Privacy Policy and Terms & Conditions

Privacy Policy

This Privacy Policy was last updated on September 2, 2019.

Our Policy

Welcome to the website (the “Website”) of Alto USA, LLC (“Alto”, “Company”, “we” “us” and/or “our”). This Website is operated by Alto and has been created to provide information about our company and our risk mitigation solutions, mobile applications and related services (together with the Website, the “Services”) to our Service visitors (“you”, “your”). Alto is committed to maintaining robust privacy protections for its users. Our Privacy Policy is designed to help you understand how we collect, use and safeguard the information you provide to us, including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Website and Services, and to assist you in making informed decisions when using our Services. By accepting our Privacy Policy and the Alto AllianceSM and Alto AssuranceSM Terms of Use “Terms of Use”), you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Use. Any capitalized terms not defined herein are defined in the Terms of Use.

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
• Age
• Race/Ethnicity
• Gender
• Birthdate
• Photos
• Geolocation information

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, use certain Services and otherwise communicate with or submit information or content to us. Personal Data is used to help us communicate with you. For example, we use Personal Data to contact users in response to questions, solicit feedback from users, and provide technical support. Wherever Alto collects Personal Data we make an effort to provide a link to this Privacy Policy

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Alto and the authorized third parties referred to herein located in the United States.

Other 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.

In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer which hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Website may set a cookie on your browser that allows you to access the Services without needing to remember and enter a password more than once during a visit to the Website. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features

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.

Analytics: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use a proprietary analytics service similar to Google Analytics, which uses cookies to help us analyze how users use the Website and enhance your experience when you use the Services. We do not implement any advertising features with our analytics service.

Our Use of Your Personal Data and Other Information

Alto uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to respond to you. Or, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Alto and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Alto and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. You can also indicate that you do not wish to receive marketing communications from us in the “Settings” section of the Website. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Please note, however, that notwithstanding your marketing preferences, we may continue to send you administrative emails.

If Alto intends to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

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.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

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.

Your Choices

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.

1. 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 itsupport@alto-us.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.
2. 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.
3. Cookies and web beacons – Your browser may offer the ability to block or delete cookies from your device.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Alto other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Alto through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or services, or modifications to existing products or services, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Alto shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Alto (the “Third Party Sites”). However, we are not responsible for the privacy practices employed by those Third Party Sites or the information or content they contain. Our Privacy Policy and the policies and procedures described herein do not apply to the Third Party Sites. The links from the Services do not imply that Alto endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies. Here are some examples of third party content and services available through or via our Site:

1. 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.

Children

Alto does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Alto through the Services, please contact us, and we will endeavor to delete that information from our databases.

Security

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

Your access to and use of the Services is subject to the Terms of Use.

Changes to Company’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Alto to make changes to this Privacy Policy. We will notify you of any significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our Website. Significant changes will go into effect 30 days following such notification. Alto reserves the right to make non-material changes or clarifications to this Privacy Policy at any time and from time to time without prior notice. Non-material changes or clarifications will take effect immediately. You should review this Privacy Policy and the Website periodically for updates, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Governing Law

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.

Data Retention

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.

Data Transfers

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. By accepting the terms of this Privacy Policy, you acknowledge, agree and consent to (1) the transfer to and processing of personal information on servers located outside of the country where you reside and (2) our collection and use of your personal information as described herein and in accordance with the data protection laws of the United States, which may be different and may be less protective than those in your country. If you are a resident of the EEA or Switzerland, please note that we use standard contractual clauses approved by the European Commission to transfer your personal information from the EEA or Switzerland to the United States and other countries.

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

Please also feel free to contact us if you have any questions about Alto’s Privacy Policy or the information practices of the Services.

You may contact us at itsupport@alto-us.com