Fine Advisors Inc. ensures the protection of its users' personal data, in compliance with the French Data Protection Act of January 6, 1978 as amended and the General Data Protection Regulation No. 2016/679. User means the person who visits one or more pages of the Site.

IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
The party responsible for processing the Personal Data collected on the Site is: Fine Advisors Inc, a company registered in the United States under number EIN 82-1064646.
Headquartered at Rockefeller Center, 610 5th Ave, STE CONC1, #182 - New York, NY 10020, represented by Charlotte Finelli, in her capacity as President.
Tel: (+1) 917 503 9727
Email: contact@fineadvisorsnyc.com

COLLECTION OF PERSONAL DATA
Under the French Data Protection Act (Loi Informatique et Libertés) and the RGPD, any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to him or her, constitutes personal data.
All personal data concerning Users is collected directly from them.
When necessary, Fine Advisors Inc. may collect personal data concerning its Users, subject to their prior consent.

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LEGAL BASIS FOR PROCESSING
Fine Advisors Inc. processes User data only in the cases provided for by the applicable regulations, and in particular :
- on the basis of the User's free, specific, informed and unambiguous consent, such as, in particular, when the User requests contact; 
- when processing is necessary for the performance of a contract or pre-contractual measures taken at the User's request, such as sending an application or taking charge of a specific file; 
- to comply with Fine Advisors Inc. legal or regulatory obligations, in particular those relating to the fight against fraud; 
- when processing is justified by the legitimate interests of Fine Advisors: in the course of commercial prospecting operations, the compilation of statistics, or the implementation of IT security measures. 

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TYPES OF DATA COLLECTED AND PURPOSES 

The following User data may be processed by Fine Advisors Inc. in its capacity as Data Controller:
- the URL of the links through which the User has accessed the www.fineadvisorsnyc.com site, the User's access provider and the User's Internet Protocol (IP) address.
- identification data from contact and recruitment forms: surname, first name, e-mail address, postal address, telephone number, CV, etc.
This data is mainly processed to:
- enable browsing on the Site and resolve any technical problems linked to the User's browsing;
- manage the relationship with the User; 
- organize, register and invite to events; 
- improve services and customer relations; 
- recruitment 
The collection of personal data is based on the legitimate interests of Fine Advisors Inc. which offers support to its customers in the accounting field.

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DATA PROCESSOR 
The recipient of the personal data collected is the Data Controller, i.e. Fine Advisors Inc.
User data is neither transferred nor made accessible to unauthorized third parties.
However, Fine Advisors Inc. may communicate Users' personal data to third parties when such communication is required by law, regulation or judicial decision, or if such communication is necessary to ensure the protection and defense of its rights.

DATA HOSTING
Fine Advisors stores and processes users' personal data in Europe (notably in France), but also in the United States.
Third-party service providers that store or process Users' Personal Information on behalf of Fine Advisors Inc, such as the Wix platform, and its subcontractors, contractually agree to protect and secure it, in accordance with industry standards and regardless of any lesser legal requirements that may apply in their jurisdiction.

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If the User is located in Europe, the United Kingdom or Switzerland, where a transfer of personal data takes place to a location outside the European Union, Fine Advisors ensures, through its processors (i) that there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place (i.e., the applicable module of the Standard Contractual Clauses for the Transfer of Personal Data to Third Countries under Regulation (EU) 2016/679 of the European Parliament and of the Council of June 4, 2021, and the ICO Addendum on International Data Transfer to the U. E. Commission's Standard Contractual Clauses, version B1.0, effective as of March 21, 2022, as revised pursuant to Section 18 of its Mandatory Clauses).
DATA RETENTION PERIOD
Personal data is kept only as long as is necessary for the purpose for which it is processed:
In this respect, data collected for application purposes on the Site (including forms, cover letters, CVs, references, etc.) are kept for a maximum of two years from the last contact with the applicant.

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Data collected in particular via the contact form on the Site, used for commercial prospecting purposes, are kept for a maximum of three years from the end of the commercial relationship.
Data obtained for the purposes of carrying out the mission entrusted to Fine Advisors is kept for a maximum of five years from the end of the mission.

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USERS' RIGHTS
In accordance with current regulations, Site Users have the following rights with regard to their personal data:
- a right of access to personal data collected and processed by the Data Controller, and the possibility of obtaining a copy thereof; 
- the right to rectify inaccurate and/or incomplete data, and the right to erase such data if the User considers that it is no longer necessary for the purposes for which it was processed, or that it has been processed unlawfully; 
- a right to limit the processing of personal data, in particular if the User questions the accuracy of the data (after verification by the Data Controller), or if the User considers that his or her data has been processed unlawfully but does not wish to delete it; 

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- a right to data portability, enabling the User to receive personal data concerning him or her in a commonly used and machine-readable format, and to transmit it to another data controller; - a right to withdraw consent, at any time, when the processing of personal data is based on the User's consent, without affecting the lawfulness of the processing based on the User's consent, carried out prior to the withdrawal of consent; - a right to object, enabling the User, at any time, to object to the processing of personal data concerning him/her, based on the legitimate interests of the Data Controller and for commercial prospecting purposes. 
EXERCISE OF RIGHTS
Any User of the Site whose personal data has been collected by the Data Controller may exercise the rights described in the previous paragraph by sending a request:
- by e-mail to: contact@fineadvisorsnyc.com, or by post
- or by post to the following address: Personal Data Management - Fine Advisors Inc - Rockfeller Center, 610 5th Ave, STE CONC1, #182 New York, NY 10020
This correspondence must be accompanied by a copy of an identity document as well as any necessary proof.

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Fine Advisors will respond to your request as quickly as possible, within a maximum of one month from receipt of your request. This period may be extended to two months if the complexity of the request so requires.
In the event of refusal, Fine Advisors will inform you of the reasons for the refusal.
Finally, any User may lodge a complaint with the CNIL at 3 Place de Fontenoy - TSA 80715 - 75334 Paris 07, or via a form on the website: www.cnil.fr.

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