Privacy Policy

The following terms beginning with a capital letter shall have the following definitions, whether used in the singular or plural:
1.1 " Customer(s) " refers to any natural person acting in the course of their professional activity or any legal entity that has entered into a service agreement with Waltr.

1.2. " Partner(s) " refers to any legal entity or natural person engaged in a professional activity with whom Waltr has entered into a collaboration, commercial or technical cooperation agreement, without any relationship of subordination to Waltr.

1.3 " Company(ies) " refers to any entity with legal personality, including commercial and civil companies, associations, and public institutions, that are related or likely to be related to Waltr.

1.4 " Legal entity(ies)" refers to any legal entity created by operation of law, distinct from the individuals who comprise it, with its own rights and obligations, including, in particular, commercial and civil companies and associations.

1.5 " Investor(s) " means any natural or legal person contributing financially to the development of the Waltr company.

1.6 " Prospect(s) " refers to any company or individual interested in the services and products offered by Waltr.

1.7 " Contact persons within partner companies " refers to any natural person working within or on behalf of one or more of our partners.

1.8 " Visitor " refers to any internet user who visits our website.

1.9 " Applicable Regulations on the Protection of Personal Data " refers to Law No. 78-17 of January 6, 1978, known as the "Data Protection Act," in its latest version in force (Decree No. 2019-536 of May 29, 2019) and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on data protection (" GDPR "), as well as any applicable legislation or regulations relating to the protection of Personal Data.

1.10 " Data Controller " means Waltr, which determines the purposes and means of processing Personal Data.

1.11 " Subcontractor " means any person who processes Personal Data on our behalf and in accordance with our instructions.

1.12 The terms " Personal Data," " Data Subject," " Processing," " Processed," and "Personal Data Breach " have the same meaning as in the Applicable Regulations on the protection of personal data.

We collect Personal Data about you directly when you:

• Visit our website www.waltr.fr;
• Fill out a contact, press, and/or application form;
• Submit an inquiry to Waltr; 
• Download one of our communication materials;
• Contact our services by email or phone;
• Subscribe to Waltr's newsletters or company news;
• Talk to our staff at a public or private event;
• Participate in our events (workshops, seminars, etc.);
• Respond to our satisfaction surveys;
• Use the digital platforms and tools provided by Waltr for data monitoring.

We may also collect your Personal Data indirectly, through third parties, in the following situations:

• We may receive Personal Data about you from the organizers of events in which you participate;
• Your Personal Data may have been transferred to us by specialized third-party companies that have first obtained your consent to use your Personal Data for commercial prospecting purposes. You may withdraw this consent at any time, in accordance with the provisions of Article 6 herein.

We collect various categories of Personal Data about you.

In all cases, we undertake to collect only Personal Data that is strictly necessary for the purposes pursued.

The table below describes the purposes of processing your Personal Data and the legal basis chosen from among those authorized by the applicable regulations on the protection of personal data, namely in this case:

• Performance of a contract : when the processing of your Personal Data is necessary to fulfill our obligations under a contract to which you are a party;
• Legal obligation : when we are required to process your Personal Data to comply with a legal obligation, including for the purpose of providing information to a public body or law enforcement authority;
• Interests : : we process your Personal Data if it is in our legitimate interest to do so, in order to best manage Waltr's business in accordance with the law, and to the extent that this interest does not override your own interests;
• Your consent : in certain cases, we ask for your specific authorization to process some of your Personal Data, and we process it only for the purposes to which you have consented (e.g., newsletter, satisfaction survey, etc.). You have the right to withdraw your consent at any time by contacting us at the address indicated in Article 6 hereof.

We may also use your personal data:

• When necessary, to help us investigate violations of our rules, regulations, and policies;
• To comply with applicable laws, court orders, or decisions of courts and tribunals, or government regulations.

We only retain your Personal Data for as long as is necessary and proportionate to the purpose for which it was collected.

The main retention periods are summarized in the table below:

5.1 Within Waltr : the people who process your Personal Data are members of our internal departments responsible for administrative management, sales, marketing and communications, relations with partner companies, and IT security.  

These individuals only have access to the Data that is necessary for them to perform their duties. Our employees have signed a confidentiality agreement regarding the Personal Data that they are required to process in the course of their duties.

5.2 Subcontractors : your Personal Data may also be disclosed to third-party service providers (publishers of software used by Waltr's services) generally acting as Subcontractors within the meaning of the Applicable Regulations on the protection of personal data, who may access, host, and/or process your Personal Data on our behalf, in accordance with our instructions.

5.3 Third parties Third Parties: our auditors, legal advisors, and third-party organizations may need to process some of your Personal Data. These third parties are not our processors within the meaning of the Applicable Regulations on the protection of personal data. In addition, as part of your contract or partnership, you may be required to create user accounts on our APU, GEMS, and SmartVitiNet platforms. The use of your Personal Data by these platforms is subject to Waltr's privacy policy. 

5.4 Public funding bodies: When you participate in a project funded by various private or public entities, the data necessary for the performance of the contract is transmitted to these parties.

5.5 Finally, we may share your Data in response to requests from courts or tribunals, government agencies, or law enforcement agencies when necessary to comply with applicable laws and procedures.

Under the conditions set forth in the Applicable Regulations on the protection of personal data, you have the following rights regarding your personal data:

• Right of access : You have the right to submit a request for access and obtain a copy of the Data we hold about you;
• Right to rectification : you have the option to correct your Data if it is incorrect or incomplete;
• A right to erasure of your Data, subject to compliance with our legal obligations;
• A right to object for legitimate reasons to prevent your Data from being processed, and to prevent this Data from being used for commercial prospecting purposes;
• Right to restrict the use of your Data : you may request to restrict certain processing of your Data;
• Right to portability: you have the right to request that your Data be directly transmitted to a third party so that it can be reused in another IT environment.

To exercise these rights or for any further information or complaints, you can contact us by email at contact@waltr.fr , specifying your request.

These rights are individual and can only be exercised by the person concerned. For this reason, we may ask you for a copy of proof of identity in connection with any request to exercise any of the rights provided for in the Applicable Regulations on the protection of personal data.

The exercise of your rights (in particular your rights to object to or delete Data) must also be reconciled with the legal obligations and legitimate interests pursued by Waltr. 

Similarly, the right to obtain a copy of the personal information we hold about you cannot in any way infringe on the privacy of others or contravene any legal provision.

We will respond to your requests within one (1) month of receipt, it being understood that this period may be extended by two (2) months depending on the complexity of your request or in the event of a large number of requests at the same time. If this is the case, we will inform you as soon as possible. 

If you do not receive a response from us within a maximum of three (3) months of your initial request, or in the event of a dispute regarding the exercise of your rights, you have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL).

As Data Controller, we implement reasonable technical and organizational measures to ensure the security, integrity, and confidentiality of your Personal Data, including to prevent the alteration or damage of your Personal Data or access by unauthorized third parties.

The main security measures we implement are as follows:

• Protection of premises by means of locked doors;
• Strict management of access authorizations to processed Personal Data;
• Securing our employees' workstations and professional IT equipment;
• Protection of the internal computer network (secure internet access, implementation of a VPN for remote access);
• Implementation of regular backups of the Personal Data processed;
• Storage of backups in a secure external location;
• Restricting access to tools and interfaces to authorized persons only;
• Separation of test and production environments;
• Verification of security measures taken by our subcontractors.

We do not transfer Personal Data to countries that do not provide an adequate level of protection without first implementing one of the appropriate safeguards provided for by the GDPR to regulate such transfers, in particular by using contractual clauses approved by the European Commission.

Our marketing communications may contain links to websites belonging to third parties, including our partners. If you click on one of these links, please note that these sites have their own privacy policies and that Waltr cannot be held liable for the terms of these privacy policies.

This version of the privacy policy was updated on August 19, 2025.
We may update this privacy policy and will notify you of any changes to this privacy policy through the usual means of communication (email).