Privacy policy | Baro Alto

Last update: May 2023

1. Subject

This privacy policy (hereinafter the «Privacy Policy ») illustrates the commitment of BARO ALTO, a Professional Limited Liability Company (PLLC) with a share capital of 1 000 €, registered in the Trade and Companies Register of Paris under the Number 808 755 409, VAT number : FR 01808755409 and whose head office is located at 8 place Vendôme in Paris (75001) (hereafter “BARO ALTO” to respect the privacy and protection of personal data of the following website : https://g-ops.com/ (hereinafter the «Website »).

The Website allows you:

to discover the team of BARO ALTO (associates, partners and employees), its activities and associated services;
to access the video resources, made available by BARO ALTO on the Website (guides in video format offered since 2014 by BARO ALTO via the “Baro Alto Academy” section);
to obtain information about training services offered by BARO ALTO (hereinafter the “Training service(s)” via the “Baro Alto Training” section);
to make one or more requests for quotes for the Trainings services;
to submit spontaneous applications to BARO ALTO.

2. Processing of your personal data

2.1. Description of the processing of your personal data

In accordance with applicable laws and regulations, BARO ALTO, acting as data controller, collects certain personal data from you when you visit the Website.

In order to respond to your spontaneous application(s), BARO ALTO, acting as a data controller, collects the following personal data:

Your first name;
Your last name;
Your e-mail address;
Your phone number;
Your CV;
Subject of your message.

In order to respond to your contact requests, BARO ALTO, acting as a data controller, collects the following personal data:

Your first name;
Your last name;
Your e-mail address;
Your phone number;
Subject of your message.

If you make a quote request for Training services, BARO ALTO, acting as a data controller, collects the following personal data:

Your first name;
Your last name;
Your e-mail address;
Your phone number;
Your company name;
Your job title;
Choice of the training you wish to follow; *
Subject of your message.

_{* Information marked with an asterisk is optional, and is not mandatory to submit the request.}

When you connect to the Website, BARO ALTO, acting as data controller, also collects the following personal data:

Connection logs ;
Connection data ;
IP address.

BARO ALTO uses your personal data for the following purposes :

Purpose	Legal basis	Retention period
Management and processing of spontaneous applications	The processing is based on pre-contractual measures and your consent	Immediate destruction of the file if you are not selected, and up to two years from the last contact with you if you have given your consent to BARO ALTO to keep your file
Receive and manage contact requests	The processing is based on your consent	Personal data is retained for a period of three years from the reception of the contact request or until withdrawal of your consent
Management and processing of the request for a free quote (Training services)	The processing is based on pre-contractual measures and your consent	Personal data is retained for a period of one year from the last contact with you
Management of requests for rights of access, portability, erasure, restriction of processing, rectification and opposition	The processing is necessary to respond to your requests to exercise your rights and is based on your consent	Personal data shall be retained for the duration of one year from the date of your request to exercise your right(s)
Management of requests for the right to object to commercial prospecting	The processing is necessary to respond to the request to exercise the right to object	Personal data shall be retained for the duration of three years from the time you exercise your right to object

2.2. Recipients / transfers of your personal data

Access to your personal data is restricted to only those persons who need your personal data in order to fulfil the specific purpose of the processing.

Your personal data may also be disclosed by BARO ALTO to third parties:

if the law or a legal procedure requires BARO ALTO to share your personal data;
in response to a request from a public or judicial authority (in particular in the event of a judicial requisition) ;
when BARO ALTO considers that the transmission of your personal data is necessary or appropriate to ensure the safety of individuals or to protect the public.

Your personal data are transferred to OVH (2 rue Kellermann, 59100, Roubaix) which hosts the Website on the servers located in France.

Your personal data is therefore not transferred outside the European Economic Area.

2.3. Security of Personal Data

BARO ALTO ensures the security of your personal data by implementing appropriate technical and organizational measures in order to guarantee a proper level of security and to implement means to guarantee the confidentiality, integrity, constant availability and resilience of the processing systems and services, restore availability and access to your personal data, as well as a procedure to regularly test, analyse and evaluate the effectiveness of the technical and organizational measures put in place by BARO ALTO.

2.4. Retention of your personal data

Your personal data should be retained only for the period required to fulfil the purpose for which BARO ALTO stores such data, to meet your needs, to fulfil its legal or regulatory obligations, to enable it to exercise its rights and/or for statistical or historical purposes.

At the end of the above-mentioned periods, your personal data will be deleted, or BARO ALTO will anonymize it.

2.5. Your rights regarding your personal data

You have the following rights regarding your personal data:

Right of access and rectification	You may request to access to your personal data. You may also request to modify the inaccurate personal data or incomplete data to be completed. Furthermore, you have the right to know the origin of your personal data.
Right to erasure	You may request the erasure of your personal data if : The data is no longer necessary for the purposes it was collected and processed;You have chosen to withdraw your consent (where consent has been collected as the legal basis for processing); this withdrawal does not impact the lawfulness of the processing before its implementation;You have objected to the treatment of your personal data;The data have been processed unlawfully ;The data should be deleted to comply with a legal obligation ; orSuch erasure is required to ensure the compliance with current legislation, in particular with regard to the retention periods applicable to the collected personal data.
Right to object	You may object to the processing of your personal data in accordance with the legal obligations imposed on BARO ALTO.
Right to restriction of processing	You may also request a restriction of processing of your Personal Data if: You contest the accuracy of such data;BARO ALTO no longer needs this data for processing purposes; andYou objected to the treatment of your personal data;
Right not to be subjected to a decision exclusively based on the basis of an automated data processing	You shall not be the subject to the decision based exclusively on automated processing that produces legal effects concerning you or significantly affects you, particularly based on profiling.
Right to portability	You may request that BARO ALTO provide you with your personal data in a structured, commonly used, machine-readable format, or request to transmit those data directly to another data controller as long as: The processing is based on your consent ; andIt is carried out by automated means.
Right to give directives on the processing of your personal data after your death	Pursuant to the Article 85 of French Data Protection Act of 6 January 1978 as amended, you can give directives on the exercise of your rights under this section after your death, (in particular on the duration of the retention of your personal data, its deletion and/or its communication) as well as designate a person responsible for the exercise of these rights. In the absence of such directives, BARO ALTO will grant the requests to your heirs, as set out in article 85(II) of the French Data Protection Act.
Right to withdraw your consent	You can withdraw your consent for the processing of your personal data at any time. The withdrawal of your consent only applies to the future processing and does not affect the lawfulness of any processing carried out by BARO ALTO based on your consent before your withdrawal or the lawfulness of any processing based on another legal basis, such as the execution of a contract between you and BARO ALTO.
Right to make a complaint to a supervisory authority	If you have any concerns or appeals regarding the protection of your personal data, you have the right to make a complaint to the Commission Nationale de l’Informatique et des Libertés via the following link : Plaintes en ligne \| CNIL The CNIL can also be contacted at the following address: 3 Place de Fontenoy, 75007 Paris – phone: 01 53 73 22 22. You are invited to inform BARO ALTO in advance so that BARO ALTO can process the request and attempt to find an amicable solution.

You may exercise your above-mentioned rights and/or ask any questions concerning the processing of your personal data by BARO ALTO using the following email address: dpo@baroalto.com or by post at the following address: Délégué à la Protection des Données Personnelles, Cabinet d’Avocats BARO ALTO, 8 place Vendôme, 75001, PARIS.

In order to process the request as quickly as possible, you may indicate in your request the purpose and the context in which your personal data was collected by BARO ALTO.

BARO ALTO may ask you to provide a copy of both sides valid identity document, if there is a reasonable doubt about your identity.

The latter will be deleted by BARO ALTO once your request has been granted.

BARO ALTO may retain a copy of your identification for the sole purpose of establishing proof in the event of a dispute with you.

2.6. Links to third party sites

In order to improve the quality of the Site, BARO ALTO may include on the Site links to third-party sites. These sites have a privacy policy that is different and independent from that of BARO ALTO. You are invited to consult the privacy policy of the third-party sites you visit.

2.7. Language

This Privacy Policy is written in English for informational purpose. Only the French version shall be deemed authentic in the event of a dispute.

2.8. Cookies

The provisions relating to the deposit of cookies on the Website are contained in the cookie policy available on the Website.

2.9. Modification of Privacy Policy

BARO ALTO reserves the right to make changes to this Privacy Policy at any time.

BARO ALTO recommends that you check this page regularly, referring to the date of the last modification.

In the event of a major change to the present Privacy Policy, BARO ALTO will notify you of such changes.