PRIVACY POLICY

This version was uploaded January 2020

As data controller, Alerion is strongly committed to protecting your personal data (hereinafter referred to as "Personal Data" or "Data"), as defined by the General Data Protection Regulation (EU) 2016/679 and by the amended French Act No. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (hereinafter collectively referred to as "Regulations").

This Privacy Policy transparently outlines the manner in which Alerion collects, stores, uses and discloses your Personal Data when you visit the Website, accessible on https://www.alerionavocats.com/ (the "Website") and/or when you request services or information offered on the Website (in the “Services" section).

When appropriate, this Policy is supplemented by our General Terms and Conditions of Services, which are attached to Alerion's engagement letter, as well as by the required information provided in our Data Collection Forms.

By using the Website, you accept this Privacy Policy.

Personal Data You Provide

If you wish to benefit from the Services offered by Alerion on certain pages of the Website, Alerion is required to collect, directly or indirectly, the following Data which are strictly necessary to use the Services:

• “Candidate” form: last name, first name, e-mail, address, telephone number, any Personal Data communicated in your message, as well as a resume (CV) and, if applicable, a cover letter in a suitable format.

• “Contact us” form: Name, first name, mail, phone, cv, cover letter any Personal Data communicated in your message.

Warning: If you use the "Contact Us" form to send us requests, you must avoid sending confidential information. Given the fact that you are not an Alerion client, this information may not be covered by the attorney-client privilege and could be disclosed to third parties.

If such information is not provided, Alerion will not be able to perform the Services you have requested . However, it is not required to provide Personal Data to visit and navigate the Website.

In addition, when consulting the Website, Alerion may collect certain Data through cookies placed on your device. The terms and conditions of collection are provided in the provisions dedicated to Cookies.

Use and processing of your Data

Legal basis for the collection and processing of Data

In general, Alerion processes your Personal Data only on the basis of the following legal purposes:

• Processing that is necessary to perform the Services offered on its Website;

• Processing that is necessary for compliance with a legal or regulatory obligation;

• Processing that is necessary for the legitimate interests pursued by Alerion or by a third party, except where such interests are overridden by your own interests, freedoms and fundamental rights.

Purposes of Data Collection

The Personal Data we collect is necessary for the performance of the Services offered by Alerion on the Website and, more precisely, to achieve the following goals and purposes:

• management of the firm's communications;

• management of registrations for events organized by the firm;

• management of job applications

• processing of your requests via the Website ("Contact Us" form);

• improvement of the content and navigability of the Website.

Who Receives Your Data

The Data collected is intended for Alerion only. The recipients of the Data are Alerion employees authorized to process such Data due to the position they hold (persons in charge of communications, recruitment and Data Protection Officer) and/or lawyers receiving requests made via the Website and their teams.

The Personal Data collected may, however, be communicated to third parties contracted by Alerion, for the performance of subcontracted services and/or services necessary for the performance of the Services (e.g. service providers in charge of Alerion's external communications). Before any transfer of information, we verify whether the purpose of each request is compliant and guarantee the transfer of the information strictly necessary for the execution of the Services by the service provider.

To date, the identified service providers are:

• the Website’s webmaster;

• the host of the Website;

• MailChimp;

• Blowgun;

• Google Analytics (if access was accepted when requesting consent to cookies).

As such, it is specified that these third parties will only have limited access to the Data necessary for the performance of their services and will be required to use them in accordance with the provisions of the Regulations.

Alerion does not, under any circumstances, transfer, sell or lease the collected Data to third parties, whether it be for a fee or free of charge.

Furthermore, in cases where the law requires or authorizes it to do so, in particular because of a court decision or any other legal request or requirement, Alerion may disclose such Data to third parties.

Transfer of your Data

The Website is hosted on servers located in the European Union.

Alerion stores Personal Data on secure servers located in the European Union.

In the case where the collected Data is transferred to companies located in the United States or in countries that do not provide an adequate level of protection, Alerion commits to entering into agreements with the recipients concerned to ensure that the Personal Data transferred is adequately protected. In particular, these transfers may be governed by standard contractual clauses validated by the European Commission in accordance with the regulations in force.

Data storage

Alerion retains Personal Data for no longer than necessary for the performance of the Services and, more generally, for the aforementioned purposes for which it was collected, subject to Alerion’s legal obligations to retain specific data or to the legal boundaries for archiving and anonymizing data.

The necessary retention period of Personal Data is defined according to the quantity, nature and sensitivity of the Data, the potential risk of damage in the event of fraudulent use or disclosure, the purpose assigned to processing the Data, and whether it is possible to achieve this purpose by other means, as well as the applicable legal requirements.

You will find below an informative list of the time limits for storing the Data. For more information on how long your Personal Data is kept for a specific purpose, please contact us at the following address: privacy@alerionavocats.com.

Data Type :Data collected via the "Contact Us" form (last name, first name, e-mail address, telephone number, message)
Retention period :3 years starting from the date of the last contact (date your last request was sent) Data collected via the "Candidate

Data Type :form (last name, first name, e-mail address, telephone number, CV, cover letter, message)
Retention period :2 years starting from the date of the last contact with the candidate

At the end of the retention period, Alerion may archive the Personal Data necessary to exercise a right and to prove this right, within the applicable legal time limit at the end of which the Personal Data concerned are deleted.

Data Protection Officer

Alerion has appointed a Data Protection Officer (DPO), whose contact details are given below in the "Contact" section at the end of these terms.

Security measures

Alerion has implemented necessary measures to protect the Personal Data. Your Data is handled electronically and/or manually and in any case, in such a way that its security, protection and confidentiality are ensured with regard to its level of sensitivity, via administrative, technical and physical measures to prevent loss, theft, use, disclosure or unauthorized modifications.

“Electronic” Data is stored on a very restricted and limited access network located within the European Union, whose servers are secure.

“Paper” Data is stored in Alerion's secure premises or archived by an archiving service provider that complies with all the security and confidentiality guarantees necessary to protect Personal Data.

The DPO and Alerion staff (lawyers and employees) are subject to heightened security requirements and professional secrecy.

Your rights

According to Articles 15 to 22 of the General Data Protection Regulations of 27 April 2016, relating to the protection of individuals with regard to the processing of personal data and the free movement of such Data (2016/679) ("GDPR"), any data subject providing evidence of his/her identity has a right of access, rectification, opposition, portability of his/her personal data and to obtain restriction of processing as well as to decide of the fate of such data after death. These rights can be exercised by contacting Alerion, 137, rue de l'Université, 75007 PARIS (FRANCE) or privacy@alerionavocats.com

Anyone whose Personal Data has been collected by Alerion has the possibility to contact the French Data Protection Authority (“CNIL”) (whose contact details can be found at https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil) if Alerion has not answered the request within one month. Once the person has been informed that we received his/her request, this period may be extended to two months, depending on the complexity and the number of requests.

Similarly, if you no longer wish to receive communications from Alerion or if you wish your Data to be deleted, please send an e-mail to: privacy@alerionavocats.com .

Links to Third Party Websites

The Website may contain links to third party websites governed by their own privacy and cookie policies, terms of use and security measures which may differ from those of Alerion.

Alerion cannot be held liable for the content or practices of these websites. For this reason, it is recommended that you consult their privacy policy before sending them any information or Data about yourself.

Modification of the Terms of the Privacy Policy

This Protection Policy may change, in particular due to legislative and regulatory changes. If so, the changes made will take effect on the date indicated at the top of this document. Visiting our Website after that date implies that you agree with the current changes.

Alerion recommends reviewing the Privacy Policy each time you use the Website in order to be kept informed of the current privacy practices and means you can use to protect your personal information.

Contact Information

For any information related to this Privacy Policy, please contact Alerion at the following addresses

• Data Protection Officer: privacy@alerionavocats.com ;

• Data Controller: Alerion, 137 rue de l'Université, 75007 Paris, paris@alerionavocats.com .