Privacy policy

1. DEFINITION

When you use the Site, we may ask you to provide personal data about yourself.

“Personal data” means any data that identifies an individual, including your surname, first names, username, photograph, postal and email addresses, job title, telephone numbers, date of birth, Site transaction data, purchase details, bank card numbers, SIRET number, EU VAT number, IP address and any other information you choose to provide about yourself.

2. PURPOSE

This policy (hereinafter the “ Policy ”) informs you about the ways in which we collect your personal data, with the utmost respect for your rights.

When collecting and managing your personal data, we comply with French Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, as amended (the “French Data Protection Act”), and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to personal data processing and the free movement of such data (the “ GDPR ”).

3. IDENTITY OF THE DATA CONTROLLER

The controller of your personal data is the sole proprietorship Aurélien ALTARRIBA, trading as “ALTARRIBA”, located at 20 rue de Ratacas MAIL BOXES ETC - MBE BAL N°307, 11100 Narbonne, France, registered under number 931 214 118 (hereinafter “ We ”).

4. PURPOSES AND LEGAL BASES FOR PROCESSING

The legal bases for collecting your personal data are:

• collection necessary to perform the contract entered into when you use our services on the Site;
• legitimate interest when you voluntarily provide personal data during your visit, allowing us to respond more effectively to requests for information about our services.

Your personal data is collected for one or more of the following purposes:

• Managing your access to and use of certain services available on the Site;
• Managing customer operations relating to contracts, invoices and customer relationships;
• Creating a database of users, customers and prospects;
• Sending newsletters, solicitations and promotional messages. If you do not wish to receive these, you may indicate your refusal when your data is collected;
• Compiling commercial and service usage statistics;
• Organizing competitions, lotteries and promotional activities, excluding online gambling requiring authorization from the online gambling regulator;
• Managing people’s reviews of products, services or content;
• Managing unpaid invoices and any disputes concerning the use of our products and services;
• Personalizing responses to your information requests;
• Complying with our legal and regulatory obligations. When collecting personal data, we tell you whether it is mandatory or optional, using visible asterisks on the Site.

5. RECIPIENTS OF PERSONAL DATA

The following have access to your personal data:

• Our company’s personnel;
• Professional oversight services, including lawyers and accountants;
• Our processors: communication providers, productivity software providers, data hosting providers, payment service providers, invoicing providers, analytics and audience measurement providers, and customer relationship management providers;
• Your personal data may also be disclosed to public bodies solely to meet our legal obligations, legal officers, public officials and debt collection bodies.

6. PERSONAL DATA RETENTION PERIODS

6.1. Customer and prospect management data:

Your personal data will not be retained longer than strictly necessary to manage our commercial relationship with you.

However, data needed to establish proof of a right or contract and retained to meet a legal obligation will be kept for the period required by applicable law.

For potential marketing to customers, their data may be retained for three (3) years from the end of the commercial relationship.

Personal data about a prospect who is not a customer may be retained for three (3) years from collection or the prospect’s last contact.

At the end of this three-year period, we may contact you again to ask whether you wish to continue receiving commercial communications.

When the right of access or rectification is exercised, identification document data may be retained for the period specified in Article 9 of the French Code of Criminal Procedure, namely one (1) year. When the right to object is exercised, this data may be archived for the limitation period under Article 8 of that Code, namely six (6) years.

6.2. Marketing opt-out lists:

Information needed to honour your right to object is retained for at least three (3) years from the exercise of that right.

6.3. Audience measurement statistics:

Information stored on users’ devices, or any other elements used to identify users and track their activity or visits, will not be retained for more than thirteen (13) months.

7. SECURITY

We take all useful precautions and appropriate organizational and technical measures to preserve the security, integrity and confidentiality of your personal data, particularly to prevent alteration, damage or unauthorized access. We also use secure payment systems consistent with current industry practice and applicable regulations.

8. HOSTING

Throughout the retention period, your data is held and stored on the servers of:

• Infomaniak - 25 rue Eugène Marziano, 1227 Les Acacias, Switzerland - https://www.infomaniak.com/
• Abby - 223 avenue du Général Leclerc, 54000 Nancy, France - https://abby.fr/

9. TRANSFERS OUTSIDE THE EUROPEAN UNION

Your data may be transferred outside the European Union in connection with the tools we use and our relationships with processors.

These transfers are protected by one of the following mechanisms:

• The data is transferred to a country recognized by a European Commission decision as providing an adequate level of protection; or
• We have entered into a specific agreement with our processors governing transfers outside the European Union, based on the European Commission’s approved standard contractual clauses between controllers and processors.

10. ACCESS, RECTIFICATION, RESTRICTION AND ERASURE

Under European personal data protection regulations, you have the following rights:

• A right of access allowing you to find out whether we process your personal data and, if so, to access that data and the legally required information about how it is processed;
• A right to rectification allowing you to request prompt correction of inaccuracies in your personal data;
• A right to erasure allowing you to request prompt deletion of your personal data, subject to the conditions of applicable law;
• A right to restrict processing of your personal data, subject to the conditions of applicable law;
• A right to data portability allowing you to receive your personal data in a structured, commonly used, machine-readable format, or request its transmission to another controller, subject to applicable legal conditions;
• A right to object to processing on grounds relating to your particular situation, subject to the conditions of applicable law;
• A right to withdraw specific consent to personal data collection at any time, particularly where processing is used for commercial marketing;
• A right to define instructions concerning the retention, erasure and disclosure of your personal data after your death.

You may obtain restriction of processing in the cases defined in Article 18 of the GDPR:

• While we verify the accuracy of personal data that you dispute;
• Where processing is unlawful and you prefer restriction to erasure;
• Where we no longer need your personal data but you require it to exercise your rights;
• While legitimate grounds are being verified after you have objected to processing.

People whose data is collected on the basis of our legitimate interest may object to its processing at any time.

However, we may continue processing where compelling legitimate grounds override your rights and freedoms or where processing is necessary to establish, exercise or defend legal claims.

You can unsubscribe from promotional emails using the link provided in those emails. Even if you opt out of promotional messages, you will continue to receive administrative messages.

You may exercise your rights at any time by emailing dpo@altarriba.fr or writing to:

If you have complaints about the way we process your personal data, please contact us using the details above.

11. PORTABILITY OF YOUR PERSONAL DATA

You have a right to portability of the personal data you have provided to us. This covers data actively and knowingly supplied when accessing and using services, as well as data generated by your activity while using them, particularly security-related data.

This right does not cover data collected and processed on a legal basis other than consent or performance of the contract between us.

You may exercise this right free of charge at any time, particularly when closing your Site account, to retrieve and retain your personal data.

We will provide your personal data by any suitable means in an open, standard, commonly used, machine-readable format consistent with current industry practice.