The website https://alto-international.com/ is operated by Alto International, a limited liability company with capital of €7,622.45, registered at the Paris Commercial and Companies Registry under the number 410 672 851, with its head office located at 99, rue du Faubourg Saint-Martin 75010 Paris, having the status of Data Controller or Joint Controller under current data protection legislation, including under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. WHAT KINDS OF PERSONAL DATA DO WE PROCESS?

The kind Personal Data we collect and process depends on the site services you use, as well as your browser preferences and device settings (especially those concerning cookies and other tracers). Data collected may include your first name and surname, title, email address, telephone number, professional information, message history, site preferences and connection log.

We allow you to share information about our services on the websites (both desktop and mobile versions and including all related apps) of various social media (Facebook, Twitter, etc.), in particular through “share” buttons. It is important to remember, however, that in order to access these social networks, you must accept, independently of your access through our site, these companies’ contractual conditions, including any provisions relating to GDPR compliance.

To find out more about the protection of your Personal Data on social media, we invite you to consult the relevant companies’ own privacy policies.

2. HOW DO WE COLLECT YOUR PERSONAL DATA?

The legal basis for our collection of Personal Data is your consent.

The legal basis for our processing of Personal Data for B2B marketing purposes is our legitimate interest.

3. WHY DO WE COLLECT YOUR PERSONAL DATA?

We collect your Personal Data in order to:

• Enable you to benefit from the services proposed by Alto International and our partners
• Remain in contact with you
• Enable you to take part in our events
• Enable us to put together our B2B marketing campaigns
• Enable us to manage and optimise client relations
• Enable us to send you information on our offers, news and events (via newsletters, invitations and other publications)
• Prepare statistics

All Personal Data required for Alto International to fulfil the above objectives will be marked with an asterisk on the various pages of our website. If you do not fill in these mandatory fields, Alto International will not be able to respond to your enquiry and/or provide the products or services requested.

4. TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA?

Your Personal Data is processed by Alto International. It will not be transferred or made accessible to any third party, except (i) to potential sub-contractors of Alto International (for example, providers of site hosting and maintenance, fraud detection services, etc.), solely for technical and logistical reasons; (ii) in case of company restructuring, including partial or total sale of assets, merger or demerger, takeover or acquisition, and any internal reorganisation more generally.

Your Personal Data may be used for the purposes of managing and optimising client relations as well as, unless otherwise directed by you, for the purpose of sending you information on Alto International’s offers, news and events, often as part of publicity-raising social media campaigns.

Your Personal Data may also be shared for marketing purposes, subject to your consent, with other companies within the Les Echos-Le Parisien Group and/or partner companies or associations of the Les Echos-Le Parisien Group. A full list of companies belonging to the Les Echos-Le Parisien Group can be found at www.lvmh.com.

Finally, Alto International may need to communicate your Personal Data to a third party if required to do so by law, pursuant to a regulatory provision or a judicial decision, or if doing so is necessary in order to protect or defend your data protection rights.

5. DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

Receivers of your Personal Data may be located outside France, including outside the European Economic Area (EEA). All Data transfers outside the EEA will be covered by appropriate data protection safeguards, primarily contractual guarantees, in accordance with applicable data protection legislation.

A copy of the safeguards put in place by Alto International will be made available upon request.

6. WHAT ARE YOUR RIGHTS?

Pursuant to current legislation, you have the right to access and to rectify your Personal Data, as well as the right to request its erasure, to object to or to limit its processing, and to secure its portability if appropriate.

You also have the right to object to the use of your Personal Data in compiling your client profile. In such cases, you will no longer be able to benefit from personalised offers or services.

You can exercise these rights in relation to Alto International directly by sending an email to aescande@alto-international.com. You may be asked to provide proof of identity.

Furthermore, you can at any moment request to stop receiving information about our offers, news or events by following the link provided at the bottom of every email that we send you. You can also contact us by telephone on 01 42 82 72 00 (without surcharge) Monday to Friday, 9.30am-12.30pm and 2pm-6pm, or by post at 99 rue du Faubourg Saint-Martin, 75010 Paris.

7. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Personal Data relating to your orders and subscriptions will be kept by Alto International for a period not exceeding the prescribed legal period, which is to say five (5) years from the end of the contractual relationship or event participation. At the end of this period, the Personal Data will either (i) be archived for accounting or evidentiary purposes for the remainder of the aforementioned prescribed legal period; or (ii) be destroyed if the relevant prescribed legal period has already expired.

Personal Data used for the purposes of sending out information about the Pelham Media Group’s offers, news and events will be kept for a period of three (3) years from the date on which it were collected or from the date of last contact with Alto International. Upon the expiry of this period, Alto International may re-establish contact with you in order to ascertain whether you would like to continue receiving information about our offers, news and events. We will then destroy your Data at the earliest possible opportunity upon receipt of your request to unsubscribe.

Finally, the connection log collected, subject to your agreement, as part of our website’s cookie and tracer system, will be conserved pursuant to applicable law for a period not exceeding thirteen (13) months. For more information, please see our Cookie Policy.

8. CONTACT INFORMATION FOR THE DATA PROTECTION OFFICER (DPO) AND THE RIGHT TO LODGE A COMPLAINT

If you have any questions about Alto International’s collection or processing of your Personal Data, you can contact Alto International’s Data Protection Officer by email at the following address: dpo@lesechos.fr

You also have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, regarding the manner in which Alto International collects and processes your Personal Data.