Effective as of May 30, 2018.
1. Our approach to information
We collect your information directly only as required to communicate with you and fulfill your requests relating to our Sites, and indirectly only as indicated in the sections 1.2 and 2.1 below. For example, if you request to be contacted regarding our events, we collect and store your relevant contact information. We only send emails to Users who explicitly opt in or with whom we have established business relationships.
1.1 Information you provide us directly
In the course of establishing communication and maintaining our Sites, we receive “Personal Information” directly from Users. Personal Information means any information or data element that is associated with or may be used to identify an individual. Definitions of Personal Information vary by jurisdiction; however, here are some examples: contact information such as: first name, last name, phone (fixed/mobile) number, address, employer, title, IP and/or MAC address, mobile device identifier, email address, user names, and transaction history; this is not an exhaustive list. Please note: we do not collect or store any credit card billing information.
1.2 Information you provide us indirectly
Additionally, we may receive “Usage Data” indirectly from Users and link such data to Personal Information. Examples may include: browser type, operating system, webpage history, or internet service provider; this is not an exhaustive list.
2. How we use this information
Our practice is not to store, collect, or share Personal Information you share directly with us unless you opt in explicitly. If you have not signed up to receive communications, registered for our events, nor requested us to perform any services for you, then you are not opted in to any type of data collection or storage, with the exception of Usage Data, noted above, and cookies, noted below. We use those sources of information not to perform a service, but to facilitate effective operation of our Sites and a positive User experience.
What types of data do cookies collect?
The types of data cookies collect depend on the category. Not all cookies collect all types of data; it varies site to site and cookie to cookie. For example, cookies might collect and store information about your web sessions, online browsing activities, browser settings and preferences, and information to identify users and devices over time to help you access and manage the site faster and so the site may operate more efficiently. This is not an exhaustive list, but gives you an idea to better understand the information involved.
What is the purpose of the types of cookies we use?
Security. Cookies strictly necessary to provide Site services and functions. For example, improving the safety and security of our Site.
Preferences & Features. Cookies that store previous selections you made to provide a more personalized experience. For example, redirecting to a mobile version of the Site when you are browsing with a smartphone.
Performance, Analytics & Research. Cookies collect information about how you use our Site. For example, identifying the pages you visit within our Site, compiling statistics on how our Site is used and identifying any errors users experience.
Please note: Some third party products that we may use, may place a unique cookie on your device to use technical information about your browser and activity on our Site. Altinity does not control the use of any such third-party embedded cookies nor is Altinity technically able to access such cookies, because they can only be accessed by the party who originally set them. Please refer to the associated links noted below where you can find a list of potential third parties and links to their privacy policies and cookies policies. We strongly recommend you read these policies to see what information they collect, use and share about you.
|Third Party||Type of Cookies||Link|
|Google Analytics and Adwords||https://policies.google.com/privacy|
|Squarespace||Squarespace Analytics and Site maintenance||https://www.squarespace.com/privacy|
How can you control cookies? Can you disable cookies?
You may control cookies through your browser setting preferences. Browser settings may be adjusted to automatically accept or decline cookies and/or to alert you when a website is attempting to put one in place. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies, please consult the privacy features in your browser. However, you should note that disabling cookies may affect the functionality of the Site and disable any customized content.
3. How we share your information
We share information with third parties only as required to fulfill Users’ requests relating to functions that we do not provide ourselves, e.g. registering for events. Except in connection with a corporate restructuring or sale of substantially all of our assets, we will not share or sell your contact information or email lists to others. We never share or sell your information for others to market to you, so there is no need to opt out of third-party marketing.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.
4. Storing your information
The information collected by us may be processed and/or stored in the United Kingdom, European Union Member Nations, the United States, or any other country in which Altinity or its service providers maintain operations. We may transfer information that we collect, including personally identifiable information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction of domicile to other countries or jurisdictions. If you are located in the European Union or other regions with laws restricting transferring of data, please note that we will comply with laws applicable to us.
5. Your choices regarding collection, use, and sharing of your information
As stated above, we believe in limiting the collection, use, and sharing of your Personal Information to the most reasonable extent possible, using it solely for the purpose that we disclose to you when we initially collect it. We also provide you with the ability to change your mind. For example, if you wish to opt out of our newsletter mailings, you may select the opt out link which can be found at the bottom of any message, in which case your email will be placed on a “do-not-mail” list and we will stop sending you any newsletters.
5.1 Rights in Certain Jurisdictions
Based on jurisdiction, there are may be certain access, erasure, and other rights which individuals may have to their data Personal Information, including the right to manage our treatment of their Personal Information and the way in which it is processed.
5.2 Provisions Applicable to Persons in the European Union and European Economic Area
This section 5.2 applies only to those who reside in the European Union or European Economic Area (EEA).
5.2.1 Transfers of information outside of the European Economic Area
Since we are part of a group of companies and use third parties services, we may process your Personal Information outside of the European Economic Area. We do this in the ordinary course of our business.
5.2.2 Your rights
As a data subject under EU data protection laws, you have specific legal rights relating to the Personal Information we collect from you. We will respect your individual rights and will deal with your concerns adequately.
a. Right to withdraw consent: Where you have given consent for the processing of your Personal Information, you may withdraw your consent at any moment.
b. Right to rectification: You may obtain from us rectification of your Personal Information. We make reasonable efforts to keep Personal Information in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
c. Right to access: You may request information regarding Personal Information that we hold about you, including information as to which categories of Personal Information we have in our possession or control, what they are being used for, where we collected them (if not from you directly), and to whom they have been disclosed, if applicable.
We will provide you with a copy of your Personal Information upon request.
d. Right to portability: You have the right to receive Personal Information that you have provided to us, and, where technically feasible, request that we transmit such Personal Information to another organization.
You have these two rights if:
- we process your Personal Information by automated means;
- we base the processing of your Personal Information on your consent, or our processing of your Personal Information is necessary for the execution or performance of a contract to which you are a party;
- you provided your Personal Information to us; and
- the transmission of your Personal Information does not adversely affect the rights and the freedoms of other persons.
You have the right to receive your Personal Information in a structured, commonly used and machine-readable format.
Your right to receive your Personal Information must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your Personal Information to another organization also involves the transmission of the personal data of other (non-consenting) individuals.
Your right to have your Personal Information transmitted from us to another organization is a right you have only if such transmission is technically feasible.
e. Right to erasure: You have the right to request that we delete the Personal Information we process about you. We must comply with this request if we process your Personal Information, unless the data is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation that binds us;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
- for the establishment, exercise or defense of legal claims.
Note that we may not be able to delete any depersonalized data on you.
f. Right to object: You may object – at any time – to the processing of your Personal Information due to your particular situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. In this event, we shall no longer process your Personal Information, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your Personal Information; otherwise, we will only restrict it.
You may always object to the processing of your Personal Information for direct marketing purposes, even if it was based on our legitimate interest for any reason. If the marketing was based on your consent, you can withdraw consent.
g. Right to lodge a complaint: You can lodge a complaint to the data protection authority. For more information, please contact your local data protection authority.
- Time period: We will try to fulfil your request within 30 days, which may be extended due to specific reasons relating to the specific legal right or the complexity of your request. In all cases, if this period is extended, we will inform you about the cause and anticipated length of the extension.
- Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.
- No identification: In some cases, we may not be able to look up your Personal Information due to the choice of identifiers provided in your request. In such cases, where we cannot identify you as a data subject, we will not be able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
- Exercise your legal rights: In order to exercise your legal rights, please contact us in writing (including electronically) at the contact details provided below.
6. Contact Information
Please direct your questions regarding the subject matter of data protection and any requests in the exercise of your legal rights to the following:
Altinity Ltd: Office 2, Derby House, 123 Watling Street, Gillingham, Kent, ME7 2YY, UK
We will investigate and attempt to resolve any request or complaint regarding the use or disclosure of your Personal Information. If you are not satisfied with our reply and you are from the European Union, you may also make a complaint to the data protection authority, as indicated in section 5.2.2(g) above.