Skip to main content

Privacy Policy

Last updated: 2024-07-30

OBJECTIVES OF THE PRIVACY POLICY

This privacy policy for 3A MANAGEMENT INTELLIGENCE (“3AMI”, "we", "us", or "our"), describes how and why we might collect, store, use, and/or share ("process") a User's information (“You”, “Your”, “Yours”, “User”) when you use our services ("Services", “Conversational Agent”) and visit our site (“Site”), such as when you:

  • Visit and interact with our “Site” chremyle.com
  • Communicate with our “Conversational Agent” through a messaging app such as WhatsApp (or any other application of ours that refers to this privacy document)
  • Interact with us through related methods or channels, including any purchase, marketing, or event

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary presents the key points of our privacy policy, but you can find more details on each of these topics by clicking on the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Sites and Services, we may process personal information based on your interaction with us and the Services, the choices you make, as well as the products and features you use.

Do we process sensitive personal information? We may process sensitive personal information when necessary with your consent or as permitted by applicable laws.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, ensure security and prevent fraud, as well as to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so.

In what situations and with which third parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we protect your information? We have implemented organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to bypass our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on your geographic location, the applicable privacy law may grant you certain rights regarding your personal information.

How to exercise your rights? The easiest way to exercise your rights is through a data subject access request, or by contacting us. We will review and process any request in accordance with applicable data protection laws.

Want to know more about what we do with the information we collect? See the full privacy notice.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you provide to us

In short: We collect the personal information you voluntarily provide to us.

We collect the personal information you voluntarily provide to us when you visit our website, engage in a conversation with our conversational agent, express interest in obtaining information about us, a partner, or our products and services, participate in activities on the Services, or otherwise contact us.

Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, as well as the products and features you use. The personal information we collect may include the following:

  • phone number;
  • age;
  • email;
  • IP address;
  • computer hardware;
  • location;
  • web browser;
  • investor profile;
  • savings capacity.

Sensitive information. When necessary, with your consent or as permitted by applicable laws, we process the following categories of sensitive information:

  • Personally Identifiable Information: This includes full name, home address, email address, and phone numbers in order to ensure quality of communication.
  • Financial information: this is the structure of savings, such as bank accounts (savings, current), in order to design the personalized solution suited to your profile and to meet the requirements of anti-money-laundering regulations.
  • Income and tax information: this includes tax notices or other proof of source of income in order to comply with anti-money-laundering regulations.

Application data. If you use our application(s), we may also collect the following information if you grant us access or permission:

  • Geolocation information. We may request access or permission to track location-based information from your mobile device, either continuously or while you use our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you can do so in your device settings.
  • Mobile device data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, system version and configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and the Internet protocol (IP) address (or proxy server). If you use our application(s), we may also collect information about the telephone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique identifier, as well as information about features of our application(s) you have used.
  • Notifications. We may request to send you push notifications, messages, or WhatsApp messages regarding your account or certain features of our application(s). If you wish to no longer receive such communications, you can disable them in your device settings.

This information is primarily necessary to ensure the security and operation of our application(s), for troubleshooting, as well as for our internal analytics and reporting.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Certain information, such as your Internet protocol (IP) address and/or characteristics of your browser and device, is automatically collected when you visit our Services.

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity (such as your name or contact details) but may include device and usage information, such as your IP address, the characteristics of your browser and device, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, as well as other technical information. This information is primarily necessary to ensure the security and operation of our Services, as well as for our internal analytics and reporting.

Like many businesses, we also collect information through cookies and similar technologies. You can learn more about this in our

The information we collect includes:

  • Log and usage data. Log and usage data are service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our Services, and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, as well as information about your activity in the Services (such as timestamps associated with your use, pages and files viewed, searches and other actions you take such as features you use), information about device events (such as system activity, error reports sometimes called "crash dumps", and hardware settings).
  • Device data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location data. We collect location data such as information about your device's location, which may be precise or imprecise. The amount of information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You may choose to refuse access to this information or to disable location settings on your device. However, if you choose to refuse, you may not be able to use certain features of the Services.

2. PURPOSES OF DATA COLLECTION

In short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and prevent fraud, as well as to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for various reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication, as well as to manage user accounts. We may process your information so that you can create and log in to your account, as well as to maintain the proper functioning of your account.
  • To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
  • To put you in touch with one of our partner wealth management advisors.
  • To respond to user requests/offer user support. We may process your information to respond to your requests and resolve any potential issues you may encounter with the requested service.
  • To request feedback. We may process your information when necessary to request feedback and contact you regarding your use of our Services.
  • To protect our Services. We may process your information as part of our efforts to maintain the security of our Services, including monitoring and preventing fraud.
  • To improve our site and products.
  • To provide personalized advertising content.
  • To contact you by email.
  • To administer a contest, promotion, or survey.

To safeguard or protect the vital interest of a person. We may process your information when necessary to safeguard or protect a person's vital interest, such as preventing harm.

3. ON WHAT LEGAL BASES DO WE RELY TO PROCESS YOUR INFORMATION?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., a legal basis) to do so under applicable laws, such as your consent, to comply with laws, to provide you with services to meet our contractual obligations, to protect your rights, or to satisfy our legitimate business interests.

This section applies to you if you are located in the EU or the UK.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases on which we rely to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., your consent) to use your personal information for specific purposes. By using our site and our conversational agent, you consent to our privacy policy. You can withdraw your consent at any time by notifying us by any means made available to you (email, unsubscribe link, etc.).
  • Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including to provide our services or at your request before entering into a contract with you.
  • Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and these interests do not override your fundamental interests and rights. For example, we may process your personal information for some of the purposes described in order to:
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services in order to improve user experience
  • Legal obligations. We may process your information when we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
  • Vital interests. We may process your information when we believe it is necessary to protect your vital interests or those of a third party, such as in situations involving potential threats to a person's safety.

This section applies to you if you are located in Canada.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for specific purposes, or in situations where your permission may be inferred (i.e., implied consent). You may withdraw your consent at any time.

In certain exceptional cases, we may be legally authorized under applicable laws to process your information without your consent, including:

  • If the collection is clearly in a person's interest and consent cannot be obtained in a timely manner
  • For investigations and the detection and prevention of fraud
  • For commercial transactions under certain conditions
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • To identify injured, sick, or deceased persons and to communicate with relatives
  • If we have reasonable grounds to believe that a person has been, is, or may be a victim of financial abuse
  • If it is reasonable to expect that the collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of court relating to the production of records
  • If it has been produced by a person in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by regulation

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in the specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services on our behalf and require access to such information to perform that work. We have contracts in place with our third parties, designed to help protect your personal information. This means they cannot do anything with your personal information unless we have instructed them to do so. They will not share your personal information with any organization other than ours. They also commit to protecting the data they hold on our behalf and to keeping it for the period we specify.

The third parties with whom we may share personal information are as follows:

  • Personally Identifiable Information: This includes full name, home address, email address, and phone numbers in order to ensure quality of communication.
  • phone number;
  • age;
  • email;
  • IP address;
  • computer hardware;
  • investor profile;
  • Financial information: this is the structure of savings, such as bank accounts (savings, current), in order to design the personalized solution suited to your profile and to meet the requirements of anti-money-laundering regulations.
  • Income and tax information: this includes tax notices or other proof of source of income in order to comply with anti-money-laundering regulations.

We may also need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information as part of, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or part of our business by another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information.

The user expressly accepts the use of cookies by continuing browsing on the site.

A cookie is a text file that may be stored on a device when consulting an online service with a browser. A cookie file allows its issuer, during its validity period, to recognize the device concerned each time this device accesses digital content containing cookies from the same issuer.

The cookies we issue allow us to:

  • establish statistics and volumes of frequentation and use of the various elements composing our Site, allowing us to improve the configuration, interest, design, and ergonomics of our services
  • adapt the presentation of our Site to your device's display preferences (language used, display resolution, operating system used, etc.) during your visits to our Site, depending on the hardware and visualization or playback software your device includes
  • memorize information relating to products, services, or information you have chosen on our Site (content of a shopping cart, etc.)

You can at any time configure your browser software so that cookies are stored on your device or, on the contrary, so that they are rejected (either systematically or according to their issuer). You can also configure your browser software so that acceptance or refusal of cookies is offered to you punctually, before a cookie can be stored on your device.

Warning: any setting is likely to modify your browsing on the Internet and your conditions of access to certain services requiring the use of cookies.

For the management of cookies and your choices, the configuration of each browser (Internet Explorer, Edge, Firefox, Safari, Google Chrome) is different. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In short: We may transfer, store, and process your information in countries other than yours.

Our servers are located in Europe. If you access our Services from outside, please note that your information may be transferred, stored, and processed by us at our facilities and by the third parties with whom we may share your personal information (see the section "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in Europe.

If you reside in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, these countries may not necessarily have data protection laws or other similar laws as comprehensive as those of your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will only retain your personal information for the time necessary for the purposes set forth in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to retain your personal information longer than [insert specific retention period] from the date on which users have an account with us.

When we no longer have a legitimate need to process your personal information, we will delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will secure your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE PROTECT YOUR INFORMATION?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of all personal information we process. However, despite our protections and our efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to bypass our security and improperly collect, access, steal, or modify your information. Although we do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services in a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from children under 18 nor market to them.

We do not knowingly solicit data from children under 18 nor market to them. By using the Services, you represent that you are at least 18 years of age or are the parent or guardian of such a minor and consent to such dependent minor's use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable steps to promptly delete such data from our records. If you become aware that we have collected data from persons under 18, please contact us at contact@chremyle.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In certain regions, such as the European Economic Area (EEA), the United Kingdom (UK), Switzerland, and Canada, you have rights that allow you to have increased access to and control over your personal information. You can review, modify, or terminate your account at any time.

In certain regions (such as the EEA, the UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) where applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will review and act on any request in accordance with applicable data protection laws.

If you are located in the EEA or the UK and believe we are unlawfully processing your personal information, you also have the right to lodge a complaint with your Member State's data protection authority or the UK's data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawal of your consent: If we rely on your consent to process your personal information, which may be explicit and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, where applicable law permits, the processing of your personal information carried out based on legal processing grounds other than consent.

Account information: If you wish at any time to terminate your account, upon your request to terminate your account, we will deactivate or delete your account and your information from our active databases. However, we may retain certain information in our files to prevent fraud, resolve issues, assist with any investigation, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most web browsers are set by default to accept cookies. If you prefer, you can generally choose to configure your browser to delete and reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our Services.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers as well as some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting that you can enable to signal your privacy preference not to have your online browsing activities monitored and collected. At this stage, no uniform technological standard for recognizing and implementing DNT signals has been finalized. As a result, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you of this practice in a revised version of this privacy notice.

13. DO WE UPDATE THIS NOTICE?

In short: Yes, we will update this notice as needed to stay compliant with applicable laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated revision date and the updated version will be effective as soon as it is accessible. We reserve the right to correct any errors, inaccuracies, or omissions and to change or update the information on the Services at any time, without prior notice.

We encourage you to review this privacy notice frequently to inform yourself of how we protect your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you can contact us by mail at the following address:

contact@chremyle.com

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT ABOUT YOU?

Based on applicable laws in your country, you may have the right to request access to the personal information we collect about you, modify that information, or delete it. To request to review, update, or delete your personal information, please complete and submit a data subject access request.