Personal data processing policy

General provisions

This personal data processing policy forms part of the legal notice of the www.billetterie.villa-carmignac.com website and applies to all users of the www.billetterie.villa-carmignac.com website and describes the processing of any personal data that may be collected by the Carmignac Gestion Corporate Foundation and/or the Villa Carmignac when the user accesses the website as well as during its use.

Collection of personal data

By using the Site and providing personal information, the User agrees to the collection and use of data in accordance with this personal data processing policy.

Browsing the Site is possible without providing any Personal Data about the User. However, in order to access certain parts of the Site, for example to download certain documents, or for other specific purposes, the Carmignac Gestion Corporate Foundation and/or Villa Carmignac may request Personal Data from the User. The communication of Personal Data in this context is voluntary. If the User does not provide this Personal Data, he/she will not be able to benefit from the corresponding services offered by the Site, such as the communication of newsletters and the downloading of documents.

Personal data processed by the Carmignac Gestion Foundation and/or Villa Carmignac

Personal data" includes any information that directly (e.g. first name, surname) or indirectly (e.g. combination of data) identifies a natural person.

The personal data that the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac may be required to process may include

• identification data, e.g. name, address, telephone number, e-mail address;
• information transmitted for example by cookies and similar technologies on websites and in emails.

Legal basis and purposes of processing

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac collects and processes personal data for the purposes (hereinafter the "Purposes") and according to the legal bases set out below.

In general, the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac bases its processing on :

• the pursuit of its legitimate interest;
• its obligation to comply with legal or regulatory provisions;
• your consent.

The purposes for which your Personal Data is collected are listed below, together with a brief description of how the data may be processed in each case.

• Communicate with the Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac.
  The Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac will follow up on your comments, as well as any other requests you may submit via the Site, such as online questions or your purchase of tickets online at the Villa Carmignac ticket office. To this end, it may be necessary for the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac to call you back by telephone or to communicate with you by e-mail.

• Direct marketing and promotion.
  Direct marketing and/or promotional operations carried out by the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac may involve the provision of specific information requested online.

• Managing your online ticket purchase at the Villa Carmignac ticket office. To reserve tickets via the online ticketing service, Villa Carmignac uses the ticketing service provider SeeTickets. Villa Carmignac collects your identity and contact data as well as the billing data and the data required to provide you with your ticket or booking confirmation. As regards identity and contact details, you are asked to enter your email address, then your surname, first name, email address, postcode and mobile phone number. Finally, you will be asked to enter a password. Indeed, booking a ticket online requires the creation of a ticketing account, so that you can later download or re-download your ticket in the event that you have lost it. The information collected in the context of the management of your online ticket purchase is recorded in a computerised file for the purposes of managing your ticket purchase and regulatory traceability, for the provision of your ticket and to enable Villa Carmignac to provide you with a welcome and to monitor invoicing.

• Organisation of your visit. When you make your reservation, we ask for your telephone number so that we can contact you to organise your visit or to warn you in the event of unforeseen circumstances or events that force us to postpone your visit.

• Updating the Site and conducting satisfaction surveys.
  The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac will use your Personal Data to update and improve the Site. The Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac will also use your Personal Data to conduct satisfaction surveys.

• Compilation of aggregate statistics regarding the use of the Site.
  When you provide Personal Data on the Site, you warrant that you have received the necessary authorisations and consents from the persons concerned by such Personal Data if they concern third parties and, where applicable, for the uses described in this policy.

The personal data you provide may be kept by the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac in order to keep a record of your access to the site, or to contact you by e-mail or by other means.

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac do not intend to keep the personal data collected in this way for longer than the purpose of the collection requires.

Profiling and automated decision making

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac does not use automated decision-making or profiling. If the Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac is led to do so, the Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac will comply with the applicable legal and regulatory requirements.

Sharing your personal data with third parties

If necessary or useful to achieve the Purposes, La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac reserves the right to disclose or make available personal data to the following recipients, insofar as this is legally or otherwise authorised or required.

• public/governmental authorities, courts, competent authorities;
• third party subcontractors who process personal data on behalf of La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac and/or to whom La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac entrusts certain of its tasks;
• Payment service providers: Your personal data is collected directly by our secure online payment service provider: PayZen. The PAYZEN secure payment solution uses the TLS protocol (encryption of all card-related information) and is subject to numerous approvals (PCI DSS certification, CB Cartes Bancaires approval, Visa Merchant agent approval). Your bank details are thus protected since only the payment agreement codes issued by the banks are kept.
• auditors or legal advisors.

It is the policy of the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac to require these external suppliers to process Personal Data in accordance with the commitments of the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac in terms of personal data processing, confidentiality and security.

Legal obligations to communicate data

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac may communicate your Personal Data in the event of an emergency to ensure the safety of individuals, or to protect the public or the Site.

Transfer outside the EU

In the event of the transfer of your data outside the EEA, this transfer will take place on the basis of a decision by the European Commission, when it has recognised that the country to which your data will be transferred ensures a level of protection equivalent to that existing in the EEA.

In the event of the transfer of your data to a country whose level of data protection has not been recognised as adequate by the European Commission, the Carmignac Gestion Foundation and/or Villa Carmignac will put in place the following guarantee to ensure the protection of your personal data: Standard contractual clauses approved by the European Commission.

In this context, La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac will check the appropriate protection measures that may be applied by its service providers to the data, such as encryption or tokenisation

Cookies

Cookies are small data files sent to the web browser you are using by the website you are visiting. The main purpose of cookies is to make it easier for you to navigate a website by remembering your user preferences, for example, or to improve the user experience. These cookies can then be stored on your computer to identify your computer.

These cookies can be either session or persistent: a session cookie is a cookie that is automatically deleted when the user closes the browser, whereas a persistent cookie remains stored on the user's computer until its expiration date.

The cookies used on the Site have a maximum lifetime of 12 months.

1. Types of cookies

1.1 Strictly necessary cookies (« Operation")

These cookies are essential in order to be able to browse the Site and take full advantage of its features such as access to certain secure Internet pages. Without these cookies, certain services you request cannot be provided.

These cookies enable a website to record your choices about the settings on that website in order to provide you with enhanced and more personal features
These cookies cannot track your browsing activity on other websites and do not collect any information about you that could be used for advertising purposes.

1.2 Performance (or "User Experience Enhancement") cookies

These cookies are used to collect information about how visitors use the Site, such as which pages are visited most often or whether certain pages show error messages. All information collected through these cookies is anonymous, and is collected for the sole purpose of developing and monitoring traffic patterns on the Site in order to improve the way the Site operates. This information is used exclusively by the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac and is not shared with third parties or connected to any other information.
Refusal to authorise cookies may prevent the site from functioning properly.

Performance cookies may be analytical cookies. These cookies are used to store the URLs of previously visited web pages, allowing us to track users' browsing from both outside and inside the Site. When you click on an advertising link of the Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac from a third party website, a cookie may be placed on your computer in order to record it in order to measure the audience of our advertisements and to ensure that they are used effectively. If the user does not wish to receive cookies, he/she may configure his/her browser to refuse them or to warn the user when he/she receives one, asking him/her whether or not he/she agrees to the placement of such a cookie.

1.3 Targeting cookies (« Advertising")

Targeting cookies are used to measure the effectiveness of an advertising campaign by enabling the delivery of targeted advertisements to users, the recurrence of which is limited. These cookies track a user's visit to a site.

1.4 Social network cookies (« Social")

The purpose of these cookies is to make the site more user-friendly and interactive, by allowing you to interact with social networks (Facebook, Twitter, LinkedIn, etc.).

These cookies may, among other things, process data relating to the amount of content shared via social networks, the fact that you have an account on a social network, the tracking of your navigation on different sites, etc. These features are based on third-party applications integrated into our site. The social network providing such an application button is likely to identify you thanks to this button, even if you did not use this button when visiting our site. Indeed, this type of application button may allow the social network concerned to track your browsing on our site, simply because your account with the social network concerned was activated on your terminal (open session) during your browsing on our site.

We invite you to consult the privacy protection policies of these social networks in order to learn about the purposes of use, particularly advertising, of the browsing information that they may collect through these application buttons. These protection policies must allow you to exercise your choices with these social networks, in particular by configuring your user accounts for each of these networks. The use and the deposit of these cookies is conditional on obtaining your consent.

2. Use of cookies

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac may use Personal Data collected by their cookies in order to analyse the behaviour of users of the Site and thus provide more relevant content.

Information from cookies placed by advertising links on third party sites may collect Personal Data.

The following is a list of the main cookies used by La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac:

Google Analytics: the cookies placed by Google Analytics are only used for analysis purposes and do not allow individual tracking of users. For more information on how Google Analytics collects and uses this data and the rights related to the use of these cookies, please consult their Privacy Policy. If you do not want Google Analytics to collect Personal Data from you, you can download and install the Google Analytics Opt-out Browser Add-on.

Facebook Pixel: We use Facebook Pixel to optimise posts based on the data collected and to build targeted audiences.

3. Other tracking technologies

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac also uses technologies substantially similar to cookies, such as Internet tags or any other technology that may be included in advertising e-mails or newsletters in order to determine whether these messages have been consulted or whether you have clicked on the links they contain. Web beacons do not deposit any data on your computer, but may be used in conjunction with cookies to analyse browsing activity on the Site.

4. How to accept or decline cookies

If you do not wish to receive cookies, you can set your browser to refuse them or to alert you when you receive one, asking you whether you agree or not to the placement of such a cookie.
You can use the cookie control panel at the bottom of the page (link "Your Cookie Preferences") to choose your preferences.

You can also set your browser to disable cookies. To do this, please refer to the "Tools" tab of your browser, or similar.

We do not recommend that you disable our cookies. If you block, turn off, or reject our cookies, some pages of the Site may not display properly or you may not be able to use certain services that require you to log in.

If you do not wish to have our cookies placed on your computer, you should disable them. To do this, please follow the appropriate instructions below for your browser:

•     Internet Explorer.
•     Google Chrome.
•     Firefox.
•     Safari.

Your rights

You have the right, subject to the applicable data protection legislation, to

• to request access to the personal data held by La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac and to receive a copy of such data;
• where applicable, to request the rectification of inaccurate personal data
• where applicable, to request the deletion of personal data when their processing is no longer necessary to achieve the purposes, or is not or is no longer lawful for other reasons, subject however to the applicable retention periods (see "Retention period" below)
• where applicable, to request the restriction of the processing of your personal data;
• where applicable, to object to the Processing of personal data, in which case we will no longer process the personal data, unless we have compelling and legitimate reasons to do so (e.g. to establish, exercise or defend a legal claim). The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac will not, however, use your personal data for direct marketing purposes if you ask us not to do so;
• if you have given your consent to the processing of your personal data, to withdraw your consent at any time;
• to request the portability of your data, i.e. the return of the personal data you have provided to us or, where technically possible, the transfer of such data to a third party;
• to lodge a complaint with our Data Protection Officer (see "Contact" section below) about the processing of personal data and, in the absence of a satisfactory response, to lodge a complaint about the processing of personal data with the relevant data protection authority.

Data security and integrity

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac uses various technical security measures or implements appropriate charters in order to protect the Personal Data collected, used or transferred against loss, misuse, falsification or destruction. However, as the Internet network is open to all and not secure, the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac cannot be held responsible for the security of the transmission of Personal Data over the Internet.

Duration of storage

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac keeps personal data for as long as we need it to achieve the Purposes. Similarly, the Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac will delete or render anonymous personal data (or take equivalent measures) as soon as it is no longer necessary to achieve the Purposes, subject however to (i) legal or regulatory requirements applicable to the retention of Personal Data for a longer period of time, or (ii) to establish, exercise and/or defend actual or potential rights in the context of legal actions, investigations or similar proceedings, including retention for legal purposes that we may impose in order to preserve relevant information.

External websites

The Site may provide links to external Internet sites. The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac do not provide any guarantee or make any declaration concerning these external websites. The owners and operators of these external websites may collect, use or transfer Personal Data under terms and conditions that differ from those of La Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac. When connecting to an external website, you must inform yourself about the confidentiality and security measures of these external websites.

Contact

If you have any questions regarding the use of your personal data, please send an email to droitdacces@villacarmignac.com

Modification

The Fondation d'entreprise Carmignac Gestion and/or Villa Carmignac reserve the right to update and modify the provisions of this personal data processing policy as required and without notice.

Any update will be notified on the www.fondationcarmignac.com website. The user is invited to reread the terms of this personal data processing policy on a regular basis so that he/she is fully aware of the manner in which the Fondation d'entreprise Carmignac Gestion and/or the Villa Carmignac use personal data.