Privacy & Cookies

A - Third-Party Privacy Policy

Summary

This Third-Party Privacy Policy describes the manners in which Alternative Earth and all Full Alternative Earth affiliates (“Alternative Earth”), as the data controller, collect, use, and protect Personal Data received from Third Parties and/or Personal Data from its Employees transferred to Third Parties.

Alternative Earth agrees to comply in all material respects with all applicable privacy laws, rules, and regulations, including but not limited to: (i) the European Regulation (EU) 2016/679 “on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing the EU Data Protection Directive” (the “GDPR”) and any implementing legislation enacted by the member states of the European Union (“European Laws”).

Alternative Earth complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. Alternative Earth has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Affiliates (and their employees) shall not be considered as Third Parties for the purpose of this Third-Party Policy. A separate Group Employee Data Privacy General Instruction applies to Alternative Earth employees (including the third-party employees subcontracted to Alternative Earth, “the Employees”).

Third Parties include applicants, clients, subcontractors, vendors/suppliers, investors, insurers, and visitors to Alternative Earth website (such parties referred to herein individually as a “Third Party” or collectively as “Third Parties”).

By providing Personal Data as below defined to Alternative Earth, Third Parties consent to the disclosure and/or collection and use of information as set forth herein unless otherwise required.

Definitions

“Personal Data” and “Personal Information” are used interchangeably herein and refer to information that can be used to identify a Third Party either on its own or in combination with other readily available data (e.g., the individual’s name, title, work location, home address, date of birth, compensation, benefits, or family members).

“Sensitive Data” means Personal Data which reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, or data which concern health, sex life or sexual orientation.

Please note that Personal Data and Sensitive Data may have different definitions depending on your country.

Personal Data Collected

Alternative Earth collects Personal Data entered by Third Parties on Alternative Earth website or through cookies used by Alternative Earth as specified below, or given in any other way, such as writings or phone calls during any transactional or administrative communications.

Subject to applicable laws and regulations, Personal Data and/or Personal Information collected may include, but is not limited to, the following:

• Personal Data such as date of birth, gender, marital status, and identification numbers including social security, driver’s license, tax identification, passport numbers and resume.
• Contact information such as name, company, address, phone number, fax number and e-mail address.
• Financial and billing information such as billing name and address, payment information (which might include credit card and/or bank account information).
• Additional information such as title, department name, fax number and additional company information, such as shareholder names, annual revenues, number of employees or industry.
• Intended Use of Personal Data.

Purpose and Legal Basis of the Processing

Alternative Earth uses Personal Information collected from Third Parties for the purposes of Alternative Earth operations and activities management, training programs, and recruiting job applicants.

Alternative Earth collects and uses the Personal Data of Third Parties for the execution of its contracts with them, to comply with its legal obligations, on the basis of Third Parties’ consent and for the purposes of the legitimate interests of Alternative Earth.

Failure to provide this information may prevent or delay the fulfilment of these obligations.

Alternative Earth processes Third Parties’ Personal Data on the following legal basis:

• Performance of a contract – the use of Third-Party Personal Data may be necessary to perform the contract that you have with us;
• Legitimate interests – Alternative Earth may use Third-Party Personal Data for its legitimate interests, as for example to improve our products and services to deliver relevant website content and for marketing purposes;
• Consent – Alternative Earth may rely on Third Parties’ consent to use Personal Data for marketing purposes;
• Legal obligation – to comply with Alternative Earth legal obligations.

Sensitive Data shall be processed only where required by local law and only where there is a legitimate purpose for Alternative Earth in doing so.

Recipient of Personal Data

To fulfil the purposes mentioned in Article 3 of the Third-Party Privacy Policy, Alternative Earth may disclose Personal Data to Third Parties on a limited and as-needed basis, including without limitation for example, services providers who advise Alternative Earth on compensation and benefit programs or administer such programs for Alternative Earth, insurers, or as otherwise required by law or detailed in this Third-Party Privacy Policy.

In the event that Alternative Earth or any portion of its assets are acquired, sold, or transferred, Alternative Earth may disclose Personal Data with the company involved to perform the operation and complete the transition, on a limited basis in compliance with applicable law.

In certain circumstances, Alternative Earth may be requested or required to disclose Personal Data in response to valid legal process or under applicable laws and/or regulations. Such circumstances may include a search warrant, subpoena, court order or other request from a government or regulatory authority or agency, including to meet national security or law enforcement requirements. Alternative Earth reserves the right to disclose such information in response to any such legitimate government or regulatory request or requirement.

Alternative Earth does not disclose or sell any Personal Data received from a Third Party (individual or legal entity) for marketing or any other commercial purpose.

International Transfer of Personal Data

Subject to applicable laws and/or regulations, Personal Data may be transferred to any country in the world where Alternative Earth does business, including countries where privacy laws may be more or less protective than the privacy laws where a Third Party is located.

In particular, Alternative Earth may transfer Personal Data of Third Parties located in the European Economic Area to countries located outside the European Economic Area. Where appropriate, Alternative Earth will ensure that Third Parties are informed of such transfer and that appropriate transfer mechanisms are in place.

Onward Transfer and Choice “Opt In – Opt Out”

Alternative Earth does not intend to disclose or use Personal Data received from a Third Party in a manner not described herein. However, should at any time Alternative Earth need to use Personal Data for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent Third Party, Alternative Earth will provide individuals with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to this contact.

If Personal Data that qualifies as Sensitive Data is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a Third Party, Alternative Earth will obtain the Third Parties’ explicit consent prior to such use or disclosure, except if the use or disclosure is in the vital interests of the Third Party or another person; necessary for the establishment of legal claims or defenses; required to provide medical care or diagnosis; necessary to carry out Alternative Earth obligations in the field of employment law; or related to data that are manifestly made public by the individual.

If the Third Party does not consent explicitly to such disclosure or use, Alternative Earth will take all reasonable measures to remove the Third Party’s Personal Data from the intended disclosure or use.

The same principles apply for the Personal Data received from Employees that is anticipated to be disclosed and/or used to a Third Party as described in the Employee Privacy General Instruction above referred to.

When the processing of Personal Data is outsourced to a Third Party processor, Alternative Earth will select reliable Third Parties, and data processing will be subject to a written agreement between Alternative Earth and the relevant Third Party processor. This written agreement will require that the Third Party processor: (i) has at least the level of security measures in place as those implemented by Alternative Earth, and (ii) will process Personal Data in strict compliance with Alternative Earth specific written instructions only for the purpose(s) mentioned in the said agreement. Alternative Earth shall be liable in case the Third Party does not process the Personal Data in an appropriate manner.

Personal Data Security

Alternative Earth maintains appropriate technical and organizational measures to process Personal Data collected from Third Parties in a secure-access environment and in a manner that complies in all material respects with applicable laws and industry standards to guard Personal Data against loss, destruction, misuse, improper disclosure, and unauthorized access or modification. These safeguards are routinely tested internally and periodically audited by outside firms.

Personal Data Retention Period

Personal Data is not kept for longer than necessary to fulfil the purpose for which it was collected. Personal Data will generally not be retained longer than the term of Third Parties’ contractual relationship with Alternative Earth unless there is any legal or regulatory provision requiring otherwise.

Personal Data Accuracy

Alternative Earth relies on the accuracy and integrity of Third Parties’ Personal Data in order to comply with its business obligations. Alternative Earth expects Third Parties to inform it of any changes to their Personal Data, such as changes to contact information, address, or any information affecting benefits or services provided by Alternative Earth.

Alternative Earth makes reasonable efforts to ensure that the Personal Data it collects and maintains is reliable for its intended use, and is accurate, complete for the purposes for which it was collected.

Rights Over Personal Data

Third Parties have a right to request access to their Personal Data and to request the rectification of any incorrect or incomplete data. Third Parties also have the right to data portability, to request the erasure of their Personal Data, to restrict the processing of their Personal Data, as well as to object to their processing by Alternative Earth, unless Alternative Earth demonstrates compelling legitimate grounds. Third Parties which are not satisfied with the way Alternative Earth processes their Personal Data have the right to lodge a complaint with the competent data protection authority.

Should a Third Party have any request for assistance regarding the exercise of their rights as above mentioned, the Third Party shall use the following e-mail address: customer.support@alternative-earth.com

Alternative Earth will allow a Third Party to review the Third Party’s Personal Data that Alternative Earth stores and maintains about that Third Party in his or her personnel file, including information relevant to the use and disclosure of that person’s Personal Data. However, in certain limited circumstances, Alternative Earth may not be able to provide a Third Party with access to all of his or her Personal Data where such refusal is permitted or required by applicable law or regulation

Subject to all applicable laws and regulations, should any Personal Data concerning a Third Party be found to be no longer needed, to be inaccurate or incomplete, or if a Third Party has withdrawn consent, Alternative Earth will take reasonable steps to erase or correct or update the information it maintains unless applicable laws or regulations exempt Alternative Earth from doing so.

These rights can vary depending on your country.

Website

An individual can access Alternative Earth website without providing any Personal Data. However, should you choose, you may provide us with certain Personal Data. Alternative Earth may use this information:

• To correspond with you;
• To allow you to participate in features or services we offer on this website;
• To provide you with a subscription or newsletter;
• To transmit your resume within Alternative Earth for possible employment opportunities.

If you subscribe to any service provided by Alternative Earth through Alternative Earth website or otherwise, and you wish to terminate that subscription and have all Personal Data about you removed from any list we maintain, please contact Alternative Earth by sending an e-mail to customer.support@alternative-earth.com, informing us of your request. We will promptly make reasonable efforts to remove all Personal Data about you from our data banks. In addition, e-mail communications from Alternative Earth inform the recipient how to stop receiving further communication.

Alternative Earth does not automatically log Personal Data about visitors to our website. Alternative Earth does not use cookies to store Personal Data, nor does Alternative Earth link non-Personal Data stored in cookies with Personal Data about specific individuals. We may collect certain non-Personal Data from a visitor to our website such as what browser was used, what pages were accessed, and the Internet address of the service provider in order to compile statistics and analyze this data for trends.

Use of Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Email us to request deletion of personal information or update your contact preferences: customer.support@alternative-earth.com

Alternative Earth website uses the following cookies to understand how the site is being used in order to improve the user experience.