The information (the “Information”) contained on this website (this “Site”) has been prepared solely for the purpose of providing background information on Comitium SAS (“Comitium”, or “we”, or “us”). Comitium SAS, whose offices are located at 1 rue Paul Cézanne, 75008 Paris, France, is a Société Anonyme par Actions Simplifiée (“SAS”) with capital of 180 000€ – RCS Paris 509 452 157.

Comitium is authorised and regulated by the French Autorité des Marchés Financiers (“AMF”), since 04/26/2019 under the number GP-19000025. Comitium is a member of the Association Française de la Gestion financière (“AFG”).

  1. Compliance with regulations and ethical standards

The purpose of this website is to present the business of Comitium. This presentation is not for sales or marketing purpose. The information contained in the website is not a contract and is not a product offering, nor a recommendation and/or solicitation of an offer to buy, nor a public offering.

The information provided is for reference purposes only and is valid on the date of their publication. It is moreover partial and incomplete and has no contractual value. It is not a recommendation for investment or advice founded on circumstances specific to the visitors of the website or that can meet to their special requirements.


  1. Handling of complaints

The asset management company Comitium SAS has created and maintains an efficient and transparent procedure for handling complaints from customers, reasonably and rapidly.

A complaint is a statement of discontent addressed by the customer to the professional. A request for information, opinion, clarification or service is not considered a complaint.

Customers may address complaints to Comitium SAS. Comitium SAS does not invoice any expenses for the handling of complaints.

Complaints may be addressed to the customer’s usual contact person at Comitium SAS by the following means:

  • by post at the following address: Comitium, 1 rue Paul Cézanne, 75008 Paris (France);
  • by email at the following address:

The Compliance and Internal Control Officer (CICO) is the person in charge of handling complaints. The CICO has the required knowledge and experience with the products, services, contracts, tools and procedures to ensure that customer complaints are handled appropriately. The CICO may seek any necessary expertise to assist him or her in handling complaints. Comitium SAS ensures that customer complaints are kept strictly confidential.

Comitium SAS acknowledges receipt of a complaint within 10 business days, unless a response is sent to the customer earlier.

A response to the customer’s complaint is prepared within two months of receipt, unless there are special circumstances, which must be explained. If a response cannot be provided within this timeframe, the customer is contacted and informed of the reason for the delay, and a new time period is indicated.

Customers may address complaints in the official language or one of the official languages of the member State in which the fund is marketed or the investment service provided.

The customer may contact the Ombudsman of the Autorité des Marchés Financiers (AMF) in the event the response to a complaint is deemed unsatisfactory, by filling in one of the forms on the following web page:

or by contacting the Ombudsman by post at the following address: Autorité des Marchés Financiers, La Médiation, 17, place de la Bourse 75082 Paris Cedex 02 (France).

The mediation charter of the AMF is available on the AMF’s website at: “The AMF Ombudsman”, then “How mediation works”.


  1. Conflicts of interest

Comitium SAS has included the prevention of conflicts of interest in each step of its decision-making process. Any potential conflict of interest must be reported to Laurent Ducoin, Compliance and Internal Control Manager, who will take the necessary steps to (i) analyse and (ii) remedy the situation. Shareholders in the Funds may obtain, upon request, additional information on the conflict of interest policy.


  1. Privacy Policy


Our Privacy Policy explains how we collect, use and protect information in relation to Comitium website and digital services (collectively, the “Services”). This Privacy Policy applies to all visitors and users who access the Services. This website is operated by Comitium SAS located at 1, rue Paul Cézanne 75008 Paris. Comitium SAS operates in its capacity of data controller for the purposes of applicable data protection laws and regulations, including the Regulation (EU) 2016/679 dated 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data (“GDPR”).

Information we collect

Depending on the Services provided by the website and used by you, on your choices and configuration of your terminal (with respect in particular to cookies), personal data concerning you (your “Personal Data”) collected and processed by Comitium mainly includes: your name, surname, e-mail address, country, telephone number, your connection logs,  as well as the information that you may disclose when you contact us. To the extent permitted by applicable law, we may combine the information collected, including information about the organization for which you work, with other information in our possession or information that you provide to us.

The Personal Data that is mandatory for Comitium to fulfil the purposes that are described below is marked with an asterisk or the mention “required” on the various pages of the website. Should you not fill in these mandatory fields, Comitium may not be able to take care of your demands and/or to provide you the requested services.  Other Personal Data is purely optional and allow us to know you better and to improve our communications and services accordingly.

When you visit the website, we may use cookies, tracers and similar tracking technologies to collect information about how you use our Services (pages consulted, links clicked), how you browse our site and provide features to you. Cookies are used to automatically collect your device identifiers and other information about you, such as the following: Internet Protocol (IP) address, logs, webpages clicked and other technical information. With your consent of cookies, our site can use information collected to complete our databases. You can modify the cookies settings at any moment on your device. We may also ask our partners to provide services, which may use cookies or similar technologies placed by us or the third party. For more information about our use of cookies, please visit our Cookie policy.

Purposes of processing

We collect and process your Personal Data with your consent and/or as necessary to meet our legal obligations or fulfil our legitimate interests (notably to prevent fraud or to protect the security of our IT systems).

We use and process Personal Data about you for purposes described below:

  • to reply to your questions, complaints or orders of documents in relation to our business;
  • to form analyses and make statistics;
  • to prevent fraud and ensure compliance;
  • to provide communication (e.g. newsletter) and to personalize future visits to the website;
  • to manage and improve our website and provide technical support.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate consent. To the extent necessary, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only the categories of Personal Data that are strictly required for the purposes mentioned above.

your rights

In accordance with applicable data protection laws and regulations, you have a right to request access to, rectification or erasure of your Personal Data, or restriction of processing, and to object to said processing, as well as the right to data portability to the extent applicable, subject to any overriding legitimate grounds that Comitium might invoke to retain your Personal Data.

You may request at any time that we stop sending you information about our offers, news and events by using the opt-out link inserted in each e-mail that we send you.

You may also give us specific instructions regarding your Personal Data after your death.

Moreover, you have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with the GDPR.

You can exercise your rights by using your account settings or by simply writing us at the following address: Please keep in mind that in case of a vague request we may engage a discussion to better understand the motivation for the request and require you to prove your identity (for example, by requesting an ID). This is made to ensure that no right of third parties are violated by your request.

Data recipients

Your Personal Data shall be processed by Comitium. It shall not be transferred or made accessible to any third party apart from:

  • our service providers (such as providers of hosting and maintenance services or communication agencies);
  • our affiliates;
  • in case of a change of control, if we sell or otherwise transfer part or the whole of Comitium or our assets to another company (e.g., in the course of a transaction like a merger, acquisition, liquidation) and;
  • to third parties if such disclosure is required by law, by a regulatory provision or by a court ruling, or if this disclosure is necessary to ensure the protection and defense of rights or to prevent harm.

Transfert of personal data & security measures

Comitium, its affiliates, or service providers may transfer information that we collect about you, across borders. If you are located in the European Union, please note that we may transfer your Personal Data to a country that does not have the same data protection laws as your jurisdiction. Any transfer of your Personal Data outside the European Economic Area shall only take place subject to appropriate safeguards being in place, such as standard contractual clauses and other contractual safeguards. You can contact us to obtain a copy of the safeguards implemented to secure data transfers operated outside the European Economic Area.

We use reasonable and appropriate information security safeguards to help keep the information collected through the Services secure and take reasonable steps to verify your identity before granting you access to your account. Among others, we utilize the following security measures:

  • Pseudonymization of certain categories of your Personal Data;
  • Encryption of your Personal Data in transit and in rest;
  • Regular vulnerability scanning and penetration testing;
  • Organizational measures (access control, restriction of access);
  • Conducting periodical data protection impact assessments and privacy audit.

Data retention

We will retain your Personal Data as long as necessary in relation with purposes of processing identified in this Privacy Policy. Information we receive about you may be retained for an extended period of time when it is the subject of a legal obligation, an investigation or otherwise to prevent harm.

The Personal Data that is collected and processed under the “Contact us” and/or a similar section shall only be kept throughout the duration of the processing of your request. It shall be deleted thereafter.

Finally, the connection logs that are collected, subject to your consent, using the cookies, tracers and other similar tracking technologies implemented on our website, shall be kept in accordance with applicable laws and regulations for a period of time that does not exceed thirteen (13) months.

Contact us

If you have any questions about this Privacy Policy and if you wish to exercise your rights, please contact our Data Protection Officer through the email info@comitium.comor to our mailing address:

1, rue Paul Cézanne
75008 Paris

Changes to our privacy policy

Comitium may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances.

Last update: July 2019


  1. Information contained in this website

Comitium is pleased to welcome you to its website. This website is for information and guidance only and is intended to provide information about the Company, its business and results.

The specific use of the information contained in this website is the sole responsibility of the user.

Comitium regularly updates its website but shall in no way be liable for any inaccuracies, errors or omissions.

Comitium shall not be held liable for any damages whatsoever resulting from information contained in this website. Likewise, Comitium shall not be held liable for any damages suffered by your technical environment, in particular your computers, software, network equipment (modems, telephones, etc.) or any material used to access our Website or to use the information contained therein.

Comitium reserves the right to modify this information at any time, without notice. Similarly, Comitium reserves the right to suspend, discontinue or cancel access to all or part of this website in the event of technical problems or force majeure.

The name “Comitium” is a registered trademark. Any fraudulent use constitutes infringement and is punishable by criminal penalties as specified in Articles L.716–1 et seq. of the French Intellectual Property Code.

All elements of Comitium’s website are protected by intellectual property rights. The reproduction and use of any documents published on this website are exclusively authorised for strictly personal and private purposes on condition that the source is mentioned. Any reproduction, use or distribution of copies made for other purposes is strictly prohibited and is subject to criminal penalties.

Comitium shall not be held liable for hyperlinks to other websites, particularly with respect to the content of such websites.

Any linking to or framing of this website is also strictly prohibited and accordingly, no element on any page of Comitium’s website may be partially or totally distributed, transferred or inserted in another Internet website or used to create derivative products, unless specifically authorised by Comitium’s management.




Welcome to the website of Comitium (the “Website”) on which we present our values, services and content (collectively, the “Services”). We use cookies and similar technologies. Cookies make your interaction with our Website and Services easy and allow us to store information on your browser or device or gain access to information stored on them.

You can always delete the “cookies” on your computer, oppose the registration of new “cookies” and receive notification before installing a new cookie by configuring your navigation device via the instructions below “Types of cookies, cookies and statistics and configuration.” Please note that if you uninstall a “cookie” or if you oppose the installation of “cookies” on your machine, you may not be able to benefit from certain services of the website.

When cookies require your permission to install them we ask you through the banner appearing on the first page of the website, provided that the pursuit of your navigation on the website implies acceptance.

This acceptance is considered as valid for a maximum period of 13 months. Beyond this, this consent will be offered again after complete erasure of cookies.

This Cookies Policy should be read in conjunction with our Privacy Policy described in the Legal Mentions.


What is a cookie?

Cookies are small text files that uniquely identify your browser or device. The cookie is stored on your browser or device by websites or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these websites recognize the cookies and your device.

We also use pixels. Pixels are small portions of code which we use on our Website. We use pixels to learn whether you have clicked on certain web content and help us to optimize our ad campaigns. This helps us measure and improve our Services and personalize your experience.


Categories of cookies

Cookies do many different jobs, like letting you navigate between pages efficiently. Thus, Cookies can tell us, for example, whether you have visited the Website before or whether you are a new visitor.

There are different categories of cookies, including:

First-party cookies

First-party cookies are small amounts of text which are served by us directly to your device.

Third-party cookies

Third-party cookies, which are served by a third party on our behalf.

What types of cookies do we use and how do we use them?

The types of cookies and similar technologies used by us and our partners in connection with the Website are described below:


Cookies that are necessary for essential purposes

These cookies are essential to provide you with the Website and Services and to use some of its features, such as to enable you to log into secure areas of the Website. Without these cookies, we would not be able, for instance, to provide you with a secure log in account or process your online requests.


Performance and Analytics Cookies

We use performance and analytics cookies to analyze how you use the Website, including which pages and videos you view most often, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Website to provide Services in accordance with these activities. These cookies do not collect information that individually identifies you and all information these cookies collect is aggregated and anonymous. On our Website, we also use third party analytics tools to help us measure traffic and usage trends for the Services (e.g. with Google Analytics).


Social Network Cookies

These cookies allow you to share Website content on social networks such as Facebook or Twitter. These cookies are not controlled by us. We invite you to consult the personal data policies of the social networks concerned to find out more about how their cookies work.


How to delete cookies

You can change your preferences by changing the settings in your browser. Most browsers will allow you to choose the level of privacy settings you want.

Deleting cookies or similar technologies means that any preference settings you have made on a website will be lost. Blocking all cookies or similar technology means functionality on our Website will be lost. If you choose to refuse cookies or pixels you may not be able to use the full functionality of our Website.


Retention period

Our cookies are stored for a limited period, which cannot exceed 13 months.


Changes to this policy

We will occasionally update this policy to reflect changes in our practices, Website and Services. When we post changes to this policy, we will revise the “Last Updated” date at the end of this policy. If we make any material changes in the way we collect, use, and/or share information held in cookies, we will notify you by prominently posting notice of the changes on the Website. We recommend that you check this page from time to time to inform yourself of any changes in this policy or any of our other policies.


Contact us

If you have any questions or comments about this policy, or privacy matters in general, please contact us via email at the following address:


Last updated: July 2019