1.1. Le site www.finexkap.com est la propriété de la société Finexkap SAS dont le siège social est situé 92 rue du Faubourg Saint-Antoine, 75012 Paris, immatriculée au Registre du Commerce et des Sociétés de Paris sous le numéro 788 592 889, société par actions simplifiée au capital social de 661 397 €, e-mail info@finexkap.com, téléphone : 01 82 83 14 47, numéro TVA intracommunautaire FR89 788 592 889.

2.1. The user is informed that the site uses cookies or other tracers.

2.2. These are likely to be installed in your terminal subject to the choices and options that you have expressed or may express at any time in accordance with this policy.

3.1. For the sake of information and transparency, Finexkap has defined this cookie policy to allow the user to know more about :

• the origin and purpose of the information processed during your navigation on the www.finexkap.com website;
• your rights regarding cookies and other tracers used by Finexkap.

4.1. Cookies, or other similar tracking devices, are data used by a server to send status information to a user's browser, and by that browser to return status information to the originating server.

4.2. Status information can be, for example, a session ID, language, expiration date, response domain, and so on.

4.3. Cookies make it possible to store status information for the duration of validity when a browser accesses the various pages of a website or when the browser subsequently returns to this website.

4.4. Only the issuer of a cookie can read or modify the information contained therein.

4.5. There are different types of cookies:

• - session cookies which disappear as soon as you leave the site;
• - permanent cookies which remain on your terminal until the expiration of their lifespan or until you delete them using the functionalities of your browser.

5.1. We use cookies and other tracking devices for the following main purposes:

• - to count visitors and identify how they use the website;
• - to count and differentiate visits;
• - implement security measures;
• - to allow you to access reserved areas (your personal space...) thanks to identifiers identifying by which site or search engine the user arrived at the expression of the search;
• - to carry out statistics and analyses of frequentation and use of the website in order to improve it;
• - to improve the relevance of online advertisements and advertising targeting by adapting advertisements to your navigation.

6.1. Les cookies et traceurs utilisés sur le site sont :

6.2. In addition, on our website, social media applications are integrated to allow you to share or to make known our content from our website to others.

6.3. Social media. The social media is likely to identify you through this button, even if you did not use this button when visiting our site

6.4. This type of button may allow the relevant social media to track your browsing on our site, simply because your account on the relevant social media is activated on your device (logged in) while you are browsing our site.

6.5. We recommend that you consult the policies of these social media in order to be aware of the purposes of use, including advertising, of the browsing information they may collect. In particular, these policies must allow you to exercise your choices on these social media, notably by setting up your accounts for use on each of them.

6.6. Google Analytics service. The user is informed that the website uses the Google Analytics service, provided by Google Inc. ("Google"), to analyse the navigation on the website and to carry out statistics and audience measurements. This data is transmitted and stored by Google on servers located in the United States. Google entities are members of the Safe Harbor and ensure an adequate level of data protection (Decision 2000/520/EC of 26-7-2000). For more information, you can go to the following page: click here.

7.1. The installation of cookies is subject to your consent. Also, during your first visit to the site, you will be asked whether you accept or refuse cookies that require your consent before they are installed on your equipment.

7.2. If you refuse them, a refusal cookie[4] will be inserted in your terminal so that Finexkap records the information that you do not want any cookies to be installed. Please note, however, that if you delete this refusal cookie, the cookies will be able to be installed on your terminal again.

7.3. On the other hand, if you consent in accordance with the terms and conditions made known to you in the information banner on the home page of the site, i.e. by continuing your navigation, the aforementioned cookies will be installed on your device.

7.4. You can change your mind at any time :

• either by deleting the rejection cookie;
• or by the various means described in the section "Deleting and/or rejecting cookies" and in the section "Right of opposition and access".

8.1. You have several options to delete cookies and other trackers.

8.2. Browser settings

8.2.1. If most browsers are set by default and accept the installation of cookies, you have the possibility, if you wish, to choose to accept all cookies or to reject them systematically or to choose which ones you accept according to their originators.

8.2.2. You can also set your browser to accept or refuse cookies on a case-by-case basis prior to their installation. You can also regularly delete cookies from your terminal via your browser. Don't forget to configure all the browsers of your various devices (tablets, smartphones, computers, etc.).

8.2.3. "For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will tell you how to change your cookie preferences. As an example " :

• for Internet Explorer™: click here ;
• for Safari™: click here ;
• for Chrome™: click here ;
• for Firefox™: click here ;
• for Opera™: click here.

8.2.4. The storage of a cookie in your device is essentially subject to your will, which you can express and modify at any time and free of charge through the choices offered to you by your browser software[5].

8.2.5. If your browser is set to accept cookies on your device, cookies embedded in the pages and content you have viewed may be stored temporarily in a dedicated area of your device. They will only be readable by their sender.

8.2.6. Conversely, you can set your browser to refuse cookies. In this respect, your attention is drawn to the fact that by setting your browser to refuse cookies, certain functionalities, pages and areas of the site will not be accessible, for which we cannot be held responsible.

8.3. Specialized platforms

8.3.1. Several platforms of advertising professionals also offer you the possibility of refusing or accepting cookies used by their member companies. These centralized mechanisms do not block the display of advertisements, but only prevent the installation of cookies that allow the advertisements to be adapted to your centres of interest.

8.3.2. For example, you can go to www.youronlinechoices.com to prohibit the installation of these cookies on your terminal. This site is provided by digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France.

8.3.3. You will thus be able to find out which companies are registered on this platform and which offer you the possibility of refusing or accepting the cookies used by these companies to adapt the advertisements that may be displayed on your terminal to your browsing information: https://www.youronlinechoices.com/fr/controler-ses-cookies/. https://www.youronlinechoices.com/fr/controler-ses-cookies/.

8.3.4. This European platform is shared by hundreds of Internet advertising professionals and provides a centralized interface allowing you to express your refusal or acceptance of cookies that may be used in order to adapt the advertisements that may be displayed on your device to the navigation of your device.

9.1. You are also informed that you have the right to question and access the information contained in the cookies used by Finexkap. This right can be applied by e-mail to info@finexkap.com.

^[1]Legal rules applicable to cookies. Article 32 of the Data Protection Act requires clear and complete information on:

• - the purpose of each type of cookie,
• - the means available to the user to oppose the installation of these cookies.

From this point of view, the question arises as to how this information should materialize to meet these requirements. Consequently, this implies for the data controller to determine with precision all the cookies used or other similar techniques on the site and, for each one, to indicate the purpose pursued. In order to comply with this obligation, it is therefore recommended to list the cookies with the indication of their purpose. This information must also be done for cookies installed by third parties.

In addition to this obligation to provide information on the purpose, data controllers must also provide information on the means available to the user to refuse cookies. In this respect, the data controller must remind Internet users that they have the option via their browser to refuse the presence of cookies. From this point of view, the fairness of the information also implies indicating that if they refuse, certain functionalities of the site may no longer be executable.

Furthermore, Article 32 establishes the principle of prior consent to the installation of cookies. However, it provides for two exceptions where access to information stored in the user's terminal equipment or the registration of information in the user's terminal equipment:

• either for the exclusive purpose of allowing or facilitating communication by electronic means;
• or for strictly necessary provision of an online communication service at the express request of the user.

In all other cases, the information must be provided with the prior consent of the user. These exceptions must be interpreted restrictively. Therefore, any cookies that have a different purpose must be subject to prior consent prior to their installation.

^[2]Duration of conservation. In its deliberation of 5 December 2013 on cookies and other tracers, the CNIL recommends that the lifetime of a cookie should not exceed 13 months from the time of their first deposit in the user's terminal equipment, without their lifetime being extended on new visits to the site. Accordingly, it is recommended to request a setting of a duration in accordance with the recommendations of the cnil of cookies "-utma "of Google Analytics 13 months from their first deposit in the user's terminal equipment.

^[3]Cookies. With regard to cookies, it is recalled that the installation of cookies on users' terminals is regulated by Article 32 II of the French Data Protection Act, which provides in particular that:

• Any subscriber or user of an electronic communications service must be informed in a clear and comprehensive manner, unless he or she has been previously informed by the controller or his or her representative;
• of the purpose of any action to access, by electronic transmission, information already stored in his electronic communications terminal equipment, or to enter information in that equipment;
• the means available to him/her to oppose this;
• Such access or registration may only take place on condition that the subscriber or user has expressed, after receiving this information, his agreement, which may result from appropriate parameters of his connection device or any other device under his control.

These provisions shall not apply if the access to or registration of information stored in the user's terminal equipment :

• either for the exclusive purpose of allowing or facilitating communication by electronic means;
• or for strictly necessary provision of an online communication service at the express request of the user.

On this point, the CNIL specifies that "Thus, given the risks they entail for privacy, cookies requiring prior information and consent of the Internet user are, in particular :

• cookies linked to operations relating to targeted advertising;
• audience measurement cookies (excluding those defined in Article 6 of this Recommendation);
• social media tracking cookies generated by social media sharing buttons.

Conversely, some cookies may be placed or read without the consent of individuals:

• cookies whose sole purpose is to enable or facilitate communication by electronic means;
• cookies strictly necessary to provide a service expressly requested by the user;
• audience measurement cookies as defined in Article 6 of this recommendation.

Audience measurement. Therefore, audience measurement cookies are in principle subject to consent, unless the following conditions are met :

• the person must be informed;
• the person must have the ability to object to them via an objection mechanism that can be easily used on all terminals, operating systems, applications and Internet browsers. No information relating to persons who have decided to exercise their right to object should be collected and transmitted to the publisher of the traffic analysis tool;
• the purpose of the device must be limited to audience measurement of the content viewed in order to allow an evaluation of the published content and the ergonomics of the site or application. The data collected must not be cross-checked with other data processing (customer files or statistics on visits to other sites, for example). The use of the deposited cookie must also be strictly limited to the production of anonymous statistics. Its scope must be limited to a single publisher and must not allow the tracking of the navigation of the person using different applications or browsing on different websites;
• the use of the IP address to geolocate the Internet user must not provide more precise information than the city. This IP address must also be deleted or anonymised once the geolocation has been carried out, in order to avoid any other use of this personal data or any cross-checking with other personal information;
• as regards cookies, they must not have a life span exceeding thirteen months and this period must not be automatically extended on new visits. Information collected through cookies should be retained for a maximum of thirteen months.

Consent. Also, audience measurement cookies, which would not meet these conditions, would be subject to consent. In this hypothesis, and as in all hypotheses in which consent is required, the CNIL recalls that consent must correspond to a manifestation of free, specific and informed will, and adds that:

• consent can only be valid if the person concerned is able to exercise his or her choice validly and is not exposed to significant negative consequences if he or she refuses to give consent. Also, the person who refuses a cookie requiring consent must be able to continue to benefit from the service (access to a website);
• the validity of the consent is linked to the quality of the information received. This information must be visible, prominent and complete. The information must be written in simple and comprehensible terms for all users, and must allow Internet users to be perfectly informed of the different purposes of the cookies deposited and read. The use of overly complex legal or technical terminology would not meet the requirement of prior information;
• consent must be expressed through positive action by the person who has been informed in advance of the consequences of his or her choice and has the means to exercise it. Appropriate systems must therefore be put in place to collect consent in practical ways that allow Internet users to benefit from user-friendly and ergonomic solutions. According to the CNIL, the acceptance of general conditions of use cannot be a valid way of obtaining consent.

Process for obtaining consent. In accordance with these principles, and after consultation with the professionals concerned, the Commission recommends a two-stage consent procedure.

In the first step, the Internet user who goes to an editor's site (home page or secondary page of the site) must be informed, by the appearance of a banner:

• of the precise purposes of the cookies used;
• of the possibility of opposing these cookies and of changing the parameters by clicking on a link in the banner;
• the fact that by continuing to browse the site, the user agrees to the placing of cookies on his/her terminal.

Insofar as consent must not be ambiguous, this banner must not disappear until the person has continued browsing, i.e. until he or she has gone to another page of the site or clicked on an element of the site (image, link, search button).

Thus, unless prior consent of the Internet user, the deposit and reading of cookies must not be carried out:

• if the Internet user goes to the site (home page or directly to another page of the site from a search engine for example) and does not continue his navigation: a simple absence of action cannot be assimilated to a manifestation of will;
• if he clicks on the link in the banner allowing him to set the cookies and, if necessary, refuses to accept cookies.

In the second step, people must be informed in a simple and intelligible manner of the solutions available to them to accept or refuse all or part of the cookies requiring consent:

• - for all the technologies referred to in the above-mentioned Article 32-II;
• - by categories of purposes: in particular advertising, social network buttons and audience measurement.

Also, in addition to this policy and the information relating to consent, a process for collecting consent must be deployed on the Finexkap website (see the mention proposed by the firm relating to cookies).

Finally, the CNIL reminds that persons who have given their consent to deposit or read certain cookies must be able to withdraw it at any time. User-friendly solutions must therefore be implemented so that the person can withdraw consent as easily as he or she has given it.

^[4]Refusal cookies. The CNIL recommends that an explanation of this "refusal cookie" be given on a dedicated page of the site, as it may cause legitimate confusion for some Internet users, who may be surprised to find a cookie when they have clicked on the "refusal" button. Thus, it is recommended that this be mentioned in the cookie policy, in the article relating to consent.

^[5]Browser settings. The CNIL considers that consent may result from the appropriate parameters of the person's connection device or any other device under his control. However, the browser's settings can only express the expression of consent by:

• if the user has been able to modify the parameters of his browser to accept or refuse cookies;
• and, if the user has been informed before placing or reading cookies, of their purposes and the means of opposing them.

The Commission points out that the browser settings do not allow, in the current state of the art, the management of technologies other than HTTP cookies. It considers that they could not therefore be regarded as satisfactory if technologies other than HTTP cookies were used, such as web beacons, flash cookies or fingerprinting techniques.

Finally, some browsers also offer the Do Not Track (DNT) option. The Commission considers that when an internet user decides to activate a do not track option, no profile should be created on that internet user and on his terminal. The Commission therefore recommends that, if this option is activated, no information should be collected to establish a profile of the Internet user and that both the Internet user and his terminal should not be tracked.

^[6]A refusal cookie should be inserted for Internet users who have activated the tab or who have sent Finexkap a request to refuse cookies.