Terms of use

Definitions

Publisher: Alpera Partners SAS, owner of the website https://www.alperapartners.com

Content: All elements constituting the information available on the website, including but not limited to text, images, and videos.

Client Information: Hereinafter referred to as “Information,” meaning all personal data that may be held by the Publisher for account management, client relationship management, and analytical or statistical purposes.

User: Any Internet user accessing the above-mentioned website, thereby generating data potentially usable by the Publisher, subject to prior agreement or implicit consent.

Personal Information: “Any information which allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies” (Article 4 of French Law No. 78-17 of January 6, 1978). The terms “personal data,” “data subject,” “processor,” and “sensitive data” have the meaning set out in the General Data Protection Regulation (GDPR: No. 2016-679).

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1. General conditions of use of the website and services provided

The website https://www.alperapartners.com constitutes an intellectual work protected by the provisions of the French Intellectual Property Code and applicable international regulations. Users may not in any way reuse, transfer, or exploit for their own purposes any part of the elements or works featured on the website.

Use of the website implies full and unconditional acceptance of the terms of use described herein. These terms may be amended or supplemented at any time; Users are therefore encouraged to consult them regularly.

The website is normally accessible at all times to Users. However, interruptions for technical maintenance may be scheduled by the Publisher. Similarly, the legal notice may be amended at any time; such changes are binding on the User, who is invited to review them as often as possible to remain informed.

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2. Description of services provided

The website aims to provide information on all company activities. The Publisher strives to provide information that is as accurate as possible. However, it cannot be held liable for omissions, inaccuracies, or failures to update, whether of its own making or that of third-party partners providing such information. All information provided on the website is for indicative purposes only and may evolve. Furthermore, the information is not exhaustive and is subject to changes made since it was posted online.

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3. Technical data limitations

The website uses JavaScript technology. The Publisher cannot be held liable for any material damage resulting from the use of the website. In addition, the User agrees to access the website using up-to-date equipment, free from viruses, and with a modern, regularly updated browser.

The website https://www.alperapartners.com is hosted within the European Union in accordance with the provisions of the General Data Protection Regulation (GDPR: No. 2016-679).

The objective is to ensure the highest possible level of accessibility. The host ensures continuous service availability, 24/7, year-round. However, it reserves the right to suspend hosting services for the shortest possible duration, notably for maintenance, infrastructure upgrades, infrastructure failure, or in cases where traffic is deemed abnormal. Neither the Publisher nor the host can be held liable for Internet network malfunctions, telephone line issues, or computer/telephony equipment failures, particularly due to network congestion preventing access to the server.

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4. Intellectual property and infringement

Alpera Partners SAS owns all intellectual property rights and holds usage rights over all elements accessible on the website, including text, images, graphics, logos, videos, icons, and sounds. Any reproduction, representation, modification, publication, or adaptation of all or part of the elements on the website, regardless of the means or process used, is prohibited without prior written authorization from Alpera Partners SAS.

Any unauthorized use of the website or of any element contained therein shall be considered as constituting infringement and pursued in accordance with Articles L.335-2 et seq. of the French Intellectual Property Code.

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5. Limitation of liability

The Publisher cannot be held liable for direct or indirect damage to the User’s equipment resulting from access to the website, whether due to the use of non-compliant equipment, the occurrence of a bug, or incompatibility.

The Publisher also disclaims liability for indirect damages (e.g., loss of market share or business opportunity) resulting from the use of the website.

Interactive spaces (contact forms) are available to Users. The Publisher reserves the right to delete, without prior notice, any content submitted in this space that contravenes applicable French law, particularly data protection provisions. The Publisher may also hold the User civilly and/or criminally liable in cases of racist, abusive, defamatory, or pornographic messages, regardless of the medium used (text, photographs, etc.).

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6. Personal data management

Users are informed of applicable regulations regarding marketing communications, the French Law of June 21, 2014 on Confidence in the Digital Economy, the French Data Protection Act of August 6, 2004, and the General Data Protection Regulation (GDPR: No. 2016-679).

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6.1 Data controller

For personal data collected through online forms and website browsing, the data controller is: Mr. Michael Sidney Levy.

The publication director of https://www.alperapartners.com is Mr. Michael Sidney Levy.

As data controller, the Publisher undertakes to comply with applicable legal provisions. In particular, it is responsible for establishing the purposes of its data processing, providing its prospects and clients with full information on the processing of their personal data (based on their consent), and maintaining a record of processing activities that reflects reality. Whenever the Publisher processes personal data through the website, it takes all reasonable measures to ensure that the data is accurate and relevant for its intended purposes.

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6.2 Types, processing, and purposes of data collected

Alpera Partners SAS may process some or all of the following data, some of which are essential for the proper functioning of the online services offered on the website:

• Connection, navigation, and usage data
• Purpose: enable and/or improve website navigation; compile audience statistics.
• Identity and/or personal data (first name, last name) and contact details such as e-mail address, company, company URL
• Purpose: respond to inquiries, schedule appointments, provide call-backs, etc.
• Technical data on browsing equipment and IP address
• Purpose: secure communications to/from the website; prevent and combat IT fraud (spamming, hacking, etc.).

All data is retained for a maximum of 12 months after collection or the end of the contractual relationship between the User and the Publisher.

Alpera Partners SAS does not sell personal data. Data is used only when necessary for the purposes described above, and occasionally for global statistical analysis.

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6.3 Right of access, rectification, and objection

In accordance with European regulations, Users of https://www.alperapartners.com have the following rights:

• Right of access (Article 15 GDPR) and rectification (Article 16 GDPR), right to update, complete, block, or erase personal data (Article 17 GDPR) when inaccurate, incomplete, ambiguous, outdated, or unlawfully collected/processed.
• Right to withdraw consent at any time (Article 13-2c GDPR).
• Right to restriction of processing (Article 18 GDPR).
• Right to object to processing (Article 21 GDPR).
• Right to data portability (Article 20 GDPR) where processing is automated and based on consent or contract.
• Right to define instructions regarding post-mortem handling of data, including whether and to whom the Publisher may transfer the User’s data.

In the absence of instructions, and once aware of a User’s death, the Publisher undertakes to delete the User’s data unless retention is necessary for evidentiary purposes or to comply with a legal obligation.

Users wishing to know how their personal data is used, to request rectification, or to object to processing may contact the Data Protection Officer (DPO) by e-mail at: contact [at] otiumcapital [dot] com. The request must specify the data to be corrected, updated, or deleted and be accompanied by proof of identity (ID card or passport). Requests for deletion of data remain subject to legal obligations regarding record-keeping or archiving.

Users may also file a complaint with the relevant supervisory authority, in particular the French CNIL (https://www.cnil.fr/fr/plaintes).

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6.4 Non-disclosure of personal data

The Publisher undertakes not to transfer client data outside the European Union or to a country deemed “non-adequate” by the European Commission, without informing the client in advance. However, the Publisher remains free to choose its technical and commercial subcontractors provided they offer sufficient guarantees under GDPR requirements.

The Publisher takes all necessary precautions to safeguard data security and to ensure it is not disclosed to unauthorized persons. Should the Publisher become aware of an incident affecting the integrity or confidentiality of client data, it must inform the client as soon as possible and detail corrective measures taken.

No “sensitive data” is collected. User data may be processed by the Publisher’s subsidiaries or subcontractors (service providers), strictly for the purposes set out in this policy.

Access to User data is limited to the Publisher’s management, administrative, and commercial staff, within the scope of their responsibilities.

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7. Incident notification

Despite best efforts, no method of Internet transmission or electronic storage is completely secure. The Publisher cannot guarantee absolute security. In case of a security breach, the Publisher will notify affected Users so they can take appropriate measures. Notification procedures comply with legal obligations at both national and European levels.

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8. Security

To ensure the security and confidentiality of personal data, the Publisher and its hosting provider use secure networks with industry-standard measures such as firewalls, pseudonymization, encryption, and password protection. During processing, Alpera Partners SAS takes all reasonable measures to protect data against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

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9. Hyperlinks, cookies, and Internet tags

The website https://www.alperapartners.com may contain links to other websites. The Publisher has no control over the content of external sites and disclaims any liability in this respect.

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9.1 Cookies

A “cookie” is a small data file sent to the User’s browser and stored on the User’s device (computer, tablet, smartphone). It contains information such as the User’s domain name, Internet service provider, operating system, and time/date of access. Cookies cannot damage the User’s device.

The Publisher may process User information related to visits to the website, such as pages viewed and searches conducted, in order to improve site content and navigation.

Users can configure their browsers to decide whether or not to accept cookies, either systematically or depending on the issuer. They can also choose to be prompted before cookies are stored. If cookies are refused or deleted, some site functionalities may be limited.

Cookie management instructions for major browsers:

• Chrome
• Firefox
• Internet Explorer/Edge
• Safari (Mac)

The website uses Google Analytics, a service provided by Google Inc. (“Google”). Google Analytics uses cookies to help analyze website use and audience measurement. Data generated (including visitor IP addresses) may be transmitted and stored on servers in the United States. Google may share this data with third parties when legally required or acting on behalf of Google, including the Publisher.

By browsing the website, Users expressly consent to the processing of their data by Google for the purposes described above.

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9.2 Internet tags

The website may occasionally use Internet tags (also known as web beacons, action tags, single-pixel GIFs, clear GIFs, or invisible GIFs) through a web analytics partner that may store the related data (including IP addresses) abroad. These tags, placed in online ads or web pages, allow measurement of user response, site usage, and the effectiveness of marketing campaigns.

External partners may collect information through these tags, generate reports on site activity, and provide additional Internet-related services.

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10. Governing law and jurisdiction

Any dispute related to the use of the website shall be governed by French law. Unless otherwise provided by law, exclusive jurisdiction is granted to the competent courts of Paris, France.