1.1 We are committed to safeguarding the privacy of individuals and organizations that visit Alpin’s website or application.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of individuals and organizations that visit Alpin’s website or application; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls for EU visitors which affect how we will process your personal data. By using the privacy controls, you can limit the collection of cookies that are not necessary.
1.5 In this policy, “we”, “us” and “our” refer to Alpin, Inc. For more information about us, see Section 12.
1.6 In this policy, “you”, and “your” refer to you and/or your employer or other organization that maintains information about you as an individual, and that is investigating, communicating with, or exploring or conducting a business relationship with us.
1.7 In this policy, “our website” refers to our publicly-accessible website (currently at https://alpin.io) and “our web application” refers to the web application (currently at https://app.alpin.io) that requires authentication via login credentials that you or we supply.
2. How we use your personal data
2.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and application (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems. This usage data may be processed in order to quantify and analyze website or application user behavior. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name, email address, mailing address, phone number, credit card information, or other details. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business, OR the performance of a contract between you or your employer and us. or taking steps, at your request, to enter into such a contract.
2.4 We may process your information included in your user profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, or other information relevant to business communications. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your and/or your employer’s request, to enter into such a contract.
2.5 We may process your personal data or the personal data of employees and other individuals in or associated with your organization that are provided in the course of the use of our services (“service data“). The service data may include user activity, subscription information, permissions, and personally identifiable information. The source of the service data is you, your employer, or any applications or subscriptions you have authorized to provide this information. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.
2.8 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website. (“transaction data“). The transaction data may include your contact details, your payment instrument details, and transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications, newsletters, and/or other content (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications, newsletters, and/or other content. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may engage third-party service providers to administer and provide our services. We may provide personal information to such third parties only for the purpose of performing services on our behalf, such as fulfilling orders and delivering updates, payment processing, providing customer service, sending marketing communications, conducting research and analysis, and providing cloud computing infrastructure. We require such third parties to agree not to disclose your personal information or use your personal information for any other purpose.
3.4 Financial transactions relating to our website and application are handled by our payment services providers: Intuit, Stripe, and Pacific Western Bank. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We have offices and facilities in the United States of America (the “United States”) and in France. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States under the Privacy Shield Framework. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from firstname.lastname@example.org
4.3 The hosting facilities for our website are situated in the United States. The hosting facilities for our web application are situated in the United States and in France. The European Commission has made an “adequacy decision” with respect to the data protection laws of the United States under the Privacy Shield framework. Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from email@example.com
5. mailto:firstname.lastname@example.orgRetaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, satisfy legal obligations, resolve disputes, protect our assets, and enforce our agreements. Because these needs can vary for different data types in the context of different products or services, actual retention periods can vary significantly.
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are satisfied with any changes to this policy.
6.3 We may notify you of changes to this policy by email or other means.
7. Your rights
7.1 In this Section 7, we have summarised the rights that EU visitors have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing email@example.com web application users can log in to the web application io to access or change their personal profile.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by emailing firstname.lastname@example.org.
8. About cookies and the cookies we use
9. Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(e) (Safari); and
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the features on our website or web application.
10. Third-party links
10.1 Occasionally, at our discretion, we may include or offer third-party information, products, or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
11. Other Privacy Laws and Principles
11.1 California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
You can change your personal information by emailing us.
11.2 How does our site handle Do Not Track signals?
We do not honor Do Not Track signals and therefore we may track, plant cookies, or use advertising even when a Do Not Track (DNT) browser mechanism is in place.
11.3 Does our site allow third-party behavioral tracking?
We do not allow third-party behavioral tracking.
11.4 COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
We do not let third-parties, including ad networks or plug-ins, collect PII from children under 13.
11.5 Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email within 7 business days.
We will notify users via in-site notification within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
11.6 CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
To be in accordance with CANSPAM, we agree to the following:
Not use false or misleading subjects or email addresses;
Identify the message as an advertisement in some reasonable way;
Include the physical address of our business or site headquarters;
Monitor third-party email marketing services for compliance, if one is used;
Honor opt-out/unsubscribe requests quickly;
Allow users to unsubscribe by using the link at the bottom of each email;
11.7 US-EU and Swiss-U.S. Privacy Shield Framework
Our application to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks is in progress and will be completed soon. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s website.
We will be responsible for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We will comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we will be subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
12. Our details
12.1 This website is owned and operated by Alpin, Inc.
12.2 We are registered as a business in the United States, and our registered office is at 2770 Arapahoe Rd Ste 132-1007, Lafayette, CO 80026.
12.3 Our principal place of business is at 1919 14th Street, Suite 700, Boulder, CO 80302.
12.4 You can contact us at email@example.com
13. Data protection officer
13.1 Our data protection officer’s contact details are:
Julien Denaes | firstname.lastname@example.org
Last Edited: 2019-04-02