Effective Date: July 31, 2018
Collection of Information
Alto will only collect Personal Information about you where we have a lawful basis to do so. A lawful basis includes when you have given us consent (e.g., information you give us voluntarily), where processing is necessary to deliver you services and where we have a “legitimate business interests.”
We may collect the Personal Information anytime you interact with the Platform, including, without limitation, when you create your account, enter and navigate the Platform, sign up and receive Alto services, make payments, participate in training sessions or communicate with us or any service providers such as trainers.
The information that we collect includes, but is not limited to:
• Personal identifiable information such as your name, contact information (physical address, email address, telephone numbers etc.), age, sexual orientation, social security numbers and passport numbers.
• Information that identifies you on our Platform including your username, password, IP address, MAC address, device type, device identifier and operating system.
• Information about transactions that you conduct with or in the Platform.
• Financial information such as credit card, bank and other payment information.
• Health information that you give us or that we collect by providing Alto services to you.
Purpose of Collection
Alto collects the Personal Information for many reasons, including, without limitation:
· Manage your accounts and transactions
· Provide services to you on Alto’s Platform
· Provide customer support
· Facilitate communication between you and us and between you and service providers such as your trainers.
· Evaluate the types of products or services that may be of interest to our customers
· Conduct direct marketing campaigns about new Alto’s features, services, products or events
· Comply with our contractual obligations to you and third parties
· Comply with governmental agency orders and laws that apply to us
· Protect our rights and property
Disclosure to Third Parties
Alto may share your Personal Information with affiliated or unaffiliated third parties in order to:
· Maintain and service the Platform
· Provide service providers (e.g., trainers) information about you so they provide better services
· Facilitate the processing of transactions and payments
· Assist Alto in servicing accounts
· Market and advertise products and services of third parties that may be interest to you
· Comply with orders from government agencies or judicial authorities
· Provide accountants information to audit the Company’s financial statements
· Provide legal counsel and courts information to enforce agreements, defend against lawsuits and protect Alto’s rights and properties
· Ensure protection and safety of Personal Information.
Procedures to Opt Out of Disclosure
You may opt out of Alto’s sharing personally identifiable data with nonaffiliated third parties by sending an email at email@example.com. Please note that, even if you direct us not to share your information, we may still have to do so as permitted by law to, among other reasons, be able to provide you services, facilitate the processing of transactions and payments, service your account, comply with our legal obligations, protect Alto’s rights and properties and ensure the protection of your Personal Information and the proper functioning of the Platform.
Cookies and Tracking Technologies
You may delete and block all cookies from our Platform, but parts of the Platform may not work as well (or at all) and you will not receive an enhanced individualized personal experience. You should refer to the help sections of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling cookies.
Security of Personal Information
Alto maintains measures to protect Personal Information against data breaches, accidental or unlawful loss, alteration or unauthorized disclosure, access or processing of personal data. If a data breach were to occur, Alto shall notify you at the email address on file as soon as reasonably practicable of becoming aware of it and will provide all reasonable assistance to protect your Personal Information.
Changing or Deleting Your Personal Information
You can review, update, change or delete your Personal Information by doing so directly in the Alto app or by writing us at firstname.lastname@example.org. We will comply with your requests in a reasonably timely manner. Please be aware that if you completely and permanently delete all of your Personal Information, then your user account may become deactivated.
Download or Access Personal Information
You may request a print-out of all of the Personal Information stored in Alto’s servers by writing to Alto at email@example.com. Upon receipt of such request, and within a reasonable period of time, Alto will provide a free machine-readable document with all the Personal Information currently stored, together with a description of how the data was used (e.g., advertisement, tracking etc.).
Deleting Personal Information
You may close an account through the app or by writing to Alto at firstname.lastname@example.org, and any personally identifiable information associated with your account will be deleted as soon as reasonably practicable or as required by law. However, please note that we may retain an archived copy of your records if we have “legitimate business purposes.” Those purposes may include the completion of transactions, complying with record retention policies, financial reporting obligations, applicable laws, resolving disputes and enforcing agreements, among others. Regulators in jurisdictions where Alto does business may also want to review Alto’s and our clients’ records, and they may require Alto to retain personally identifiable information about our customers for an indefinite period of time.
Opting Out of Email Communication
The Platform contains areas such as discussion boards or blogs where you may be able to publicly post information or communicate with others, review service providers, and submit media content. Such use is subject to our User Terms and may be viewed by the public at large. Any information, including Personal Information which you post on such public areas of the Platform will be public, and, therefore, anyone who accesses such postings will have the ability to read, collect and further disseminate such information.
No Responsibility for Privacy Practices of Third Parties
Notice to Residents of Countries outside the United States of America
California Privacy Rights
Section 1798.83 of the California Civil Code grants residents of California the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes, including the categories of Personal Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Alto pursuant to Section 1798.83 of the California Civil Code, please contact us via email to email@example.com or by writing us at the address provided below.
Alto Fitness, LLC
P.O Box 1078, Hightstown,
NJ 08520, USA
General Data Protection Regulation (GDPR)
The European Union and the United Kingdom have created a framework for the proper collection, storage, and processing of personal data of nationals or residents of any European Union country and the United Kingdom. If you are a resident of any one of those countries, you have many core rights, including, among others: (i) the right to give or withhold consent to gather personally identifiable data about you, and to tell us to stop doing so at any moment; (ii) the right to be notified of any data breaches that compromises your personally identifiable data within 72 hours after we become aware of such breach, with a statement about what we are doing to correct the situation; (iii) the right to demand that your personally identifiable information be protected, secured and stored in a GDPR compliant technological platform; (iv) the right to view, correct or delete personal data; and (v) the right to request us to completely delete your personal data stored in our servers, discs or elsewhere (subject to limitations discussed above).
Alto is striving to become compliant with GDPR regulations and has designated Nicole L’Vov as the data protection officer who will serve as the central focal point for all GDPR questions and concerns. All inquiries should be made to her at firstname.lastname@example.org.