LEGAL NOTICES AND DATA PROTECTION POLICY

1. WEBSITE PUBLISHER

This website is published by HOMA Capital, a simplified joint-stock company with share capital of €1,176,472, registered with the Paris Trade and Companies Register under number 524 396 348, whose registered office is located at 1 boulevard Pasteur, 75015 Paris, France.
HOMA Capital is a portfolio management company authorised by the French Financial Markets Authority, the Autorité des marchés financiers (AMF), since 13 January 2011 under number GP-11000002. HOMA Capital is also registered with ORIAS under number 25002961.
HOMA Capital is subject to the AMF General Regulation and the applicable provisions of the French Monetary and Financial Code.

Contact details

HOMA Capital can be contacted:
  • by post: HOMA Capital, 1 boulevard Pasteur, 75015 Paris, France;
  • by telephone: +33 1 75 77 47 00;
  • by email: contact@homacapital.fr.
Publishing Director: Lionel Tangy-Malca, President
Editorial Manager: Caroline Bendavid, Investor Relations

2. HOSTING AND WEBSITE DESIGN

The website is hosted by:
OVH SAS
2 rue Kellermann
BP 80157
59100 Roubaix
France
The website was designed by Mawjo Design and developed by Atelier Yvon.

3. INFORMATION RELATING TO THE PRODUCTS PRESENTED

This website presents collective investment undertakings whose distribution is authorised in France and which are accessible to French residents.
The information published on this website is provided for information purposes only. It does not constitute an offer, investment advice or a personalised recommendation.
Investing in collective investment undertakings involves risks, including the risk of loss of capital. Before making any investment decision, investors should carefully review the applicable regulatory documentation, including the prospectus, the Key Information Document and, where applicable, any other regulatory document.
No subscription may be made directly through this website.

Luxembourg-law funds

The website also presents Luxembourg-law funds managed by HOMA Capital and distributed in France.
The information relating to these funds is provided for information purposes only. Any subscription must be made through an authorised financial intermediary, on the basis of the regulatory documentation in force and applicable to the relevant fund, including documents approved or recognised by the Luxembourg financial supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF).

4. INTELLECTUAL PROPERTY

The website www.homacapital.fr, its structure, content, texts, images, graphic elements and databases are protected by the applicable provisions of the French Intellectual Property Code.
Any reproduction, representation, adaptation, modification, distribution or exploitation, in whole or in part, of the website or its content, without the prior written authorisation of HOMA Capital, is prohibited, except where permitted by applicable law.
The content of the website is intended for strictly personal and non-commercial use.

5. DATA CONTROLLER

The General Data Protection Regulation, known as the GDPR, has applied since 25 May 2018.
For the processing of personal data described in this policy, the data controller is:
HOMA Capital
1 boulevard Pasteur
75015 Paris, France
Email: contact@homacapital.fr
HOMA Capital determines the purposes and means of the processing of personal data carried out in connection with its activities.

6. DATA COLLECTED AND PURPOSES OF PROCESSING

HOMA Capital may process the following categories of data:
  • identification data, including first and last name;
  • professional and personal contact details, including email address, postal address and telephone number;
  • job title, company and information relating to the relationship with HOMA Capital;
  • information provided as part of a contact request;
  • communication preferences and choices relating to consent or objection;
  • data required to manage relationships with clients, investors, prospects and partners;
  • data required to comply with HOMA Capital’s legal and regulatory obligations;
  • technical data required for the security and operation of the website.
The data is processed for the following purposes:
  • responding to requests sent to HOMA Capital;
  • managing relationships with clients, investors, prospects and partners;
  • sending requested documents, presentations, invitations and communications;
  • sending electronic communications where the applicable legal requirements are met;
  • managing communication preferences, consents and objections;
  • complying with the legal, regulatory and professional obligations applicable to HOMA Capital;
  • ensuring the security, maintenance and proper functioning of the website;
  • protecting and enforcing HOMA Capital’s rights and interests in the event of a dispute.
Each processing activity is based on an appropriate legal basis, including the performance of a contract or pre-contractual measures, compliance with a legal obligation, the consent of the data subject or HOMA Capital’s legitimate interest, depending on the purpose of the processing.

7. EMAIL CAMPAIGNS AND OPEN TRACKING

HOMA Capital may send electronic communications to its contacts where the legal requirements applicable to direct marketing and the sending of such communications are met.
Certain emails may contain a tracking pixel used to measure whether the email has been opened. Where open tracking is subject to consent, it is activated only for contacts who have provided their consent.
Consent to open tracking is separate from consent to receive electronic communications.
Open tracking is used for the purposes specified when consent is collected, including measuring deliverability and improving the management of email campaigns. It is not used to create profiles of data subjects or personalise communications, unless specific information has been provided and separate consent has been obtained where required.
Data relating to open tracking may include an identifier associated with the email address and information relating to the opening of the email. The exact categories of data, purposes and retention periods depend on the configuration implemented with Key Performance Group.
Each person may withdraw their consent or object to open tracking at any time, in particular by using the “Tracking opt-out” link included in the relevant emails, or by contacting HOMA Capital at: contact@homacapital.fr.
Withdrawing consent to open tracking does not automatically unsubscribe the person from HOMA Capital’s electronic communications.
Where technical processing strictly necessary for deliverability is maintained, it is limited to the data and purposes strictly necessary for that function. It is not used for individualised marketing reporting, personalisation or profiling.
The CNIL considers that the use of tracking pixels must be assessed in light of the purpose pursued. Pixels used to measure campaign performance, personalise communications or create profiles generally require consent, while the exemption relating to deliverability is subject to strict conditions.

8. SERVICE PROVIDERS AND DATA RECIPIENTS

Personal data may be accessed by:
  • authorised HOMA Capital employees;
  • technical service providers acting on behalf of HOMA Capital;
  • service providers responsible for hosting, maintenance and security;
  • Key Performance Group, for hosting contact databases, managing and sending email campaigns, and producing reports;
  • administrative, judicial or professional authorities where required by law.
Key Performance Group operates within the applicable contractual framework and in accordance with HOMA Capital’s instructions. Its precise role, as well as the role of any subsequent processors, must be specified in the relevant contracts and data protection agreements.
HOMA Capital does not sell the personal data of its contacts.

9. DATA HOSTING AND TRANSFERS

Data is hosted and processed in the locations specified in the contracts entered into with the relevant service providers.
Data relating to contacts and email campaigns is hosted and accessed exclusively within the European Economic Area.
Where data is transferred outside the European Economic Area, HOMA Capital implements the safeguards required under applicable data protection law, including an adequacy decision or standard contractual clauses, where necessary.

10. DATA RETENTION PERIODS

Personal data is retained for a period proportionate to the purpose for which it is processed.
The applicable retention period depends in particular on:
  • the nature of the relationship with the data subject;
  • the purpose of the processing;
  • applicable legal and regulatory obligations;
  • applicable limitation periods;
  • the need to retain evidence.
Data relating to contact requests is retained for the time necessary to process the request, and subsequently for the period necessary to manage any potential claims.
Data used for communications or direct marketing is retained in accordance with the rules applicable to direct marketing and the duration of the relationship with the data subject.
Data relating to consents, refusals and objections is retained for a period enabling HOMA Capital to comply with the choices expressed and demonstrate that they have been taken into account.
Data relating to clients, investors and regulatory obligations is retained for the periods required by applicable laws and regulations.

11. DATA SUBJECT RIGHTS

Subject to the conditions provided for by applicable law, each data subject has:
  • the right to access their personal data;
  • the right to rectify inaccurate or incomplete data;
  • the right to erasure;
  • the right to restriction of processing;
  • the right to data portability, where applicable;
  • the right to object where processing is based on legitimate interest or relates to direct marketing;
  • the right to withdraw consent at any time where processing is based on consent;
  • the right to define instructions concerning the retention, erasure and disclosure of their personal data after their death, in accordance with applicable law.
To exercise their rights, data subjects may contact HOMA Capital:
HOMA Capital may request proof of identity where there is a reasonable doubt as to the identity of the person making the request.
Data subjects also have the right to lodge a complaint with the French Data Protection Authority, the Commission Nationale de l’Informatique et des Libertés (CNIL):
www.cnil.fr

12. COOKIES AND OTHER TRACKERS

The website www.homacapital.fr uses cookies and other trackers to ensure its proper functioning, security and to improve the browsing experience.
On their first visit, users may accept all cookies by clicking “Accept” or access the settings by clicking “Settings”.
Cookies necessary for the operation of the website are always active. Other categories of cookies, including functional, performance, analytics and advertising cookies, are disabled by default. Users may select the categories they wish to authorise and save their choices by clicking “Save & Apply”.
Preferences relating to email open tracking are managed separately through the relevant link included in each email sent by HOMA Capital.

13. HYPERLINKS

The website may contain links to third-party websites. HOMA Capital does not control those websites and cannot be held responsible for their content, practices or data protection policies.
Users are invited to review the privacy policies of third-party websites before providing them with personal data or using their services.
The creation of a link to www.homacapital.fr is subject to the prior approval of HOMA Capital where the link is created for commercial or promotional purposes.

14. WEBSITE AVAILABILITY

HOMA Capital endeavours to keep the website accessible. However, HOMA Capital does not guarantee that the website will be continuously available, uninterrupted or error-free.
HOMA Capital may modify, suspend or discontinue all or part of the website, in particular for maintenance, security or update purposes.

15. GOVERNING LAW

The website is governed by French law.
Subject to any mandatory provisions to the contrary, any dispute relating to the use of the website shall fall under the jurisdiction of the competent French courts.

16. UPDATES

This page was last updated on 5 August 2026.
HOMA Capital may amend this policy to reflect changes to its processing activities, services or applicable law.