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This “Privacy Policy” describes the privacy practices of Alphaa, Inc. and our subsidiaries and affiliates (collectively, “Alphaa”, “we”, “us”, or “our”) in connection with the https://Alphaa.com website, and any other website that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), in connection with our marketing activities, and as otherwise described in this Privacy Policy. In addition, this Privacy Policy describes your rights and choices with respect to the Personal Information we collect.
We provide important information for individuals located in the European Economic Area, Switzerland, and United Kingdom (collectively, “Europe”) in the Notice to European Users, and for California residents in the section entitled Information for California Residents.
We collect personal information as described below. Note, however, that our business customers may transmit personal information to us as part of the services we provide through our security and compliance automation platform. This Privacy Policy does not apply to such personal information that we process on behalf of our business customers. Our use of this personal information is restricted by our agreements with those business customers. If you have concerns regarding personal information that we process on behalf of a business, please review their privacy policy and direct your concerns to that business, or review their privacy policy.
Table of Contents
Personal Information We Collect
Information you provide to us. Personal information you provide to us through the Service or otherwise includes:
Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
Information we obtain from other third parties. We may receive personal information about you from third-party sources, such as marketing partners, publicly-available sources and data providers. Our use of any information obtained from our business customers is restricted by our agreements with those business partners.Â
A list of our sub processors and nature of processing can be found at https://Alphaa.com/sub-processors.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer, and activity occurring on or through the Service. The information that may be collected automatically includes your computer type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.
Referrals
Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.
How We Use Your Personal Information
We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To operate the Service. We use your personal information to:
For research and development. We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
How We Share Your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:
Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
Partners. We may sometimes share your personal information with partners or enable partners to collect information directly via our Service.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Your Choices
In this section, we describe the rights and choices available to all users. Users located in Europe can find additional information about their rights below in the section entitled Notice to European Users, and California residents can find additional information about their rights in the section entitled Information for California Residents.
Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@Alphaa.com. You may continue to receive service-related and other non-marketing emails.
Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://www.allaboutcookies.org. We use Google Analytics to help us understand user activity on the Service. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage and about how Google protects your data at https://policies.google.com/privacy. You can prevent the use of Google Analytics relating to your use of the Service by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout.
Advertising choices. You can limit use of your information for interest-based advertising by:
You will need to apply these opt-out settings on each device from which you wish to opt-out.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Other Sites and Services
The Service may contain links to other websites, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites, or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
Security Practices
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. Email, in particular, is an insecure way to transmit personal information. Please take special care regarding what information you send to us via email.
Children
The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law, will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
How to Contact Us
If you would like to exercise your rights under this Policy, please submit your request via email to legal@alphaa.ai
Please direct any questions or comments about this Policy or privacy practices to privacy@Alphaa.com. You may also write to us via postal mail at:
USÂ Contact: Alphaa AI,Inc. 2035 Sunset Lake Rd, Newark, Delaware - 19702 USA
Indian Contact: Alphaa AI, Inc. WA-109, B-2, Shakapur, East Delhi, Delhi - 110092Â
Information for California Residents
Scope. This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents online and offline in our capacity as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Notice of right to opt-out of the “sale” of your Personal Information. Based on our understanding of the term “sell” under the CCPA, we do not “sell” your Personal Information and have not sold it to third parties for a business or commercial purpose in the 12 months preceding the effective date of this Privacy Policy. However, like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information, where you will find instructions on opting-out of the use of your information for interest-based advertising.
We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form web forms, may contain other categories of personal information not described below.
Statutory category of Personal Information (Cal. Civ. Code § 1798.140)
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Personal Information we collect in this category (See the “Personal information We Collect” section above for description)
Identifiers (excluding online identifiers)
California Customer Records (as defined in California Civil Code section 1798.80)
Commercial Information
Geolocation Information
Sensory Information
Online Identifiers
Internet or Network Information
Inferences
May be derived from the information listed above
Sources. We describe the sources from which we collect this Personal Information in the section above entitled Personal Information We Collect. Purposes. We describe the business and commercial purposes for which we collect this Personal Information in the section above entitled How We Use Your Personal Information. Disclosure. We disclosed this Personal Information to the categories of third parties described in the section above entitled How We Share Your Personal Information.
Notice to European Users
The information provided in this Notice applies only to individuals in the European Economic Area, Switzerland, and United Kingdom (collectively, “Europe”).
Privacy Shield Data Protection Principles
Alphaa complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom, and Switzerland, as applicable, to the United States in reliance on Privacy Shield. Alphaa has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the terms in this notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit, https://www.privacyshield.gov
If you have any inquiries or complaints regarding the handling of your personal information under Privacy Shield, our contact details are provided in the “Contact Us” section. For any unresolved privacy concerns, please contact our US based third party dispute resolution provider (free of charge) at https:// www.jamsadr.com/eu-us-privacy-shield. You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint when other dispute resolution procedures have been exhausted. Alphaa is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Choice. When Alphaa maintains Personal Information about you outside of a direct relationship with you, because we obtained or maintain your Personal Information as a processor, Alphaa’s customers are responsible for providing you with certain choices about the customer’s use or disclosure of your personal information.
When we obtain or maintain your Personal Information as a controller, we may disclose the Personal Information, without offering you a choice, in the following cases: to our processors or service providers; to our affiliates; as part of a corporate restructuring (e.g., a merger or acquisition); or as required by law. You may also choose to disable third-party cookies that collect Personal Information through Alphaa’s website. If we disclose your Personal Information to other third parties, we will obtain your consent. We also allow you to choose to opt out of marketing-related emails from us, and to update or correct Personal Information in your account.
Onward Transfer. In the context of onward transfer, Alphaa is responsible for the processing of personal data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on our behalf. Alphaa shall remain liable under the Privacy Shield Principles if our agent processes your Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Alphaa is not responsible for the event giving rise to the damage.
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal information” governed by European data protection legislation.
Controller. Alphaa is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.
Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.
Processing Purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.
Legal Basis
To operate the Service
Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law
Processing is necessary to comply with our legal obligations.
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.
Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Retention
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Your rights
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
Cross-Border Data Transfer
If we transfer your personal information from Europe to another country that is not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of protection to personal information, that transfer will be performed subject to appropriate safeguards (most commonly standard contractual clauses) and otherwise in accordance with applicable European data protection laws. Please contact us for further information about any such transfers or the specific safeguards applied.
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