SASU OMOTE ADVISORY (hereinafter "OMOTE Advisory", "we", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data when you visit our website at https://omote-advisory.com/, interact with us through our online forms (including LinkedIn Lead Gen), or use our services. https://omote-advisory.com/, interagissez avec nous via nos formulaires en ligne (y compris LinkedIn Lead Gen), ou utilisez nos services.

We comply with the European Union's General Data Protection Regulation (GDPR), ensuring that your data is collected and processed in a lawful, fair, and transparent manner.

Our activities are exclusively B2B (Business-to-Business). The data we collect primarily concerns professionals in the context of their professional activity.

The controller of your personal data is:

SASU OMOTE ADVISORY
25 Av. de Wagram, 75017 Paris
General contact : contact@omote-advisory.com

RIALTO Kernel contact : rialto@omote-advisory.com

Given its size and the nature of its activities, OMOTE Advisory is not required to formally designate a Data Protection Officer (DPO). Any question regarding data protection may be addressed to contact@omote-advisory.com.

We may collect and process the following categories of personal data

• Contact information — first name, last name, professional email address, phone number, job title, company name, and country, provided when filling out our forms (website, HubSpot, LinkedIn Lead Gen).
• Technical data — IP address, browser type, referring and exit pages, operating system, navigation data, collected via cookies, JavaScript, CSS files, and analytics tools.
• Communication data — information you provide via email, phone, online contact forms, or during commercial exchanges and demonstrations.

We do not collect any sensitive data within the meaning of Article 9 of the GDPR (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning sex life or sexual orientation).

We process your personal data based on one or more of the following legal grounds :

• Consent (Article 6.1.a of the GDPR) : when you submit your personal information through our forms (website, HubSpot, LinkedIn Lead Gen), subscribe to our communications, or accept non-essential cookies.
• Contractual obligations (Article 6.1.b of the GDPR) : when you request our advisory services or subscribe to RIALTO Kernel, we process your data to perform the contract between us.
• Legal compliance (Article 6.1.c of the GDPR) : we may process your data to comply with legal and regulatory obligations, particularly in accounting and tax matters.
• Legitimate interest (Article 6.1.f of the GDPR) : we process certain data within the framework of our legitimate business interests, including improving our services, IT security, and measured and proportionate B2B commercial prospecting.

We use your personal data for the following purposes :

• Respond to your requests and provide our advisory services and products, including RIALTO Kernel.
• Schedule demonstrations, commercial discussions, and pilot phases.
• Send relevant commercial and technical communications (subject to your consent where required).
• Analyze the performance of our website and improve our services using tools such as Google Analytics, HubSpot, and analytical cookies.
• Ensure the security of our website and prevent fraud.

We may implement automated lead scoring through HubSpot to identify the most relevant profiles for our services. This scoring does not produce any legal or significant effect on data subjects, and never replaces a human decision for commercial or contractual engagement.

You can object to any automated processing by contacting us at contact@omote-advisory.com.

Your personal data is not sold, rented, or shared for commercial purposes with unauthorized third parties. We may share your data with the following categories of recipients :

• Authorized OMOTE Advisory employees, strictly within the scope of their duties.
• Authorized partners directly involved in the provision of our services, under strict confidentiality obligations.
• Trusted third-party technical service providers, acting on our behalf and under our instructions: web hosting, HubSpot (CRM and marketing), Google Analytics (audience analysis), videoconferencing tools for demonstrations.
• Competent authorities when disclosure is required by law or by judicial decision.

Our website uses cookies and similar technologies (JavaScript, HubSpot trackers) to improve your browsing experience, analyze audiences, and personalize our communications. Cookies may collect data such as your IP address, browser type, and pages visited.

You can manage your cookie preferences via our consent banner on your first visit, or disable cookies through your browser settings. Some parts of the site may not function properly without cookies.

We retain your personal data according to the following durations :

• Commercial prospect data — 36 months from the date of last active contact. After this period, your data is anonymized or deleted, unless you explicitly consent to extended retention.
• Customer data — duration of the contractual relationship, plus 5 years to comply with applicable accounting and tax obligations.
• Unsolicited application data — maximum 24 months from receipt, unless an earlier deletion is requested.
• Cookies and navigation data — maximum 13 months, in accordance with CNIL recommendations.
• Data from LinkedIn Lead Gen forms — 36 months from submission, unless earlier deletion is requested.

In accordance with the GDPR, you have the following rights regarding your personal data

• Right of access: you may request a copy of the data we hold about you.
• Right to rectification: you may request the correction of inaccurate or incomplete data.
• Right to erasure: you may request the deletion of your data, within the limits provided by law.
• Right to restriction of processing: you may request to limit the processing of your data in certain cases.
• Right to data portability: you may request the transfer of your data to another organization in a structured, machine-readable format.
• Right to object: you may object to the processing of your data based on legitimate interest, particularly for commercial prospecting purposes.
• Right to withdraw consent: at any time, without affecting the lawfulness of prior processing based on that consent.

To exercise any of these rights, contact us at: contact@omote-advisory.com. We commit to responding within one month.

You also have the right to lodge a complaint with the French Data Protection Authority (Commission Nationale de l'Informatique et des Libertés, CNIL), located at 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or via their website www.cnil.fr. You may also lodge a complaint with your local data protection authority.

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These measures include in particular the encryption of communications, strict access management, employee awareness, and regular evaluation of our security practices.

As a France-based company, we primarily store and process your data within the European Economic Area (EEA). However, some of our third-party providers (notably HubSpot, whose infrastructure may be located in the United States) may transfer your data outside the EEA.

In such cases, these transfers are governed by Standard Contractual Clauses (SCCs) approved by the European Commission, or by other appropriate safeguards provided for in Articles 46 et seq. of the GDPR, in order to ensure a level of protection equivalent to that of the European Union.

When you submit your data through a LinkedIn Lead Gen form linked to our campaigns (in particular those concerning RIALTO Kernel), this data is collected by LinkedIn and then transferred to OMOTE Advisory in accordance with LinkedIn's general terms and this privacy policy. The processing of this data by OMOTE Advisory is governed by this privacy policy.

We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations. Any material modification will be published on this page with an updated effective date, and you will be notified through our usual channels when required.

For any question or concern regarding this Privacy Policy or the processing of your personal data, you can contact us at:

SASU OMOTE ADVISORY

25 Av. de Wagram, 75017 Paris, France

General contact: contact@omote-advisory.com

RIALTO Kernel contact: rialto@omote-advisory.com