© 2025 Entropy Algorithmics, All Rights Reserved
EU GDPR POLICY
Entropy Algorithmics is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by us is controlled by us, and we are the data controller of your personal information. When your details are provided to us as a consequence of a consulting mission, then Entropy Algorithmics, acting as a data controller, may itself (or through a third party) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, "Your Personal Information"). When processing Your Personal Information, the Administrator may also act as a data controller.
The Administrator is located in France at 31 Avenue de Saint Roman, 06240 Beausoleil and can be contacted at contact@entropyalgorithmics.com.
This policy (the "EU Privacy Policy") explains the manner in which we collect, utilize, and maintain nonpublic personal information about clients and potential clients ("Client" or "Clients") based in the European Union ("EU") or the European Economic Area ("EEA"), as required under the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This EU Privacy Policy applies to any consulting mission conducted by us for your benefit.
COLLECTION OF YOUR PERSONAL INFORMATION
Entropy Algorithmics collects Your Personal Information from the following sources, as applicable:
- contractual documents and other information provided by the Client in writing, in person, by telephone, electronically, or by any other means (this information includes name, address, income, financial and investment qualifications, tax-related information, birth date, nationality, passport or other identification number, and employment information);
- recurring services and subscriptions provided to the Client over a pre-determined period or on a pay-as-you-go basis;
- on-site and remote staff training; and
- other interactions with Entropy Algorithmics (for example, discussions with our staff).
WHY WE USE YOUR PERSONAL INFORMATION
Your Personal Information may be processed by Entropy Algorithmics and/or the Administrator (or any of their affiliates, agents, employees, delegates, or subcontractors) for the following purposes, as applicable:
- to facilitate the monitoring and completion of a consulting mission on an ongoing basis (the "Services") as necessary to fulfill all contractual obligations related to the agreed upon checklist of service items to be fulfilled by us;
- to comply with our legal obligations such as to report tax-related information to local tax authorities;
- to disclose information to other third parties such as service providers (including, for example, accountants, auditors, or other professionals) and technology providers in order to comply with any potential legal obligation or in order to pursue the legitimate interests of Entropy Algorithmics; and/or
- to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein;
COUNTRIES HAVING ACCESS TO YOUR PERSONAL INFORMATION
Entropy Algorithmics' servers, which store and keep Your Personal Information, are located in France and in the United States.
Entropy Algorithmics also has service providers whose personnel will have access to Your Personal Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the performance of the contract between Entropy Algorithmics and its clients. These jurisdictions either (i) afford an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, then Entropy Algorithmics has entered into agreements with these service providers incorporating clauses that are the same as or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and impose obligations no less onerous than those contained in this EU Privacy Policy.
COLLECTING INVESTOR INFORMATION LEGALLY
Entropy Algorithmics is able to legally collect and use Your Personal Information because
- you have consented to its doing so;
- it is necessary for the performance of a contract to which the Client is a party or in order to take steps at the request of the Client prior to entering into a contract or to otherwise perform the Services;
- collecting and using Your Personal Information is necessary for Entropy Algorithmics to fulfill its legitimate business interests, which may include to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protect their legal rights; and/or
- it is necessary to comply with any applicable regulatory, judicial, or other legal obligations applicable to Entropy Algorithmics.
RETENTION OF CLIENT INFORMATION
Entropy Algorithmics will retain Your Personal Information for the purposes described in 1, 2, and 3 in the immediately preceding paragraph for as long as required for the purposes described above. In particular, and without limitation to the foregoing, Entropy Algorithmics has obligations imposed under applicable legal systems that require it to retain Your Personal Information for certain minimum time periods.
YOUR RIGHTS
You have the right to
- be informed, as this EU Policy seeks to do, about Your Personal Information that Entropy Algorithmics collects from you, uses, and retains;
- obtain confirmation from Entropy Algorithmics that your Personal Information is being collected, used, and retained as described above and access Your Personal Information held by us;
- have Your Personal Information corrected if it is inaccurate or incomplete at any time;
- erasure (or the right to be forgotten) which means you can request deletion or removal of any of Your Personal Information that Entropy Algorithmics holds at any time, subject to Entropy Algorithmics' rights to retain Your Personal Information as provided under the GDPR;
- block or suppress Entropy Algorithmics' collecting and using Your Personal Information, which means Entropy Algorithmics can continue to store Your Personal Information but cannot further collect or use it in any way;
- obtain and reuse any of Your Personal Information that Entropy Algorithmics holds for your own purposes across different services, which allows you to move, copy, or transfer Your Personal Information easily from Entropy Algorithmics to another place identified by you to Entropy Algorithmics in a safe and secure way without hindrance to the usability of Your Personal Information;
- object to Entropy Algorithmics' collecting, using, or retaining Your Personal Information when this is based on your legitimate interest or the performance of a task in the public interest or your desire not to receive direct marketing even if otherwise legally permitted; and
- withdraw your consent to the use of Your Personal Information at any time, as described below.
To make any requests as listed above, please contact us or email the Administrator at contact@entropyalgorithmics.com.
Entropy Algorithmics will respond to requests relating to your rights above within one month of receipt of your request or within two months of receipt of your request when the request is more complex.
WITHDRAWAL OF YOUR CONSENT
You can tell Entropy Algorithmics to stop collecting, using, and retaining Your Personal Information at any time by emailing the Administrator at contact@entropyalgorithmics.com. You should note that notwithstanding your withdrawal of consent, Entropy Algorithmics and its Administrator may be legally required to retain some or all of Your Personal Information.
PROTECTION OF CLIENT INFORMATION
Entropy Algorithmics maintains appropriate technical and organizational measures to ensure a level of security appropriate to address potential risks, including physical, electronic, and procedural safeguards that comply with the GDPR to protect customer information, including
- the pseudonymization and encryption of Your Personal Information when appropriate;
- ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
- ensuring that the Adminsitrator can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and
- regular testing, assessment, and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.
The Administrator restricts access to the personal and account information of Clients to those employees who need to know that information in the course of their job responsibilities. The Administrator will destroy, erase, or make unreadable data, computer files, and documents containing Your Personal Information that is nonpublic prior to disposal.
MAKING A COMPLAINT
If you would like to make a complaint about the way Entropy Algorithmics has collected, used, or retained Your Personal Information, please contact us at contact@entropyalgorithmics.com. You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work, or place of the alleged infringement if you consider that the processing of Your Personal Information carried out by Entropy Algorithmics or its service providers infringes the GDPR.
FORMER CUSTOMERS
This EU Privacy Policy also applies to former Clients in the EU and the EEA.
FURTHER INFORMATION
This EU Privacy Policy is in addition to Entropy Algorithmics' existing Privacy Policy, a copy of which is available from the Administrator. The Administrator reserves the right to change this EU Privacy Policy at any time and without prior notification. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy is intended to comply with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws. If you have any questions about this EU Privacy Policy, please email us at contact@entropyalgorithmics.com. No further action is required on your part.
Entropy Algorithmics is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by us is controlled by us, and we are the data controller of your personal information. When your details are provided to us as a consequence of a consulting mission, then Entropy Algorithmics, acting as a data controller, may itself (or through a third party) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, "Your Personal Information"). When processing Your Personal Information, the Administrator may also act as a data controller.
The Administrator is located in France at 31 Avenue de Saint Roman, 06240 Beausoleil and can be contacted at contact@entropyalgorithmics.com.
This policy (the "EU Privacy Policy") explains the manner in which we collect, utilize, and maintain nonpublic personal information about clients and potential clients ("Client" or "Clients") based in the European Union ("EU") or the European Economic Area ("EEA"), as required under the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This EU Privacy Policy applies to any consulting mission conducted by us for your benefit.
COLLECTION OF YOUR PERSONAL INFORMATION
Entropy Algorithmics collects Your Personal Information from the following sources, as applicable:
- contractual documents and other information provided by the Client in writing, in person, by telephone, electronically, or by any other means (this information includes name, address, income, financial and investment qualifications, tax-related information, birth date, nationality, passport or other identification number, and employment information);
- recurring services and subscriptions provided to the Client over a pre-determined period or on a pay-as-you-go basis;
- on-site and remote staff training; and
- other interactions with Entropy Algorithmics (for example, discussions with our staff).
WHY WE USE YOUR PERSONAL INFORMATION
Your Personal Information may be processed by Entropy Algorithmics and/or the Administrator (or any of their affiliates, agents, employees, delegates, or subcontractors) for the following purposes, as applicable:
- to facilitate the monitoring and completion of a consulting mission on an ongoing basis (the "Services") as necessary to fulfill all contractual obligations related to the agreed upon checklist of service items to be fulfilled by us;
- to comply with our legal obligations such as to report tax-related information to local tax authorities;
- to disclose information to other third parties such as service providers (including, for example, accountants, auditors, or other professionals) and technology providers in order to comply with any potential legal obligation or in order to pursue the legitimate interests of Entropy Algorithmics; and/or
- to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein;
COUNTRIES HAVING ACCESS TO YOUR PERSONAL INFORMATION
Entropy Algorithmics' servers, which store and keep Your Personal Information, are located in France and in the United States.
Entropy Algorithmics also has service providers whose personnel will have access to Your Personal Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the performance of the contract between Entropy Algorithmics and its clients. These jurisdictions either (i) afford an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, then Entropy Algorithmics has entered into agreements with these service providers incorporating clauses that are the same as or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and impose obligations no less onerous than those contained in this EU Privacy Policy.
COLLECTING INVESTOR INFORMATION LEGALLY
Entropy Algorithmics is able to legally collect and use Your Personal Information because
- you have consented to its doing so;
- it is necessary for the performance of a contract to which the Client is a party or in order to take steps at the request of the Client prior to entering into a contract or to otherwise perform the Services;
- collecting and using Your Personal Information is necessary for Entropy Algorithmics to fulfill its legitimate business interests, which may include to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protect their legal rights; and/or
- it is necessary to comply with any applicable regulatory, judicial, or other legal obligations applicable to Entropy Algorithmics.
RETENTION OF CLIENT INFORMATION
Entropy Algorithmics will retain Your Personal Information for the purposes described in 1, 2, and 3 in the immediately preceding paragraph for as long as required for the purposes described above. In particular, and without limitation to the foregoing, Entropy Algorithmics has obligations imposed under applicable legal systems that require it to retain Your Personal Information for certain minimum time periods.
YOUR RIGHTS
You have the right to
- be informed, as this EU Policy seeks to do, about Your Personal Information that Entropy Algorithmics collects from you, uses, and retains;
- obtain confirmation from Entropy Algorithmics that your Personal Information is being collected, used, and retained as described above and access Your Personal Information held by us;
- have Your Personal Information corrected if it is inaccurate or incomplete at any time;
- erasure (or the right to be forgotten) which means you can request deletion or removal of any of Your Personal Information that Entropy Algorithmics holds at any time, subject to Entropy Algorithmics' rights to retain Your Personal Information as provided under the GDPR;
- block or suppress Entropy Algorithmics' collecting and using Your Personal Information, which means Entropy Algorithmics can continue to store Your Personal Information but cannot further collect or use it in any way;
- obtain and reuse any of Your Personal Information that Entropy Algorithmics holds for your own purposes across different services, which allows you to move, copy, or transfer Your Personal Information easily from Entropy Algorithmics to another place identified by you to Entropy Algorithmics in a safe and secure way without hindrance to the usability of Your Personal Information;
- object to Entropy Algorithmics' collecting, using, or retaining Your Personal Information when this is based on your legitimate interest or the performance of a task in the public interest or your desire not to receive direct marketing even if otherwise legally permitted; and
- withdraw your consent to the use of Your Personal Information at any time, as described below.
To make any requests as listed above, please contact us or email the Administrator at contact@entropyalgorithmics.com.
Entropy Algorithmics will respond to requests relating to your rights above within one month of receipt of your request or within two months of receipt of your request when the request is more complex.
WITHDRAWAL OF YOUR CONSENT
You can tell Entropy Algorithmics to stop collecting, using, and retaining Your Personal Information at any time by emailing the Administrator at contact@entropyalgorithmics.com. You should note that notwithstanding your withdrawal of consent, Entropy Algorithmics and its Administrator may be legally required to retain some or all of Your Personal Information.
PROTECTION OF CLIENT INFORMATION
Entropy Algorithmics maintains appropriate technical and organizational measures to ensure a level of security appropriate to address potential risks, including physical, electronic, and procedural safeguards that comply with the GDPR to protect customer information, including
- the pseudonymization and encryption of Your Personal Information when appropriate;
- ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
- ensuring that the Adminsitrator can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and
- regular testing, assessment, and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.
The Administrator restricts access to the personal and account information of Clients to those employees who need to know that information in the course of their job responsibilities. The Administrator will destroy, erase, or make unreadable data, computer files, and documents containing Your Personal Information that is nonpublic prior to disposal.
MAKING A COMPLAINT
If you would like to make a complaint about the way Entropy Algorithmics has collected, used, or retained Your Personal Information, please contact us at contact@entropyalgorithmics.com. You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work, or place of the alleged infringement if you consider that the processing of Your Personal Information carried out by Entropy Algorithmics or its service providers infringes the GDPR.
FORMER CUSTOMERS
This EU Privacy Policy also applies to former Clients in the EU and the EEA.
FURTHER INFORMATION
This EU Privacy Policy is in addition to Entropy Algorithmics' existing Privacy Policy, a copy of which is available from the Administrator. The Administrator reserves the right to change this EU Privacy Policy at any time and without prior notification. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy is intended to comply with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws. If you have any questions about this EU Privacy Policy, please email us at contact@entropyalgorithmics.com. No further action is required on your part.