Welcome to Aluminary! The protection of your privacy and your personal data is taken very seriously and of utmost concern for Aluminary.
Aluminary works hard to earn and keep your trust. Therefore, Aluminary uses personal data solely to provide you with the Aluminary Services. Aluminary will never rent, sell, or otherwise provide personal data to any third party for advertising or for marketing purposes without your consent.
As a visitor to our mobile application, you expect a high level of quality not only from our platform, but also from the processing of your personal data. We are responsible for the handling of your data, which we process according to your wishes and the requirements of the French and EU data protection laws. Personal data is data that identifies you or makes you identifiable. We only process personal data if this is permitted by law or if you have given your prior consent.
The responsible body for the collection and processing of personal data is:
Aluminary 11 rue Pierre Mendes France 87350 Panazol France Email: email@example.com
If you have any questions about data protection or data security, please contact our data protection officer:
Marjo Jarvinen/Aluminary 11 rue Pierre Mendes France 87350 Panazol France Email: firstname.lastname@example.org
Our service providers include, for example, data centers, analysis service providers, and payment service providers. Our service providers are prohibited from processing your data for other purposes or for themselves. It is important to us that you can find out at any time from the following information which personal data is collected during your use of the Aluminary mobile application and how we process it afterwards.
The responsible authority regarding data protection is the French Data Protection Authority: Commission Nationale de l’Informatique et des Libertés (CNIL).
You have the following rights regarding the processing of personal data:
You have the right to object to the processing of your data at any time for reasons arising from your particular situation if the legal requirements are met. If you object to the processing of your data for advertising purposes or wish to revoke your consent, a short message to our data protection officer using this contact form or by post to Aluminary, 11 rue Pierre Mendes France, 87350 Panazol, France is sufficient at any time. Your data will then no longer be processed for the communication purposes covered by the objection or the revocation of consent. This does not affect the legality of the processing carried out until the objection or revocation. After your objection to the processing of your personal data for communication purposes or the revocation of your consent, we are obliged under data protection law in accordance with the requirements of the French data protection supervisory authorities to include the necessary data (name, address, e-mail address) in our internal communication blacklist and – only for this purpose – to permanently store (block) and use for comparison with our future communication files. (Art. 21 (3), Art.17 (3) (b), Art.6 (1) (c) GDPR). In this way, compliance with your communication objection or the revocation of your consent can be permanently ensured. If you have any questions about the processing of your personal data by us, we will of course be happy to provide you with information about the data concerning you at any time. Furthermore, you have a right to correction, deletion, restriction of processing, objection, and the right to data transfer if the legal requirements are met. In all these cases, please contact our data protection officer (see contact data under item 1) at the communication addresses listed there. Finally, you have the right to complain to a competent data protection supervisory authority.
Aluminary – as it is usual and necessary for internet pages to be used – processes so-called server log files when you visit our internet page. When our website is accessed, our web server records the domain name or the IP address of your computer, the file name, and the URL which was requested, as well as the http response code and, if applicable, the URL referring to our website (legal basis: Art. 6 (1) (b) GDPR). This procedure is technically necessary and customary to enable the use of our website. Here we are supported by our technical service providers, which we use as contract processors. The above-mentioned data is logged and used for the purpose of defence against illegal use or attempted attacks on our web server (Art. 6 (1) (f) GDPR). The data will be deleted after 60 days.
If you register for our mobile platform, we process the data provided for this purpose in order to provide you with the platform (legal basis: Art. 6 (1) (b) GDPR). The mandatory information requested during registration is a prerequisite for fulfilling the service. We require your date of birth as proof of age, as our offer is only aimed at persons who have reached the age of 18. We need your email address to send you a confirmation and notifications. Within the scope of registration and use of our service, the processing is necessary for the fulfilment of the contractual service such as the provision of the platform and payment processing. The contract with you is thus the legal basis for this processing (Art. 6 (1) (b) GDPR). We will also process your data to the extent required by law to fulfil our archiving and storage obligations in accordance with French commercial and tax law (Art. 6 (1) (c) GDPR). The provision of personal data and registration data is necessary for the conclusion of the contract. In addition, we use your data for direct advertising – i.e. to send you information about our services and campaigns (in accordance with Art. 6 (1) (f) GDPR) in order to win you as a customer (information in accordance with Art. 13 (1) (d) GDPR). You can object to the use of your data for communication purposes at any time under the above contact details. We will process your data within the scope of registration as long as you do not request deletion, unless there are contractual or legal reasons for not doing so.
If you order a service from us, it will be processed to fulfil the contractual service such as delivery and payment processing. The sales contract with you is the legal basis for this processing (Art. 6 (1) (b) GDPR). We will also process your data to the extent required by law to fulfil our archiving and storage obligations under French commercial and tax law (Art. 6 (1) (c) GDPR). In addition, we use your data for direct communication – i.e. to send you information about our products and campaigns (in accordance with Art. 6 (1) (f) GDPR) in order to keep you as a customer (information in accordance with Art. 13 (1) (d) GDPR). You can object to the use of your data for communication purposes at any time under the above-mentioned contact data. Further recipients of these data within the scope of the handling of the contract about the order are payment service providers (only payment data). The duration of the processing depends on the purpose of the fulfilment of the contract as well as the associated further legal requirements for storage and proof. We use the data for direct communications as long as you have not objected.
After successful registration with Aluminary, you may provide additional information about yourself (e.g. nationality, city of residence, professional background, interests). Providing additional information beyond what is required at registration is entirely optional and on a voluntarily basis but enables you to better use our services. Additionally, you can upload, publish, send, or display comments, photos, profiles, messages, notes, text, information, music, video, advertisements, listings, and other content (User Content) on or through Aluminary, or transmit to or share with other users accessing the Aluminary mobile application. You may also form relationships with other users, perform searches and queries, and form groups. Aluminary collects all the aforementioned information so that Aluminary can provide you with the services and offer personalized features. In most cases, Aluminary retains the information so that, for instance, you can return to view prior messages you have sent.
Any information and user content (except personal messages to other users) you have submitted to Aluminary or to others via our platform may be accessed by the owner of the alumni community (Alumni Relations team or a local Alumni Association) when they visit the Aluminary mobile application.
If you choose to invite other people to Aluminary to join the network, the names and email addresses of the invitees need to be entered. The names and email addresses of people that are invited will be used by Aluminary only to send your invitation email (including an optional personal message) and corresponding reminders. Aluminary stores this information to send the invitation email, to register a contact connection if your invitation is accepted, and to track the success of Aluminary referral program.
In the context of our platform we use the functions of the web analysis service Google Analytics. Provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. The Google Analytics cookie (legal basis Art. 6 (1) (f) GDPR) is stored because of our legitimate interest in analyzing user behavior in order to optimize our website and advertising. We are supported in this by Google as a contract processor. Google will use this information for the purpose of evaluating the user’s use of the website, compiling reports on website activity and providing other services to website operators relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.
IP Anonymization: The IP anonymization function is activated on our website. Your IP address will be shortened by Google within the European Union or in a contracting state of the Agreement on the European Economic Area before transmission to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. We ensure the adequacy of data transfer to the USA through the agreement of EU Standard Contractual Clauses with Google.
Data processing agreement: We have concluded an agreement with Google for data processing and fully implement the strict requirements of the French data protection authorities when using Google Analytics.
If you have any questions or requests, please do not hesitate to contact us. We process your data to answer your service requests (Art. 6 (1) (b, f) GDPR). The communication of email marked as mandatory data is necessary in order to process and answer your request. The voluntary provision of further data makes it easier for us to process your enquiry. We store the information from your inquiry after answering the inquiry generally for six years, if it concerns commercial or business emails (§ 257 Abs.4 HGB, Art. 6 (1) (c) GDPR).
With your explicit consent, which can be revoked at any time, we will inform you by email about our products and campaigns such as updates and events of our platform and/or about our various product newsletters (§ 7 Abs.2 Nr.3 UWG). We process your obligatory information when granting your consent in order to send you the information you have chosen and to address you personally (Art. 6 (1) (f) GDPR). In order to receive certain information, you must first register (see explanation under Registration). When obtaining your consent, we use the so-called double opt-in procedure online to prevent our email messages from being sent to email addresses of persons who have not requested or do not want them. Your IP address is also recorded and stored for documentation purposes in accordance with the specifications of the data protection supervisory authorities. (Art. 7 (1), Art. 6 (1) (c) GDPR). We store your data collected for communication purposes as long as the purpose exists or until we receive a revocation of your consent or your objection to the processing of your data for advertising purposes.
If we should change the purposes of the processing in the course of the time, we will inform you by an update of these references to the data protection in advance.
The specified storage periods may be extended accordingly if a longer statutory or contractual storage period exists in individual cases, in particular if the data are processed for different purposes.
If certain data fields are designated as mandatory fields and/or marked with an asterisk ( * ), the provision of this data is either required by law or contract, or we need this data for the conclusion of the contract, the desired service, or the stated purpose. Of course, you also have the right to specify the data in the mandatory fields at your discretion. Failure to provide this information may result in the contract not being fulfilled by us or the desired service not being provided, or the stated purpose not being achieved.
The payment and bank information that is stored or entered within the framework of an order is processed for the purpose of payment processing, so we can provide our contractual service to you (legal basis: Art. 6 (1) (b) GDPR). Furthermore, we use companies as contract processors in order to be able to offer our customers payment methods customary in the market. These include Amex, Visa, PayPal (Art. 6 (1) (f) GDPR). The data will be kept until the statute of limitations of the mutual claims and the necessary data will be kept within the scope of fulfilling the commercial and tax retention periods (Art. 6 (1) (c) GDPR).
In the event Aluminary has good reason to believe that you have breached your obligations under Section 5, Aluminary will review your personal data, communication, and networking to the extent as required to verify such a breach.
We take technical and organizational security precautions to protect your personal data against accidental or intentional manipulation, loss, destruction, or against access by unauthorized persons and to guarantee the protection of your rights and compliance with the applicable data protection regulations of the EU and France. The measures taken should guarantee the confidentiality and integrity of your data as well as the availability and resilience of the systems and services when processing your data in the long term. They should also quickly restore data availability and access in the event of a physical or technical incident. Our security measures also include encryption of your data. All information that you enter online is technically encrypted and only then transmitted. This means that this information cannot be viewed by unauthorized third parties at any time. Our data processing and security measures are continuously improved in line with technological developments. The employees of Aluminary are or will be obliged in writing to maintain confidentiality and to comply with the data protection requirements of the GDPR.
Effective Date: 21st April, 2022