Last updated June 7th, 2024


Publisher: Otium Management SAS, owner of the website

Content: All elements constituting the information present on the website, including texts, images, videos.

Customer Information: Hereinafter referred to as “Information,” which corresponds to all personal data that may be held by the Publisher for managing your account, customer relationship management, and for analysis and statistical purposes.

User: Internet user using the aforementioned website, generating data potentially usable by the Publisher, subject to prior agreement or logical consent.

Personal Information: “Information that allows, in any form whatsoever, directly or indirectly, the identification of natural persons to whom they apply” (Article 4 of Law No. 78-17 of January 6, 1978). The terms “personal data,” “data subject,” “processor,” and “sensitive data” have the meanings defined by the General Data Protection Regulation (GDPR: No. 2016-679).

1. General Conditions of Use of the Website and Services Offered

The website constitutes an intellectual work protected by the provisions of the Intellectual Property Code and applicable International Regulations. The user may not in any way reuse, transfer, or exploit for their own account all or part of the elements or works on the website. Use of the website implies full acceptance of the general conditions of use described below.

These conditions of use may be modified or supplemented at any time; Users are therefore invited to consult them regularly.

The website is in principle accessible to Users at any time. An interruption for technical maintenance may however be decided by the Publisher. Similarly, the legal notices may be modified at any time: they are nonetheless binding on the User who is invited to refer to them as often as possible to take note of them.

2. Description of Services Provided

The website aims to provide information about all activities of the company. The Publisher strives to provide information as accurate as possible. However, they cannot be held responsible for omissions, inaccuracies, and deficiencies in updating, whether due to their fault or the fault of third-party partners who provide this information. All information indicated on the website is given as an indication and is likely to evolve. Furthermore, the information provided is not exhaustive. It is given subject to modifications having been made since it was put online.

3. Contractual Limitations on Technical Data

The website uses JavaScript technology. The website cannot be held responsible for material damages related to the use of the website. Moreover, the User agrees to access the website using recent hardware, free of viruses, and with an updated, latest-generation browser. The website is hosted by a provider within the territory of the European Union in accordance with the provisions of the General Data Protection Regulation (GDPR: No. 2016-679). The objective is to provide a service that ensures the best accessibility rate. The host ensures the continuity of its service 24 hours a day, every day of the year. However, they reserve the right to interrupt the hosting service for the shortest possible durations, notably for maintenance, infrastructure improvement, infrastructure failure, or if the Services and Provisions generate abnormal traffic. The Publisher and the host cannot be held responsible in case of Internet network malfunction, telephone lines, or computer and telephone equipment, particularly due to network congestion preventing access to the server.

4. Intellectual Property and Counterfeiting

Otium Management SAS owns the intellectual property rights and holds the usage rights on all elements accessible on the webwebsite, including texts, images, graphics, logos, videos, icons, and sounds. Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the website, regardless of the means or process used, is prohibited, except with prior written authorization from Otium Management SAS. Any unauthorized exploitation of the website or any of its elements will be considered as constituting an infringement and will be prosecuted in accordance with the provisions of Articles L.335-2 and following of the Intellectual Property Code.

5. Limitations of Liability

The Publisher cannot be held responsible for direct and indirect damage caused to the User’s equipment when accessing the webwebsite, resulting either from the use of equipment not meeting the specifications indicated in point 3, or from the appearance of a bug or incompatibility. The Publisher cannot also be held responsible for indirect damages (such as loss of market or opportunity) resulting from the use of the website. Interactive spaces (contact form) are available to Users.

The Publisher reserves the right to delete, without prior notice, any content depowebsited in this space that would contravene the applicable legislation in France, particularly the provisions relating to data protection. Where applicable, the Publisher also reserves the right to question the civil and/or criminal liability of the User, particularly in the event of messages of a racist, insulting, defamatory, or pornographic nature, regardless of the medium used (text, photograph…).

6. Management of Personal Data

The User is informed of the regulations concerning marketing communication, the law of June 21, 2014, for confidence in the Digital Economy, the Data Protection Act of August 6, 2004, as well as the General Data Protection Regulation (GDPR: No. 2016-679).

6.1 Responsible for Collecting Personal Data

For Personal Data collected as part of form validation and browsing on the website, the Data Controller is: Mr. Michael Sidney Levy. The legal representative of the website is Mr. Pierre-Edouard Stérin. As the Data Controller of the data it collects, the Publisher undertakes to respect the framework of the legal provisions in force. It is particularly their responsibility to establish the purposes of their data processing, to provide their prospects and customers, from the collection of their consents, with complete information on the processing of their personal data and to maintain a register of treatments in line with reality. Each time the Publisher processes Personal Data via the website, it takes all reasonable measures to ensure the accuracy and relevance of the Personal Data with regard to the purposes for which it processes them.

6.2 Type, Processing, and Purpose of Data Collected

Otium Management SAS is likely to process all or part of the following data:

  • Connection, navigation, and website usage data
    Processing: to allow and/or improve navigation on the website, establish audience statistics.
  • Identifying and/or private data (first name, last name) and contact data such as email address, company, company URL
    Processing: to answer a question, make an appointment, be called back, etc.
  • Technical data on the computer equipment used for navigation, IP address
    Processing: to secure communications with or from the website, prevent and combat computer fraud (spamming, hacking…).

All data are kept for a maximum period of 12 months after collection or the end of the contractual relationship between the User and the Publisher. Otium Management SAS does not market Personal Data which are used only by necessity for the purposes described above and occasionally for global statistical analysis.

6.3 Right of Access, Rectification, and Opposition

In accordance with the European regulations in force, Users of the website have the following rights:

  • Right of access (Article 15 GDPR) and rectification (Article 16 GDPR), update, completeness of Users’ data, right to lock or delete Users’ personal data (Article 17 GDPR) when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication, or storage is prohibited.
  • Right to withdraw consent at any time (Article 13-2c GDPR).
  • Right to limit the processing of Users’ data (Article 18 GDPR).
  • Right to oppose the processing of Users’ data (Article 21 GDPR).
  • Right to data portability that Users have provided, where these data are subject to automated processing based on their consent or a contract (Article 20 GDPR).
  • Right to define the fate of Users’ data after their death and to choose to whom the Publisher should communicate (or not) their data to a third party previously designated.

As soon as the Publisher has knowledge of the death of a User and in the absence of instructions from them, the Publisher undertakes to destroy their data, unless their conservation is necessary for probative purposes or to meet a legal obligation. If the User wishes to know how the Publisher uses their Personal Data, request to rectify them, or oppose their processing, they can contact the Data Protection Officer (DPO) in writing at the following address: contact [at] otiumcapital [dot] com. In their letter, the User must indicate the Personal Data they wish to correct, update, or delete, identifying themselves precisely with a copy of an identity document (identity card or passport). Requests for the deletion of Personal Data will be subject to the obligations imposed on the Publisher by law, particularly regarding the conservation or archiving of documents. Finally, Users can lodge a complaint with the supervisory authorities, including the CNIL (

6.4 Non-communication of Personal Data

The Publisher refrains from processing, hosting, or transferring the Information collected on its Users to a country outside the European Union or recognized as “non-adequate” by the European Commission without prior notice to the user. For all that, they remain free to choose their technical and commercial subcontractors provided they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: No. 2016-679).

The Publisher undertakes to take all necessary precautions to preserve the security of the Information and, in particular, that it is not communicated to unauthorized persons. However, if an incident impacting the integrity or confidentiality of the User’s Information is brought to the attention of the Publisher, it will promptly inform the User and communicate the corrective measures taken.

Moreover, the Publisher does not collect any “sensitive data.” The User’s Personal Data may be processed by subsidiaries of the Publisher and subcontractors (service providers), exclusively to achieve the purposes of this policy. Within the limits of their respective attributions and for the purposes mentioned above, the main persons likely to have access to the Users’ data are mainly the agents of our customer service.

No personal information of the User of the website is published without the User’s knowledge, exchanged, transferred, ceded, or sold on any medium to third parties. Only the hypothesis of the acquisition of the website and its rights would allow the transmission of the said information to the potential acquirer who would, in turn, be held to the same obligation of conservation and modification of the data concerning the User of the website

7. Incident Notification

Despite the Publisher’s best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. Therefore, the Publisher cannot guarantee absolute security. If they become aware of a security breach, they will notify the affected Users so that they can take appropriate measures. Their incident notification procedures consider their legal obligations, whether at national or European level. They undertake to fully inform their Users of all issues related to the security of their account and provide them with all the necessary information to help them meet their own regulatory reporting obligations.

8. Security

To ensure the security and confidentiality of Personal Data and Personal Health Data, the Publisher uses networks protected by standard devices such as firewalls, pseudonymization, encryption, and passwords.

When processing Personal Data, the Publisher takes all reasonable steps to protect it against any loss, misuse, unauthorized access, disclosure, alteration, or destruction.

9. Hypertext Links, “Cookies,” and Internet Tags

The website may contain a number of hypertext links to other websites. However, the Publisher does not have the ability to check the content of the websites thus viwebsited and will therefore assume no responsibility for this fact.

9.1 “Cookies”

A “Cookie” is a small file of information sent to the User’s browser and stored within the User’s terminal (e.g., computer, tablet, smartphone). This file includes information such as the User’s domain name, the User’s Internet service provider, the User’s operating system, as well as the date and time of access. Cookies do not risk in any way damaging the User’s terminal.

The Publisher may process information about the User’s visit to the website, such as the pages viewed and the searches performed. This information allows the Publisher to improve the content of the website and the User’s navigation experience.

Cookies facilitating the browsing and/or the provision of services offered by the website, the User can configure their browser to allow them to decide whether or not they want to accept them, so that Cookies are saved in the terminal or, on the contrary, rejected, either systematically or according to their sender. The User can also configure their browser software so that the acceptance or rejection of Cookies is proposed punctually, before a Cookie is likely to be recorded in their terminal. The Publisher informs the User that, in this case, not all the functionalities of their browser software may be available.

If the User refuses the storage of Cookies in their terminal or browser, or if the User deletes those stored there, the User is informed that their browsing and experience on the website may be limited. This could also be the case when the Publisher or one of its service providers cannot recognize, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings, or the country from which the terminal seems to be connected to the Internet.

If necessary, the Publisher declines all responsibility for the consequences related to the degraded operation of the website and any services offered, resulting from (i) the refusal of Cookies by the User (ii) the impossibility for the website to save or consult the Cookies necessary for their operation due to the User’s choice. For the management of Cookies and the User’s choices, the configuration of each browser is different. It is described in the browser’s help menu, which will allow the User to know how to modify their preferences regarding Cookies.

At any time, the User can make the choice to express and modify their wishes regarding Cookies. The Publisher may also call on the services of external providers to help them collect and process the information described in this section.

Finally, by clicking on the icons dedicated to social networks such as LinkedIn appearing on the website and if the User has accepted the deposit of Cookies by continuing to browse the Websiteor the mobile application of the social network concerned, LinkedIn may also place Cookies on your devices (computer, tablet, mobile phone). These types of Cookies are only placed on your devices if you consent to them, by continuing your browsing on the Websiteor the mobile application of the social network. At any time, the User can withdraw their consent to these Cookies.

The website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses Cookies to help the website and the Publisher analyze the use of the website and improve its performance. The data generated by the Cookies about the use of the website (including the User’s IP address) will be transmitted to and stored by Google on servers located in the United States. Google will use this information to evaluate your use of the website, to compile reports on the website’s activity for the Publisher, and to provide other services relating to website activity and Internet usage. Google may disclose this data to third parties if required by law or if these third parties process the data on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You can deactivate the use of Cookies by selecting the appropriate settings on your browser. However, such deactivation could prevent the use of certain functionalities of this website. By using this website, you expressly consent to the processing of your personal data by Google in the conditions and for the purposes described above.

  • How to deactivate/delete cookies?
  • Instructions on Chrome: Chrome Support
  • Instructions on Firefox: Firefox Support
  • Instructions on Internet Explorer / Edge: Microsoft Support
  • Instructions on Safari (Mac): Apple Support
  • Other browsers: refer to the online help of the browser in question.

9.2 Internet Tags

The website may occasionally use Internet tags (also known as web beacons, pixel tags, or clear GIFs) and deploy them through a web analytics partner that may be located (and thus store corresponding information, including the User’s IP address) in a foreign country. These tags are placed both in online advertisements allowing internet users to access the website and on various pages of the website.

This technology allows the Publisher to evaluate visitors’ responses to the website and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the use of this website by the User. The external service provider may collect information about visitors to the website and other webwebsites through these tags, compile reports on the website’s activity for the Publisher, and provide other services relating to the use of the website and the Internet.

10. Governing Law and Jurisdiction

Any dispute related to the use of the website is subject to French law. Except in cases where the law does not allow it, exclusive jurisdiction is granted to the competent courts of Paris.