This document is governed by French law. The French version is the sole legally binding version; this translation is provided for convenience only.
Introduction and Scope
This personal data protection policy describes how Fundscreener, published by Kyubi Partners, collects, uses, retains and protects users' personal data in accordance with the General Data Protection Regulation (GDPR). This policy applies to all users of the Fundscreener application.
Types of Data Collected
Fundscreener collects the following data:
- Identification data (surname, first name, email address, etc.)
- Connection data (IP address, connection logs, etc.)
- Browsing and application usage data
This data is collected to ensure the proper functioning of the service and to improve the user experience.
Purposes of Data Processing
Fundscreener uses personal data for the following purposes:
- Providing and personalising the service
- Managing user accounts
- Analysing use of the application in order to improve its features
- Informing users of updates and important events
- Ensuring user security and data protection
Legal Basis for Processing
The processing of personal data by Fundscreener is based on the following legal grounds:
- The performance of the contract between Fundscreener and users (access to the service)
- Users' consent for certain features (e.g. marketing, notifications)
- Fundscreener's legitimate interest in improving and securing the service
Data Retention
Fundscreener retains personal data for the period necessary to achieve the purposes for which it was collected. Data may be archived for an additional period in order to comply with legal obligations. Specific retention periods are communicated to users upon request.
Users' Rights
In accordance with the GDPR, Fundscreener users have the following rights:
- Right of access: to obtain confirmation that personal data is being processed and to access such data
- Right to rectification: to request the correction of inaccurate data
- Right to erasure: to request the deletion of personal data under certain conditions
- Right to object: to refuse the processing of their data in certain cases
- Right to restriction of processing: to restrict the use of their data in certain cases
To exercise these rights, users may contact Fundscreener at the following email address: data@fundscreener.app
Data Sharing and Transfer
Fundscreener does not share users' personal data with third parties, except in the following cases:
- Trusted partners for the performance of services related to the application (e.g. hosting, external APIs)
- Legal obligations or requests from judicial authorities
All of Fundscreener's partners respect the confidentiality of data and apply protection measures in compliance with the GDPR.
Data Security
Fundscreener implements technical and organisational measures to ensure the security of personal data against unauthorised access, loss, alteration or disclosure. These measures include data encryption, secure authentication and regular security audits.
The fundscreener.app website: forms and document uploads
This section describes the processing specific to the www.fundscreener.app website, separate from that of the application.
Sign-up forms (Copilot early access, audit request)
When you complete a form, we collect your professional email address, the language you are browsing in and the date of the request. This data is used solely to answer your request and to inform you when the relevant service opens. The legal basis is your consent, obtained through double confirmation: an email is sent to you, and your address is recorded only after you click the link it contains.
These addresses are processed by Intuit Mailchimp (The Rocket Science Group LLC, United States), acting as a processor. The transfer outside the European Union is governed by the European Commission's standard contractual clauses and by the provider's certification under the EU–US Data Privacy Framework. Every email includes an unsubscribe link, and you may at any time request the deletion of your address by writing to data@fundscreener.app.
Uploading a portfolio statement (free audit)
The audit form lets you upload a document (portfolio statement as a PDF, spreadsheet, text file or photograph). The file is transmitted over an encrypted connection and kept in a private storage area, not publicly accessible, at our hosting provider. Only authorised members of the Fundscreener team access it, through signed download links valid for seven days.
The file is used for the sole purpose of producing the requested audit, then automatically deleted no later than thirty days after upload, through an expiry rule applied to the storage. The legal basis is the performance of pre-contractual steps taken at your request.
Important recommendation: we invite you to anonymise your statement before uploading it — only ISIN codes and amounts are useful to us. If the document you upload contains personal data relating to your own clients, you remain the controller of that data; Fundscreener then acts as a processor, on your instructions alone and for the duration of the audit.
Hosting and protection of the website
The website is hosted by Cloudflare, Inc., which also provides protection against attacks and automated submissions. In that capacity, Cloudflare processes technical connection data (IP address, timestamp, browser type), kept for a short period for security and service reliability purposes.
The website sets a single functional cookie, fs_lang, which remembers the language you chose for one year. It serves no analytics purpose and does not identify you.
Retention periods specific to the website
- Confirmed email address: until you unsubscribe, and at most three years after our last exchange
- Unconfirmed email address: deleted no later than six months after the request
- Uploaded portfolio statement: thirty days at most
- Technical connection data: a few days
Cookie Policy
Fundscreener uses cookies to improve the user experience and for traffic analysis. Users can configure their cookie preferences via their browser settings. Fundscreener uses, in particular, functional cookies and audience measurement cookies. For more details, see the Cookie Policy.
Amendments to the GDPR Policy
Fundscreener reserves the right to amend this personal data protection policy at any time. Users will be informed of any amendments by notification in the application. Continued use of the service after the policy has been updated constitutes acceptance of the changes.
Contact
For any questions regarding this personal data protection policy or to exercise their rights, users may contact Fundscreener's Data Protection Officer at the following email address: data@fundscreener.app