Privacy Policy – end-users
May 2022
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MoreThan Capital – Privacy Policy - Users
This Privacy Policy is edited by MoreThan Capital.
The Company offers a platform MoreThan Capital (hereafter, the “Platform”) to its users which
have subscribed on the Platform and as such have a user account (hereafter, the “Users”).
The Platform is available at the following url address https://more-thancapital.
us.hivebrite.com.
The Company uses a solution called “Hivebrite”, which enables the import and export of user
lists and data, the management of content and events, the organization of emailing campaigns
and opportunity research and sharing as well as the management of funds and contributions
of any kind.
In this regard, as data controller, the Company is particularly aware and sensitive with regard
to the respect of its Users privacy and personal data protection. The Company commits to
ensure the compliance of the processing it carries out as data controller in accordance with
the applicable provisions of the “Loi n°78-17 dated January 6, 1978, relative à l’informatique,
aux fichiers et aux libertés” and the EU Regulation EU 2016/679 regarding data protection
dated April 27, 2016.
In order to do so, the Company has put in place an appropriate privacy policy which guarantees
an optimal level of protection of its Users’ data.
This privacy policy is intended for the Users of the Platform of the Company.
ARTICLE 1. COLLECTED PERSONAL DATA
1.1 When subscribing on the Platform
When subscribing on the Platform, the User is informed that its following personal data is
collected. The User commits to only provide accurate, exhaustive, and regularly updated data
regarding its identity, its content and any information in general. Under no circumstances shall
the Company be liable for any data that is illegal contrary to public order provisions.
In the event the User does not consent to the collection of the above-mentioned date, it shall
be informed that it cannot have access to the Platform.
1.2 During the use of the Platform
The User may validly publish, at its own initiative, any content on the Platform which shall be
kept by the Company.
The User commits not to publish any content which contains, including but not limited to, any
remarks/images/pictures, contrary to application legislation and regulations, to public order and
good morals, or affecting the rights of third parties, including but not limited to:
- Identity fraud of a third person;
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- Remarks/publish pictures or images that are violent, defamatory, offensive, malicious,
obscene, inciting to discrimination or hatred, racist, xenophobic, anti-Semitic,
condoning or approving war crimes, inciting to committing a crime, offense, act of
terrorism, or contrary to the security of minors;
- Counterfeiting the intellectual property rights of a third person;
- Commercial canvassing or elements that could be qualified as unfair competition.
In any event, Hivebrite shall not be liable for the content, accuracy, or up-to-date state of the
information freely published by the User.
The User consents that, following the publication of the content, its information will become
public on the Platform and that as such, same information will be published, modified,
translated, reproduced in any form and accessible, saved and reproduced by other Users and
the Company.
In most cases, Users post contents without previous moderation from the Company. The
Company does not alter the content or information of the User, except under exceptional
circumstances. The Company reserves its right to freely delete or amend the content or
information of the User, without prejudice to the Users.
In the case of delivery of content on the Platform which is contravenes with the present privacy
policy, applicable law or the rights of third parties, any person can inform the Company of the
existence of such Content at the following address: [email protected].
The User is informed that the Company does not collect any particularly sensitive data within
the meaning of applicable legislation and regulations.
1.3 Cookie data
The Company informs the User that Hivebrite, as well as its subcontractors, uses a tracking
technology on its terminal such as cookies whenever the User navigates on the Platform.
A cookie is a message that, subject to the User settings, is sent to its terminal when the User
navigates on a website. The aim is to collect data regarding the internet navigation of the User
to send tailor-made services to its terminal (computer, mobile phone or tablet).
The cookies that are sent to the User’s terminal are detailed under Article 2 of the present
privacy policy.
The purpose of the process of the data collected through the cookies and the settings of such
processing is detailed under article 9 of the present privacy policy.
ARTICLE 2. THE PURPOSE OF THE DATA PROCESSING
The Company and its subcontractors collect, process and host personal data that are freely
transferred by the User when accessing the services proposed by the Platform.
The Company only collects and processes the User’s personal data for the purpose for the
optimal implementation and use of the Platform that is put at its disposal.
ARTICLE 3. USER’S CONSENT TO THE COLLECTION OF DATA
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The Company informs the User that no personal data within the meaning of applicable
legislation and regulations shall be collected without the prior explicit consent of the User.
The User expresses its consent upon its subscription on the Platform, and after having been
able to consult the present privacy policy.
The Company and its subcontractors commit to a lawful and fair collection of the User’s data,
in full transparency and in compliance with the rights conferred to the User pursuant to
applicable legislation and regulations.
ARTICLE 4. LENGHT OF DATA RETENTION
The Company informs the User that the data is retained only during the length of the User’s
subscription on the Platform.
In accordance with application legislation, cookie data will be automatically deleted thirteen
(13) months following their placing on the User’s terminal.
Finally, the data regarding the identification of the Users in case of exercise of their rights
pursuant to Article 6 of the present privacy policy shall be retained for (i) one (1) year in case
of exercise of their access or rectification rights and (ii) three (3) years in case of exercise of
their opposition right.
ARTICLE 5. OBLIGATIONS OF THE COMPANY
As data controller and in accordance with applicable legislation and regulations, the Company
commits to:
- Only collect the Users’ data for the strict purpose as described under article 2 of the
present privacy policy;
- Keep a processing register;
- Put in place all necessary technical and organizational appropriate measures in order
to ensure the security, confidentiality, integrity, availability and the resilience of the
process systems and services;
- Limit the access to the Users’ data to the persons duly authorized to this effect;
- Increase awareness and train staff members regarding the processing of personal
data;
- Guarantee to the Users their rights regarding the access, portability, erasure,
rectification and opposition in relation to the collection and processing of their data;
- Notify the competent supervisory authority of any security breach presenting a serious
risk regarding the rights and liberties of the Users within 72 hours of the occurrence of
such a breach;
- proceed with the deletion of the Users’ data in the event of an absence of any contact
with the Company for a period of three (3) years;
- Only subcontract the processing of the Users’ data to Hivebrite which, as subcontractor,
has put all necessary technical and organizational measures in order to guarantee the
security, confidentiality, integrity, availability and resilience of the processing systems
and services.
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For any additional information on Hivebrite, you can consult the webpage available at
the following address: www.hivebrite.com.
ARTICLE 6. EXERCISE OF THE USERS’ RIGHTS
The User is duly informed that it disposes at any time, meaning prior to, during or following the
processing of data, to a right to access, copy, rectify, oppose, port, limit and delete its data.
In addition, in the event the User considers that its rights have not been respected, the User
of which the personal data is collected can file a reclamation before the competent supervisory
authority. For any additional information, you can review your rights on the websites of the
competent authorities.
The competent supervisory authorities are listed on the following website:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
ARTICLE 7. HOSTING OF THE USERS’ PERSONAL DATA
The personal data collected by the Company is hosted by the following service providers:
Host Nature of the hosting
Microsoft Azure Cloud
Privacy policy:
https://www.microsoft.com/enus/
TrustCenter/Privacy/gdpr/default.aspx
Hosting of all data and content produced /
provided by the User, as well as images,
profile pictures and backups
AmazonAWS
Privacy policy:
https://aws.amazon.com/compliance/gdprcenter/
ARTICLE 8. DATA BREACH
In case of breach of its systems, or theft, deletion, loss, alteration, disclosure, unauthorized
access, or any other malicious act, the Company commits, in the event the said breach
presents a serious risk regarding the rights and freedoms of the Users, to notify the Users,
within a period of seventy two (72) hours as of the occurrence of the breach, of (i) the nature
of the breach, (ii) the probable consequences of the malicious act, (iii) the appropriate
measures proposed to remedy the malicious act.
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The malicious act presenting a serious risk regarding the rights and freedoms of the Users
shall be notified to the competent supervisory authority.
The User is duly informed that the Company shall not be liable in case of breach of IT security
which can cause damages to computer equipment, as well as in case of breach or malicious
act by a third party targeting the system or the Platform.
ARTICLE 9. COOKIE MANAGEMENT CONFIGURATION AND OTHER DATA
The User’s consent is requested through a banner at the bottom of the Platform homepage.
In case of consent, the User’s internet navigator shall automatically transmit to the Company
the data collected and detailed under Article 1.2.
The User is informed that the cookies and trackers will be automatically deleted following a
period of thirteen (13) months.
The User may at all times configure its navigator in order to prevent the creation of cookie files.
However, certain functionalities of the services proposed by the Platform may not function
properly without cookies. In addition, even if most navigators are configured by default and
accept the creation of cookie files, the User has the possibility to choose to accept the creation
of all cookies other than the functional cookies or to systematically decline them or to choose
the cookies it accepts depending on the issuer by configuring the following settings:
• Internet Explorer:
- Click on the settings menu, followed by “Internet Options”;
- Under the “General” tab on the upper-left hand side, scroll down to “Browsing history”;
- Check the "Temporary Internet files and website files," "Cookies and website
data," "History," and "Download History" boxes;
- Click on “Delete”;
- Close out of Internet Explorer and reopen it for changes to take effect.
• Firefox:
- Click on your Tools bar;
- Click on “Preferences”;
- On the menu to the right, select "Privacy";
- Under the “history option”, there is a shortcut titled "clear your recent history", click on
that;
- Select only the top four options and hit clear now.
• Safari:
- Click on “Safari” in the top left corner of the finer bar;
- Click on “Preferences”;
- Click on the “Privacy” tab;
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- Click on “Manage Website Data”;
- Click on “Remove All”;
- Click “Remove Now”.
• Google Chrome:
- Click the Tools menu;
- Click on “More tools”;
- Clear browsing data;
- At the top, choose a time range.
- To delete everything, select “All time”;
- Next to "Cookies and other site data" and "Cached images and files", check the boxes;
- Click on “Clear data”.
In order to configure the data settings, please find below the recommendations of the
Company:
Data collected for the following
purposes:
Settings
General data enabling the proper
functioning of the Platform and the
improvement of the services proposed
by the Platform.
Data that is essential for the provision of services by the
Company, non-configurable.
Data regarding the management of
payment services proposed by the
Platform, delinquencies and litigation.
Data that is essential for the provision of services by the
Company, non-configurable.
Data enabling the creation of User files. Management by the User in its login area;
Unsubscribing to newsletters / commercial offers by clicking
on the appropriate link;
Request for deletion of the data base of the Company by
writing to the following address
[email protected] and subject to providing a
proof of identity.
Compilation of statistics with the
purpose of improving the functioning of
the Platform notably by analysing the
traffic of the Platform (modules which
are more or less consulted, preferred
routes, level of activity depending on the
Clearance of cookie history in the navigator pursuant to the
above instructions;
Using the “incognito mode” whilst navigating;
Request for deletion of the data base of the Company by
writing to the following address
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day of the week et hour of the day, etc.)
and by adapting the Platform according
to the needs and tastes of the Users
(recognition of the User when it
accesses the Platform).
[email protected] and subject to providing a
proof of identity.
Management of requests to access,
rectify, delete, limit and oppose.
Request for deletion of the data base of the Company by
writing to the following address
[email protected] and subject to providing a
proof of identity.
ARTICLE 10. PERSONS AUTHORIZED TO ACCESS THE USERS’ DATA
The data of the Users are accessible only to the persons duly authorized to do so by the
Company for administrative or maintenance purposes of the Platform to the exclusion of any
commercial use, and if applicable, in order to enforce the rights exercised by the Users
regarding their data (in particular the right to access, rectify, oppose, port and to be forgotten).
The Company informs the User that, outside of hosting and payment services, it uses the
following subcontractor:
- The company KIT UNITED for its HIVEBRITE solution, a French société par actions
simplifiée with a capital of 284.280,00 Euros, registered with the Paris Companies
register under the number 75339171300017, having its registered office at 8, rue de la
Grande Chaumière, 75008 – Paris.
Especially in light of any future developments of the applicable legislation and regulations, the
Company reserves its right to proceed with any modification of its privacy policy and commits
to duly inform you if any such modification occurs.
Date of privacy policy: May 2022.