Ced, World Centre of Excellence for Destinations, a joint-stock company headquartered UQAM Campus, Pavillon JE, 3e Floor, P.O. Box 8888, centre-ville branch, 1564 Saint-Denis Street, Montréal, Qc, Canada H2X 3K2, (“we”) is responsible for the processing of your personal data. The purpose of this document is to inform you of how we use and protect your personal data, as well as the reasons why we process this data.
This information applies equally to all Ced products and services, and it should be understood that additional information may be provided to you if necessary when you purchase a particular product or service.

1. What personal data are we collecting and working with?

We collect and use only the personal data that we need for the purposes of our business operations, which allow us to offer you personalized and quality services.

We may collect different categories of personal data from you, including:

• Identification and contact information (surname, first name, place and date of birth, photo, passport and identity card numbers, postal and e-mail addresses, telephone number, gender, age and signature);
• Identification and authentication data, in particular when using Ced services (technical logs, computer traces, information on security and use of the terminal, IP address);
• Tax data (tax number, tax status, country of residence);
• Family situation (marital status, marital fiscal regime, number of children);
• Employment information (employment, name of employer, pay, pay slip);
• Various legal documents (deed of assignment, deed of succession, deed of resale of stock market securities);
• Banking, financial and transaction data (bank details, card number, transaction data, including transfer information, investor profile, value of your assets);
• data related to the use of subscribed products and services in connection with banking, financial and transaction data;
• data relating to interactions with us: on our website, on our application, on our pages, on social networks, during interviews and telephone or video conversations, in emails.

The data we use may be collected directly from you or obtained from the following sources for the purpose of verifying or contributing to our databases:

• Publications and databases made accessible by the official authorities (Official Journal)
• Third parties such as business intelligence, anti-fraud agencies, in accordance with data protection regulations;
• Internet sites and social media pages containing information you have made public and databases made public by third parties.

2. Special cases of data collection, including indirect collection

Ced may collect information about you although you are not a Ced customer.
The following list (non-exhaustive) are examples of personal data collected by Ced from non-clients, such as:
• Prospects, guarantors, agents;
• Legal representatives, corporate officers and authorized persons of a Ced client corporation if we have a company as a client;
• Beneficial owners and shareholders of a Ced client corporation;
• Principals or beneficiaries during transactions made in connection with a Ced customer;

3. Why and how do we use your personal data?

A. To comply with our legal and regulatory obligations
We use your personal data to fulfill various legal and regulatory obligations, including:
• The fight against both money laundering and the financing of terrorism;
• Compliance with applicable legislation on international sanctions and embargoes;
• The fight against tax fraud, compliance with tax audits and reporting obligations;
• Responses to official requests from duly authorized public officials or judicial authorities.

B. To execute a contract with you or provide you with pre-contractual information
We use your personal data to:
• Provide you with information about our products and services;
• Assist you with transaction requests;
• In the context of customer relationship management, in particular:
• Evaluation of your needs and your knowledge, for example in the field of crypto assets;
• The security of the payment services you use.

C. To serve our legitimate interests
We use your personal data to set up and develop our products or services, optimize our risk management and defend our interests in court, including for the purposes of:
• Proof of transactions or operations;
• IT management including infrastructure management (eg exchange platforms) and business continuity including personal safety;
• Prevention of fraud and abuse (security measures, control of unusual transactions);
• establishment of anonymized statistical models, tests, for research and development, in order to optimize Ced’s risk management or improve our offer;

D. To respect your choice when we ask for your consent for a particular service
In some cases, consent is required to process your data, for example:
• When the purposes described above lead to an automated decision-making process that has legal effects that affect you or affect you significantly, we will inform you separately of the underlying reason as well as the expected significance and consequences of this decision.

4. To which categories of entities can your personal data be disclosed?

In order to fulfill the above purposes, we disclose your personal data only to :
• financial, judicial or state agencies, public bodies on request and to the extent permitted by regulation;
• certain regulated professions such as lawyers, notaries and auditors.

5. Data transfer outside the European Economic Area

In case of international transfers from the European Economic Area (EEA):
• If the European Commission has made a decision of adequacy, recognizing that country a level of protection of personal data equivalent to that provided by the EEA legislation, your personal data will be transferred on this basis;

To obtain a copy of these texts or to know how to access them, you can send a written request to our Data Protection Officer by mail addressed to Ced – Data Protection Officer, 18 Avenue du Ponant 92390 Villeneuve-la-Garenne.

6. How long do we keep your personal data?

We store your personal data for the longest period of time necessary to comply with the applicable legal and regulatory provisions or another period taking into account operational constraints, effective management of customer relations and responses to legal or regulatory requests.
With regard to customers, the majority of information is kept for a minimum of 5 years in accordance with regulatory requirements.

7. What are your rights and how can you exercise them?

In accordance with the applicable regulations, you have different rights, namely:
• Right of access: You can obtain information about the processing of your personal data as well as a copy of these personal data.
• Right of rectification: If you believe that your personal data are inaccurate or incomplete, you may require that your personal data be modified accordingly.
• Right of cancellation: you may require the erasure of your personal data within the limits of what is permitted by the law.
• Right to limit processing: you can request the limitation of processing of your personal data.
• Right of opposition: You can oppose the processing of your personal data, for reasons related to your particular situation. You have the absolute right to oppose the processing of your personal data for the purposes of commercial prospecting, including profiling related to this prospection.
• Right to the portability of your data, when this right is applicable, you have the right that the personal data you have provided to us are returned to you or, where technically possible, transferred to a third party;
• Right to set guidelines for the retention, erasure or disclosure of your personal data, applicable after your death.
• Right to withdraw your consent: if you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time.

You can exercise the rights listed above, by mail addressed to our Data Protection Officer at Ced – Data Protection Officer, UQAM Campus, Pavillon JE, 3e Floor, P.O. Box 8888, centre-ville branch, 1564 Saint-Denis Street, Montréal, Qc, Canada H2X 3K2 or on our website.
In accordance with the applicable regulations, you are entitled to lodge a complaint with the competent supervisory authority such as the CNIL (National Commission for Informatics and Liberties) in France.

8. How can you review the changes to this personal information and privacy document?

In a world in constant technological evolution, we regularly update this information document.
We invite you to read the latest version of this document on our site and we will inform you of any substantial changes through our site.

9. How to contact us?

If you have any questions about the use of your personal data covered by this document, you can contact our Data Protection Officer by mail, addressed to Ced – Data Protection Officer18 Avenue du Ponant 92390 Villeneuve-la-Garenne, who will process your request.

10. Miscellaneous

Information about our cookies policy and computer security is available on our website.