This English version is provided for convenience only. Synapses Partners is a French company and its legal information is published in French at synapses-partners.com/legal. In the event of any discrepancy, the French version prevails and is the only one that binds the company. French law applies, as stated below.
Legal notice
Last updated: 2026-09-29 · Version 1.1
Publisher of the site
| Name | SYNAPSES PARTNERS |
| Legal form | Société par actions simplifiée unipersonnelle (single-shareholder simplified joint-stock company) with share capital of €5,000 |
| Registered office | 15 rue de Dantzig, 75015 Paris, France |
| Registration | RCS Paris 999 600 950 — SIRET 999 600 950 00011 — APE code 70.22Z — EUID FR7501.999600950 |
| VAT | VAT not applicable — small-business exemption (franchise en base), Article 293 B of the French General Tax Code |
| Contact | contact@synapses-partners.com |
Publication director: Mr Nicolas DELHAY, President.
Hosting provider
Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, United States — www.cloudflare.com, telephone +1 888 993 5273.
Intellectual property
All elements of the site and of the Polaris Market platform — text, graphics, logos, icons, sounds, software, databases, calculation methods — are the exclusive property of Synapses Partners or of its licensors, protected by the French Intellectual Property Code.
Synapses Partners is the producer of the databases it has assembled, within the meaning of Articles L. 341-1 et seq. of the French Intellectual Property Code. Any extraction or re-use, qualitatively or quantitatively substantial, of their content is prohibited, as is the repeated and systematic extraction or re-use of non-substantial parts.
Any reproduction, representation, adaptation or exploitation, in whole or in part, without prior written authorisation, is unlawful.
Disclaimer regarding content
The content published on the site and distributed by newsletter is provided for information purposes only. It does not constitute investment advice, a personal recommendation or a solicitation to buy or sell financial instruments. Sources are believed to be reliable, but their accuracy and completeness are not guaranteed. Past performance is not a reliable indicator of future results. Any investment decision is the sole responsibility of the reader.
Some content is produced with the assistance of artificial intelligence systems, under human supervision, and is identified as such.
Personal data
See the Privacy policy.
Complaints
Complaints: contact@synapses-partners.com. Complaints are acknowledged within ten working days and answered within two months. Failing an amicable settlement, the dispute will be referred to the competent courts as set out in the “Governing law” section. As our services are reserved for professionals, consumer mediation does not apply.
Hyperlinks
Links to third-party sites are provided for the reader's convenience. Synapses Partners exercises no control over those sites and disclaims any liability for their content.
Governing law
This site is governed by French law.
Privacy policy
Last updated: 2026-10-03 · Version 1.7
1. Data controller
SYNAPSES PARTNERS, SASU with share capital of €5,000, RCS Paris 999 600 950, registered office 15 rue de Dantzig, 75015 Paris, France. Contact: contact@synapses-partners.com.
Data protection officer: none has been appointed, as the appointment is not mandatory given the nature of the activity. Requests relating to personal data are handled at the address above.
2. Processing operations
| # | Processing | Data | Legal basis | Retention period |
|---|---|---|---|---|
| 1 | Client relationship management | Identity, role, business contact details, correspondence, contracts | Performance of the contract | Term of the contract + 5 years |
| 2 | Polaris Market user accounts | Last name, first name, work email, role, permissions, hashed password, second factor | Performance of the contract | Term of the contract + 12 months |
| 3 | Connection logs | IP address, timestamp, URL, user agent | Legitimate interest (security, evidence) | Up to 90 days |
| 3bis | Application audit log | User, action, target, IP address, user agent (sign-in and account administration) | Legitimate interest (security, evidence) | 12 months |
| 4 | Newsletters — World Morning Brief, ESG Morning Brief, Digital Assets Morning Brief, People Moves AM (daily), Quantitative finance (weekly), their weekly and monthly reviews, and the French money market barometer (monthly) | Work email, name, company, subscription and confirmation status, individual unsubscribe token. No open or click data: our newsletters contain no tracking pixel or tracking link | Consent (double opt-in) for any sign-up from the site; legitimate interest (B2B prospecting) for existing business contacts — unsubscribe possible at any time | 3 years from the last active contact |
| 4bis | Requests made from the site (demonstration, fund analysis, pricing, advisory engagement, regular reporting, security pack) | Title, first name, last name, company, role, work email, optional telephone, subject, message, ISIN codes where applicable, time-stamped consent | Pre-contractual steps taken at your request | 3 years from the last contact; 12 months if no follow-up |
| 5 | Commercial prospecting | Business contact details, history of exchanges | Legitimate interest | 3 years from the last contact |
| 6 | Anti-money-laundering obligations | Identity documents, beneficial owners, supporting documents | Legal obligation | 5 years after the end of the relationship |
| 7 | Accounting and invoicing | Billing data | Legal obligation | 10 years |
| 8 | Complaints | Content, correspondence, outcome | Legal obligation and legitimate interest | 5 years |
| 9 | Content uploaded by clients | May incidentally contain the names of business contacts | Processing on behalf of the client | As instructed by the client |
| 10 | Distributed-ledger address labels | Public addresses attached to entities, never to natural persons | Legitimate interest | Term of the service |
3. Where the data comes from
Data comes from: the data subjects themselves; our clients (for the users they designate); publicly accessible business sources (company websites, professional directories, press releases, professional networks) for B2B prospecting.
At first contact, the person is informed of the origin of their data and of their right to object.
4. Recipients
Data is never sold, rented or exchanged. It is accessible to the managing director of Synapses Partners and, to the extent necessary, to the categories of recipients below. The identity of the providers in each category is available on request at contact@synapses-partners.com.
| Category of recipient | Role | Location | Safeguards |
|---|---|---|---|
| Platform hosting | Polaris Market and its databases | European Union | Data processing agreement |
| Editorial pipeline hosting | Production and sending of the newsletters | France (European Union) | Data processing agreement |
| Site delivery and protection | Network filtering, DNS, page delivery | European Union and worldwide | Standard contractual clauses |
| Email delivery | Newsletters and service emails | European Union and United States | Standard contractual clauses |
| Artificial intelligence assistance | Processing of uploaded content and editorial drafting | European Union and United States | Standard contractual clauses; no training on your data |
| Backup | Encrypted copies, unreadable by the provider | European Union and United States | Standard contractual clauses |
| Technical monitoring | Reporting of application errors | United States | Standard contractual clauses |
| Website usage measurement, with your consent | Click and scroll maps, session recordings with masked inputs | United States | Standard contractual clauses |
| Chartered accountant | Accounting and tax obligations | France | Accountant’s duty of professional secrecy |
5. Transfers outside the European Union
Any transfers to third countries rely on an adequacy decision or on the European Commission's standard contractual clauses, supplemented where necessary by additional measures.
6. Security
Encryption of communications (HTTPS enforced), named accounts, hashed passwords, two-factor authentication available, server-side permission checks, upstream network filtering, logging, encrypted and replicated backups, automated security tests before every release, security review against the OWASP framework.
7. Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability of your data, as well as the right to give instructions on what happens to it after your death.
To exercise these rights, write to contact@synapses-partners.com or by post to the registered office, enclosing proof of identity. We reply within one month; this period may be extended by two months for complex requests.
You may lodge a complaint with the CNIL, the French data protection authority — 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr.
8. Subscribing to and unsubscribing from the newsletters
Signing up from the site works by double opt-in: after your request, a confirmation email is sent to you and the subscription becomes active only once you have clicked the link it contains. Every issue carries a one-click unsubscribe link. Unsubscription takes effect immediately; the address is kept on a suppression list to make sure nothing further is sent to it.
9. Cookies and trackers
Public website: no advertising tracker. Traffic is measured with Cloudflare Web Analytics, without cookies or any visitor identifier (page views, referrers, device type, loading times), which is exempt from consent. Only with your consent, collected through a banner that lets you decline as easily as accept, Microsoft Clarity measures how pages are used (clicks, scrolling, session recordings in which inputs are masked); its cookies are kept for 13 months at most, your choice is stored on your device for 6 months and can be changed at any time through the "Manage cookies" link in the footer. Items strictly necessary to the service remain exempt from consent: the Cloudflare Turnstile widget that protects the forms against automated submissions (security).
Newsletters: in line with the CNIL recommendation of 12 March 2026 on tracking pixels in email, our newsletters contain no tracking pixel or tracking link. We measure neither opens nor clicks. The only personalised element in each email is the unsubscribe link, which carries a token specific to its recipient (a security measure exempt from consent). The only image, the logo, is served from the same address for every recipient.
Polaris Market platform: strictly necessary session cookies (polaris_token, and on mobile polaris_refresh), exempt from consent. The platform's home page embeds market widgets provided by TradingView, an independent third party that may set its own cookies; access to those widgets is subject to TradingView's privacy policy, and their loading may be made conditional on your consent depending on the configuration chosen. Quotes and economic calendars are otherwise served from the Synapses Partners cache, with no call from your browser to a third party.
10. Content produced with the assistance of artificial intelligence
Some editorial content is produced with the assistance of artificial intelligence systems under human supervision, and is identified as such. Our clients' personal data is not used to train such systems.
11. Changes
This policy may be amended. The version that applies is the one published on the site, whose update date appears at the top.
Complaints
Last updated: 2026-09-29 · Version 1.1
1. Definition
A complaint is any statement recording a client's dissatisfaction with Synapses Partners. A request for information, for an opinion, for clarification, for a service or for work to be carried out is not a complaint.
2. How to submit a complaint
| Channel | Details |
|---|---|
contact@synapses-partners.com | |
| Post | Synapses Partners, 15 rue de Dantzig, 75015 Paris, France |
| Oral (telephone, meeting) | Put in writing by Synapses Partners and confirmed to the client |
These details appear in the onboarding document, in the general terms of use, in the general terms of sale and on the website.
3. Time limits
| Step | Maximum time |
|---|---|
| Written acknowledgement | 10 working days from receipt |
| Final reasoned reply | 2 months from receipt |
| Informing the client if a time limit is exceeded | Before the deadline expires, with the reason and a new date |
4. Handling
- Recording in the internal complaints register (section 7), under a unique number, on receipt.
- Acknowledgement to the client, stating the handling time and the avenues of recourse.
- Investigation: gathering the facts, the documents and, where relevant, the technical logs.
- Written reasoned reply, in plain language, setting out the position of Synapses Partners, the measures taken and the avenues of recourse.
- Closure and archiving.
5. Avenues of recourse to be stated in every reply
- CNIL for complaints concerning personal data.
- The competent court.
6. Root-cause analysis
A half-yearly review of complaints is carried out: volume, type, recurring causes, corrective measures. Its conclusions are used to improve our services and processes.
7. Complaints register
Each complaint is recorded in an internal register: number, date received, client, channel, subject and type, dates of acknowledgement and reply, outcome, corrective measure. This register is not public.
Retention: complaints and their handling are kept for five (5) years.
8. Classification
Quality and availability of the service · Accuracy of the data · Invoicing and pricing terms · Content of a piece of advice or a deliverable · Personal data protection · Security · Commercial relationship · Other.
