PRIVACY POLICY

SARL ALNOTRA - Algerian Sovereign Cloud

Version 1.0 - January 2025

English translation of the French original.

PREAMBLE

The purpose of this Privacy Policy is to inform users of ALNOTRA's services about how their personal data is collected, processed and protected, in accordance with Law No. 18-07 of 10 June 2018 on the protection of natural persons in the processing of personal data.

ALNOTRA attaches the utmost importance to protecting the privacy and personal data of its customers and users. By using our services, you accept the practices described in this policy.

ARTICLE 1 - DATA CONTROLLER

The controller of the personal data is:

SARL ALNOTRA

• Share capital: DZD 2,000,000
• Trade Register number: 16/00 - 1283240 B 25
• Registered office: Algeria
• Email: contact@alnotra.com
• DPO email: privacy@alnotra.com

ARTICLE 2 - DATA COLLECTED

2.1 Identification data

In order to provide our services, we collect the following data:

• Last name and first name
• Company name (for legal entities)
• Postal address
• Email address
• Phone number
• Trade register number (for professionals)
• Tax identification number (NIF)

2.2 Billing data

• Bank details (for payments by bank transfer)
• Transaction history
• Invoices and credit notes

2.3 Technical data

• IP address
• Connection logs
• Browser type and operating system
• Geolocation data (country/region)
• Session identifiers

2.4 Service usage data

• Configuration of the subscribed services
• Usage statistics (bandwidth, disk space, etc.)
• Support tickets and history of exchanges
• Communication preferences

2.5 Sensitive data

In accordance with Article 18 of Law No. 18-07, ALNOTRA does not collect any sensitive data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, nor any genetic, biometric or health data or data relating to sex life.

ARTICLE 3 - PURPOSES OF PROCESSING

The personal data collected is processed for the following purposes:

3.1 Performance of the contract

• Creation and management of the customer account
• Provision of the ordered services
• Billing and payment management
• Technical support and customer assistance

3.2 Legal obligations

• Compliance with accounting and tax obligations
• Responding to requests from judicial authorities
• Retention of connection data (Law No. 18-04)

3.3 Legitimate interests

• Improvement of our services
• Fraud prevention and securing of the infrastructure
• Anonymised statistics and analyses

3.4 Consent

• Sending commercial communications and newsletters
• Participation in satisfaction surveys
• Use of non-essential cookies

ARTICLE 4 - LEGAL BASIS FOR PROCESSING

In accordance with Law No. 18-07, each processing of personal data is based on a legal basis:

ARTICLE 5 - RETENTION PERIOD

Personal data is retained for the following periods:

When these periods expire, the data is deleted or irreversibly anonymised.

ARTICLE 6 - RECIPIENTS OF THE DATA

6.1 Internal access

Only authorised ALNOTRA employees have access to personal data, within the limits of their duties:

• Sales department
• Technical and support department
• Accounting department
• Management

6.2 Processors

ALNOTRA may use processors for certain processing operations. These processors are contractually bound to:

• Process the data only according to our instructions
• Guarantee the confidentiality of the data
• Implement appropriate security measures
• Not subcontract without our authorisation

Categories of processors:

• Payment service providers (SATIM)
• Transactional email providers
• Technical maintenance providers

6.3 Authorities

The data may be disclosed to the competent authorities (tax administration, judicial authorities) upon a lawful request.

6.4 No international transfer

In accordance with Law No. 18-07, ALNOTRA does not transfer any personal data to foreign countries without the prior authorisation of the National Authority for the Protection of Personal Data (ANPDP).

All data is hosted exclusively on servers located in Algeria.

ARTICLE 7 - DATA SECURITY

ALNOTRA implements appropriate technical and organisational measures to ensure the security of personal data:

7.1 Technical measures

• Encryption of data in transit (TLS 1.3)
• Encryption of data at rest (AES-256)
• Firewalls and intrusion detection systems
• Strong authentication for access to systems
• Regular, encrypted backups
• Monitoring 24 hours a day, 7 days a week

7.2 Organisational measures

• Strict access control policy
• Staff training in data protection
• Security incident management procedures
• Regular security audits
• Confidentiality clause for all employees

7.3 Notification of breaches

In the event of a personal data breach likely to result in a risk to your rights and freedoms, ALNOTRA undertakes to:

• Notify the ANPDP within 72 hours
• Inform you as soon as possible if the risk is high
• Document the incident and the corrective measures taken

ARTICLE 8 - YOUR RIGHTS

In accordance with Law No. 18-07, you have the following rights over your personal data:

8.1 Right of access

You can obtain confirmation that your data is being processed and access all of your personal data.

8.2 Right to rectification

You can request the correction of inaccurate or incomplete data concerning you.

8.3 Right to erasure

You can request the deletion of your personal data when:

• The data is no longer necessary for the purposes of the processing
• You withdraw your consent
• The data has been processed unlawfully

This right does not apply when the processing is necessary to comply with a legal obligation.

8.4 Right to object

You can object to the processing of your data on legitimate grounds, except when the processing meets a legal obligation.

8.5 Right to restriction

You can request the restriction of the processing of your data in certain cases provided for by law.

8.6 Right to data portability

You can receive your data in a structured, commonly used and machine-readable format.

8.7 Exercising your rights

To exercise your rights, you can:

• Send an email to: privacy@alnotra.com
• Send a letter to our registered office
• Use your client area (for certain requests)

We will respond to your request within a maximum of thirty (30) days. Proof of identity may be requested to verify your identity.

8.8 Complaints

If you believe that your rights are not being respected, you can lodge a complaint with the National Authority for the Protection of Personal Data (ANPDP).

ARTICLE 9 - COOKIES

9.1 What is a cookie?

A cookie is a small text file placed on your device (computer, tablet, smartphone) when you visit a website.

9.2 Cookies used

ALNOTRA uses the following categories of cookies:

Essential cookies (mandatory)

• Authentication and session maintenance
• Security and fraud prevention
• Storing privacy preferences

Analytics cookies (with consent)

• Audience measurement and visit statistics
• Improvement of the user experience

Marketing cookies (with consent)

• Personalisation of communications
• Measuring the effectiveness of campaigns

9.3 Managing cookies

On your first visit, a banner informs you about the use of cookies and allows you to:

• Accept all cookies
• Refuse non-essential cookies
• Customise your choices

You can change your preferences at any time in your account settings or via your browser settings.

9.4 Cookie lifetime

Cookies have a maximum lifetime of 13 months, in accordance with the recommendations of the ANPDP.

ARTICLE 10 - DATA OF MINORS

ALNOTRA's services are intended for persons of full age (18 years or older). We do not knowingly collect personal data concerning minors.

If we discover that data concerning a minor has been collected without parental consent, we will delete it as soon as possible.

ARTICLE 11 - CHANGES TO THE POLICY

ALNOTRA reserves the right to change this Privacy Policy at any time.

In the event of a substantial change, we will inform you by:

• Email to the address associated with your account
• A notification in your client area
• An information banner on our website

Changes take effect thirty (30) days after notification. Your continued use of the services after that date constitutes acceptance of the amended policy.

ARTICLE 12 - CONTACT

For any question about this Privacy Policy or the protection of your personal data, you can contact us:

Data Protection Officer (DPO)

• Email: privacy@alnotra.com
• Address: SARL ALNOTRA, Algeria

General support

• Email: contact@alnotra.com
• Website: www.alnotra.com

ARTICLE 13 - NEWSLETTER, PROSPECTING, LIVE CHAT AND AUDIENCE MEASUREMENT

Update of 20 October 2026.

13.1 Newsletter

You can subscribe to the ALNOTRA newsletter from the footer of the site, by ticking the box provided in the contact form or in the welcome form of the live chat. Subscription is based on your consent (article 3.4): it is never presumed, no box is pre-ticked, and creating a customer account does not subscribe you to the newsletter. A welcome email confirms the subscription.

Data processed: email address, name if you provided it, date of subscription, language and market (Algerian or French site), and the origin of your visit described in article 13.3.

You can unsubscribe at any time through the link at the bottom of every newsletter, without justification; your address is then removed from the mailing list. We send a few emails a year.

Customer accounts also receive the emails required to perform the contract (invoices, credentials, incidents, maintenance), on the basis of article 3.1.

13.2 Prospecting file and customer relationship

Requests you send us through the contact form, the live chat or the newsletter subscription are recorded in our customer relationship management tool, with your contact details, the content of your message and its date, in order to answer them and to follow up commercially (articles 3.3 and 3.4). Customer accounts appear there with their billing details and a summary of their orders.

Retention period: data of a prospect without a customer account is deleted three years after the last contact (article 5); data of a customer follows the term of the contract and the legal obligations. Deleting a customer account deletes its record in the customer relationship tool and removes it from the mailing lists.

13.3 Origin of visits and partner codes

When you reach the site from a campaign, a third-party site or a partner link, we may record the origin of the visit (campaign parameters of the address, referring site, landing page, date, partner code) for the duration of your session, in order to measure our campaigns and to remunerate our partners. This information is written to a cookie, for 90 days, only if you accept the "marketing" category of the banner (article 9); it is attached to your account when the account is created.

13.4 Live chat

The live chat module only loads at your request, when you click the "Chat" button. Conversations, the email address and the name you provide are kept for twelve months after the last exchange, in order to follow up your request (articles 3.1 and 3.3), then deleted.

13.5 Audience measurement

Traffic on the site is measured by a tool hosted on our own servers that sets no cookie and keeps no data allowing you to be identified: statistics are aggregated (page views, geographic origin at country level, device type). Your browser's "Do Not Track" setting is honoured. This measurement falls under our legitimate interest (article 3.3) and does not require your consent.

13.6 Hosting and processors

The newsletter, the customer relationship tool, the live chat and the audience measurement are free software operated by ALNOTRA on its own servers. None of this data is entrusted to a third-party provider or transferred abroad (article 6.4). Emails are routed through ALNOTRA's mail server.

13.7 Your rights

You may exercise the rights of access, rectification, objection and erasure described in article 8 on all of these processing operations, by email to the address given in article 12. Withdrawal of your consent to the newsletter is exercised through the unsubscribe link; withdrawal of your consent to cookies, through the "Cookies" link at the bottom of every page.

SARL ALNOTRA - Algerian Sovereign Cloud Privacy Policy - Version 1.1 - October 2026 Compliant with Law No. 18-07 on the protection of personal data