used in a way that is transparent, accurate and compliant with the law.

You can send any requests concerning your personal data to privacy@enerfip.eu , specifying "Personal data" in the subject line of the message.

Right of complaint to a supervisory authority

If you have any difficulty concerning your personal data, or if you feel that Enerfip is using your personal data inappropriately, please do not hesitate to inform us by any means.

You also have the right to lodge a complaint with the competent authority:

Commission Nationale de l'Informatique et des Libertés (CNIL) on its website: https://www.cnil.fr/fr/plaintes , or by post by writing to: CNIL, 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07

Legal information

Enerfip respects the privacy of Internet users and complies strictly with Law No. 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties, as amended, known as the "Data Processing and Individual Liberties" Law, and since 25 May 2018 with European Data Protection Regulation (GDPR) No. 2016/679.

As such, the site has been declared to the CNIL under receipt numbers 1817465, 1817462 and 1817463.

We take data protection very seriously and therefore have a dedicated customer service department to answer any questions you may have about your aforementioned rights. You can contact us at confidentialite@enerfip.fr.

Updating our privacy policy

Our privacy policy is frequently updated. The latest version is always available on our website

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