Adopted on January 26th 2021
LOGICAL PICTURES, whose registered office is 4 rue de la République 69001 Lyon, France, registered under the Commercial Registry of Lyon under number 847 756 764 (hereinafter referred to as “LOGICAL PICTURES”), and LOGICAL CONTENT VENTURES, a simplified joint-stock company, with variable capital of a minimum of €100,000, whose registered office is located at 59-61 Passage Choiseul Paris 75002, France (hereinafter referred to as “LCV”) are co-data controller of Personal Data under this Privacy Policy, which relates to:

The LOGICAL CONTENT VENTURES PLATFORM available on www.logicalcontentventures.com/investor-login (hereinafter referred as the “Platform”), and
The following website : www.logicalcontentventures.com (hereinafter referred to as the “Website”).

Both LOGICAL PICTURES and LCV are committed to safeguarding Your privacy. Contact us at investing@logicalcontentventures.com if You have any questions or problems regarding the use of Your Personal Data and we will gladly assist You.
By duly accepting the Terms and Conditions of the Platform and any services available on them (hereinafter designated as the “Service”), You consent to the Processing of your Personal Data as described in this Privacy Policy.

1. Definitions used in this Privacy Policy
2. Personal Data protection principles
3. Data Subject’s rights
4. Personal Data we gather
5. How we use Your Personal Data
6. Who else can access Your Personal Data
7. How we secure Your Personal Data
8. Children
9. Cookies and other technologies we use
10. Contact information

1. Definitions

Any term not defined below but starting with a capital letter is defined in the T&Cs.
Personal Data – any information relating to an identified or identifiable natural person.
Processing / Processed – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data Subject – any natural person whose Personal Data is being Processed, either as a User, a Subscriber or an Investor as those terms are defined in the T&Cs.
You/Your (either capitalized or not) – refers to the concerned natural person reading the Privacy Policy whose Personal Data is being processed.
We/us (either capitalized or not) – LOGICAL PICTURES and LCV, as co-controller of Personal Data under the applicable regulations.
T&Cs – the Terms and Conditions of the Platform.

2. Personal Data Protection Principles

We promise to follow the following Personal Data protection principles:

Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider Your rights before Processing Personal Data. We will provide You information regarding Processing upon request.
Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
Processing is limited with a time period. We will not store Your personal data for longer than needed.
We will do our best to ensure the accuracy of data.
We will do our best to ensure the integrity and confidentiality of data.

3. Personal Data Subject’s rights

You have the following rights:
1. Right to information – meaning you have the right to know whether your Personal Data is being Processed; what data is collected, from where it is obtained and why and by whom it is Processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data collected.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in the seven (7) following grounds you can request for your Personal Data to be erased from our records:
– Your Personal Data is used for canvassing purposes;
– Your Personal Data is no longer necessary in relation to the purposes for which such Personal Data is collected or processed by Us;
– You request to withdraw Your consent to the Processing of Your Personal Data by Us and where there is no other legal ground for the Processing;
– You object to the Processing of Your Personal Data by Us and there is no overriding legitimate grounds for the Processing,
– Your Personal Data have been unlawfully processed;
– Your Personal Data have to be erased for compliance with a legal obligation in European Union law or Member state law to which We are subject;
– Your Personal Data have been collected when You were a minor in relation to the offer of information society services (blog, forum, social network, website, etc.).
5. Right to restrict Processing – meaning where one of the four (4) following situations applies, you have the right to restrict the Processing of your Personal Data:
– When you have exercised Your right to rectification: You contest the accuracy of Your Personal Data, for a period enabling Us to verify the accuracy of your Personal Data;
– When You have objected to Processing, pending the verification whether Our legitimate grounds override those of Your Personal Data;
– When We no longer needs Your Personal Data for the purposes of the Processing, but You requires them for the establishment, exercise or defense of legal claims,
– When the Processing is unlawful, and You oppose the erasure of Your Personal Data and request the restriction of their use instead.
6. Right to object to Processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. You can exercise this right not to be subject to a decision based solely on an automated Processing anytime the results of such decision produces legal effects or affects you significantly.
8. Right to Personal Data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is technically possible, as a direct transfer from one processor to another.
9. Right to file a complaint – in the event that we refuse your request under the right to access, we will justify our refusal. If you are not satisfied with the way your request has been handled, please contact us.
10. Right for the help of supervisory authority – meaning you have the right to seek help from the applicable supervisory authority and the right for other applicable legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right to withdraw any given consent for Processing of your Personal Data.

4. Personal Data we gather

Personal Data You have provided us with
These are : e-mail address, first name, last name, legal entity, country of origin, legal representative’s name and first name, personal data related to your fiscal residency, information regarding your organization (address, size, activity, financial and patrimonial situation).

Personal Data automatically collected about you
This includes information that is automatically stored by cookies and other session tools. On our Platform no Personal Data is automatically collected through cookies.

Personal Data from our partners
Our partner BNP PARIBAS is collecting and processing Personal Data directly from you to the KYC process for the Services and on its own platform, in compliance with its own privacy policy.

5. How we use your personal data

We use Your Personal Data in order to:

perform Our Services and more specifically to allow your Subscription;
allow the management of your User Space and Security Tokens portfolio;
manage our contractual relationship;
fulfil an obligation under law or contract.

We use your Personal Data on legitimate grounds and/or with your consent.
Purpose 1: based on your consent, to perform our Services
Purpose 2: based on your consent, to allow the management of your User Space
Purpose 3: based on legitimate grounds, to manage our contractual relationship
Purpose 4: based on legitimate grounds, to comply with legal obligations and/or use of your Personal Data for purposes permitted by law.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the Personal Data was gathered. To do this, we will ensure that:

the link between purposes, context and nature of Personal Data is suitable for further Processing;
the further Processing would not harm your interests and
there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.

6. Who else can access Your Personal Data

We do not share your Personal Data with third parties outside of our trusted partners (such as BNP Paribas) or subcontractors as described below. Some of those trusted partners or subcontractors may have access to some of your Personal Data in order to manage the back-offices of the Website and / or the Platform.

Our subcontractors:

The Blockchain XDEV, a company duly organized under the laws of France, having its registered office at 8 rue Barthélémy d’Anjou, 92100 Boulogne Billancourt, France RCS: Nanterre 847 672 250: it is acting as the hosting company of the Platform and, in order to administer the Platform and Services, it may have access to your Personal Data;
BLUEHOST – ENDURANCE INTERNATIONAL GROUP, a company duly organized under the laws of Massachussets (USA), having its registered office at 10 Corporate Drive Suite #300 Burlington, MA 01803 (USA): such company is the hosting company of the Website and has NO access to your Personal Data.

We only work with subcontractors who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so.

7. How we secure Your Personal Data

We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
Note that you have to keep your username and password secret concerning your account.

8. Children

We do not intend to collect or knowingly collect information from children. We do not target children with our Services.

9. Cookies and other technolo-gies we use

We do NOT use cookies and/or similar technologies to analyze customer behavior, to administer the Site or Platform, to track Data Subject’s movements, or to collect information about you.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. If cookies were used, we inform you that we would be the sole entities to have can access to them. You would be abled in such case to control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

10. Contact Informa-tion

Supervisory Authority
Commission Nationale de l’Informatique et des Libertés
3 place de Fontenoy, 75007 Paris
+33 (0) 1 53 73 22 22
Changes to this Privacy Policy
We reserve the right to make change to this Privacy Policy.