Bathys Asset Management
AMF-authorised management company, no. GP-20260013
Last update: 24 August 2026
This policy describes how Bathys Asset Management processes personal data collected via the www.bathys-am.com website, pursuant to Regulation (EU) 2016/679 (GDPR) and amended Act No 78-17 of 6 January 1978.
Investor data of the managed funds, collected via the bathys.vasco.fund subscription portal, is subject to a separate policy, accessible from that portal.
1. Data controller
Bathys Asset Management, SAS, 161 boulevard Haussmann, 75008 Paris, RCS Paris 107 955 783.
Contact for any questions or requests regarding personal data: dataprotection@bathys-am.com.
2. Processed data and purposes
Enquiry forms
Identification and contact details (surname, first name, company, job title, email address, telephone number) as well as the content of the message. Purpose: to respond to the request and, where applicable, initiate discussions prior to a business relationship. Legal basis: pre-contractual measures or Bathys Asset Management's legitimate interest in responding to its contacts.
Applications
Data submitted as part of a job application (CV, career history, contact details). Purpose: processing the application and managing the recruitment process. Legal basis: pre-contractual measures and legitimate interest.
Site operation and security
Technical connection data (IP address, timestamp, browser type) recorded in the site logs. Purpose: security, abuse prevention and proper functioning of the service. Legal basis: legitimate interest.
3. Cookies
The site uses neither audience measurement cookies, nor advertising cookies, nor third-party trackers. Only cookies strictly necessary for the operation and security of the site are deposited, which do not require prior consent within the meaning of Article 82 of the Data Protection Act (Loi Informatique et Libertés).
4. Retention periods
- Contact requests: three years from the last exchange.
- Unsuccessful applications: two years from the last contact, in accordance with the recommendation of the CNIL, unless the candidate agrees to a longer retention period.
- Technical journals: 12 months.
These timeframes apply without prejudice to the legal retention and archiving obligations applicable to Bathys Asset Management.
5. Recipients
The data is accessible only to authorised employees of Bathys Asset Management. It may be processed, on behalf of and upon the instructions of Bathys Asset Management, by its technical service providers (hosting, messaging, site maintenance), who are bound by a contract complying with Article 28 of the GDPR.
No data collected via the website is sold or rented to third parties.
6. Data localisation
The data is hosted within the European Union. No transfer to a third country is carried out in connection with the site.
7. Security
Bathys Asset Management implements appropriate technical and organisational measures to protect data against unauthorised access, alteration, disclosure or loss, and to ensure its confidentiality, integrity and availability.
8. Your rights
You have the right of access, rectification, erasure and restriction, a right to object to processing based on legitimate interests, a right to data portability where the processing is based on consent or a contract and is carried out by automated means, as well as the right to define directives concerning the fate of your data after your death.
These rights may be exercised at the address dataprotection@bathys-am.com or by post to the registered office. A response will be provided within one month of receipt of the request, which may be extended by two months in the event of complexity. Proof of identity may be requested in the event of reasonable doubt.
You can also lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.
9. Policy evolution
This policy may be amended to reflect changes to the website or regulations. The applicable version is the one published on the website on the date of consultation.
For any questions regarding the processing of your personal data: dataprotection@bathys-am.com.