Confidentiality
Privacy and Confidentiality
Foreword
Presentation of the CORUM Butler Group
CORUM Butler is the parent company of the Group, which directly owns CORUM Asset Management, CORUM Butler Asset management, Butler Investment Managers, Butler Corum Asia, CORUM Life and the Group’s other unregulated subsidiaries (together, the Group). The Group, whose capital is exclusively held by its directors and managers, specializes in real estate savings and corporate credit for individual and institutional customers.
CORUM ASSET MANAGEMENT is the Group’s portfolio management company, a SAS with capital of €600,000, headquartered at 1 rue Euler, 75008 Paris, registered with the PARIS Trade and Companies Register under no. 531 636 546, with APE code 6630 Z (hereinafter referred to as “CORUM AM”).
CORUM AM has been approved by the Financial Market Authority (www.amf-france.org) (AMF) under the terms of the AIFM Directive 2011/61/EU, and has been granted GP-11000012 on April 14, 2011. In particular, it is the management company for the SCPIs managed within the Group:
– SCPI Corum Origin, registered in the PARIS Trade and Companies Register under no. 749 907 507, whose prospectus was granted SCPI visa no. 12-17 by the AMF on July 24, 2012;
– SCPI Corum XL, registered in the PARIS Trade and Companies Register under no. 824 562 581, whose prospectus received SCPI visa no. 19-10 from the AMF on May 28, 2019;
– SCPI CORUM Eurion, registered in the PARIS Trade and Companies Register under no. 880 811 567, whose prospectus received SCPI visa no. 20-04 from the AMF on January 21, 2020.
CORUM AM also acts as a marketing agent for subscriptions and redemptions of the Corum Eco mutual fund.
CORUM BUTLER ASSET MANAGEMENT LIMITED, is a Group portfolio management company, Private Company Limited by Shares, with share capital of €150,000, whose registered office is at 2-4, Ely Place, Dublin 2 and registered number 618674 (hereinafter referred to as “CORUM Butler AM”).
CORUM Butler AM was authorized as a UCITS Management Company and Alternative Investment Fund Manager (AIFM) on October 19, 2018 by the Central Bank of Ireland under number C176313. CORUM Butler AM is the management company for the UCITS managed within the Group:
- CORUM ENTREPRISES SICAV, a French-registered SICAV approved by the AMF on 07/08/2018, whose CORUM Eco subfund is invested in units of the Irish-registered master fund CORUM Butler Entreprises.
- CORUM Butler UCITS ICAV, an Irish open-ended collective asset management vehicle with multiple sub-funds, registered on January 29, 2018 and approved by the Central Bank as a UCITS. CORUM Butler UCITS ICAV has 3 sub-funds:
- CORUM Butler Entreprises Fund
- CORUM Butler Short Duration Bond Fund
- CORUM Butler Smart ESG Fund.
- CORUM Butler Credit Strategies ICAV, an Irish open-ended collective asset management vehicle, registered on July 12, 2019 and approved by the Central Bank as a UCITS. CORUM Butler Credit Strategies ICAV has 3 sub-funds:
- Butler Credit Opportunities Fund
- CORUM Butler European High
- Butler VAG Credit Opportunities Fund.
The financial management of the UCITS funds managed by CORUM Butler AM is sub-delegated to a regulated Group company, Butler Investment Managers Limited.
The supplement, prospectus and key investor information for the Funds’ sub-funds are available free of charge in electronic form at www.corumbutler.com.
BUTLER INVESTMENT MANAGERS LIMITED, a limited liability company with its registered office at 50 Marshall Street, London, W1F 9BQ, United Kingdom, is authorized by the Financial Conduct Authority (number 477024) and registered in England and Wales under registration number 06407390.
BUTLER CORUM ASIA is a Group management company whose registered office is at 3 Temasek Avenue #21-52 Centennial Tower, Singapore 039190, Singapore and registered under UEN number: 201801553W. Butler Corum Asia is licensed and regulated in Singapore by the Monetary Authority of Singapore (MAS).
CORUM LIFE has been approved as an insurance company with its registered office at 1, rue Euler 75008 PARIS. CORUM LIFE is registered with the Registre du Commerce et des Sociétés de PARIS, under number 852 264 332, and approved in France by the Autorité de Contrôle Prudentiel et de Résolution (ACPR).
Definitions
Personal data: Any information directly or indirectly identifying a natural person (e.g. name, telephone number, photograph, date of birth, town of residence, etc.).
Processing of personal data: Any operation, or set of operations, concerning such data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, reconciliation or interconnection, blocking, erasure or destruction, etc.).
Data controller: The data controller is the legal entity (company, municipality, etc.) or natural person who determines the purpose of a processing operation (also known as the aims) and the way in which it is carried out (also known as a processing operation), i.e. the aim and the way in which it is carried out. In practice, this is usually the legal entity represented by its legal representative.
Subcontractor: The processor is the natural or legal person (company or public body) that processes data on behalf of another organization (“the controller”), as part of a service or provision. Processors have obligations concerning personal data, which must be included in the contract between them and the data controller:
– an obligation of transparency and traceability ;
– data protection principles must be taken into account right from the design stage of new products or the launch of new projects;
– an obligation to guarantee the security of processed data;
– an obligation to provide assistance, warnings and advice (for example, in the event of personal data breaches).
Legal basis and purposes of processing
The Group’s management companies carry out various processing operations, the legal bases of which are as follows: contractual or pre-contractual performance, your consent, performance of its legal and regulatory obligations, its legitimate interests.
The purposes of processing and their legal basis are listed below:
– On the basis of the performance of pre-contractual measures taken at the request of prospects and/or the performance of the contract entered into, each of the Group’s management companies is likely to implement processing operations for the following purposes:
– the management of operations required for the products or services subscribed to;
– management of commercial relations;
– staff management
– On the basis of your consent, the Group’s management companies may carry out processing for the following purposes:
– management of cookies subject to consent;
– sending electronic communications about the Group’s products and news;
In compliance with our legal and regulatory obligations, the Group’s management companies may carry out processing operations for the following purposes:
– management of our general accounts ;
– managing the fight against money laundering and the financing of terrorism ;
– management of official requests from authorized supervisory authorities
Based on our legitimate interests, the Group’s management companies may carry out processing operations for the following purposes:
– establishing proof of transactions;
– fraud prevention;
– analyzing your data, in particular to personalize the products we offer according to your profile, and to send you personalized or non-personalized messages or communications concerning our products or services;
– management of cookies not subject to consent;
– to respond to your contact requests.
The purposes pursued on the basis of our legitimate interests are carried out with due respect for your rights and freedoms.
Data processing
Unless otherwise stated, the data collected by CORUM Butler SAS, or by another Group entity, is necessary for the purposes for which it is processed.
Some data processed by Group entities is collected indirectly, for example via one of the various CORUM Butler Group entities. Furthermore, the data collected may be transferred within the Group.
Data subjects
The persons concerned by the processing are :
– prospective customers who contact CORUM AM or any other Group entity in order to obtain information about the products and services offered,
– customers of the various Group entities,
– staff members of Group entities
– partners of the various Group entities,
– any user of this website.
Data recipients
Subject to compliance with the principle of data minimization, the data collected may be transmitted to some or all of the recipients listed below:
– authorized members of the internal departments of the various Group entities,
– the Group’s contractual partners and subcontractors,
– competent regulatory and supervisory authorities.
Data retention period
Where applicable, data collected by the Group’s various entities will be kept for the period necessary to fulfill the purposes described above, plus the period of legal prescription. More specifically :
| Purpose | Retention time |
| Management of operations required for the products or services subscribed to | For the duration of the contractual relationship, then five (5) years from the end of the contract. |
| Managing your commercial relationship with us | For the duration of the contractual relationship, then five (5) years from the end of the contract. |
| To manage our commercial relationship with you, including responses to your contact requests if you are a prospect. | Your data will be kept for three (3) years from the date of your last action. |
| Cookie management | Data will be kept for a maximum of thirteen (13) months. |
| General accounting management | The current fiscal year, increased by ten (10) years from the end of the fiscal year. |
| Managing the fight against money laundering and the financing of terrorism | For the duration of the contractual relationship, then five (5) years from the end of the contract. |
| Management of official requests from authorized control authorities | For the duration of the contractual relationship, then five (5) years from the end of the contract. |
| Establishing proof of transactions | For the duration of the contractual relationship, then five (5) years from the end of the contract. |
| Fraud prevention | The data may be kept for up to twelve (12) months from the time the alerts are issued, before being qualified.
Alerts deemed irrelevant or unqualified at the end of the twelve (12) month period are deleted. Qualified alerts are kept for a maximum of five (5) years from the closure of the fraud file. For persons registered on a list of proven fraudsters, data concerning them is deleted after a period of five (5) years from the date of registration on the list. If legal proceedings have been initiated, the data will be kept until the end of the legal proceedings, plus the period during which the legal prescriptions have been acquired. The statute of limitations in civil and commercial matters is five (5) years from the end of the contract. |
| Recruitment | Two years from the last contact with the unsuccessful candidate. |
| Staff management | For the duration of the employment contract, then five (5) years from the end of the contractual relationship for information required to comply with applicable accounting, social or tax obligations. |
Data Security
The CORUM Butler Group pays particular attention to the security of personal data. Technical and organizational measures have been put in place to ensure data integrity and confidentiality.
The Group carefully selects partners and subcontractors who may be required to process personal data, ensuring that they comply with current regulatory obligations.
Data Transfer outside of European Union
In principle, the Corum Butler Group does not transfer personal data outside the European Union. If this were to happen, the Group would implement the necessary measures to secure exchanges. For example,
– By ensuring that the transfer takes place in a country that has been the subject of an adequacy decision by the European Commission,
– By ensuring that the transfer constitutes one of the cases of exemption provided for in Article 49-1 of the RGPD, or
– By implementing the European Commission’s standard contractual clauses.
Rights and conditions
In accordance with Article 13 (2) b/ of the GDPR, any data subject is informed that he or she may request from the Group at any time:
– Access to personal data concerning them,
– Rectification or deletion of such data,
– Limitation of or objection to processing,
– Data portability,
– Opposition to processing,
– Withdrawal of consent.
To exercise these rights, please contact CORUM AM:
– By e-mail at [email protected]
– By post at the following address:
CORUM Asset Management
Délégué à la Protection des Données
1, rue Euler – 75008 Paris,
If, after contacting the Group’s Data Protection Officer or one of his or her correspondents, you feel that your data protection rights have not been respected, you may submit a complaint to the CNIL on the CNIL website via the online complaint teleservice, or by post by writing to : CNIL – Service des Plaintes – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07; or to your local data protection authority.