The website http://app.alto-international.com/ is operated by Alto Asia, a limited liability company
registered at the Hong Kong Companies Registry under the number 2305848, with its head office
located at 5F, 42, Wong Chuk Hang Road in Hong Kong SAR, 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 Asia and Alto-International
• 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 Asia. 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.
Finally, Alto Asia 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 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 as well as the
GDPR.
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
office@alto-asia.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.
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.
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 Asia’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.
Cookie Policy
1. What are cookies?
A cookie is a file containing a small amount of information which is stored on your computer or
mobile phone when you visit a website. This text file is saved by your web browser, subject to your
preferences, in a special place on your device each time you use an online service.
A cookie file allows the sender to identify the device onto which it has been saved for as long as it is
valid.
Cookies are saved for a period of 13 months.
2. How do we use cookies on our website?
Only the placer of a cookie can read or change the information contained in it.
The cookies used on our app allow us to ensure that our service runs smoothly.
This information is useful for:
• facilitating site navigation
• ensuring that the log in is recognized
2.1. Cookies we place on your device through our website
When you visit our site, we may, subject to your preferences, store a number of cookies on your
device which will allow us to recognise your browser for as long as they are valid.
The cookies that we place are used for the purposes described below and are subject to the
preferences expressed in your web browser settings at the time of your visit to our site.
The cookies that we place enable us to:
Facilitate and improve site navigation:
• by accommodating your device’s display preferences (language, display resolution,
operating system etc.)at the time of your visit, as well as by adapting to your particular
hardware and viewing or visualisation software.
• by putting various security measures in place.
2.2. Cookies placed on your device by site analytics companies
How cookies are placed and used by third parties is governed by the third parties’ own privacy
protection policies. We will inform you of the existence of the cookies that we are aware of and the
ways in which you can make choices about these cookies.
3. Your cookie management options
You have several options for managing your cookies. Any changes to your settings are likely to alter
your experience of our website (and your internet navigation more generally), as well as your ability
to access certain specific services. You can at any moment express or alter your cookie preferences
in the ways described below.
You can configure your web browser settings so that cookies will be saved or, alternatively, rejected
by your device either systematically or according to their sender. You can also configure your web
browser to accept or reject cookies immediately, before the cookie can be saved on your device. For
more information, please see the “How to change your browser’s cookie settings” section below.
1. Accepting cookies
In order to place cookies on a device, the device’s user must agree to accept them. This acceptance
can be expressed or altered at any time, free of charge, via the user’s browser settings. If you have
set your browser to allow cookies to be saved on your device, the cookies on the webpages and
content that you view may be stored temporarily in a special space on your device. They will then be
accessible only by whoever placed them.
1. Rejecting cookies
If you do not allow cookies to be saved on your device, or if you delete any that may already be
saved there, you will no longer be able to benefit from a number of functions necessary for
accessing certain areas of our site. This will be the case if you try to access any of our content or
services that require you to sign in. The same will be true when we – or our partners – do not
recognise your device’s browser, its language or display settings, or the country from which it is
connecting to the internet. In these circumstances, we cannot accept any responsibility for the poor
service functionality that may result from our inability to place or access the necessary cookies.
c.1 How to change your browser’s cookie settings
The process for changing your cookie settings is different in every browser. You will find a
description of your options and an explanation of how to configure your settings accordingly in your
browser’s Help menu.
• For Internet Explorer™: https://support.microsoft.com/fr-fr/help/17442/windows-internet-
explorer-delete-manage-cookies
• For Safari™: https://support.apple.com/fr-fr/HT201265
• For Chrome™: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
• For Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-
preferences?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies
• For Opera™: https://www.opera.com/help/tutorials/security/privacy/
• ..
c.2 Rejecting an analytics cookie
Analytics cookies are placed by Google.
You can reject Google analytics cookies by following this deactivation link
(www.google.com/analytics/learn/privacy.html), which saves in your browser a cookie whose sole
purpose is to deactivate all Google analytics cookies.
It is important to remember, however, that it is these analytics cookies that allow us to measure and
track our website traffic, the pages visited and interactions that take place there. Deactivating these
cookies will prevent us from being able to collect any data about your visits to our site, and will
therefore prevent us from suggesting editorial content that might have been adapted in light of that
data.