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OUR DATA CONTROLLER INFORMATION

The legal person who is responsible for the processing of personal data is ALTO SOCIAL ANALYTICS, S.L (hereinafter “Alto Analytics”), with identification number. B85090538, registered in Company Registry of Madrid, office based in Avenida De Europa, 24, 28108, Alcobendas, Madrid Spain.

Our Data Protection Officer information is the following should you need to get in contact: dpo@alto-analytics.com

WHY DO WE COLLECT AND PROCESS PERSONAL DATA?

IF YOU HAVE SIGNED UP FOR OUR NEWSLETTER

We inform you that the personal data that could be provided through our Site will be processed with the following purposes: to offer you new services or products and send you information related to our activities through email.

Your personal data will be kept until determined by the applicable regulations or if you request otherwise, as explained below.

You are free to provide or not the data that may be required, however, all data requested are necessary for the provision of an optimal service.

The legal bases for the processing of your data is given electronically by checking the corresponding box on Alto Analytics Site.

Except as explicitly consented by you or as a legal obligation, we do not disclose to third parties the personal data you have provided us. However, we may use e-mailing tools from companies out of the EEA who we have made sure they process your data safely, fact that you consent to when subscribing to our newsletter.

IF YOU HAVE CONTRACTED ANY OF OUR SERVICES

We require customers who contract any of the Services offered on our Site (collectively, the “Services”) to give us contact information (collectively “Customer Data”), such as their name, company name, address, phone number, e-mail address, financial qualification and billing information, such as billing name and address, along with the number of customers within the organization that will be using the Services. When Customers have interest in our services we might also request as part of the sales process additional information about them and their companies such as title, department name, fax number, annual revenues, number of employees, or industry. When projects are initiated, we might also need to request sensitive information such as project’s business goals or launch dates of products or services within project scope depending on the nature of the project.

Customer information is considered confidential and customers can opt in for a dedicated Non-Disclosure Agreement (“NDA”) as part of the contract. Customers can also opt out of providing any additional information when asked as well as update or remove their personal information at any time by requesting their account manager to do so or at info@alto-analytics.com.

Alto Analytics uses client information collected to set up the services for the client’s employees. We may also use the information to contact clients to further discuss additional services, the Services that we provide them, and to send information regarding our company or partners, such as promotions and events or Company announcements or email newsletters. Clients email addresses and any personal client information will not be distributed or shared with third parties. Clients can opt out from receiving such information from us, at any time by sending an email to their account manager or to info@alto-analytics.com.

All financial and billing information that we collect is used solely to check the qualifications of Customers and to bill for the Services. This billing information is not used by Alto Analytics for marketing or promotional purposes. Alto Analytics uses a third-party bank intermediary to manage the invoicing and payment processing. This intermediary is solely a link in the distribution chain, and is not permitted to store, retain, or use the information provided, except for the sole purpose of payment processing.

Customers of the Service might be using Analyzer to host Customer Data. Alto Analytics will not share, distribute, print, or reference any such Customer Data except as provided in the contract with the customer, or as may be required by law. Individual records may at times be viewed or accessed only for the purpose of resolving a problem, support issue, or suspected violation of contract, or as may be required by law. Of course, customers are responsible for maintaining the confidentiality and security of their user registration and password.

The Customers Data will be kept by Alto Analytics until the contract of the Services have ceased and will be blocked until determined by the applicable regulations.

COLLECTED INDEXED INFORMATION

Alto Analytics Analyzer’s service collects information that has been made publicly available on the Internet and that is accessed, used and maintained in connection with the provision of the Analyzer service.

Analyzer provide Customers with different services such as the ability to: (i) monitor, access, and manage indexed information relating to their businesses, brands, activities and industries; (ii) initiate online conversations with individuals posting indexed information on the Internet; (iii) analyze trends in indexed information, such as volume; and (iv) measure engagement with, and performance of, indexed information posted by Customers.

To provide these services, Alto Analytics collects indexed information from a variety of publicly available portions of the Web, such as Web sites, blogs, news Web sites, and social networking Web sites. In general, anyone can find the indexed information via any standard Internet search engine or by visiting the applicable Web sites themselves. Alto Analytics obtains indexed information using proprietary Web crawler technology, via public APIs, or through agreements with Web site operators or other third party providers. The Company also may obtain indexed information directly from Customers’ social networking Web sites upon their request and in accordance with the authentication process established by such social networking Web sites. When the Company collects indexed information via its own Web crawling technology, the Company abides by the applicable Web sites’ robots.txt protocols. The Company does not circumvent technical controls in place to prevent unauthorized access, such as use of CAPTCHA technology. The Company’s Web crawlers are designed to limit crawling to portions of Web sites that are made public by the applicable Web site operator.

Customers are responsible for their use of indexed information. Alto Analytics requires customers to use indexed information in accordance with the terms of service of the applicable Web site from which the indexed information is obtained or derived, and applicable law.

Analyzer provides customers with various methods to analyze and draw conclusions from indexed information, such as categorizing or aggregating indexed information and displaying it through various graphs and representations, as well as supplementing it with other data and insights. In some cases, the Company uses third parties to provide additional analysis of and supplemental data for the indexed information. The Company also provides customers with the ability to conduct historic analysis on indexed information to the extent such data is available. Should the costumer be located in a third country which does not ensure an adequate level of data protection, for the purposes of Article 46(2) of GDPR, the Customer must sign our additional Standard Contractual Clauses.

SECURITY

Whether you have requested our newsletter, you are our Customer, or your information has been indexed by us we’re serious about guarding the security of your personal information. We take appropriate organisational, technical, administrative and physical security measures to to help protect against the loss, misuse, and alteration of your data. We use a secure server to store the information you give us.

Specifically, our Analyzer service has security measures in place, including administrative, technical and physical, to help protect against the loss, misuse, and alteration of the Data under our control. Customers can opt in for Secure Socket Layer (SSL) technology to protect information using both server authentication and Data encryption to help ensure that data is safe, secure, and available only to them. Alto Analytics provides unique user names and passwords that must be entered each time a User logs on. These safeguards help prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of data. Customers are solely responsible for protecting their passwords, limiting access to their computers, and signing out of Analyzer after their sessions end.

INTERNATIONAL TRANSFER OF INFORMATION COLLECTED

To facilitate Alto Analytics global operations, the Company may transfer and access collected information from around the world, including the United States.

For European visitors to the Site and customers of Analyzer note that in order to provide the information or services requested, information may be transferred outside of the European Economic Area (“EEA”). By visiting the Site or contracting Services with the Company, Customers agree to Alto Analytics transferring such Information outside the EEA.

YOUR RIGHTS

Whether you have requested our newsletter, you are our Customer, or your information has been indexed by us, you have the right to obtain information about whether Alto Analytics is processing personal data that concerns you or not.

You have the right to access your personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes that they were collected for.

In certain circumstances, you may request the limitation of your data processing, in which case we will only keep them for the exercise or defence of claims.

In certain circumstances and for reasons related to your particular situation, you may object to the processing of your data. Alto Analytics L will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

You can obtain a copy of your personal data in a structured and commonly electronic format and transfer your data, and other information you have provided, from one electronic processing system to another if you wish.

You may exercise these rights by sending an email to dpo@alto-analytics.com telling us what right/s you wish to exercise, we will send you a simple template to fill in.

Likewise, we inform you that you can enforce your right to file a claim trough the competent Data Protection control authority.

CHANGES TO THIS PRIVACY STATEMENT

Alto Analytics reserves the right to change this Privacy Policy. Alto Analytics will provide notification of the material changes to this Privacy Policy through the defined communication channel in Customer’s contracts at least thirty (30) business days prior to the change taking effect.

COOKIES

When customers interact with the Alto Analytics commercial website or with Alto Analyzer service we strive to make the experiences easy and meaningful. When customers come to any of our services our Web servers sends a cookie to their computers. Cookies are files that Web browsers place on a computer’s hard drive and are used to inform Alto Analytics whether customers and visitors have visited the Site and/or Analyzer previously.

Standing alone, cookies do not identify customers personally. They merely recognize browsers. Unless customers choose to identify themselves to Alto Analytics they remain anonymous to Alto Analytics. Alto Analytics uses cookies that are session-based and persistent-based. Session cookies exist only during one session, i.e., only while customers are navigating the Site or Analyzer. These cookies disappear from customers or visitors’ computers when they close their browsers or turn off their computer. Persistent cookies remain on their computers after closing the browsers or turning off the computers. If customers disable browser’s ability to accept cookies, they will be able to navigate the Site, but the Analyzer functionality may be affected, and they may not be able to successfully use all Analyzer services.

Analyzer uses session cookies containing encrypted information to allow the system to uniquely identify customers while they are logged in. This information allows Analyzer to process customer online transactions and requests. Session cookies help Alto make sure customers are who they say they are after they have logged in and are required in order to use Analyzer application. Alto Analytics uses persistent cookies, for a maximum of 90 days, which only Alto Analytics can read and use, to identify the project that the user is associated with. We are especially careful about the security and confidentiality of the information stored in persistent cookies.

For our Site we use Google Analytics cookies, which we set automatically as part of the Google Analytics embedded scripts and which follow the Google Analytics policy, to track and analyse non-personally identifiable usage and volume statistical information from visitors to our Site to help us with its administration and improve its quality. Such cookies will not be used to associate individual Site visitors to any personally identifiable information. All data collected by Google Analytics on behalf of Alto Analytics is used only to provide us with information on site usage and is not shared with any other third parties.