5. HOW LONG DO WE
KEEP YOUR
INFORMATION?
In Short: We keep your information
for as long as necessary
to fulfill 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
1 day .
When we have no ongoing
legitimate business need to
process your personal
information, we will either
delete or anonymize
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.
6. HOW DO WE KEEP
YOUR INFORMATION
SAFE?
In Short: We aim to protect your
personal information
through a system of organizational and technical security measures.
We have implemented
appropriate and reasonable
technical and organizational
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
unauthorized
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.
7. 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 privacy@aleacor.com .
8. 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.
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.
If you have questions or
comments about your privacy
rights, you may email us at privacy@aleacor.com.
9. 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
recognizing
and implementing DNT signals
has been
finalized. 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 recognizing
or
honoring DNT signals, we do not respond
to them at this time.
10. 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 |
NO
|
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 behavior, interest data,
and interactions
with our and other
websites,
applications,
systems, and
advertisements |
NO
|
G. Geolocation data | Device location |
NO
|
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 |
NO
|
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 | |
NO
|
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.
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:
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
privacy@aleacor.com ,
by
emailing
us
at
privacy@aleacor.com,
or by
referring
to the
contact
details
at the
bottom
of
this
document.
Under
certain
US
state
data
protection
laws,
you
can
designate
an authorized
agent
to
make
a
request
on
your
behalf.
We
may
deny
a
request
from
an
authorized
agent
that
does
not
submit
proof
that
they
have
been
validly
authorized 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 authorized 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 privacy@aleacor.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
"HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?"
11.
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.
12.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you
have
questions
or
comments
about
this
notice,
you
may
email
us
at
privacy@aleacor.com
or contact
us
by
post
at:
__________
Via
F.
Borromini
14
Mentana 00013
Italy
If
you
are a
resident
in the
European
Economic
Area
or
Switzerland, we
are
the
"data
controller"
of
your
personal
information.
We
have
appointed
Matteo
Lancia
to be
our
representative
in the
EEA
and
Switzerland.
You
can
contact
them
directly
regarding
our
processing
of
your
information,
by
email
at
matteo@aleacor.com,
or by
post
to:
Via
F.
Borromini
14
Mentana 00013
Italy
13.
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
mayhave
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:
privacy@aleacor.com .