Information We Collect
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:
- First and last name
- Email address
- Physical address
- Phone number
- Social Security Number
- Driver’s License number
- Geolocation information
Non-Identifiable Data: When you interact with Alto through the Services, we receive and store certain personally non-identifiable information, such as anonymous usage data, general demographic information, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Such information,which is collected passively using various technologies, is used to help us improve the Services and customize the user experience, and it cannot presently be used to specifically identify you. Alto may store such information itself or such information may be included in databases owned and maintained by Alto affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Alto often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. This aggregate information is used to track trends and analyze use patterns on the Website, and it does not identify you personally. Alto may share this aggregate data with its affiliates, agents and business partners. Alto may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes
Location Information: Our Services may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Services. If you choose to enable our location features, your location information may be publicly displayed within the Services. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.
Online Tracking: Do Not Track (“DNT”) is a web browser setting that requests that a web application or website disable its tracking of an individual user. There is no regulation requiring companies to change their practices in response to a DNT signal. At this time, Alto does not respond to a DNT signal from your web browser. For more information on DNT, please visit www.allaboutdnt.com.
Our Use of Your Personal Data and Other Information
Our Disclosure of Your Personal Data and Other Information
Alto is not in the business of selling, trading, renting or otherwise sharing for marketing purposes your Personal Data without your consent. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: Alto, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include vendors who are performing services for Alto, mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Alto may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Alto, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
You can visit the Website without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services. You can also modify or update the Personal Data that we collect by accessing your “Profile” information on our Website. Modifying your Personal Data may restrict your access to certain Services.
- Email – Those who wish to opt-out from receiving emails will have their address removed within 1-10 days of receipt of their request to opt-out or to unsubscribe at email@example.com. If you have multiple email addresses you will need to opt-out for each address in order to be removed from our active database.
- Location information – You may have the ability to turn location-based services on and off by adjusting the settings of your Internet browser or mobile device or, for some devices, by revoking permission for our mobile apps to access your location information.
- Cookies and web beacons – Your browser may offer the ability to block or delete cookies from your device.
Links to Other Web Sites
- Social Media – We may facilitate easy access to third party sites and online services, like social networks and other services that host user-generated content such as LinkedIn and Twitter.
Alto takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We implement certain technological security measures including encryption, firewalls and secure socket layer technology, however these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. No Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Alto via the Internet. By using our Services, you acknowledge that you understand and agree to assume these risks.
Access From Your Mobile Phone
We collect and use information about you in the same way and for the same purposes if you access the Services from your mobile phone, as we do when you use our website.
Other Terms and Conditions
This notice and our privacy practices will be subject exclusively to the laws of the State of California within the United States of America. By using our Services, you hereby irrevocably submit to the exclusive jurisdiction of the competent courts of California any claim or matter arising under or in connection with the Services.
Your Personal Data Rights
You may be aware of a European Union law called the General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency to help users take advantage of those rights. As available and except as limited under applicable law, individuals have the rights described below:
If you wish to access the personal information that Alto collects, you can do so at any time by contacting us using the contact details provided under “How to Contact Us” heading below.
Alto account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Alto account holders may also contact us to accomplish the foregoing or if you have additional requests or questions.
If you are a resident of the European Economic Area (“EEA”), you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information where it is technically possible. Again, you can exercise these rights by contacting us using the contact details below.
Similarly, if you are a resident of the EEA, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the U.S. and Canada) are available here.)
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We keep your personal data only as require by law or as long as necessary for legitimate and essential business purposes, such fulfilling an order, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are an account holder.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
Legal Basis for Processing Your Personal Information (EEA Visitors/Customers Only)
If you are a user located in the EEA, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate business interests. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How To Contact Us” heading below.
Access to Information
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
How to Contact Us
You may contact us at firstname.lastname@example.org