Effective Date: July 31, 2018
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us online at email@example.com, or by mail at: Reitler Kailas & Rosenblatt LLC. 885 Third Avenue, 20th floor. New York, NY 10022-4834
a) “Contact Information” means (i) your name, (ii) your physical address, (iii) your email address and (iv) your telephone number.
b) “Effective Date” means the date set forth at the beginning of this document.
c) “Alto Affiliates” means (i) any parent, subsidiary, member, officer, director, employee, or agent of Alto or any company under common control with Alto, or (ii) any third party with which Alto has a commercial relationship.
d) “Customer” is a person that opens a Customer Account.
f) “Financial Account Information” means your credit card number, credit card expiration date and credit card verification code, all with respect to one or more credit cards that you have the lawful right to use, and your bank account number, bank account title, bank name, branch location and routing number, all with respect to one or more accounts that you have the lawful right to access.
g) “Provider” is a service Provider or other professional that opens a Provider Account.
h) “Transaction Information” means all information related to transactions that Customers conduct via the Platform.
i) “User” is a person that opens a Customer Account or a Provider Account.
j) “User Account” means an account permitting access to the Platform (which may be designated by you as either a “Customer Account” or a “Provider Account”), with which is associated a User name and password.
k) “User Account Information” means information that identifies you to Alto’s Platform, including your User name, password, internet protocol address, MAC address, device type and device identifier.
3. Types of Personal Information We Collect
Alto collects the following types of information about you (collectively, “Personal Information”):
a) Contact Information
b) Financial Account Information
c) Transaction Information
d) User Account Information
4. Mechanisms for Collection of Personal Information
Alto collects Personal Information (i) upon a User’s creation of a User Account, (ii) upon logging into the Platform, (iii) upon interaction on the Platform, including without limitation when you enter a contest, take a survey, or buy merchandise by means of the Platform, and (iv) when you communicate with Alto.
5. Purpose of Collection and Use of Personal Information
Alto may use Personal Information to:
• Operate and improve the Platform;
• Target offers to Users;
• Administer the Platform’s facilities for communications among and between customers and Providers and the public in general;
• Evaluate eligibility of customers for certain offers, products or services;
• Evaluate the types of offers, products or services that may be of interest to customers;
• Provide customer support;
• Communicate with Users regarding support, security, technical issues, commerce, marketing, and transactions;
• Facilitate marketing, advertising, surveys;
• Administer the Platform, User Accounts and transactions with respect to User Accounts; and
• Administer and carry out our obligations under contracts and to comply with the law.
6. Disclosure of Personal Information
We may disclose your Personal Information to:
• Alto Affiliates, which may use the Personal Information for the purposes described in Section 5.
• Service providers which act for us or provide services for us, such as for marketing or for the processing of payments, and as to such service providers their use of Personal Information is subject to our agreements with them and any applicable laws.
• Providers arrange transactions with Customers via the Platform or the App;
• any person or government agency in response to a subpoena;
• to a government agency in response to an investigation, regardless of whether or not a subpoena has been issued;
• any person to enforce our rights or protect our property, to protect the rights, property or safety of others, or to investigate fraud;
• any person, at your specific direction; and
• Alto’s employees and outside professionals (such as lawyers and accountants) for the purpose of auditing, compliance, and corporate governance.
7. Cookies and Related Technologies
You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of our Platform. You should refer to the help sections of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling cookies.
8. Email Policies
Alto reserves the right to send you e-mail relating to your User Account, and to the Alto Service. You agree to receive such emails, but may opt out by sending us a message at: firstname.lastname@example.org
9. No Responsibility for Privacy Practices of Third Parties
10. Interactions With Others
The Platform may contain areas where you may be able to publicly post information, communicate with others such as by discussion boards or blogs, review 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 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. Transaction Information will be shared only with Providers whom you select to work with via the Platform.
11. Accessing and Correcting Personal Information
You may correct or update certain of your Personal Information via your “Profile” screens on the Platform.
You may close an account, but Alto will nevertheless retain your Personal Information so as to protect the business interests of Alto, Alto Affiliates, Customers, Providers and other Users. Those interests include the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.
13. Notice to Residents of Countries outside the United States of America
14. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can 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 during the proceeding calendar year. In particular, the law provides that companies must inform Users about 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 following address:
Reitler, Kailas & Rosenblatt LLC,
885 Third Avenue, 20th Floor.
New York NY, 10022-4834