The information and materials contained on this website do not constitute legal advice and the user should not act based on such information and materials or consider them as substitutes for legal advice in specific cases. The Alster Group is not responsible to the user for the content of web pages that contain links to this page, or for the content of those web pages to which links that this page contains lead.
Identity of the Responsible Entity
Responsible Entity: Alster Group Holding, LLC
Domicile: CERRO EL PLOMO 5855, OFFICE 308, SANTIAGO, DISTRICT OF LAS CONDES, CHILE
Principles applied in data processing. In the treatment of your personal data, the Recipient will apply the following principles that meet the requirements of the new European data protection regulation:
Principle of legality, loyalty, and transparency: The Recipient will always require the relevant consent for the processing of your personal data, which may be for one or more specific purposes, regarding which you will be previously informed with absolute transparency.
Principle of minimization of data: The Recipient will only request the data that is strictly necessary for the purpose or purposes requested.
Principle of limitation of the conservation period: The data will be kept for the period of time strictly necessary for the purpose or purposes of its treatment.
The Recipient will inform you of the corresponding conservation period according to the purpose. In the case of subscriptions, the Recipient will periodically review the lists and eliminate those records that have been inactive for a considerable time.
Principle of integrity and confidentiality: Your data will be treated in such a way that its security, confidentiality, and integrity is guaranteed. You should know that the Recipient takes the necessary precautions to avoid unauthorized access or improper use of its users’ data by third parties.
Obtaining personal data. To browse www.alster.law it is not necessary for you to provide any personal data. The cases in which you do provide your personal data are the following:
When contacting us through the contact forms or when sending an email. The Recipient informs you that you have the right to:
Request access to stored data.
Request a rectification or cancellation.
Request the limitation of the treatment of your data.
Request the portability of your data.
The exercise of these rights is personal and therefore must be exercised directly by the interested party, requesting it directly from the Recipient. This means that any client, subscriber or collaborator who has provided their data at any time can contact the Recipient and request information about the data stored and how it has been obtained, request its rectification, request the portability of his/her personal data, oppose its treatment, limit its use or request the cancellation of the data in the Recipient’s files.
To exercise your access, rectification, cancellation, portability and opposition rights, you must send an email to email@example.com together with the valid proof in law, such as a photocopy of your ID or equivalent.
You have the right to effective judicial protection and to file a claim before the supervisory authority, i.e., the Spanish Data Protection Agency, if you consider that the treatment of personal data that concerns you violates the Regulations.
Purpose of the processing of personal data. When you connect to the website to send an email to the Recipient, subscribe to its newsletter or take out a contract, you are providing personal information for which the Recipient is responsible.
The personal data used and the purpose of its treatment by the Recipient will be different according to the information capture system:
Contact forms: The Recipient requests personal data, which may include the following: Name and surname, email address, telephone number and address of your website, in order to respond to your queries.
For example, the Recipient uses this data to respond to your messages, questions, complaints, comments or any concerns you may have regarding the information included on the website, the services provided through the website, the treatment of your personal data, questions regarding the legal texts included on the website, as well as any other queries you may have that are not subject to the conditions of the website or the contract. There are also other purposes for which the Recipient processes your personal data:
To guarantee compliance with the conditions contained in the Legal Notice and in the applicable law. This may include the development of tools and algorithms that help this website to ensure the confidentiality of the personal data it collects.
To support and improve the services offered by this website.
To analyze navigation. The Recipient collects other non-identifying data that is obtained using cookies, which are downloaded to your computer when you browse the website. The characteristics and purpose of cookies are detailed in the Cookies Policy.
To manage social networks. The Recipient has a presence on social networks. If you become a follower on the Recipient’s social networks, the treatment of your personal data will be governed by this section, as well as by those use conditions, privacy policies and access regulations that belong to the appropriate social network (in each case) and that you have previously accepted. You can check the privacy policies of the main social networks through these links:
The Recipient will process your personal data in order to correctly manage its presence on the social network, inform you of its activities, products or services, as well as for any other purpose that the regulations of social networks allow.
In no case will the Recipient use the profiles of followers on social networks to send advertising individually.
Security of personal data.
To protect your personal data, the Recipient takes all reasonable precautions and follows the best practices in the industry to avoid its loss, misuse, improper access, disclosure, alteration, or destruction.
The website is hosted on its own server. The security of your data is guaranteed, as all the necessary security measures are taken.
Content from other websites
The pages of this website may include embedded content (for example, videos, images, articles, etc.).
Embedded content from other websites behaves in exactly the same way as if you had visited the other website.
On the Cookies Policy page, you can consult all the information regarding the collection policy, the purpose, and the treatment of cookies.
Legitimacy of data processing
The legal basis for the treatment of your data is the following: consent.
Categories of personal data
The categories of personal data that the Recipient processes are the following:
Retention of personal data.
The personal data you provide to the Recipient will be kept until you request its deletion.
Recipients of personal data
Google Analytics is a web analytics service provided by Google, Inc., a Delaware company whose main office is located at 1600 Amphitheater Parkway, Mountain View (California), CA 94043, United States (“Google”). You can find more information at: https://analytics.google.com
Google Analytics uses “cookies”, which are text files located on your computer to help the Recipient analyze the use made by users of the website. The information generated by cookies regarding your use of the website (including your IP address) will be directly transmitted to and filed by Google on servers in the United States.
You can also see a list of the types of cookies used by Google and its collaborators, and all the information related to their use of advertising cookies.
When browsing www.alster.law, non-identifying data can be collected, which may include the IP address, geolocation, a record of how the services and sites are used, browsing habits, and other data that cannot be used to identify you.
The Website uses the following third-party analytics services:
The Recipient uses the information obtained to obtain statistical data, analyze trends, administer the site, study navigation patterns and collect demographic information.
Accuracy and veracity of personal data
You agree that the information provided to the Recipient is correct, complete, exact, and current, and to keep it duly updated.
As a User of the website, you are solely responsible for the veracity and correctness of the data you send to the site, releasing the Recipient from any liability in this regard.
Acceptance and consent
To exercise your rights of access, rectification, cancellation, portability, and opposition, you must send an email to firstname.lastname@example.org together with the valid proof in law, such as a photocopy of your ID or equivalent.
The exercise of your rights does not include any data that the Recipient is obliged to keep for administrative, legal or security purposes.
These policies will be in force until they are modified and replaced by others, which will be duly published.
Code of Conduct
General Declaration of Business Philosophy
Alster Group Holding, LLC & Subsidiaries
Alster is committed to developing a high-quality, close personal service, providing advice with the highest integrity, ethics, and honesty standards that are adjusted to the needs of everyone who chooses us. Our solutions are based on 4 main pillars: talent, processes, data, and technology. In this way, our conduct is guided by innovation and creativity, always safeguarding moral and behavioral integrity; i.e., respect for the rules and customs of those places where we carry out our actions. Within this behavioral framework, Alster, its collaborators and all the members of its network must adhere to our values, which are the foundations of our organizational culture.
Our values are the following:
Wearing the colors
We are driven by our philosophy and vision, we are committed to challenges and we are excited to be part of Alster and its network.
We are passionate about our clients
We act on our shared values. We engage with the needs of our clients, create memorable experiences and we are not satisfied with a service that is simply good.
Ethics are not compromised
We stick to our principles; we make conscious and beneficial decisions for all parties. We are transparent in our actions. We always seek excellence, but with a focus on humanity.
We have courage; we challenge the status quo
We seek to make a difference; we take charge of change and build new ways of doing things. We see opportunities where others see problems, creating unique services and products. We have the courage and the ability to change course when necessary.
We work smart
We exceed the standard; we are committed to doing it right the first time. We make things happen; we are protagonists of change. We learn from our mistakes and improve; we are always in beta.
We create value by collaborating
We promote collective talent. We understand that participatory environments strengthen the creative process and streamline work. Listening to others is key to creating synergy and avoiding misunderstandings.
Policies and practices
- Conflicts of Interest
A conflict of interest may arise in any situation in which the allegiances of a collaborator or member of our network are divided between commercial interests that, to a certain extent, are incompatible with the interests of Alster. Alster strives to create an environment that protects its clients, suppliers and collaborators from such conflicts and expects that no one in its community will place themselves in a position that appears to be, or can be interpreted as being, in conflict with the interests of Alster or its clients.
It is extremely important to identify and avoid any conflict of interest, whether real or apparent. A conflict of interest exists when your private interests in any way interfere or compete with Alster’s interests, or appear to be in conflict.
Unless approved in advance by the supervisor of a collaborator or member of our network, neither a collaborator nor his/her spouse, partner or any other immediate family member can have a financial interest directly or indirectly (whether as an investor, lender, collaborator or other service provider) with a competitor, or with a client or provider if that collaborator or his/her subordinates deal directly or indirectly with that client or provider during their work at Alster. It is vitally important for maintaining our integrity that no one in Alster is influenced or affected by interests or relationships that conflict with Alster’s best interests.
- Gifts and Entertainment
We avoid giving material gifts of any value to clients or potential clients. Branded items related to marketing campaigns of minimal real value are our only exception, and these gifts must be executed through our authorized areas.
We also do not accept gifts with a value greater than $250 USD from anyone looking to do business of any type with Alster. A collaborator can attend a dinner/event with a business contact, but even in that situation, expenses should be minimal and there should be no sign of quid pro quo.
Normal commercial entertainment, such as meals, music, theater, sports events etc. will be deemed appropriate if it is reasonable in nature and intended to have good faith business discussions or to foster better business relationships. All activities must be previously reported and approved by the collaborator’s supervisor. No collaborator may accept tickets or entertainment invitations if the host will not be present at the event with the collaborator.
- Bribery and Fraud
Wherever you are in the world, and whatever industry you are operating in, we do not accept or receive anything that looks, sounds, feels, or smells like a bribe.
The following behaviors are expressly prohibited:
- Payment or receipt of money, gifts, loans, or other favors that may influence business decisions or compromise independent judgment.
- Payment or receipt of refunds or “bribes” to obtain business for or from Alster.
- Payment of bribes to government officials to obtain favorable resolutions.
- Any other activity that would similarly degrade Alster’s reputation or integrity.
- The delivery of gifts to government officials, including gifts of little value, is strictly regulated and in many cases prohibited. Please check with the People & Culture Area before providing or paying for meals, snacks, travel or lodging expenses, or giving anything of value to any local, federal, state, or foreign government official.
- Any collaborators or members of our network who are receiving, accepting, or tolerating a bribe, another illegal payment, or who try to initiate such activities, will be responsible for the termination of our relationship and possible criminal proceedings against them.
- Any collaborator or member of our network who attempts fraud or participates in fraud will be responsible for the termination of our relationship and possible criminal proceedings against him/her.
- All collaborators and members of our network have the responsibility to inform Alster of any bribery, actual or potential bribery, or fraud in the performance of their functions or activities related to Alster.
- International Operations
Laws and customs vary throughout the world, but all partners and members of our network must uphold Alster’s integrity in other nations as diligently as they would in their own country. When doing business in other countries, it is imperative that our community is sensitive to foreign legal requirements and the laws of Chile.
- Corporate Opportunities
The Alster community, i.e., partners, members of our network or providers, are prohibited from taking advantage of opportunities that are discovered through the use of corporate property, information or their position linked to Alster or its clients, without the express written consent of Alster. No person that belongs to the Alster community may use Alster’s property, information, or their position in or on behalf of Alster for improper personal gain, nor may he or she compete directly or indirectly with Alster. Alster’s collaborators have an obligation to the company to promoting its legitimate interests whenever possible.
Each collaborator and member of our network must immediately inform their supervisor or their point of contact in charge within Alster of all real or apparent conflicts of interest. The Board of Alster and its members, directly or through delegated committees, will be responsible for the interpretation and application of this Code of Conduct in particular situations and will recommend an adequate resolution of the conflict.
Use of information and property of Alster
- Confidential Information
Confidential information includes all non-public information about Alster, our clients and our partners, and other people who provide services to us or who work for us, as well as our suppliers, which, if disclosed, could be useful to competition or harmful to Alster or its clients. This could range from information about the work we are doing for specific clients, to the status and performance of a client’s personnel, or even Alster’s strategic plans. We are an open culture and we tend to hire open people, but we must be vigilant in drawing a clear line on this matter, particularly in relation to the information of clients who trust our services.
Confidential information about Alster and its operations belongs to Alster. All partners and network members should be aware that, in any competitive environment, proprietary information and trade secrets must be protected in the same way as all other important assets of Alster. You must not, without proper authorization, transfer or release, to anyone who is not an Alster collaborator, or to an Alster collaborator who does not need to know, confidential data or information. This information should not be used in any other way than as intended when carrying out work tasks. All files, records and reports acquired or created during the course of any relationship with Alster belong to Alster. The originals or copies of such documents may be removed from Alster’s offices for the sole purpose of allowing the collaborator to fulfill its duties with Alster and must be returned at any time upon request.
Each supervisor is responsible for controlling the disclosure and use of confidential information by collaborators under their direction. Additional restrictions on the use of confidential information are established in more detail in the Confidentiality Agreement that each of you signed upon accepting employment with Alster.
- Data protection and privacy
Alster respects and is diligent in protecting the privacy of collaborators, clients, and members of its network, as well as others who provide services for us or work for us, and will comply with applicable data protection and privacy laws.
- Property and facilities owned by Alster
Alster’s property, facilities or physical resources may not be used for requested or distribution activities that are unrelated to a collaborator’s services with Alster, except for charitable activities that have been pre-approved by Alster.
- Trademarks, service marks and copyrights
No contributor or network member may negotiate or enter into any agreement regarding Alster’s trademarks, service marks or logos without the express written mandate of Alster’s Senior Management.
Likewise, the use of the trademark or service mark of another company, including one with which Alster has a business relationship, always requires authorization or approval from our Legal Area to guarantee that the use of that company’s brand is appropriate. Collaborators should avoid unauthorized use of others’ copyrighted materials and should consult with Senior Management if they have any questions about the permissibility of photocopies, extracts, electronic copies, or the use of copyrighted materials.
- Record keeping and accounting practices
We never alter, adjust, or manipulate our reports and records for any reason. We record and report the truth.
Alster has adopted controls in accordance with internal needs and the requirements of applicable laws and regulations. These established accounting practices and procedures must be followed to ensure complete and accurate recording of all transactions. All collaborators, within their areas of responsibility, are expected to adhere to these procedures, as indicated by the internal regulations. Any accounting adjustments that deviate materially from GAAP must be approved by Senior Management and reported to Alster’s independent auditors.
In addition, all transactions, agreements, and off-balance-sheet obligations, contingent or otherwise, and other Alster relationships with non-consolidated entities or others, must be disclosed to Alster’s Senior Management or Board of Directors and independent auditors. If you find or suspect an error in the financial records you are dealing with, you should notify your supervisor, director, or Senior Management.
No director, collaborator or non-collaborator and member of our network may interfere with or attempt to improperly influence, directly or indirectly, the audit of Alster’s financial records.
The violation of these provisions will result in disciplinary action, which may include dismissal, and may also cause the offender to be subject to substantial civil and criminal liability. If a contributor becomes aware of any improper accounting practice or transaction regarding Alster’s resources, they should immediately report the matter to their supervisor or to a member of Alster’s Board Audit Committee. They can also raise their concerns through one of the options established in this Code of Conduct. There will be no retaliation against collaborators who disclose questionable accounting or auditing matters.
- Timely and true disclosure
Alster collaborators involved in the preparation of reports and/or documents filed or sent to Alster’s regulatory entities, as well as those used in public communications made by Alster, must generate full, fair, accurate, timely and understandable disclosures. Alster collaborators must not knowingly hide or falsify information, or misrepresent or omit material necessary facts, to avoid misleading Alster’s public auditors or independent investors.
- Employment policies
Alster is committed to a work environment in which all people are treated with respect and dignity. Every individual has the right to work in a professional environment that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Therefore, we hope that all relationships between people in the workplace are professional and free from prejudice and harassment.
Alster guarantees equal employment opportunities without discrimination or harassment based on race, color, nationality, national or ethnic origin, socioeconomic level, creed or religious belief, political opinion, sex, gender reassignment, pregnancy or maternity, age, disability, alienation or citizenship, marital status (or civil partnerships or other unions recognized by law), genetic predisposition or carrier status, sexual orientation, gender identity, military service, or any other characteristic protected by state or local law. Alster prohibits and will not tolerate such discrimination or harassment. Alster’s anti-discrimination and anti-harassment regulations are found in the Hygiene and Safety Regulations and provide more detailed information on prohibited conduct, reporting procedures and protection against retaliation.
Alster is committed to providing a safe workplace for all collaborators. In addition, various laws and regulations impose on Alster the responsibility to safeguard its collaborators against health and safety risks. For this reason, and to protect the safety of themselves and others, collaborators and others must follow all safety instructions and procedures that Alster adopts. Questions about potential health and safety risks at Alster or at clients’ offices should be directed immediately to the collaborator’s supervisor.
Alster’s Board of Directors is exclusively responsible for the final interpretation of the Code of Conduct. This can be reviewed, changed, or amended at any time by the Board of Directors of Alster.
- Reporting suspected non-compliance - Compliance
Alster has established a Compliance Committee comprised of the CEO, the P&C Manager and the Administration and Finance Manager. All infringements or suspected infringements of this Code of Conduct must be reported immediately to the head of area, Senior Management, an Alster director, or the Compliance Committee. If the violation or suspected violation involves any of these parties, or concerns accounting, internal controls, or audit matters, the report must be made directly to the Alster Compliance Committee at email@example.com. Reports made via the ethics hotline can be made confidentially and anonymously. If you are making an anonymous report, please provide as much detail as possible, including copies of documents that you consider relevant to the matter.
Alster will immediately investigate all reports of alleged non-compliance with this Code of Conduct and other reported irregularities, and will determine an appropriate course of action. Retaliation in any form against a person who reports a violation of this Code of Conduct or the law, even if the report is wrong or aids in the investigation of a reported violation, is itself a serious violation of this policy. Acts of retaliation must be reported immediately and will be appropriately disciplined.
- Disciplinary actions
Alster will take appropriate measures against any collaborator whose actions violate this Code of Conduct. Disciplinary actions may include the immediate termination of the contract, or others. In this regard, more details on these actions can be found in Alster’s Hygiene and Safety Regulations and in the framework contracts for the provision of services with members of our network. If the organization has suffered a loss, it may pursue actions against the responsible persons or entities as permitted by law. If laws have been violated, Alster will cooperate fully with the appropriate authorities. The entire Alster community is expected to cooperate in internal investigations of misconduct.
- Waivers and amendments
Any waiver of any provision of this Code of Conduct can only be granted by the Board of Directors. Amendments to this Code of Conduct must be approved by the Board or the Compliance Committee.
We prohibit any type of discrimination or harassment, whether due to race, skin color, religion, beliefs, gender, sexual orientation, gender identity, gender expression, nationality, ancestry, citizenship, age, different abilities or disabilities, genetic information, marital status, domestic partnership status, status as a victim of domestic violence, compulsory military service, military reserve, national guard, military guard, belonging or having connections to any political party, or any category protected by local, state, regional, federal or national laws.