5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short:
We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services
may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short:
We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services
and your account
, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a
'sale'/'sharing'
(which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section
'
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
'
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice
: http://www.altallo.com/cookies
.
Google Analytics
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short:
We may transfer, store, and process your information in countries other than your own.
Our servers are located in
the United States
. If you are accessing our Services from outside
the United States
, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see
'
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
'
above), in
the United Kingdom,
United States,
Europe,
and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations.
Our Standard Contractual Clauses can be provided upon request.
We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:
We keep your information for as long as necessary to
fulfil
the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
No purpose in this notice will require us keeping your personal information for longer than
twelve (12)
months past the termination of the user's account
.
When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymise
such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:
We aim to protect your personal information through a system of
organisational
and technical security measures.
We have implemented appropriate and reasonable technical and
organisational
security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised
third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short:
We do not knowingly collect data from or market to
children under 18 years of age
.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at
Mel@altallo.com
.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
Depending on your state of residence in the US or in
some regions, such as
the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada
, you have rights that allow you greater access to and control over your personal information.
You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like
the EEA, UK, Switzerland, and Canada
), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below.
We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent:
If we are relying on your consent to process your personal information,
which may be express and/or implied consent depending on the applicable law,
you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below
or updating your preferences
.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
when applicable law allows,
will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in the emails that we send,
or by contacting us using the details provided in the section
'
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
You may also opt out of interest-based advertising by advertisers
on our Services.
For further information, please see our Cookie Notice: http://www.altallo.com/cookies
.
If you have questions or comments about your privacy rights, you may email us at mel@altallo.com
.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (
'DNT'
) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for
recognising
and implementing DNT signals has been
finalised
. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for
recognising
or
honouring
DNT signals, we do not respond to them at this time.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:
If you are a resident of
California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia
, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category
|
Examples
|
Collected
|
A. Identifiers
|
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
|
|
B. Personal information as defined in the California Customer Records statute
|
Name, contact information, education, employment, employment history, and financial information
|
|
C
. Protected classification characteristics under state or federal law
|
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
|
NO
|
D
. Commercial information
|
Transaction information, purchase history, financial details, and payment information
|
NO
|
E
. Biometric information
|
Fingerprints and voiceprints
|
NO
|
F
. Internet or other similar network activity
|
Browsing history, search history, online
behaviour
, interest data, and interactions with our and other websites, applications, systems, and advertisements
|
NO
|
G
. Geolocation data
|
Device location
|
|
H
. Audio, electronic, sensory, or similar information
|
Images and audio, video or call recordings created in connection with our business activities
|
NO
|
I
. Professional or employment-related information
|
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
|
|
J
. Education Information
|
Student records and directory information
|
NO
|
K
. Inferences drawn from collected personal information
|
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
|
NO
|
L
. Sensitive personal Information
|
Debit or credit card numbers
and account login information
|
YES
|
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information.
We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category
G
- As long as the user has an account with us
- Category
I
- As long as the user has an account with us
- Category
L
- As long as the user has an account with us
Sources of Personal Information
How We Use and Share Personal Information
Will your information be shared with anyone else?
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be
'selling'
of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
- Category B. Personal information as defined in the California Customer Records law
- Category
G
. Geolocation data
- Category
I
. Professional or employment-related information
- Category
L
. Sensitive personal information
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know
whether or not we are processing your personal data
- Right to access
your personal data
- Right to correct
inaccuracies in your personal data
- Right to request
the deletion of your personal data
- Right to obtain a copy
of the personal data you previously shared with us
- Right to non-discrimination
for exercising your rights
- Right to opt out
of the processing of your personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law)
, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (
'profiling'
)
Depending upon the state where you live, you may also have the following rights:
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including
California's and Delaware's
privacy law)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us
by visiting http://www.altallo.com
,
by emailing us at mel@altallo.com
,
or by referring to the contact details at the bottom of this document.
We will
honour
your opt-out preferences if you enact the
Global Privacy Control
(GPC) opt-out signal on your browser.
Under certain US state data protection laws, you can designate an
authorised
agent to make a request on your behalf. We may deny a request from an
authorised
agent that does not submit proof that they have been validly
authorised
to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an
authorised
agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at
mel@altallo.com
. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California
'Shine The Light'
Law
California Civil Code Section 1798.83, also known as the
'Shine The Light'
law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section
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HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
'
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated
'Revised'
date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
contact our Data Protection Officer (DPO) by email at
Mel@altallo.com
,
by phone at 07306665615
,
or
contact us by post at:
Argyll & Buchanan Limited
Data Protection Officer
Clyde Offices
48 West George Street
Glasgow
, Scotland
G2 1BP
Scotland
If you are a resident in the United Kingdom, we are the
'data controller'
of your personal information. We have appointed Mel Sutton
to be our representative in the UK. You can contact them directly regarding our processing of your information ,
by email at mel@altallo.com
,
by visiting http://www.altallo.com
,
by phone at 07306665615
,
or by post to:
Clyde Offices
48 West George Street,
Glasgow
,
Scotland
G2 1BP
Scotland
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country
or state of residence in the US
, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to
withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please
visit: http://www.altallo.com
.