Cookie management policy

Lord Services (hereinafter also referred to as “the company”, “we” or “us” in this policy) is a limited company with a board of directors (“société anonyme à conseil d’administration”), with a share capital of 37 000 €, registered with the Montpellier Trade and Companies Register (“Registre du Commerce et des Sociétés” or “RCS”) under the number 889 272 639, and incorporated in France with its registered office at 455 Avenue du Professeur Etienne Antonelli - 34070 Montpellier, intra-Community VAT number: FR60 889 272 639, SIRET number: 889 272 639 00010, phone number: +33 (0)4 83 43 29 44, e-mail address: contact@davensi.com.

Lord Services' main business is the provision of all digital asset services, including the creation, development and operation of a digital asset trading platform, the exchange of digital assets for other digital assets, and the purchase or sale of digital assets for legal tender. In that respect, Lord Services operates as a digital asset service provider (in French “prestataire de services sur actifs numériques” or “PSAN”).

For more information on our, click here.

The company operates the publicly accessible website with the following URL address (hereinafter referred to as the “Website”): http://app.davensi.com. The purpose of the Website is to:

Provide users with information on the business and services offered by the company in addition to its news (events, publications, etc.);

Offer features and/or information for users to contact the company and present the services provided by the company, its current or future projects and the team working on said projects;

Provide users with a means to create an online account and access to the digital assets trading platform and the various related services as outlined in our general terms and conditions;

Provide users with the opportunity to take part in one-off fundraising operations.

The company also manages social media pages to present its business, publish content and interact with internet users (e.g. Facebook, Instagram, Twitter, YouTube, Pinterest and LinkedIn).

The company uses cookies, tags, pixels and other trackers or similar technologies (hereinafter referred to as the “cookies”) on the Website. Such cookies may be installed on the user’s computer or device during the user’s browsing or interactions on the Website, subject to the choices and options which the user has indicated or may indicate at any time in accordance with this cookie management policy. These cookies and the data collected through this means are used by the company and third parties / partners mentioned on the list provided below (see the list of cookies in Article 3 below) or in the cookie management module offered on our Website and which may be accessed through the following icon:

axeptio.png

Our cookie management policy explains what cookies refer to, the types of cookies that we use on the Website and specifies the rights you have with regard to accepting or refusing the installation of cookies on your device. 

1. What is a cookie?

1.1    Cookies are small files, generally consisting of alphanumeric characters (e.g. letters and figures) that are used to store and retrieve information. They are installed by a web server on the user’s computer or electronic device to send status information to the browser and obtain the same information back from the browser. For example, status information may be a session identifier, language, expiry date, response domain, etc.

1.2    Cookies are generally used to obtain information about the user’s browsing habits, computer or device, in order to improve the content and service offered by the website in question, determine website traffic and provide internet users with customised services.

1.3    The concept of cookies as used in this policy covers all types of trackers or similar technologies, e.g.:

  • HTTP cookies;
  • As well as the use of other methods:
    • Local shared objects sometimes called “Flash cookies”;
    • Local storage implemented within HTML 5;
    • Device fingerprinting;
    • Identifiers generated by operating systems (whether advertising or not: IDFA, IDFV, Android ID, etc.);
    • Hardware IDs (MAC address, serial number or any other device ID);
    • etc.

1.4    In any case, there are different sorts of cookies:

  • Session cookies, which expire once the user closes the browser or leaves the Website; or
  • Persistent cookies which are stored until the expiry of their lifespan or validity, or until the user deletes them using the browser features for instance or through the cookie management module made available on our Website.

2. What are the main types of cookies?

There are two main types (or categories) of cookies, subject to different legal regimes.

a) So called “operating” cookies not subject to the user’s consent

So called “operating”, i.e. cookies whose sole purpose is to enable or facilitate communication by electronic means on, from or to the Website or which are strictly necessary for the provision of an online communication service at the express request of the Website user, do not require the user’s consent for their installation.

Accordingly, the company may use such “operating” cookies, in particular technical cookies that are essential for browsing the Website and cookies that are strictly necessary to provide certain services explicitly requested by the user, without seeking your prior consent. If the user deactivates these "operating" cookies, for instance by using the browser features, he/she may not be able to access the Website, and/or to properly visualize the content and information available on the Website and/or to enjoy all the features of the Website.
 

b) Other cookies, subject in principle to the user’s consent

The use of other cookies as referred to below is subject in principle to the user’s prior consent. Users are free to accept these cookies by expressly consenting to their installation and reading in their browser (with the understanding that users will have the option to withdraw their consent at any time under the conditions and in accordance with the terms referred to in Article 4 below), or refuse them.

To find out more about the details of the cookies used on the Website and the purposes for which they are used, the user is invited to consult Article 3 below.

3. What cookies do we use and for what purpose?

The cookies that we and our partners may install on your device may fulfil the following purposes:

3.a. “Operating” cookies

These cookies (i.e. "operating" or "necessary" cookies) have the sole purpose to enable or facilitate communication by electronic means, or are strictly necessary for the provision of an online communication service at the express request of the Website user. These cookies enable the Website to function (and the user to navigate on the Website) in an optimal manner and provide the user with certain online services at his/her request. 

These cookies are not subject to the user's consent and are installed by default. Insofar as these cookies are necessary to offer you a better user experience or to allow you to benefit from certain features of our Website, we do not offer any dedicated technical means to allow you to oppose the installation of these cookies or to deactivate them. However, you have the possibility of deactivating them (as with certain other cookies) by other means, for example by means of the functionalities offered by your browser, it being specified that in this case may not be able to access the Website, and/or to properly visualize the content and information available on the Website and/or to benefit from all the functionalities of the Website, and/or to properly visualize the content and information available on the Website and/or to benefit from all the functionalities of the Website.
 

Name of the cookie (name of the cookie publisher / depositor)

Purpose of use of the cookie

Categories of data collected by the cookie and retention period

Entities using the cookie / recipients of the data

Lifetime of the cookie

axeptio_cookies, axeptio_all_vendors, axeptio_authorized_vendors (Axeptio)

These cookies are used to remember the choices of the user, namely the acceptance and / or refusal of our cookies, by purpose of cookies.

These cookies are also intended to manage the display and redisplay of the cookie management module.


 

See our privacy policy https://app.davensi.com/en/privacy-policy

The company and Axeptio (https://www.axeptio.eu/en/terms et https://www.axeptio.eu/en/privacy-policy)

[to be completed : a maximum lifetime of 6 months should be provided]

SULUSESSID (Sulu)

This cookie is used to maintain an anonymized unique identifier for your session.

See our privacy policy https://app.davensi.com/en/privacy-policy

The company and Sulu (https://sulu.io/privacy-and-legal-notices)

This cookie will expire when your browsing session is over.

_zlcmid (Zendesk)

This cookie stores user's machine-id for the chatbox authentication and is used to ensure the technical provision of the chatbox.

See our privacy policy https://app.davensi.com/en/privacy-policy

The company and Zendesk.

For more information about how Zendesk may process your data, see Zendesk's Privacy  and Cookies Policies: https://www.zendesk.co.uk/company/privacy-and-data-protection/

and Zendesk In-Product Cookie Policy: https://support.zendesk.com/hc/en-us/articles/4408824378650

[to be completed : a maximum lifetime of 6 months should be provided]

_GRECAPTCHA (Google)

This cookie is used in order to provide “reCAPTCHA” to secure our contact forms. “reCAPTCHA” uses an advanced risk analysis engine and adaptive challenges to keep malicious software from engaging in abusive activities on our Website and to block fake users.


 

For more information : https://support.google.com/recaptcha/?hl=en#6262736 or https://www.google.com/recaptcha/about/ 

See our privacy policy https://app.davensi.com/en/privacy-policy

The company and Google.

For more information about how Google may process your data, see Google's privacy  and cookies policies: https://policies.google.com/?hl=en 

[to be completed : a maximum lifetime of 6 months should be provided]

 

3.b Monitoring, measurement and evaluation of audience and browsing activity

The purpose of these cookies is to produce statistics on visits of the Website: tests, monitoring, measurement and analyses of audience, traffic, browsing and performance.

The purpose of these cookies is to collect information about your use of our Website in order (i) to establish statistics on visits and perform audience, traffic and browsing measurements and analyses, (ii) to assess, understand and report on how you use our Website (e.g.: identification of how you reach our Website or how you use it, retrace your browsing history on our Website, etc.), (iii) to allow us to carry out market positioning research with respect, for example, to third-party websites, particularly those of our competitors, and (iv) to enable us, depending on the results obtained (depending on the analysis of the browsing path of Internet users, for example), to adapt our Website with a view to continuously improving the performance of the said Website and the user experience (particularly based on users’ browsing requests and preferences).

The operation of these cookies is based on the identification of “single visitors” which subsequently allows us to measure the number of visits, the number of visitors, the number of pages viewed, browsing duration and paths followed by the visitor, the activity and interactivity of the visitor with the Website, the frequency of visits (to the Website or specific pages of the Website), the performance of various pages of the Website, etc.

The installation of these cookies on your device is subject to your prior consent which is collected in accordance with Article 4 of this cookie management policy.

Name of the cookie (name of the cookie publisher / depositor)

Purpose of use of the cookie

Categories of data collected by the cookie and retention period

Entities using the cookie / recipients of the data

Lifetime of the cookie

 

Google Analytics is a tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners tags (libraries) to record information about the page a user has seen, for example the URL of the page.

_ga, _gid (Google Analytics)

These cookies are used to distinguish unique visitors on the Website by assigning each one a randomly generated number as a user ID. This allows in particular to calculate the number of visitors, sessions, ... and to know how they use the Website, which the company uses for example in order to improve the Website.

For more information : https://support.google.com/analytics/answer/6004245?hl=en

See our privacy policy https://app.davensi.com/en/privacy-policy

The company and Google.

For more information about how Google may process your data, see Google's privacy  and cookies policies: https://policies.google.com/?hl=en 

[to be completed : a maximum lifetime of 6 months should be provided]

_gat_UA-180872593-1 (Google Analytics)

These cookies are used to reduce the frequency of certain requests made to Google servers and/or to persist session state.

For more information : https://support.google.com/analytics/answer/6004245?hl=en

  

[to be completed : a maximum lifetime of 6 months should be provided]

4. When and how do we collect your consent for the installation of cookies? What are your rights regarding cookies?

4.1 Context for obtaining your consent, scope of your consent and exceptions

4.1.1    The installation of cookies on a computer or device as well as the reading of cookies via the Website are in principle subject to the user’s consent. This means the freely given, specific, informed and unambiguous indication of the user’s agreement for this purpose. This consent is collected through our cookie management module (accessible in the footer) available via the following icon:
 

axeptio.png

under the conditions and procedures outlined below.

Therefore, when users first visit the Website, they are asked if they accept cookies that require their consent, which are classified into various categories depending on the intended purpose, before these cookies are installed on their computer or device. Cookies subject to such consent are only installed on the user’s device if the user expressly accepts them either as a whole or in an individual manner for each purpose of the cookies in question within our cookie management module (refer to the module that allows users to consent to or refuse the use of cookies, depending on the specific purpose of said cookies).

Important:

In cases where your consent is required, such consent is strictly optional and you may refuse to give it to us. In any case, if you consent to all or part of these cookies being installed and read, you naturally have the option to withdraw you consent at any time through the cookie management module.

– Furthermore, unless otherwise specified by you via our cookie management module under the conditions and in accordance with the procedures outlined below, your choice (overall consent, partial consent or refusal) will be retained for 6 months, at the end of which you will once again be asked to consent (or not) to the installation of such cookies on your device.

4.1.2    Exception to the consent for “operating” cookies used by our Website. Such cookies are not subject to your prior consent. Accordingly, these cookies are installed on your device by default during your browsing on the Website, without seeking your prior consent. Insofar as these cookies are necessary to provide you with the best possible user experience and allow you to take advantage of certain features of our Website, we do not provide you with the dedicated technical means to refuse these cookies or to disable them. However, you can disable them (in the same way as some other cookies for that matter) by other methods, such as via the features offered by your browser, with the understanding that in this case you may not be able to access the Website and/or properly visualize the content and information available on the Website and/or take advantage of all the features of the Website

4.2    Practical procedures for collecting your choice regarding cookies (consent / refusal)

The cookie management module contains information for users about the cookies that we may install / read on their device due to the browsing of the Website (also refer to the details about these cookies in Article 3 of this cookie management policy). The cookie management module is displayed when users first connect to our Website, then, irrespective of the option selected by the user (overall consent, partial consent or refusal) it is displayed again every 6 months. It is also displayed again if users delete the cookies through their browser features. 

The cookie management module offers the user the following choices:

  • Either to fully refuse the use of all cookies by clicking on “Refuse all cookies”: no cookies (apart from “operating” cookies) will be installed;
  • Or to fully consent to the use of all cookies by clicking on “Accept all cookies”: all cookies will be installed;
  • Or to personalise these options to more thoroughly manage the accepted (or refused) cookies, by clicking on “Cookie settings”. In this case, the user will see a 1st screen with the list of "operating" cookies for information purposes (with the understanding that the “operating” cookies are not subject to prior consent, and thus are installed by default and cannot be refused by the user via our cookie management module). Then a 2nd screen will allow the user to choose the cookies subject to consent that he accepts or refuses. As a reminder, the cookies are “refused” by default. Consequently, the user is prompted to click on the dedicated button for each category of cookies in question within our cookie management module to select the cookies that he/she wishes to accept. The user shall then save the options by clicking on “Save my choices”. It is specified that in principle, the cookies that the user has not expressly accepted are considered as refused and will not be installed. This page also offers the user the “Accept all cookies” button as well as the “Back” button allowing the user to return to the previous pages of the module.

To access our cookie management module, click on the following icon:
 

axeptio.png

Available in the footer on all pages of our Website.

In any case you can freely and at any time withdraw your consent to the use of cookies by disabling one or more cookies in accordance with the details provided below.

4.3    Practical procedures for changing your cookie options (withdrawal of consent or objection)

At any time, you have several options to change the settings of your cookies, including to withdraw your consent or to object to the use thereof (i.e. installation/reading of cookies on your device).

4.3.1    You may, at any time via the cookie management module, simply, freely and individually (i.e. in a distributive manner) depending on the intended purposes of the cookies, opt to withdraw your consent or to object to the use of cookies other than the “operating” cookies on your computer or device.

To do so, click on the following icon:
 

axeptio.png

available in the footer on all pages of our Website and make your choice in accordance with Article 4.2 above.

4.3.2    If you prefer, you can also use one of the following options.

a) Setting your browser

Although most browsers are set by default and accept the installation of cookies, you have the option, if you wish, to set your browser to accept all cookies or to systematically reject them or to only select those that are accepted depending on the issuers/senders (provided that this feature is offered by your browser). Furthermore, you can also regularly delete cookies from your device via your browser.

In any case, these actions must be carried out for each device: tablets, smartphones, computers, etc.

You can therefore freely configure your browser software (Internet Explorer, Firefox, Google Chrome, etc.) so that the cookies are:

  • Accepted and stored in your computer or device: in this case the cookies integrated in the pages and content that you have consulted will be systematically stored;
  • Refused: in this case, the cookies integrated in the pages and content that you have consulted will not be stored;
  • Subject to your choice in each case: therefore, the storing of cookies will be subject to your acceptance or refusal.

To configure your cookie preferences for accepting or refusing cookies, you need to take into account your browser configuration insofar as each browser offers different setting methods to manage cookies and these change regularly. Therefore, you should consult the help menu of your browser which will enable you to determine how to change your cookie preferences. For example:

Lastly, we nevertheless draw your attention to the fact that in the current state of the art, browsers:

  • Do not all allow you to differentiate cookies based on their purpose (the consequence of which is that you often have to “Accept all” or “Refuse all” when configuring your choices);
  • Do not all allow the user to express a valid consent (the consequence of which is that even though you may have consented to cookies via your browser, we will ask you for specific consent again under the aforementioned terms and conditions prior to any installation/reading by us of cookies subject to your consent);
  • Do not all allow the user to express a choice on technologies other than “cookies for tracking purposes” in the strictest sense of the term. It is also possible that certain cookies, trackers or other similar technologies may not be blocked in principle (e.g.: device fingerprinting) and can still be installed on your device and/or activated despite your refusal expressed in your browser settings.

We therefore recommend that you use the module dedicated to this purpose to manage your cookie choices on the Website (see above).

b) Cookie settings via interprofessional digital advertising platforms 

Several professional advertising platforms also offer users the option to set their preferences regarding the targeted/behavioural advertising used by their member companies. In general, these centralised mechanisms do not block the displaying of all advertisements but prevent the display of targeted/behavioural advertisements tailored to the user’s areas of interest which are defined based on the user’s previous web activity and browsing.

For example, the platform edited by NAI (Network Advertising Initiative) accessible on the https://www.youronlinechoices.com/uk/your-ad-choices page offers such features. For another illustration, see also the European platform http://www.youronlinechoices.com/fr/controler-ses-cookies/ proposed by the digital advertising professionals grouped within the European association EDAA (European Digital Advertising Alliance).

Although these platforms can help you to manage your targeted advertisement preferences, they do not necessarily block advertisements in general, or the installation of all cookies on your device.

Therefore, we recommend that you use the module dedicated to this purpose to manage your cookie choices on the Website (see above).

 

c) Use of third-party tools available online

Some publishers of cookies that we use on our Website offer dedicated rejection modules. We therefore recommend that the user refer to the information pages indicated in the above table (refer to details of cookies that we use) to identify such modules, where applicable.

For example, the user may view specific information on the Google Analytics opt out browser add-on module on the following page: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631. The user may also opt to disable Google Analytics cookies directly by going to the following page: https://tools.google.com/dlpage/gaoptout?hl=en.

 

4.3.3 You can obtain information on how to control your data when browsing the internet on the website of the National Commission for Informatics and Liberties (or “Commission national de l’informatique et des libertés” or "CNIL" (https://www.cnil.fr/fr/maitriser-mes-donnees, in particular https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser). In this regard, third-party cookies are usually not necessary to take advantage of the resources available on the internet. If you wish to limit your traces, it is recommended to refuse them by default, referring to the advice of the CNIL.

5. Where can you find additional information about personal data processing?

The cookies as such are not considered as personal data. However, they can lead to the collection of information considered as personal data and therefore to the processing of such data. 

In this respect, you are informed that by consenting to the installation of all or part of the cookies on your device, you consent for the purposes associated to the processing of personal data concerning you collected via this method, with the understanding that such processing operations may involve the processing, combination and cross-referencing of a significant volume of personal data from various sources.

For more information regarding the processing of your personal data by the company, particularly the processing of personal data collected via cookies incorporated on our Website, please consult our privacy policy.

 

Date of last update : January 06, 2024