[Draft] Legal Notice

Company Name

This website was created by Moringa Partnership. It is managed and updated by Moringa Partnership.

Moringa Partnership SAS
Société par Actions Simplifiée (simplified joint stock company) with a Board of Directors with a share capital of 10’000 euros.
Registered in the Creteil Trade and Companies Registry under n° 789 961 893 RCS Creteil.
Registered office : 47 rue du Faubourg Saint-Honoré, 75401 Paris Cedex 08, France.
Siren n° : 789 961 893
Principal activity (APE): 7022Z- Business consulting and other management advisory services
Intra-community VAT number : FR24 789 961 893

Website hosting : OVH, 2 rue Kellermann, 59100 Roubaix, France


All information available through the privileged area (where applicable) of the Website is confidential and proprietary to Moringa Partnership. This includes all investment information and results, offering materials, financial statements and other information provided through this part of the Website. You will use your best efforts to keep all this information strictly confidential. You will not disclose any of this information to any person or use it for any purpose other than those expressly permitted by Moringa Partnership in writing.


You may only access the privileged area (where applicable) of the Website by using the password that we, Moringa Partnership, have provided. You agree to keep the password confidential, and not to provide it to any other person except your employees, counsel and other professional advisors who have a need to access the information to advise you regarding Moringa Partnership. You will immediately notify us if you become aware of any theft or unauthorized use of the password. You are responsible for any unauthorized use of the password.

Limitation Of Liability

Moringa Partnership uses reasonable efforts to include accurate and up to date information on this Website however, errors and omissions may occur. You understand and acknowledge that all information provided on this Website is provided AS IS, AS AVAILABLE and WITH ALL FAULTS and we make no representation or warranty, or give any indemnity, of any kind, express or implied, as to the operation of our Website, the accuracy of the information or any other matters referred to on the Website. You agree that, in consideration for providing you with access to the privileged area of our Website and the information within it, it is reasonable for Moringa Partnership to not be liable for any direct or indirect special, incidental, consequential or punitive damages or lost profits arising from the use of material presented in this Website.
Content and information provided by third parties other than Moringa Partnership is identified clearly where it appears. We publish this content as supplied to us and are not responsible for its accuracy or timeliness. You must take appropriate steps to verify this information before acting upon it.

No Offer Of Securities – No Solicitation

The Website is for informational purposes only. No information on the Website should be construed as a solicitation, advice, offer, recommendation, representation of suitability or endorsement of any security, investment, product or services. The information provided on this Website should not be relied upon in connection with any investment decision.

This Website is not specifically intended for residents of a country or a jurisdiction in particular and the information it contains is not intended for access or use by any person or entity in any jurisdiction or country where such access or use would be contrary to law or regulation or which would subject Moringa Partnership or its affiliates to any registration requirement, or to be otherwise regulated in any way, within such jurisdiction or country.

In particular, (i) the Website does not constitute and may not be used for or in connection with either an offer to any person to whom it is unlawful to make such an offer or a solicitation (démarchage) by anyone not authorised so to act in accordance with articles L. 341-1 to L. 341-17 of the French Financial Code (Code Monétaire et Financier), (ii) Moringa Partnership and its affiliates will not offer, sell or otherwise transfer, directly or indirectly, securities to the public in France within the meaning of article L. 411-1 of the French Financial Code (Code Monétaire et Financier) and articles 211-1 et seq. of the General Regulation of the Autorité des Marchés Financiers, and (iii) Moringa Partnership and its affiliates shall not be deemed to provide investment advice within the meaning of articles L. 541-1 et seq. of the French Financial Code (Code Monétaire et Financier) nor any other investment services within the meaning of articles L. 321-1 et seq. of the French Financial Code (Code Monétaire et Financier).

The offerings of securities in entities advised or managed by Moringa Partnership or its affiliates will in any case only be made through Prospectuses, Private Placement Memoranda, Offering Memoranda or Offering Circulars distributed by persons authorized by Moringa Partnership or its affiliates and in compliance with applicable laws.

Performance Data

Any performance data expressed on this Website is an indication of past performance and does not indicate or guarantee future results. Moringa Partnership advises all users of this Website that there is a possibility of loss on all investments and investor principal is not guaranteed. Additionally, Moringa Partnership engages in certain strategies that may involve investments that are illiquid and may be subject to heightened risk of loss, as such these investments may not be suitable for many investors.
This Website has been compiled in good faith by Moringa Partnership; however, no representation or warranty is made as to the completeness or accuracy of the information it contains. In particular, you should be aware that this information may be incomplete, may contain errors or may have become out-of-date. Moringa Partnership makes no commitment, and disclaims any duty, to update such reports. Moringa Partnership reserves the right to add, modify or delete any information at this Website at any time.

Data Protection

The use of the present website by visitors does not require the transmission of personal data by Moringa Partnership and Moringa Partnership does not intend to collect or process visitors’ personal data through its website.

Notwithstanding the above and to the extent that IP addresses can be considered as personal data, you agree that your use of the website may imply the automatic transmission of your IP address to Moringa Partnership through cookies or other comparable technical means. In any event, Moringa Partnership undertakes not to transfer your IP address or any other of your personal data to any third party.


Copyright in the content published on this Website is owned by Moringa Partnership, except where otherwise indicated by a third party’s proprietary notice. Unless expressly prohibited by a notice published on any page on this Website, you may make a print copy of such parts of the Website as you may reasonably require for your own personal use. All other use is prohibited.


This website is governed by French law, and only the French courts may deal with any dispute that may arise in relation to this website.
To the extent that any part of these terms and conditions of use is found to be invalid, unlawful or unenforceable by any court of competent jurisdiction such part shall to that extent be severed from the remaining terms all of which shall remain in full force and effect as permitted by law.

Personal Data Protection And Cookies Policy

I. Personal data protection

As a data controller, Moringa Partnership processes personal data in accordance with laws relating to the processing of personal data, including Act No. 78-17 (January 6, 1978) which pertains to information technology, data files and civil liberties, as well as Regulation 2016/679 of the European Parliament (April 27, 2016) (the General Data Protection Regulation, commonly referred to as the “GDPR”) which pertains to the protection of natural persons with regard to the processing of personal data and the free movement of such data and which came into force on May 25, 2018.
Moringa Partnership monitors changes to legislation pertaining to the protection of personal data to make sure that it is in compliance and that it processes data lawfully, fairly, and in a transparent manner.
Moringa Partnership maintains a register of processing activities under its responsibility.
The purpose of this notice is to define the terms and conditions for the processing of personal data by Moringa Partnership via its website and as part of the services it provides.

Data processing purposes

Personal data shall be collected and processed for specific purposes and shall not be processed at a later date in a manner incompatible with those purposes, except in cases provided for by law. Moringa Partnership process the data for the following purposes:
• For the purpose of our legitimate interests
• For the execution of a contract to which the data subject is party or in order to take steps at the data subject’s request prior to entering into a contract
• For the compliance with legal and/or regulatory obligations to which we are subject
• For any other specific purposes to which the data subject has consented
The data processed shall be relevant and limited to only what is necessary for the purposes for which it is being processed.

Data processed

On our website, you will find 2 types of data that may be collected:
• Automatically collected data: during your visit to our website, anonymous data is collected on our servers for technical purposes, an element is saved by your browser in the form of a cookie. For more information on how we use cookies, please refer to Section 2 below.
• Data transmitted directly: this is data that you voluntarily transmit to us via e-mail.

Moringa Partnership may need to process the following personal data transmitted directly:
• Personal information (first name, last name, age, nationality, occupation, etc.)
• Personal information issued by government agencies (identity documents, etc.)
• Contact information (address, telephone number, email)
• Bank information (account number)
This data may be collected directly from you, or indirectly through one of our counterparties.
Moringa Partnership does not process data related to ethnicity, sexual orientation, political affiliation, religious or philosophical beliefs, or union membership. It does not process genetic, biometric, or health-related data, nor does it process data related to criminal convictions and offenses, unless necessary and required or permitted by applicable legislation.

Retention period

Moringa Partnership will retain the data for as long as necessary for the above mentioned purposes for which it is processed and shall not exceed the limits imposed by the legislation in force. When Moringa Partnership no longer needs your data, we will ensure that it is safely destroyed or anonymized in accordance with our internal policy.
Some data may be retained for an additional period of time so that we can manage claims and pre-litigation and/or litigation, so that we can meet our commercial, legal, and regulatory obligations, or so that we can respond to requests from authorized authorities.

The sharing and transfer of data outside of the European Union

In principle, the data may be transferred to, hosted in or accessed from, a member State of the European Union.
However, the data may also be transferred to, hosted in or accessed from a country outside the European Union, provided that the European Commission has acknowledged that such country ensures an adequate level of protection or one of the following conditions is met, in accordance with the applicable laws and regulations:
• The transfer is protected by appropriate safeguards;
• The data subject has given his or her consent regarding the transfer;
• The transfer is necessary for the performance of a contract between the data subject and us or the implementation of pre-contractual measures taken at the data subject’s request;
• The transfer is necessary for the conclusion or performance of a contract concluded, in the data subject’s interest, between us and another natural or legal person;
• The transfer is necessary for important reasons of public interest;
• The transfer is necessary for the establishment, exercise or defense of legal claims ;
• The transfer is required by a court, a tribunal or an administrative authority of the third country, whose judgment or decision is recognized or enforceable; or
• The transfer is not repetitive, concerns only a limited number of data subjects, is necessary for the purposes of our compelling legitimate interests (as notified to the data subject) which are not overridden by the interests or rights and freedoms of the data subject, and in this case, suitable safeguards with regard to the protection of the data have been taken.
We will do this only in order to execute a contract which you have signed, to fulfill a legal obligation, to protect the public interest, or to defend Moringa Partnership’s legitimate interests.

Data security and privacy

Moringa Partnership shall take necessary measures to ensure the data we collect is kept secure and confidential, that is, to ensure that only authorized associates tasked with processing data related to our services, will have access to your data and that their clearance is limited.

Procedure in case of a data breach

Moringa Partnership shall inform the National Commission of Informatics and Liberties (CNIL) of any breach of personal data within at least 72 hours of having become aware of the breach. If a data breach is likely to pose a high risk to the rights and freedoms of a natural person, Moringa Partnership shall inform the person concerned as soon as possible.

Your rights

Under the current legislation on data protection, you have the following rights:
• The right to access his/her data and to know, as the case may be, the source from which his/her data originates and whether such data came from publicly accessible sources,
• The right to ask for a rectification of his/her data in cases where such data is inaccurate and/or incomplete,
• The right to ask for a restriction of processing of his/her data,
• The right to request that your data be transferred, for data processing which is dependent on your consent or on the execution of a contract which has been, or will be, carried out.
• The right to ask that Moringa Partnership limit the processing of your personal data,
• The right to withdraw your consent at any time (for all data processing subject to your consent),
• The right to lodge a complaint with a competent supervisory authority, namely that of the country in the European Economic Area where your habitual residence or your workplace is situated, or where the alleged violation of the regulations occurred (the French Data Protection Authority (C.N.I.L) at the following address: Service des Plaintes, 3 Place de Fontenoy, TSA 80715 – 75334 Paris Cedex 07 – 01 53 73 22 22 – “https://www.cnil.fr/plaintes”).
You may exercise your rights at any time by contacting our Data Protection Officer:
• either by email at: dpo@moringapartnership.com
• or by mail at the following address:
Moringa Partnership
47 rue du Faubourg Saint-Honoré,
75008 Paris, France.

II. Cookies Policy

We attach great importance to your right to privacy and we strive to provide you with information which is as accurate as possible to enable you to exercise your rights in full.
As a result, we have developed this Cookie Policy to describe how we gather the information collected by this site and to enable you to adjust your privacy settings to suit your needs.

What is a cookie?

Cookies are files containing information that are uploaded to any device using the Internet – for example, your computer, tablet or mobile phone – when you visit a website. They are stored on your device to keep track of your visits to the website and your preferences when you browse pages.
In general, cookies can be divided into the following categories, depending on their expiry date:
• Session cookies – these cookies are linked to the login of the session. They expire at the end of the browser session and are stored in a temporary memory.
• Permanent cookies – these cookies allow websites to store your information and settings for your next visits, for example, your language choice. They are stored in your browser until you delete them manually or your browser deletes them on the expiry date of the cookies.
In addition, cookies can be classified according to the following categories, depending on the site that configured them:
• Proprietary cookies – configured by the website you are browsing.
• Third-party cookies – configured by a third-party site different from that on which you are browsing, such as the website of a company carrying out monitoring or marketing activities (for example, advertising networks).
We also use web beacons, also known as “pixel tags”, which may be present on our sites. These tags are generally used in combination with cookies to identify our users and better understand their behavior. In our policy, the term “cookies” may be used to refer to all technologies that we may use to store data in your browser or device, which collect information or help us identify you in the manner described in this policy.

How do we use cookies?

The list of cookies used on this website and their objectives:

If you have any questions about cookies, their collection or use, please contact us at dpo@moringapartnership.com.

Our websites also contain links to external social networks such as Facebook, Twitter, and LinkedIn. The use of these sites may result in the installation of social media cookies. Please note that social networks are responsible for the processing of personal data they perform using cookies. We have no control over the process used by social networks to collect information about your browsing on our site or the associated personal data to which they have access. These social networks apply their own privacy policy. For more information on the purpose and scope of the processing of personal data by a social network, your rights in this regard, and the privacy settings, please consult the privacy policy of the relevant third-party website or social network.

Deletion and Modification of cookies

You may at any time refuse cookies set by the website by deleting them. This can be done through the settings of your Internet browser. However, if your computer blocks all cookies, certain pages on this site may not work properly and certain services may be inaccessible.
In order to manage cookies in the way that best meets your needs, you can change your browser settings based on its configuration to control or prevent cookies from being stored :

• Internet Explorer™: Tools Menu > Internet Options > Privacy
(See http://windows.microsoft.com/en-us/windows-vista/Block-or-allow-cookies)
• Safari™: Safari Menu > Preferences > Privacy
(See http://support.apple.com/kb/PH17191?viewlocale=en_US)
• Chrome™: Chrome Menu (tools) > Settings > Show advanced settings > Privacy > Content settings > Cookies
(See https://support.google.com/chrome/answer/114662)
• Firefox™: Tools menu > Options > Privacy > History > Cookies
(See https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)
• Opera™: Preferences > Advanced > Cookies
(See http://help.opera.com/Windows/10.20/en/cookies.html)

More information on Cookies: On the CNIL website: http://www.cnil.fr/vos-droits/vos-traces/les-cookies/