Contents

- Introduction
- Person responsible for the processing
- Personal data collected and processed by Silvr
- Purposes and legal bases of the processing
- Recipients of personal data
- How long we keep your personal data
- Transfers of your data outside the European Economic Area ("EEA")
- Your rights
- Data security
- Modifications

Data protection policy

Date of last update : July 2021

Contents

- Introduction
- Person responsible for the processing
- Personal data collected and processed by Silvr
- Purposes and legal bases of the processing
- Recipients of personal data
- How long we keep your personal data
- Transfers of your data outside the European Economic Area ("EEA")
- Your rights
- Data security
- Modifications

SILVR is aware of the importance of ensuring data confidentiality and is committed to implementing the highest standards of confidentiality and security to ensure your privacy is respected and protected.


This data protection policy informs you of the commitments and practical measures taken by SILVR to ensure that your personal data is kept confidential.

1. Person responsible for the processing

As the data controller, SILVR Société par Actions Simplifiées, registered in the Paris Trade and Companies Register under number 884 558 453, whose registered office is located at 144 AV CHARLES DE GAULLE 92200 NEUILLY-SUR-SEINE, is responsible for collecting and processing your personal data.

2. Personal data collected and processed by Silvr

When you subscribe to SILVR's services, we collect the following personal data:

  • contact data: e-mail address, telephone number, etc. ;
  • identification data: surname, first name, date of birth, copies of identity documents, proof of address, etc. ;
  • banking and financial data: bank details, card number, bank statements;
  • connection data: IP address, browser type and version, operating system and other software installed in your environment, mobile platform, technical identifier(s), error reports and performance data;
  • cookies: see our cookie policy for more details on how we use cookies.

We also analyse performance data from the various connected platforms:

  • Sales data: Shopify | Prestashop | WooCommerce | etc.
  • Collection data: Stripe | Paypal | Payplug | Mercanet | etc.
  • Marketing data: Facebook | Google | TikTok | Amazon | etc.
  • Financial data: bank accounts

3. Purposes and legal bases of the processing

SILVR shall ensure that it collects and processes only data that is strictly necessary for the purpose for which it is processed. SILVR collects and processes your personal data for various purposes based on the various legal bases detailed below.

Performance of the contract or pre-contractual measures

We collect and process your personal data to enter into and perform our contracts and to manage the business relationship for the following purposes:

  • Subscription to SILVR's services and execution of the TOS ;
  • Study of the financing file ;
  • Commercial relationship management.

Legitimate interests :

We collect and process your personal data to protect our legitimate interests for the following purposes

  • Fraud prevention ;
  • Personalization of our offers ;
  • Improved navigation on our website;
  • Management of cookies not subject to consent ;
  • Solvency check ;
  • Creation of scoring models.

Compliance with our legal and regulatory obligations:

We collect and process your personal data to comply with applicable regulations, including banking and financial regulations for the following purposes

  • Identification, identity verification and "Know Your Client" in the context of the fight against money laundering and terrorist financing;
  • Resolve any disputes and enforce our contracts.

Consent :

For certain activities, such as marketing and cookies, we seek your consent to process your personal data. You can withdraw this consent at any time.

4. Recipients of personal data

In accordance with the purposes set out in this policy, SILVR may share your personal data with :

  • Duly authorised SILVR employees and managers. Any SILVR employee with access to your personal data is subject to strict confidentiality obligations.
  • Partners essential to the provision of SILVR's services such as, but not limited to, our payment partner, our debt collection partners in the context of dispute or non-payment management.
  • Service providers, acting as subcontractors, to perform services relating to SILVR's services, including email service providers, telephony service providers, audience analysis services, identity document analysis service.
  • Competent authorities where appropriate, such as public authorities and administrative authorities, or anti-money laundering and anti-terrorist financing bodies.

5. How long your personal data will be kept

The retention periods we apply to your personal data are limited and proportionate to the purposes for which they were collected:

Goals
Shelf life
Managing our anti-money laundering and counter-terrorist financing obligations
The entire duration of the contractual relationship, after which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The common law limitation period in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the proceedings and until the expiry of the ordinary and extraordinary remedies.
Analysis and management of funding applications
The entire duration of the contractual relationship, after which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The common law limitation period in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until the expiry of the ordinary and extraordinary remedies.
Management of prospect information
The data is kept for five (5) years from the date of its collection or from our last contact with the prospect
Management of our accounts
The data is kept for a period of ten (10) years in accordance with the provisions of Article 123-22 of the Commercial Code
Fraud prevention
The data is kept for a period of ten (10) years
Cookie management
The duration of data retention shall not exceed 13 (thirteen) months
Goals
Management of our obligations in terms of the fight against money laundering and the financing of terrorism

For the entire duration of the contractual relationship, at the end of which only the data necessary for pre-litigation or litigation purposes are archived until the legal prescription period is acquired. The common law limitation period in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until the expiry of the ordinary and extraordinary remedies.
Analysis and management of financing requests

For the entire duration of the contractual relationship, at the end of which only the data necessary for pre-litigation or litigation purposes are archived until the legal statute of limitations has expired. The common law limitation period in civil and commercial matters is five (5) years. In the event of litigation, this data is kept for the duration of the procedure and until the expiry of the ordinary and extraordinary remedies.
Management of prospect information

Data is kept for five (5) years from the date of collection or last contact with the prospect
Management of our accounts

The data is kept for a period of ten (10) years in accordance with the provisions of Article 123-22 of the Commercial Code
Fraud prevention

Data is kept for a period of ten (10) years
Cookie management

Data will not be retained for more than 13 (thirteen) months

6. Transfers of your data outside the European Economic Area ("EEA")

Your personal data is stored and processed within the European Union. The processing does not involve any transfer of data outside the EEA.

However, should this happen, we will put in place contractual mechanisms and binding legal processes to legally transfer personal data outside the EEA.

7. Your rights

In accordance with the applicable regulations, you have rights regarding the personal data we collect, including

  • the right of access: you can obtain information about the data we hold about you and the processing carried out;
  • the right of rectification: you can modify or correct your data;
  • the right to erasure: you can ask us to delete your data in certain circumstances (please note that legal or regulatory provisions or legitimate reasons may require us to retain your data);
  • the right to restrict and object: you can ask us to restrict or object to the processing of your data, in certain circumstances (please note that we may continue to process your personal data if we have a legitimate reason to do so);
  • the right to portability: you can ask us to receive data in electronic form and/or ask us to transmit this information to a third party where technically possible.

You can exercise your rights and contact our data protection department in the following ways:

  • By e-mail to the following address dpo@silvr.co
  • At the following postal address: 144 av Charles de Gaulle, 92200 Neuilly-Sur-Seine

For any request to exercise your rights, we may ask you to provide an official document of identity in order to verify that you are the person concerned by the personal data that is the subject of the request.

We undertake to respond to any request as soon as possible. You will receive a reply within a maximum of one (1) month from the date of receipt of your request. However, we inform you that this period may be extended by two (2) months if your request is particularly complex or given the number of requests. In this case, you will be informed of such an extension and the reasons for it within a maximum of one (1) month from receipt of your request.

You can also file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the French personal data regulator (www.cnil.fr).

8. Data security

SILVR ensures the security of your personal data by taking all physical, technical and organisational measures to ensure the confidentiality, integrity and availability of personal data, including encryption and anonymisation. We also require all of our employees and partners of SILVR to adhere to strict standards of personal data security.

9. Amendments

We will update this privacy policy regularly. Any changes will be posted on this page with an updated revision date.