Legal information and privacy policy
Website Publisher
SURL ARCAN (a Monégasque single-member limited liability company) with share capital of €8,000
Registered Office
c/o AAACS, One Monte-Carlo, 6 Avenue Princesse Alice, 98000 Monaco
RCI No.
26S10426
Intra-Community VAT No.
FR79000196609
Manager
Anthony Raymond
Contact
Hosting
Infomaniak Network SA
Rue Eugène-Marziano 25, 1227 Geneva, Switzerland
The data controller for the data collected via this website is SURL ARCAN, whose registered office is located at c/o AAACS, One Monte-Carlo, 6 Avenue Princesse Alice, 98000 Monaco, represented by Anthony Raymond. For any questions regarding the processing of your data, you may write to contact@arcan-consulting.com.
The processing activities described in this policy are based, depending on the case, on the performance of pre-contractual measures when you contact us via the form (art. 5-3), on your consent when you subscribe to the legal watch (art. 5-1), or on ARCAN's legitimate interest in measuring the traffic to its website for strictly statistical purposes, as described in Article 3 (art. 5-6).
Data processed in connection with the performance of engagements entrusted to ARCAN, including on the basis of contract performance or legal obligations such as anti-money laundering requirements, is processed exclusively within the ARCAN Space and is subject to a dedicated privacy policy (see Article 4).
ARCAN has not appointed a Data Protection Officer (DPO), as such an appointment is not required under Article 29 of Monégasque Law No. 1.565 of 3 December 2024.
| Purpose | Legal Basis | Categories of Data | Retention Period |
|---|---|---|---|
| Responding to requests received via the contact form | Performance of pre-contractual measures (art. 5-3) | Identity, contact details, message content | Duration necessary to process the request, and where applicable, to establish the contractual relationship |
| Sending the monthly legal watch | Consent (art. 5-1) | Email address | Until consent is withdrawn |
| Website audience measurement (Matomo) | Legitimate interest (art. 5-6) | Browsing data, statistical identifier | 14 months |
Fields marked as mandatory in the contact form are necessary to process your request: without them, ARCAN will not be able to respond to it. Other fields are optional.
You may withdraw your consent at any time, as easily as you gave it. Each edition of the legal watch contains a one-click unsubscribe link. Withdrawing your consent does not affect the lawfulness of processing carried out before such withdrawal.
The website uses Matomo, an audience measurement tool self-hosted by ARCAN on its Infomaniak hosting, in order to measure website traffic and improve the user experience. The browsing data collected for this purpose does not leave ARCAN's infrastructure and is not transmitted to any third party.
This processing is configured to limit data collection to what is strictly necessary: IP address anonymisation, no cross-referencing with other processing activities, no tracking of browsing on other websites, and a strictly statistical purpose. Under these conditions, it is based on ARCAN's legitimate interest in measuring the traffic to its website (art. 5-6), without requiring your prior consent.
You may nevertheless object at any time to this statistical tracking via the opt-out form available at the bottom of every page of the website, under "Tracking Management". This choice is remembered by a technical cookie until it is deleted by your browser or by you.
The retention period for the associated data is 14 months.
No other cookie is placed on your device by this website.
This website does not, through its browsing activity, collect any data relating to the performance of engagements entrusted to ARCAN by its clients. Data processed for that purpose — identity, economic and financial information, data relating to beneficial owners, notably under AML/CFT obligations (Monégasque Law No. 1.362 of 3 August 2009) — is processed exclusively within the ARCAN Space, the secure management tool made available to clients, and is subject to a dedicated privacy policy communicated to each client upon entering into the relationship.
The data collected via this website is intended for ARCAN, in the person of its Manager.
It may be disclosed, to the extent necessary for each purpose, to the technical service providers mentioned in Article 17 of this policy, acting as data processors, as well as to the competent administrative and judicial authorities, where required by law.
See the table in Article 2 for details of the retention periods applicable to each processing activity.
The rights set out in Articles 8 to 14 may be exercised by written request addressed to contact@arcan-consulting.com.
Where ARCAN has reasonable doubts as to the identity of the person exercising a right, it may request additional information necessary to confirm that identity, in particular a copy of a valid proof of identity.
ARCAN will inform you in writing of the action taken on your request within one month of its receipt. In the case of a complex request or multiple requests, this period may be extended by two months; you will then be informed of the reasons for the extension within one month.
The exercise of these rights is free of charge. In the event of a manifestly unfounded or excessive request, in particular due to its repetitive nature, ARCAN may charge a reasonable fee or refuse to act on the request.
You have the right to obtain confirmation as to whether or not data concerning you is being processed and, where applicable, to access that data as well as the information provided for in Article 12 of Monégasque Law No. 1.565 of 3 December 2024.
ARCAN will provide you with a copy of the data undergoing processing. For any additional copies, ARCAN may charge a reasonable fee based on administrative costs. The provision of this copy may not adversely affect the rights and freedoms of others, nor information covered by a legal obligation of secrecy.
You have the right to obtain, as promptly as possible, the rectification of any inaccurate or incomplete data concerning you, including by providing a supplementary statement.
You have the right to obtain the erasure of data concerning you, in particular where you withdraw your consent and no other legal basis for the processing exists, where the data is no longer necessary for the purposes pursued, or where it has been unlawfully processed.
This right does not apply where the processing is necessary for compliance with a legal obligation, in particular relating to anti-money laundering and counter-terrorist financing, or for the establishment, exercise or defence of legal claims.
You have the right to obtain restriction of the processing of your data in the cases provided for in Article 15 of Monégasque Law No. 1.565 of 3 December 2024, in particular where you contest the accuracy of the data, for the period enabling ARCAN to carry out the necessary verifications, or where you still need the data for the establishment, exercise or defence of legal claims.
You have the right to object at any time, without having to provide any justification, to the processing of your data for prospecting purposes, as well as to its use on behalf of third parties or its disclosure to third parties for such purposes. In that case, your data will no longer be processed for those purposes.
With regard to the processing based on the legitimate interest described in Article 3 (website audience measurement), you have the right to object to it at any time, on grounds relating to your particular situation, via the opt-out form available at the bottom of every page of the website, under "Tracking Management". ARCAN will then no longer process your data for that purpose, unless there are compelling legitimate grounds that override your interests, rights and freedoms (Article 17 of Monégasque Law No. 1.565 of 3 December 2024).
For data that you have provided to ARCAN yourself, where its processing is based on your consent or on the performance of a contract and is carried out by automated means, you have the right to receive it in a structured, commonly used and machine-readable format, and to transmit it to another data controller. Where technically feasible, you may obtain the direct transmission of that data from one data controller to another.
ARCAN does not make any decision producing legal effects concerning you or significantly affecting you, based solely on automated processing, including profiling.
Pursuant to Article 20 of Monégasque Law No. 1.565 of 3 December 2024, the ascendant, descendant up to the second degree, surviving spouse, cohabitant or partner within the meaning of Monégasque Law No. 1.481 of 17 December 2019 of a deceased person may, provided they demonstrate a legitimate interest, exercise the rights of access, rectification, erasure, restriction, objection and portability with regard to information relating to that person.
You have the right to lodge a complaint with the Data Protection Authority (APDP), the supervisory authority competent in the Principality of Monaco:
Le Concorde, 11 rue du Gabian, 98000 Monaco — apdp.mc
You also have the right to bring a full judicial appeal before the Monaco Court of First Instance (Tribunal de première instance).
In connection with the operation of this website, ARCAN uses the following provider, acting as a data processor: Infomaniak Network SA (hosting of the website and of the self-hosted Matomo audience measurement tool). This arrangement is governed by a written Data Processing Agreement (DPA), compliant with the GDPR and the Swiss Federal Act on Data Protection, whose safeguards substantially meet the requirements of Article 26 of Monégasque Law No. 1.565 of 3 December 2024.
Data processed in connection with client engagements, within the self-hosted management tool operated by ARCAN, is subject to a dedicated privacy policy.
ARCAN implements appropriate technical and organisational measures to ensure a level of security commensurate with the risks, in accordance with Article 31 of Monégasque Law No. 1.565 of 3 December 2024. The ARCAN Space, the secure digital environment made available to clients for tracking their engagements, benefits from enhanced protection measures.
The website, as well as the Matomo audience measurement tool, are hosted by Infomaniak Network SA, headquartered in Switzerland (Rue Eugène-Marziano 25, 1227 Geneva), an ISO 27001-certified provider. This hosting arrangement involves a transfer of data outside the Principality of Monaco. Switzerland appears on the list of countries with an adequate level of protection, established on 1 April 2009 and kept in force pending the publication of the list provided for in Article 97 of Monégasque Law No. 1.565 of 3 December 2024.
ARCAN does not transfer any personal data to a country, territory or international organisation that does not offer an adequate level of protection within the meaning of Monégasque Law No. 1.565 of 3 December 2024.
In the event of a personal data breach likely to result in a risk to your rights and freedoms, ARCAN will notify the APDP as soon as possible and, where feasible, within a maximum of seventy-two hours of becoming aware of it, in accordance with Article 32 of Monégasque Law No. 1.565 of 3 December 2024.
Where the breach is likely to result in a high risk to your rights and freedoms, ARCAN will inform you as soon as possible and will communicate to you, in clear terms, the nature of the breach, its likely consequences, and the measures taken to address it.
ARCAN may amend this policy from time to time, in particular in the event of legislative or regulatory changes or the implementation of new processing activities. Any amendment will be published on this page.
This privacy policy is governed by the law of the Principality of Monaco. Any dispute relating to its application shall fall within the exclusive jurisdiction of the Monégasque courts.
You can object to the tracking of your browsing on this website. This protects your privacy, but it also prevents us from understanding how to improve your experience.