Personal Data Protection Policy

Last update 07/01/2021

ARTICLE 1 : Preamble

Within the framework of the use of its services and in particular of the services accessible on its Internet site, aloha-agence.com, in its capacity as data controller, is likely to collect and process personal data concerning you.

The purpose of this privacy policy is to explain to users of our services

• How their personal data is collected and processed.

• Personal data is any data that can identify a user. This includes the first and last name, the email address, the location of the user or his IP address;

• What are the rights of the users concerning these data;

• Who is responsible for processing the personal data collected and processed?

• To whom this data is transmitted;

• The site's policy regarding "cookies" files.

In this policy, references to "you" are to the individual whose personal information we collect, use and process.

aloha-agence.com is committed to protecting and respecting your privacy. This policy, together with our terms and conditions and our cookie policy and the documents referred to therein, set out the basis on which any personal data we collect from you or that you provide to us will be processed exclusively by us.

We will only use your personal data for the purposes and in the manner described below, which describe the steps we take to ensure that the processing of your personal data complies with the Data Protection Acts 1988 to 2018 and any subsequent data protection and privacy. Legislation (the "Acts"), European Union law, including the General Data Protection Regulation (EU) 2016/679 (the "GDPR") and any subsequent amendments (together the "Data Protection Legislation").

Under this policy, and unless we have entered into a different agreement with you, we will be what is known under the GDPR as the "controller" of the personal data you provide to us.

We take particular care and care to ensure that we collect and process such data in accordance with the regulations.

ARTICLE 2: General principles of data collection and processing

In accordance with the provisions of Article 5 of the European Regulation 2016/679, the collection and processing of data of the users of the site respect the following principles:

• Lawfulness, fairness and transparency: data may only be collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his/her data is being collected and for what purpose it is being collected;

• Purpose limitation: the collection and processing of data is carried out to meet one or more of the purposes set out in these general conditions of use;

• Minimisation of data: only the data necessary for the proper execution of the objectives pursued by the site are collected;

• Conservation of data reduced in time: the data is kept for a limited period, of which the user is informed. When this information cannot be communicated, the user is informed of the criteria used to determine the duration of conservation;

• Integrity and confidentiality of the data collected and processed: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

In order to be lawful, and in accordance with the requirements of Article 6 of the European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the conditions listed below:

• The user has expressly consented to the processing ;

• The processing is necessary for the proper performance of a contract;

• The processing is required by law;

• The processing is necessary for the protection of the vital interests of the data subject or of another natural person;

• Processing may be necessary for the performance of a task carried out in the public interest or in the exercise of official authority;

• The processing and collection of personal data is necessary for the purposes of the legitimate and private interests pursued by the controller or by a third party.

ARTICLE 3: The information we collect and its purposes

We collect and process the following data about you for the following purposes:

Information you provide to us:

We collect your personal data when you interact with us or when you use our Services. This personal data is collected during the following actions:

• When you create an account on our platform or change your account settings

• When you contact us directly by phone, email or message;

• When you sign in with your account on our site or use our programmatic interface (API).

The information you provide to us may include:

Identity data: your name, email address, phone number.

INFORMATION WE COLLECT ABOUT YOU

Information collected automatically. With respect to each of your visits to our Site and your use of Our Application, we will automatically collect the following information:

Technical Data: technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information , authentication information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, frequency of application use, and other performance data;

Usage Data: Information about your links that you wish to shorten, which includes the full Uniform Resource Locators (URLs) to be shortened and any phone numbers used to call us.

NO SPECIAL CATEGORIES OF PERSONAL DATA

We do not require or collect any personal data that is your sensitive personal data or any special category of personal data under the GDPR, unless you choose to provide us with that information.

Transmission of data to third parties

The data collected on the aloha-agence.com website may be communicated to its service providers in the context of the performance of all or part of the services.

This is the case when subscribing to an offer on the site (except for specific quotes or custom agreements). Transactions are processed and stored by our banking partner Crédit Mutuel, which keeps in its computer systems a proof of the transaction including the order form and the invoice as well as the means of payment for the renewal.

Finally, aloha-agence.com may be required to provide personal information to the French or foreign public authorities authorized.

The aloha-agence.com website is hosted by Monaco telecom, whose administrative headquarters are located at 4-6 avenue Albert II – 98000 MONACO

ARTICLE 4: Use of "Cookies" files

The site uses "cookies" techniques.

A "cookie" is a small file stored by the site on the user's hard disk, containing information about the user's browsing habits.

These files allow the site to process statistics and information about traffic, to facilitate browsing and to improve the service for the user's convenience.

For the use of "cookies" files involving the saving and analysis of personal data, the user's consent is necessarily requested.

This user consent is considered valid for a maximum period of 13 (thirteen) months. At the end of this period, the site will again request the user's permission to save "cookies" files on his or her hard drive.

Opposition of the user to the use of "cookies" files by the site

Users are informed that they may oppose the recording of these "cookies" files by configuring their browser software or by setting the confidentiality window on their first visit to the site.

For information, users can find the steps to follow to configure their browser software to oppose the recording of "cookies" files at the following addresses:

• Chrome : https://support.google.com/accounts/answer/61416?hl=fr

• Firefox: https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences

• Safari : http://www.apple.com/legal/privacy/fr-ww/

• Internet Explorer : https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

• Opera : http://www.opera.com/help/tutorials/security/cookies/

In the event that the user decides to deactivate the "cookies" files, he/she will be able to continue browsing the site. However, any malfunction of the site caused by this manipulation could not be considered as being due to the site editor.

Description of the "cookies" files used by the site

While browsing the site, the user is informed that third party "cookies" files may be recorded.

These are more specifically the following third parties: CréditMutuel (only during a transaction)

In addition, the site integrates social network buttons, allowing the user to share his activity on the site. Cookies from these social networks may be stored on the user's computer when he/she uses these features.

The user's attention is drawn to the fact that these sites have their own confidentiality policies and general conditions of use that may differ from the site. The site editor invites users to consult the privacy policies and general conditions of use of these sites.

ARTICLE 5: Rights of the user

In accordance with the regulations concerning the processing of personal data, the user has the rights listed below. In order for the data controller to comply with the user's request, the user is obliged to provide the data controller with his first and last name as well as his e-mail address. The data controller is obliged to respond to the user within a maximum of 30 (thirty) days.

Presentation of the user's rights regarding data collection and processing

Right of access, rectification and deletion

The user can access, update, modify or request the deletion of his or her personal data from his or her personal space.

The user can, at any time, delete his or her account and the personal data attached to it by sending an email to : contact@aloha-agence.com.

Right to limit and oppose the processing of data

The user has the right to request the limitation or to oppose the processing of his data by the site, without the site being able to refuse, unless it can demonstrate the existence of legitimate and compelling reasons, which can prevail over the interests and rights and freedoms of the user.

Right not to be subject to a decision based exclusively on an automated process

In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him, or significantly affects him in a similar way.

Right to determine the fate of data after death

The user is reminded that he/she can organize what should be the fate of his/her collected and processed data if he/she dies, in accordance with the law n°2016-1321 of 7 October 2016.

Right to have recourse to the competent supervisory authority

In the event that the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or, if he/she believes that one of the rights listed above is infringed, he/she is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent judge.

Personal data of minors

In accordance with the provisions of Article 8 of the European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data. If the user is a minor under the age of 15, the consent of a legal representative will be required in order for personal data to be collected and processed. The site editor reserves the right to verify by any means that the user is over 15 years of age, or that he/she has obtained the consent of a legal representative before browsing the site.

SECTION 6: What we do with your information

We will only use your personal information where permitted by law and in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

ARTICLE 7: Data controller

The data controller

The data controller is responsible for determining the purposes and means of processing personal data.

Obligations of the data controller

The data controller undertakes to protect the personal data collected, not to transmit them to third parties without the user's knowledge and to respect the purposes for which these data were collected.

The site has an SSL certificate to ensure that the information and data transfer through the site are secure.

An SSL certificate ("Secure Socket Layer" Certificate) is intended to secure the data exchanged between the user and the site.

In the event that the integrity, confidentiality or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means.

ARTICLE 8: Conditions for changing the privacy policy

This privacy policy can be consulted at any time at http://www.aloha-agence.com/uk/tos-en

. The site editor reserves the right to modify it in order to guarantee its conformity with the law in force.

Consequently, the user is invited to consult this privacy policy regularly in order to be informed of the latest changes that will be made.

The user is informed that this privacy policy was last updated on: 01/07/2021.