Privacy & Terms

Last updated 12th April 2024

Personal data policy

April 12, 2024
1) Introduction

The purpose of this personal data policy (hereinafter the “Policy”) is to inform you about the personal data that we collect about you, the reasons for which we use it, and the people with whom we share it and the rights you have.

If you are an OPENSTONE customer, that is to say subscribed to our online service on our “apps” applications (Android or IOS), potential customer, or if you visit our website (Openstone), this Policy concerns you.

INNOVATIVE FINANCE manages data on behalf of the investment vehicles grouped under the name OPENSTONE and listed on this page. INNOVATIVE FINANCE acts as data controller in the processing of data.

2) Who are we ?


INNOVATIVE FINANCE is a company registered in the PARIS Trade and Companies Register under number 901 549 766 00011. INNOVATIVE FINANCE processes personal data on behalf of Investment Vehicle Companies whose commercial name is OPENSTONE.


3) What is a personal data?


Personal data is data that identifies you directly (for example, your first name, last name, email address) or indirectly (for example, your IP address, your IBAN or your user ID).

4) What personal data do we collect?


We may collect the following personal data about you:

  • Identity and contact data: last name, first name, email address, telephone number, postal address, marital status, financial situation
  • Connection and usage data: IP address, browser type, operating system, pages visited, connection dates and times, etc.
  • Payment data: information relating to your means of payment, such as your bank card number, expiration date and visual cryptogram, RIB;
  • Investments made

5) Why do we use your personal data?


The legal basis for processing your information is the performance of the contract you enter into with OPENSTONE when you create an account, and our legitimate interest when we contact you by email for commercial reasons and respond to your inquiries regarding our products and services.

We use your personal data for the following purposes:

  • Manage your registration to our website or applications
  • Provide you with the services you have requested
  • Improve and personalize your user experience
  • Send you marketing and advertising communications 
  • Carry out statistical analysis
  • Comply with our legal obligations
6) Who do we share your personal data with?


We may share your personal data with our service providers: we may use service providers to help us provide the services you have requested, such as hosting providers, payment service providers, software analysis and marketing.

Data may be transferred to countries outside the European Union which guarantee an adequate level of protection.

Provider Aim/Object
Amazon AWS Storage of datas
Forest Admin Back-office management
Heroku Server management
Yousign Signature of subscription contracts
MailChimp Management of marketing and communication emails
Sinch SMS Send transactional text message
Firebase Tool allowing tracking of analytics of mobile app
HotJar Tool allowing tracking and interaction with users to enhance the client experience
Google Analytics Tool allowing tracking analytics
HubSpot CRM (Customer relationship management)
Intercom Communication with users on the website or the app
Google Drive Internal collaborative platform

Public authorities: we may disclose your personal data to public authorities if the law requires us to do so or if we believe it is necessary to protect our rights or the rights of others.

7) How long do we keep your personal data?

We retain your personal data for the period necessary to fulfill the purposes for which we collected it, and then for an additional period to comply with our legal obligations.

The data necessary for subscribing to our services will be kept for the duration of the commercial relationship, and up to 10 years after the end of your contract, in compliance with OPENSTONE's financial obligations. 

Unless you unsubscribe using the link available at the end of the emails you receive, the data that is necessary for us to send you advertising emails and respond to your requests will be kept throughout the commercial relationship, and/or for 3 years from the last contact.

8) What are your rights ?

You have the following rights regarding your personal data:

  • Right of access: you have the right to obtain a copy of your personal data and information about how we process it.
  • Right of rectification: you have the right to request the rectification of your personal data if they are inaccurate or incomplete.
  • Right to deletendatas: You have the right to request the deletion of your personal data in certain cases, for example if it is no longer necessary for the purposes for which we collected it.
  • Right to restriction of processing: you have the right to request restriction of the processing of your personal data in certain cases, for example if you contest its accuracy.
  • Right to object to processing: You have the right to object to the processing of your personal data in certain cases, for example if you receive marketing communications from us.
  • Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller

9) How to exercise your rights?

To exercise your rights, you can contact us by email at welcome@openstone.com or by post to the following address:

Innovative Finance SAS

6 rue d’Armaillé 75017 Paris

10) Contact

If you have any questions about this Policy, you can contact us by email at welcome@openstone.com or by postal mail at the following address:

Innovative Finance SAS

6 rue d’Armaillé 75017 Paris

11) Claims

If you believe, after contacting us, that your rights over your data have not been respected, you can file a complaint with the personal data protection authority in your country.

12) Modification of the Policy

We may modify this Policy at any time.

1 . Introduction

1.1 By checking the corresponding checkbox on the Openstone platform available at https://www.openstone.com or any of its subdomains (the “Platform”) when creating an account, you are accepting these Terms of Service and thus agreeing that you will abide by these Terms of Service and any other terms displayed on the Platform (collectively, the “Agreement”).  The Agreement is between Openstone, a brand of Innovative Finance SAS (“we”, “our” or “Openstone”) and  (a) you on your own behalf as an individual, and (b) the entity on whose behalf you are accessing and using the Platform and Services (as hereafter defined), whether as an employee, associated person, independent contractor, agent, or in a similar representative capacity ((a) and (b), collectively “you” and “yourself”), and governs your access to and use of the Platform and the services and applications offered by Openstone thereon (collectively, the “Services”).  Openstone provides investment brokerage and permits qualified individuals to invest in private equity funds via the Platform.

OPENSTONE HAS THE RIGHT TO CHANGE THE PLATFORM, THE SERVICES AND/OR THIS AGREEMENT AT ANY TIME WITHOUT PRIOR NOTICE, WHETHER AS A RESULT OF CHANGES IN LAW, RULE, REGULATION OR POLICY OR OTHERWISE.  THEREFORE, EACH TIME YOU ACCESS OR USE THE PLATFORM OR THE SERVICES, YOU SHOULD VISIT AND REVIEW THE THEN-CURRENT AGREEMENT.  YOUR CONTINUED ACCESS AND/OR USE OF THE PLATFORM AND/OR THE SERVICES CONSTITUTES ACCEPTANCE OF SUCH CHANGES.

1.2 Capitalized terms used herein are defined in Section 12 (Definitions) of these Terms of Service.

2. General Securities Laws Principles

2.1 The laws applicable to alternative investments are complicated and occasionally ambiguous.  In general, they are designed to protect unsophisticated investors from making poor investment decisions.  You qualify to invest with Openstone if you meet certain criteria based on the fit questionnaire we ask you to fill-up.

2.2 Due to the nature of the funds we offer, Openstone investments are available exclusively for investors that qualify based on applicable national securities laws and regulations governing these types of securities transactions that must be observed.

2.3 You must make your own assessment regarding regulatory requirements as may be applied to your activities on the Platform.

3. User Obligations

3.1 To Act Responsibly.  You are undertaking to act responsibly – which means that, by entering into this Agreement with us, you are undertaking the following:

3.2 Requirements to Use the Services.

(a) That you have the right, power, authority, and capacity to enter into this Agreement on your own behalf or on behalf of any entity for whom you are acting and to abide by all of the terms and conditions contained herein, and that if any aspect of your use of the Services violates provisions of applicable laws, rules or regulations to which you are subject, you will promptly cease use of the Services and close your account;

(b) That you will not use a false name or use an email address owned or controlled by another person in connection with your use of the Services;

(c) That you are solely responsible for maintaining the confidentiality of your password;

(d) That you will update your registration information with Openstone as needed so that it remains true, correct and complete;

(e) That during the registration process on the Platform you agree to be bound by the terms and conditions of the Non-Disclosure Agreement, displayed on the Platform, by checking the corresponding box.

3.3 Requirements Related to Investments.

(a) That you will only invest in a Openstone fund or other financial product offered through the Platform after carefully reviewing and assessing the terms of the investment, including the related private placement memorandum, subscription agreement and organizational documents as well as all other related information and materials provided through the Platform;

(b) That you will use your own judgment before making any decision to invest;

(c) That you will obtain such professional advice as is appropriate to protect your interests, including legal, tax, accounting and other advice (i.e., consult with an attorney); and

(d) That you have reviewed and understand the discussion of risks made available with the investment documentation on the Platform, and that you are otherwise aware of the risks of making alternative investments.

3.4 General Requirements.  In addition, you are undertaking not to:

(a) Violate this Agreement or any law, rule or regulation;

(b) Trick, defraud, deceive or mislead Openstone, such as by disguising the source of materials or other information you submit to the Services or using tools which anonymize your Internet protocol address to access the Services;

(c) Interfere with or disrupt (or attempt to interfere with or disrupt) access and enjoyment of the Platform or Services of other users or any host or network;

(d) Disparage, tarnish or otherwise harm Openstone, the Platform and/or the Services;

(e) Upload or transmit (or attempt to upload or transmit) to the Platform and/or the Services (i) any material that acts as a passive or active information collection or transmission mechanism, or (ii) any computer code designed to disable, disrupt, distort, harm or otherwise impede, in any manner (including aesthetically), the use or operation of any technology and/or to corrupt any data, including viruses, worms, Trojan horses, spyware, adware ransomware or any other malicious or invasive computer code;

(f) Reverse engineer, alter, modify, decompile, reverse assemble, disassemble, modify or attempt to discover, derive or copy or create any derivative works of any software, source code, structure, methods of, models or data with respect to the Platform or the Services, including all trade secrets therein;

(g) Access or search (or attempt to access or search) the Platform or Services by any means, such as any automated system or unauthorized script or software, other than currently available, published interfaces provide by Openstone, unless you have been specifically allowed to do so in a separate agreement with Openstone; for the avoidance of doubt, scraping the Platform or Services is expressly prohibited without the prior written consent of Openstone;

(h) Remove, obscure or change any copyright, trademark, logo, notices, instructions, warnings, labels, hyperlink or other proprietary rights notices contained in or on the Platform or Services or on any third party website and/or Openstone software on which Openstone code is embeddable or embedded on;

(i) Remove, obscure or change any notice, banner, advertisement or other branding on the Platform or the Services;

(j) Interfere with or circumvent any security feature of the Platform or the Services or any feature that restricts or enforces limitations on use of or access to the Platform or Services, such as probing or scanning the vulnerability of any system, network or breach;

(k) Make any false or fraudulent representations to Openstone in order to gain access to the Platform or Services;

(l) Distribute or cause the distribution of Sensitive Information;

(m) Sell access to the Platform or the Services or any part thereof other than through a mechanism approved by Openstone in writing;

(n) Expect Openstone to provide investment advice or recommend any investment;

(o) Treat any Content, email or other information you receive as a result of your access to or use of the Platform or the Services as a recommendation or representation of any kind by Openstone, any affiliate of Openstone or any employee, officer, director, representative or other agent of any of the foregoing (each a “Company Person”) on which you should rely unless such information has been expressly identified as created by a Company Person;

(p) Claim any ownership right in any material, software or intellectual property displayed on, published by or otherwise available through the Platform, including Content (other than Your Content);

(q) Copy or distribute Content (excluding Your Content) except as specifically allowed in this Agreement;

(r) Use any Content, or other information acquired from Company Persons, investors, or otherwise through your access to or use of the Platform or Services, for commercial or investment activity outside of the Services, without prior written approval from Openstone;

(s) Claim any right to access, view or alter any source code or object code of Openstone;

(t) Use the Platform to market services, particularly investment advisory services that might cause Openstone to have to register as an investment adviser with a local regulator; or

(u) Market competing services to persons you have identified through Openstone.

3.5 Openstone Employees and Affiliates.  You understand that Company Persons may participate in the Services as investors, and that Openstone is not responsible for any of their activities, including statements or other information in any emails or other communications such individuals make in that capacity.

3.6 Confidentiality.  By registering with Openstone, or otherwise using the Platform or the Services or viewing Content made available through the Platform or the Services in any way, you may be exposed to Sensitive Information.  You shall maintain Sensitive Information in confidence. You may not distribute or republish, or permit or cause any third party to distribute or republish, any information you acquire through the Platform or the Services via an Internet website or otherwise, including Sensitive Information.  You may not use Sensitive Information for any reason other than your evaluation of a particular investment opportunity unless approved in advance in writing by Openstone.

3.7 Other User Obligations.

3.8 This Agreement does not entitle you to any support, upgrades, updates, add-ons, patches, enhancements, or fixes for the Platform or the Services (collectively, “Updates”).  Openstone, however, may occasionally provide automatic Updates to the Platform or the Services at its sole discretion (and without any advanced notification to you).  Any such Updates for the Platform or the Services shall become part of the Platform or the Services, as applicable, and subject to this Agreement.

4. Privacy and Protection of Personal Information

4.1 Privacy Notice.  Openstone values your privacy.  Please review our Privacy Notice to learn more about how we collect and use information about you via the Services.  The Privacy Notice explains how Openstone processes your personal information and protects your privacy when you access Openstone and use the Services.

4.2 Amendments to the Privacy Notice.  We may amend the Privacy Notice at any time in our sole discretion, effective upon posting the amended Privacy Notice at the domain of https://www.openstone.com/privacy-terms/ where the prior version of the Privacy Notice was posted, or by communicating these changes through any written or other contact method we have established with you.  Your use of the Platform or the Services following the date on which such amended Privacy Notice is published will constitute consent to such amendments to the extent they do not have retroactive applicability.

5. Ownership of Platform, Services and Content; Investor Questionnaire

5.1 All rights, title, and interests in and to the Platform, the Services and Content (other than Your Content) is and will remain the exclusive property of Openstone and its licensors.  The Platform, the Services and Content are protected by copyright, trademark, and other laws of both the European Union as well as those of other countries.  Except as expressly provided herein, nothing in this Agreement gives you a right to use the Openstone name or any of the Openstone trademarks, logos, domain names or other distinctive brand features.

5.2 Execution of the “Investor Questionnaire”.  In accordance with applicable regulatory requirements, Openstone requires all new investors to undergo an appropriateness assessment either by way of completing an investor questionnaire on the Platform or participating in an appropriateness assessment process via a distribution partner, as applicable, both of which are designed to separate investors qualified to invest in Openstone funds or other financial products offered through the Platform from those that are not.  Openstone and any distribution partner in this process rely on representations made by investors or distribution partners, as applicable.

6. Reservation of the Company’s Rights

• 6.1 Right to Control Content.  Any Content on the Platform (including Your Content) may be deleted by Openstone at any time without notice to you.

• 6.2 Right to Terminate User Access.  Openstone reserves the right to terminate your access to and use of the Platform and the Services without notice and, if you violate this Agreement, to pursue other remedies at law or in equity, provided that Openstone shall in such a case provide to a user who has invested in a fund or other financial product offered on the Platform all investor information that is required under applicable law via a durable medium.

• 6.3 Right to Refuse or Cancel Registration.  Openstone may refuse registration of or cancel your user account in its discretion for any reason or for no reason.  In addition, Openstone reserves the right at all times (but will not have an obligation) to remove or refuse to transmit, communicate or distribute any Content with respect to the Services and to terminate users and/or reclaim usernames.

• 6.4 Openstone also reserves the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (a) satisfy any applicable law, rule, regulation, legal process or governmental request, (b) enforce this Agreement (including investigation of potential violations hereof),  (c) detect, prevent or otherwise address fraud, security or technical issues, (d) respond to user support requests, and/or  (e) protect the rights, property or safety of Openstone, its users and the public.

7. Scope of Openstone’s Obligations

• 7.1 Introductions.  We are not obligated to introduce you to anyone connected to Openstone feeder funds or other financial products offered on the Platform, including fund managers, fund analysts, or other investors.

• 7.2 No Recommendations.  We do not guarantee the accuracy of information provided by funds, their managers or other financial products offered on the Platform or otherwise.  

• 7.3 Verifying Advertisement Accuracy.  The Services may contain or deliver advertising and sponsorships.  Advertisers and sponsors are responsible for ensuring that material submitted for inclusion is accurate and complies with applicable laws, rules and regulations.  We are not responsible for any such compliance or any error, inaccuracy or problem in any advertiser’s or sponsor’s Content.

8. Term and Termination

• 8.1 Unless terminated by Openstone, this Agreement will remain in full force and effect while you access or use the Platform or any of the Services.

• 8.2 You may terminate this Agreement at any time by requesting Openstone to delete your account by contacting bonjour@openstone.com.  Openstone may terminate this Agreement at any time, particularly if you are suspected of violating any provision of this Agreement.

• 8.3 Upon termination of this Agreement for any reason, you shall destroy and remove from all computers, and other storage media all copies of any intellectual property owned by Openstone or any other user of the Services that you acquired via use of the Platform or the Services.  Additionally, any provision which by their nature should survive the termination of this Agreement shall survive termination, including, without limitation, Sections the following provisions shall survive any termination of this Agreement:  Sections 3.4(d), 3.4(u), 3.6, 4, 5.1, 6, 7, 8.3, 9, 10, and 11.

9. Disclaimers, Limitations, Waivers of Liability

• 9.1 In case of willful misconduct, Openstone shall be liable according to the statutory provisions of applicable law.

• 9.2 In case of gross negligence, Openstone shall be liable according to the statutory provisions of applicable law.

• 9.3 In case of ordinary negligence, Openstone shall – provided that the standard of liability is not limited according to statutory provisions of applicable law (such as any limitation to the duty of care observed in own affairs) – only be liable for breach of material contractual obligations (material contractual obligations are obligations the breach of which endangers the purpose of the agreement and the fulfilment of which the investor generally relies and may reasonably rely on); in this case Openstone’s liability shall be limited to the typical damages that were reasonably foreseeable.

• 9.4 The aforementioned limitations of Section 9.3 do not apply to damages resulting from injury to life, body or health and the assumption of a guarantee for the condition of goods and/or work or fraudulent concealment of defects by Openstone.

• 9.5 The aforementioned limitations of liability shall, subject to the provisions of Section 9.4(a), apply to  any liability claims for whatever legal reason but in particular due to impossibility, default, defective or incorrect delivery, breach of contract, breach of obligations in contractual negotiations and tort, as far as such claims are subject to fault, and (b) any breach of duty by vicarious agents or any other person for whose conduct Openstone can be held liable according to the statutory provisions of applicable law.

• 9.6 Openstone is not responsible for any technical malfunction or other problems of any telephone, network or service, computer systems, servers or providers, computer or mobile phone equipment, software, failure of email or media players on account of technical problems or traffic congestion on the Internet or at any website or combination thereof, including injury or damage to your or to any other person’s computer, mobile phone or other hardware or software, related to or resulting from using or downloading materials in connection with the web and/or in connection with the Platform or the Services, including any mobile software.  Under no circumstances will Openstone be responsible for any loss or damage, including any loss or damage to any Content or personal injury or death, resulting from anyone’s use of the Platform, the Services, any Content or third party applications, software or Content posted on or through the Platform or the Services or transmitted to users or any interactions between users of the Platform or the Services, whether online or offline.

• 9.7 We make no warranty and disclaim all responsibility and liability for the completeness, accuracy, availability, timeliness, security or reliability of the Platform, the Services or any Content thereon or any Content you receive as a result of your relationship with Openstone.  Openstone will not be responsible or liable for any harm to your computer system, loss of data or other harm that results from your access to or use of, or inability to access or use, the Platform or the Services or any Content.  Openstone has no responsibility or liability for the deletion of, or the failure to store, transmit or distribute any Content and other communications maintained by the Services.  We make no warranty that the Services will meet your requirements or be available on an uninterrupted, secure or errorfree basis.  No advice or information, whether oral or written, obtained from Openstone or through the Platform or the Services, will create any warranty not expressly made herein.  The Platform, the Services and Content are provided on an AS-IS, WHERE IS, AS AVAILABLE basis at your sole risk.

10. Indemnification

• You will defend, indemnify and hold Openstone and its affiliates harmless from and against any and all suits, claims, losses, liabilities, damages, judgments, costs and expenses (including attorneys' fees) arising from your (a) use of or access to, or inability to use or access, the Platform, any Content or any Services, (b) violation of any of the terms of this Agreement, and/or (c) Your Content.

Openstone, a brand of Innovative Finance SAS

5 Parv. Alan Turing, 75013 Paris - France

Email: bonjour@openstone.com

Website: www.openstone.com

Management Board: Yazid Aksas, Nadim Takchi

Registered in the Commercial Register at: Paris, France

Journalistically and editorially responsible person : Nadim Takchi, CEO

Notice on dispute resolution:

Pursuant to our obligation to inform you under the Regulation No 524/2013 on Online Dispute Resolution for consumer disputes, you may access the platform of the EU Commission regarding online dispute resolution under the following link https://ec.europa.eu/consumers/odr/

Performance Not Guaranteed

Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections are not guaranteed and may not reflect actual future performance. Your capital is at risk.

Risk of Loss

Investments offered by Openstone involve a high degree of risk and may result in partial or total loss of your investment. Alternative investments are complex, speculative investment vehicles and are not suitable for all investors. Openstone products are restricted to investors who have filled the appropriateness questionnaire on the platform.

Illiquid Investments

Investments offered by Openstone are illiquid and there is no guarantee that you will be able to exit your investments early. Additionally, investors will typically receive illiquid and/or restricted membership interests that may be subject to holding period requirements and/or liquidity concerns. In the most sensible investment strategy for private equity investing, private equity should only be part of your overall investment portfolio. Further, the private equity portion of your portfolio may include a balanced portfolio of different private equity funds. Investments in private equity are highly illiquid and those investors who cannot hold an investment for the long term (at least 10 years) should not invest.

Risk Summary

Due to the potential for losses, this type of investment can be very complex and high risk.

What are the key risks?

1. You could lose all the money you invest

• If the business offering this investment fails, there is a high risk that you will lose all your money.

• Advertised rates of return aren’t guaranteed. This is not a savings account. If the issuer doesn’t pay you back as agreed, you could earn less money than expected or nothing at all. A higher advertised rate of return means a higher risk of losing your money. If it looks too good to be true, it probably is.

2. You are unlikely to be protected if something goes wrong

The compensation schemes, in relation to claims against failed regulated firms, does not cover investments in unregulated collective investment schemes. You may be able to claim if you received regulated advice to invest in one, and the adviser has since failed.

3. You are unlikely to get your money back quickly

• You are unlikely to be able to cash in your investment early by selling your investment. In the rare circumstances where it is possible to sell your investment in a ‘secondary market’, you may not find a buyer at the price you are willing to sell.

• You may have to pay exit fees or additional charges to take any money out of your investment early.

4. This is a complex investment

• This kind of investment has a complex structure based on other risky investments, which makes it difficult for the investor to know where their money is going.

• This makes it difficult to predict how risky the investment is, but it will most likely be high.

• You may wish to get financial advice before deciding to invest.

5. Don’t put all your eggs in one basket

• Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.

• A good rule of thumb is not to invest more than 10% of your money in high-risk investments.

No Investment Recommendations

Openstone does not make investment recommendations and no communication, through this website or in any other medium should be construed as a recommendation for any security offered on or off this investment platform. No material provided by Openstone is intended to address the financial objectives, situation or specific needs of any individual investor. Alternative investments in private placements, and private equity investments via feeder funds in particular, are speculative and involve a high degree of risk and those investors who cannot afford to lose their entire investment should not invest. Prospective investors should carefully consider the risk warnings and disclosures for the respective fund or investment vehicle set out therein. Information provided by Openstone is subject to change, may be incomplete, and has been obtained from sources believed to be reliable, but not guaranteed. Openstone assumes no liability for the information provided. The value of an investment may go down as well as up and investors may not get back their money originally invested. Past performance is not necessarily a guide to future performance. An investment in a fund or investment vehicle is not the same as a deposit with a banking institution. Please refer to the respective fund documentation for details about potential risks, charges and expenses.