Legal Notice
Summary: Privacy Policy
Identity
Pursuant to the provisions of Articles 6-III and 19 of Law No. 2004-575 of June 21, 2004, on Confidence in the Digital Economy (LCEN), users of the culturepatrimoine.fr website are hereby informed of the identities of the various parties involved in the creation and maintenance of the site.
Website Editor
Culture Patrimoine
Company Name: CULTURE PATRIMOINE, LLC
Share capital: 585,020 euros
Company represented by Mr. Nicolas NICAISE, Mr. Arthur MAITRE, Ms. Laëtitia ALDEGUER, and Ms. Aurélie KHALDI, acting as co-managers.
Headquarters:
1 Volney Street
75002 Paris – France
📞 Phone: 01 79 74 24 42
✉️ Email: contact@culturepatrimoine.fr
Registration number: 488 989 369 Paris Commercial Register
ORIAS Number: 07 005 593
Single Registry of Insurance, Banking, and Financial Intermediaries: www.orias.fr
Publisher
The person responsible for publication is one of the co-managers of Culture Patrimoine.
Accommodation
The site is hosted by IONOS SARL
7, Place de la Gare
BP 70109
57200 Sarreguemines Cedex
France
Hosting Contact
IONOS SARL:Phone 0970 808 911 (no surcharge)
Email: info@ionos.fr
Personal information
Any information collected on this website is intended exclusively for Culture Patrimoine in connection with its activities.
In accordance with the General Data Protection Regulation (GDPR), users have the right to access, correct, object to, restrict, and delete their personal data.
You may exercise these rights by sending a request to the following email address: contact@culturepatrimoine.fr.
Introductory Document
In accordance with the various laws and regulations governing our business activities, please find below the regulatory information that governs our contractual relationship.
SARL CULTURE PATRIMOINE
Represented by Mr. Nicolas NICAISE, Mr. Arthur MAITRE, Ms. Laëtitia ALDEGUER, and Ms. Aurélie KHALDI, acting as co-managers, Registered office: 1 rue Volney 75002 PARIS, Capital: 585,020 Euros, Registration number: 488 989 369 Paris Trade and Companies Register, ORIAS number: 07 005 593 www.orias.fr
- Financial Investment Advisor No. D003830 (CIF): Member of the CNCEF (https://wwwcncef.org), accredited by the Autorité des Marchés Financiers (www.amf-france.org)
- Insurance Intermediary (IAS – COA) regulated by the ACPR 4 Place de Budapest 75346 PARIS Cedex 9
- Banking and Payment Services Intermediary (M-IOBSP) regulated by the ACPR 4 Place de Budapest 75346 PARIS Cedex 9
- Banking and Financial Sales
- Real estate agent, real estate transaction license and business license CPI 7501 2016 000 011113 issued by the Paris Chamber of Commerce and Industry
Financial investment advisor:
In connection with consulting services provided on a non-independent basis and in accordance with applicable regulations, Culture Patrimoine may receive fees, commissions, or monetary or non-monetary benefits in connection with the provision of advisory services, paid or provided by a third party or by a person acting on behalf of a third party, subject to compliance with the rules on benefits and fees requiring disclosure to the Client, the obligation to improve service, and compliance with the obligation to act in the Client’s best interests.
Culture Patrimoine also informs the Client that its services are based on a comprehensive analysis of various types of financial instruments.
Sustainability Policy:
In March 2018, the European Commission published an action plan to finance sustainable growth, which included three recommendations specifically targeting the financial sector:
– Redirect capital flows toward sustainable investments in order to achieve sustainable and inclusive growth;
– Manage financial risks arising from climate change, resource depletion, environmental degradation, and social issues;
– Promote transparency and a long-term perspective in economic and financial activities.
Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019, on sustainability-related disclosures in the financial services sector was subsequently adopted. This Regulation establishes harmonized rules on transparency regarding the integration of sustainability risks and the consideration of negative sustainability impacts in investment decisions, as well as the provision of sustainability-related information on financial products.
In line with this approach, Culture Patrimoine is subject to Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019, on the disclosure of sustainability-related information in the financial services sector. This policy is therefore established in accordance with Article 3 of that Regulation.
Information on sustainability risks
Culture Patrimoine is implementing a policy for selecting financial products based primarily on the following criteria
- A selection of investments, based in particular on the product governance framework he has established within the firm, which enables him to select investments that align with his clients’ sustainability preferences.
Insurance
In the insurance sector, it should also be noted that insurers must offer policyholders or members unit-linked products consisting of securities, FCPR-type investment funds, venture capital firms, or certified assets that contribute to financing the energy and ecological transition, socially responsible investment, or the financing of social enterprises (list referred to in Article L. 131-1-2 of the Insurance Code).
With specific regard to the insurance products offered by Culture Patrimoine—which include unit-linked products—customers are encouraged to refer to the information available on the websites of the relevant management companies.
Compensation Policy:
Culture Patrimoine ensures that its compensation structure—comprising both fixed and variable components—does not encourage excessive risk-taking with regard to sustainability.
This compensation structure does not take into account the distribution of specific products. Consequently, and like other investment contracts and vehicles, investment contracts and vehicles that promote ESG characteristics or are classified as sustainable investments are recommended to the client provided they meet the client’s objectives and needs.
Insurance broker:
Culture and Heritage reports:
- Whether it provides Level 2 advisory services: issuing a personalized recommendation that explains to the Client why, among several contracts or options, one or more contracts or options best meet their requirements and needs.
- That he is not contractually obligated to work exclusively with one or more insurance companies
Banking intermediary and mortgage advisor:
Culture Patrimoine offers an advisory service within the meaning of Article L. 519-1-1 of the Monetary and Financial Code regarding real estate loan agreements. As part of this service, the recommendations provided by Culture Patrimoine pertain to its own product range (non-independent advice).
Culture Patrimoine also works with specialized brokers under a business referral agreement.
A loan is a financial commitment and must be repaid. Be sure to assess your ability to repay before taking out a loan. The IOBSP may not require any payment of any kind before the loan funds are actually disbursed.
Banking and Financial Sales
Culture Patrimoine also acts as a banking and financial broker for the clients listed below (Eres)
Real estate transaction (without handling funds)
Activity governed by Law No. 70-9 of January 2, 1970, known as the Hoguet Law, and the related laws, decrees, and ordinances, under the authority of real estate professional license CPI 7501 2016 000 011113 issued by the Paris Police Prefecture on August 16, 2008, and renewed with the Paris Chamber of Commerce and Industry (CCI) since then.
Key partners:
Culture Patrimoine works with the following partners, among others: Interinvest, Corum, Sofidy, Primonial, La Française, Perial, Colocatere, Eres, Alpheys, Axa, Generali, Swiss Life, UAF, MMA, Arbevel, Ageas, April, Oradeo, Lombard Lux… A complete and up-to-date list is available upon request.
General Liability and Professional Liability Insurance (PLI) and Financial Guarantees:
Culture Patrimoine also holds financial guarantees and a professional liability insurance policy with MMA COVEA RISKS, policy no. 113.516.288.
Processing of Personal Data and Privacy:
Culture Patrimoine operates under strict confidentiality and professional secrecy obligations. In the course of providing its services, Culture Patrimoine may process personal data pertaining to the Client, to which the Client consents.
In accordance with the provisions of Law No. 78-17 of January 6, 1978, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Culture Patrimoine undertakes to collect and process data solely for the purposes agreed upon between Culture Patrimoine and its Client, to preserve the security and integrity of such data, to disclose this information only to third parties to whom it is necessary to transmit it in order to perform the agreed-upon services, and more generally to act in accordance with the regulatory requirements to which it is subject. The Client is informed that they have the right to request access to their personal data from the data controller, as well as the right to request a restriction on the processing of their personal data, upon simple request.
The name and contact information of the data controller at Culture Patrimoine are as follows: Laetitia ALDEGUER – 1 rue Volney, 75002 Paris – 0179742442 – laetitia.aldeguer@culturepatrimoine.fr
The Customer has the right to file a complaint with the French Data Protection Authority (CNIL):
National Commission for Information Technology and Civil Liberties (CNIL) 3 Place de Fontenoy P.O. Box 80715 75334 PARIS CEDEX 07
Conflict of interest:
Culture Patrimoine has established a written policy for managing conflicts of interest, with the aim of identifying, preventing, and managing situations that could give rise to a conflict of interest. When the measures in place are insufficient to ensure, with reasonable certainty, that the risk of harming the Client’s interests will be avoided, Culture Patrimoine undertakes to provide the Client with a specific written description of the conflict of interest, thereby enabling the Client to make an informed decision regarding the service provided.
Complaints, applicable law, and mediation:
For any complaints, the Customer must first contact Culture Patrimoine to seek an amicable resolution. The complaint, submitted in writing, should be sent to: Culture Patrimoine – Complaints Department – 1 rue Volney, 75002 Paris, info@culturepatrimoine.fr
Culture Patrimoine undertakes to acknowledge receipt of the complaint within ten business days and to respond to it within a maximum of two months from the date the complaint was submitted, unless exceptional and duly justified circumstances arise. If the Customer is not satisfied with the response to their complaint, they may refer the matter to the following competent consumer ombudsman:
In connection with financial investment advisory services:
The Ombudsman, Autorité des marchés financiers 17 Place de la Bourse 75082 PARIS CEDEX 02
For other services: CMAP – Consumer Mediation Service consommation@cmap.fr 39 Avenue F.D. Roosevelt, 75008 Paris.
The applicable law is French law.
Services and rates:
On our website, www.culturepatrimoine.fr, you can find our services and rates under the heading “Our Expertise -> Our Services and Rates,” a copy of which was provided to you today.
Contact information and updates:
Customers may contact Culture Patrimoine by phone at 0179742442, by mail at 1 rue Volney, 75002 Paris, or by email at info@culturepatrimoine.fr
Culture Patrimoine will provide the Customer with any updates to this information via email or through the Customer’s online archive. The Customer may also obtain this information at any time by simply requesting it from Culture Patrimoine.
The Client is advised of the importance of providing complete and truthful information. The Client is also advised of the adverse effects that any lack of completeness or truthfulness may have on the quality of the advice and recommendations provided.
Please review this document, keep a copy signed by us, and return a copy signed by you.
