Alotten Privacy Policy

Introduction: This Privacy Policy (“Privacy Policy”) explains how Alotten, Inc. (either the “Company” or “Alotten”) collects, uses and discloses your personal information, including the categories of personal information we process and the purposes for which we use it. This Privacy Policy applies to any personal information you provide to Alotten and any personal information we collect when you use any service we provide (each, a “Service), contact or communicate with us, visit or use our websites or applications, visit an Alotten location or attend events or seminars involving Alotten. This Privacy Policy may be supplemented by additional privacy statements, data processing terms or agreements, or other terms or notices relevant to the applicable Services.
This Privacy Policy does not apply to your use of any third-party sites linked to from or otherwise used or accessed in connection with our websites or Services.
Collecting your information
1. Types of information we collect
  
  The personal information we collect varies depending upon the nature of our Services and how you interact with us. Where we collect sensitive personal information (such as payment information), this information is only collected where strictly relevant to the Services we provide and is done in accordance with applicable law. The information we collect about you may include the following:
  1. Contact details: such as your name, email, postal address, social media handle, and phone number
  2. Unique identifiers: such as Passport Number, National ID, National Insurance Number or pension scheme reference number
  3. Demographic details: such as your date of birth, age, gender, race, ethnicity, photo and marital status
  4. Employment information: such as job title, employee number, employment status, salary, employment benefits, and employment history, qualifications and affiliations
  5. Health information: such as medical records, health status, benefits information and medical assessment outcomes
  6. Financial information: such as credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details, bank account details, tax information, and other financial information necessary to process payments to you
  7. Marketing and communications preferences: such as interests and preferred language
  8. Online information: such as computer, device and connection information (e.g. IP address, browser type, operating system, unique device identifier), usage data collected when visiting our websites, device location information
  9. Events information: such as information about your interest in and attendance at our events, including provision of feedback forms
  10. Background checking information: such as inclusion on a sanctions list or a public list of disqualified directors, the existence of previous or alleged criminal offenses, or confirmation of clean criminal records, information in relation to politically exposed persons (“PEPs”)
  11. Comments, feedback or other information provided to us: such as social media interactions with our social media presence, comments provided on feedback forms or surveys and feedback or other ideas provided in connection with our Services
  12. Account login credentials: such as username and password, password hints and security information related to a Service we provide
  13. Payment information: such as credit or debit card number and bank account details
2. Sources of information
  We collect personal information about you in the following ways:
  1. Information you provide directly to us: we collect personal information about you when you request a Service from us; visit an Alotten site or attend an event or seminar; apply for a position at Alotten; through your use of our Services; when you provide comments, feedback or communicate with us
  2. Information from your organization: we may obtain personal information about you from the organization with which you are employed or affiliated, in order to provide Services to them and/or manage your access to and use of the organization’s Service
  3. Information we collect automatically: we may collect certain types of information about you automatically when you use our Services, visit our websites or communicate with us online or through the emails that we may exchange. We may collect this information through the use of “cookies” or similar technologies such as web beacons, gif or pixel tags or other unique identifiers to analyze online activity.
  4. Information from third parties: we may collect personal information about you from other third parties, such as recruitment agencies, insurers, underwriters, reinsurers, credit reference agencies, medical professionals, government bodies, claimants, sponsors, joint venture entities or business partners, as well as vetting and data validation agencies and other professional advisory service providers.
3. Impact of failing to provide information
  You are required to provide any personal information we reasonably require (in a form acceptable to us) to meet our obligations in connection with the Services we provide to you, including any legal and regulatory obligations. Where you fail to provide or delay in providing information, we reasonably require to fulfill these obligations, we may be unable to offer the Services to you and/or we may terminate the Services provided with immediate effect.
4. Information you provide relating to third parties
  Where you provide personal information to Alotten about third-party individuals (e.g. information about your employees, spouse, civil partner, child(ren), dependents or emergency contacts), where appropriate, you should provide these individuals with a copy of this Privacy Policy beforehand or otherwise ensure they are otherwise made aware of how their information will be used by Alotten. Where you provide information to us about your beneficiaries, we may require you to provide explicit consent on their behalf.
5. Information relating to children
  Our Services are not directed to children, and we do not knowingly collect personal information from children. Certain Alotten solution lines may process data related to children, such as their date of birth, address, and other identifiable information. This information is not collected directly from children, but from other parties such as from our client, the carrier, or directly from you as the parent or guardian of the child (e.g., so that the child may be named a beneficiary to an insurance policy or pension plan).
Processing your information: We will use the information we collect about you in connection with the Services to:
1. offer and provide the Services to you and other customers, partners, users, prospective customers or partners, employees or other third parties as legitimately related to our business (and provided that personal information used in our Services will be aggregated and anonymized except for a client’s own data accessed in the Services such client subscribed for);
2. carry out due diligence, identity, credit reference, bankruptcy, sanctions, data validation, anti-money laundering, “Know Your Customer” and other business acceptance, vetting and risk management agency checks;
3. evaluate human resources or other market information pertaining to our legitimate business or prospective business;
4. process payments;
5. communicate with you and to respond to your requests, inquiries, comments and concerns;
6. research, audit, reporting and other business operations purposes, including determining the effectiveness of our promotional campaigns and evaluating business performance;
7. fulfill legal and regulatory obligations, resolve disputes and monitor compliance with the same;
8. transfer books of business to successors of the business in the event of a sale or reorganization, including the planning and due diligence purposes both prior to closing and after a transaction has closed;
9. process applications for employment and inform recruitment decisions taken about appointments and new hires;
10. conduct market research and canvass your views about the Services and to develop and improve our products and Service offerings generally;
11. offer other products and Services that may be of interest to our clients, partners or prospective clients or partners, including sending newsletters, know-how, promotional material and other communications;
12. perform benchmarking, modeling, market research and data analysis associated with the development of new and existing processes, products and Services; and
13. invite you to events or seminars, including arranging and administering those events.
Legal grounds for processing: We rely on the following legal grounds to collect and use your personal information:
1. Performance of the service contract
  
  When we offer Services or enter into a contract with you to provide Services, we will collect and use your personal information where necessary to enable us to take steps to offer you the Services, process your acceptance of the offer and fulfill our obligations in the contract with you.
2. Legal and regulatory obligations
  
  The collection and use of some aspects of your personal information is necessary to enable us to meet our legal and regulatory obligations. For example, Alotten is licensed and regulated by certain industry regulators and is required to provide some services in accordance with relevant regulatory rules.
3. Legitimate interests
  
  The collection and use of some aspects of your personal information is necessary to enable us to pursue our legitimate commercial interests.
  
  For example, we have legitimate interests in:
  - providing our Services;
  - operating our business, and managing and developing our relationships with clients, suppliers and with you;
  - understanding and responding to inquiries;
  - receiving information from third parties to provide their services related to our business;
  - sharing data in connection with mergers and acquisitions and transfers of business;
  - improving our Services; and
  - understanding how you and our clients use or would like to use our Services.
  Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.
4. Consent
  
  We rely on your consent to collect and use personal information concerning any agreement we have with you, including for our Services or other services or matters.
  
  Where we rely on your consent to collect and use your information, you are not obliged to provide your consent and you may choose not to provide your consent. We may allow you to subsequently withdraw your consent after it is provided to the extent we are legally required or otherwise choose to do so. Where you refuse to provide information that we reasonably require to provide the Services, we may be unable to offer you the Services and/or we may terminate the Services provided with immediate effect.
  
  Where you choose to receive the Services from us you agree to the collection and use of your personal information in the way we describe in this Privacy Policy.
5. Substantial public interest
  
  If applicable law allows, we may collect and use your information for a substantial public interest. For example, to prevent or detect unlawful acts or in public health.
Country specific exemptions and grounds for legal processing

In certain circumstances, we may also rely on specific exemptions provided for under applicable local/national laws in the United Kingdom (“UK”), EU Member States or other countries worldwide. We may also rely on specific legal grounds for processing provided for under applicable local/national laws in the UK, EU Member States or other countries worldwide.
Accuracy of your information: We rely on the availability of accurate personal information in order to provide the Services to you and operate our business. You should therefore notify us of any changes to your personal information, particularly changes concerning your contact details, bank account details or any other information that may affect our relationship and/or the Services provided to you.
Recipients of your information: We generally share your personal information with the following categories of recipients where necessary to offer, administer and manage the Services provided to you:
1. within Alotten: we may share your personal information within our organization for the processing purposes outlined in this Privacy Policy;
2. in connection with Services: where necessary to develop, offer, administer and manage the Services provided to you;
3. law enforcement bodies: where necessary to facilitate the prevention or detection of crime or the apprehension or prosecution of offenders;
4. public authorities, regulators and government bodies: where necessary for us to comply with our legal and regulatory obligations;
5. third party suppliers: where we outsource our processing operations to suppliers that process personal information on our behalf. These processing operations shall remain under our control and will be carried out in accordance with our security standards and strict instructions;
6. successors of the business: where Alotten or the Services are sold to, acquired by or merged with another organization, in whole or in part. Where personal information is shared in these circumstances it will continue to be used in accordance with this Privacy Policy;
7. business partners: such as joint venture entities, sponsors and/or other third-party business partners who collaborate or co-operate with Alotten on projects, events, products or Services. You should refer to their privacy notices for more information about their privacy practices; and
8. internal and external legal counsel and auditors: where necessary for legitimate business operations.
Overseas transfers of your information: We and/or our customers and partners operate on a global basis, and we therefore reserve the right to transfer personal information about you to other countries to be processed for the purposes outlined in this Privacy Policy. In particular, we may make such transfers to offer, administer and manage the Services provided to you and improve the efficiency of our business operations. We shall endeavor to ensure that such transfers comply with all applicable data privacy laws and regulations and provide appropriate protection for the rights and freedoms conferred to individuals under such laws.
Where we collect personal information about you in the UK or the European Economic Area (the “EEA”) we may transfer the information to countries outside the UK or EEA for the processing purposes outlined in this Privacy Policy. This may include transfers to countries that the European Commission (the “EC”) and UK data protection regulator consider to provide adequate data privacy safeguards and to some countries that are not subject to an adequacy decision. Where we transfer personal information to countries that are not subject to an adequacy decision we shall put in place appropriate safeguards, such as standard contractual clauses approved by the EC or UK data protection regulator, as appropriate. Where necessary, we may implement additional technical, organizational or contractual measures to ensure an adequate level of protection for your personal information.
Retention of your information: We retain appropriate records of your personal information to operate our business and comply with our legal and regulatory obligations. These records are retained for predefined retention periods. In most cases we shall retain your personal information for no longer than is required under the applicable laws, except that for purposes of providing Services, we will retain your data for so long as we provide our Services, provided that personal data shall be aggregated and encrypted in connection with the provision of our Services. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.
Information Security: The security of your personal information is important to us, and we have implemented appropriate security measures to protect the confidentiality, integrity and availability of the personal information we collect about you and ensure that such information is processed in accordance with applicable data privacy laws.
Your Information Rights
You have the following rights under applicable data privacy laws in respect of any personal information we collect and use about you:
1. Right to access: a right to access and inspect your personal information or be provided with a permanent copy of the information being held about you.
2. Right to correction: a right to request the correction of your personal information or in cases where the accuracy of information is disputed, to supplement the information to give notice that you dispute its accuracy.
3. Right to erasure: a right to request the erasure of your personal information, particularly where the continued use of the information is no longer necessary.
4. Right to object to processing: a right to object to the use of your personal information, particularly where you feel there are no longer sufficient legitimate grounds for us to continue processing the information.
5. Right to object to direct marketing: a right to object to the use of your personal information for direct marketing purposes. See Section Error! Reference source not found. below for further information.
6. Right to restrict processing: a right to request the restriction of your personal information from further use, e.g. where the accuracy of the information is disputed, and you request that the information not be used until its accuracy is confirmed.
7. Right to portability: The right to request that some aspects of your personal information be provided to you or a third party of your choice in electronic form to enable its reuse.
8. Right to object to automated decision making: a right to object to decisions involving the use of your personal information, which have been taken solely by automated means. See below for further information.
9. Right to lodge a complaint with a regulator: a right to complain to the relevant data protection regulator about our processing of your personal information. See below for further information.
It is important to note, however, that some of the rights described above can only be exercised in certain circumstances. If we are unable to fulfill a request from you to exercise one of your rights under applicable data privacy laws, we will write to you to explain the reason for refusal. Where required, further information concerning these rights and their application can be obtained by contacting us.
Direct Marketing: We will use your personal information to send you direct marketing about other products and services that we feel may be of interest to you. We will give you the opportunity to refuse direct marketing at the point that you apply or register to receive the services and, on each occasion, thereafter that you receive direct marketing communications from us. You can also change your marketing preferences at any stage by contacting us. Please note that, even if you opt out of receiving direct marketing communications, we may still send you service-related communications where necessary.
Automated Decisions: Where you apply or register to receive a Service, we may carry out a real-time automated assessment to determine whether you are eligible to purchase or receive the Service. An automated assessment is an assessment carried out automatically using technological means (e.g., computer systems) without human involvement. This assessment will analyze your personal information and perform certain checks, such as credit or fraud prevention checks. Where your application to receive the Service does not appear to meet the eligible criteria, it may be automatically refused, and you will receive notification of this during the application process. However, where a decision is taken solely by automated means involving the use of your personal information, you have the right to challenge the decision and ask us to reconsider the matter, with human intervention. If you wish to exercise this right, you should contact us.
Complaints: If you wish to make a complaint about the way we use your personal information you should raise this with us by contacting us using the details set out below. However, if you are not satisfied with the way we have handled your complaint you have the right to raise the matter with the relevant data protection regulator in your country.
Contact us: If you have any questions about the content of this Privacy Policy or the rights conferred to you under the applicable data privacy laws, you should contact legal@alotten.com.
Changes to this Privacy Policy: This Privacy Policy is not contractual, and Alotten reserves the right to reasonably amend it from time to time to ensure it continues to accurately reflect the way that we collect and use personal information about you. Any updates or changes to this Privacy Policy will be made available to you. You should periodically review this Privacy Policy to ensure you understand how we collect and use your personal information.

This Privacy Policy became effective on April 17, 2023.