Altio is committed to protecting the security of Your Personal and Business information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.
However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that Your information will be secure at all times. Transmission of personal information over the Internet is at Your own risk and You should only enter, or instruct the entering of, personal information to the Service within a secure environment.
For the purpose of this policy, the terms "personal Information", "personal data", "process" and "processor" shall have the same meaning as set out in Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
1. Information we collect
When you use our Website, you may provide Altio with two main types of information: (1) Non-Personal Information and (2) Personal Information. We collect information from you when you (a) use and/or access our Website, (b) open and/or respond to our emails, (c) contact Altio, (c) visit any page online that displays our content, (d) purchase products through our Website, and/or (e) provide information to any of our Service Providers. To view our Website you do not need to submit any Personal Information other than your name, email address, general geographic location, profession and/or industry that you operate in.
1.1 Personal Information
1.2 Non-Personal Information
“Non-Personal Information” is general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you use our Website. We collect Non-Personal Information such as:
• Business information via API and information manually submitted by You via email or via our website. Business information includes accounting information, invoices and bills, client information and any information that is gathered from the various API keys provided to Altio. This information is confidential and will only be used for the purpose of the service and to enrich any benchmark as long as there is a statistical inability for any other clients to reverse engineers the benchmark to identify your information. Any business information will be secured within our systems and accessible to only the Altio employees in charge of your company or Altio senior management. During a transaction, certain information will be shared with the investor as to enable a transaction. Altio will focus on limiting to the maximum extent the transfer of information and will provide the ability for you to review in advance what information is being shared with investors.
• Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Website, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
• Aggregate: We may collect non-identifying and statistical information about the use of our Website, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.
• Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on our Website and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your Personal Information.
1.3. Information you provide by using the Website
You may submit User Content (as defined in the Terms and Conditions) to the Website, including certain information via online forms.
1.4. Information you send to other Users
2. How we use and share information
2.1 General Use.
• operate, maintain, and improve our sites, products, and Website;
• if you are a borrower, (or a director, partner, member, shareholder, beneficial owner or guarantor of a borrower):
o to ascertain your borrowing needs;
o to assess your creditworthiness and to make credit-related decisions; and
o if you miss any repayment of your loan, to trace your whereabouts and recover debts or enforce a loan contract or personal guarantee and to verify any payment plan you have proposed or income and expenditure form you have submitted;
• respond to comments and questions and provide customer service;
• provide technical support;
• to carry out mandatory or other regulatory checks;
• to comply with our legal and regulatory obligations;
• to carry out statistical analysis and market research and testing;
• for the prevention and detection of fraud, money laundering, or other illegal or criminal activity
• send information including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;
• communicate about promotions, upcoming events, other news about products and services offered by us and our selected partners;
• send you reminders, support and marketing messages;
• manage our administration of the Website;
• link or combine user information with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
• protect, investigate, and deter against fraudulent, unauthorized and/or illegal activity;
• to process orders and/or otherwise provide and deliver products and services you request;
• to process and deliver orders for additional services;
• identify you as a user in our system;
• facilitate the creation of and secure your Account on our network; and/or
• develop and improve marketing and advertising for the Website and partner services.
The information collected in the aggregate enables Altio to better understand your use of the Website and to enhance your experience. We may use financial information to process payment for any purchases made on the Website, enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Website, you agree to receive certain communications from us including but not limited to the following:
Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time on our website. Out of respect for your privacy, you may elect not to receive these types of communications by changing your account setting through the Website.
Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
Supplementation of Information. In order to process your financial details or credit card orders, we can use a third party provider to validate and verify your account information. All billing and account information is transmitted via https, which is a secure encrypted protocol system.
2.2 Parties with whom we may share your information:
We may disclose your Personal and Business information to other registered members of our marketplace, including:
• to operate our system and seek to match investors and borrowers;
• to provide transactional and performance information;
• to provide updates (including if and when there are late repayments or if and when a risk-banding has been downgraded); and
• if required to enforce (or make preparations to enforce) any loan contract or personal guarantee.
In this context, investors may mean individual corporate investors or institutional investors.
If you, as a registered member of our system, receive information about another registered member, then you must only use that information to communicate with us about your loan contract with that member. You acknowledge that we are not responsible for misuse of transactional or other information by other members but you must inform us promptly if you are the victim of any misuse of that information.
We may disclose your personal data:
• to companies in our group and our affiliates;
• to our suppliers, sub-contractors and third party data processors (including card payment and direct debit payment processors, marketing and data analytics service providers, collection agents, tracing agents, insolvency practitioners, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; marketplace support; and back-up and business continuity);
• with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
• to credit reference and fraud prevention agencies;
• if we are unable to provide you with credit by one of the investors on the platform and if you consent, to third parties who may be in a position to arrange credit for you;
• to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
• if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency;
• if you are represented by an Agent, to your Agent; and
• to any other person with your prior consent to do so.
Third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.
Save as expressly provided above, or otherwise without your consent, we will not share your personal data with any third party.
We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. For example, we will disclose your Personal Information in the following circumstances: (i) to investigate and defend Altio members against any third party claims and/or allegations and/or otherwise to protect Altio from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Website and/or (v) to protect the security and/or integrity of the Service. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address, user ID history, fraud complaints, and usage history, without a subpoena, in connection with an investigation of fraud, intellectual property infringement, piracy, and/or other unlawful activity.
2.4 Business Transitions
2.5 Data Retention
We will not keep your personal data for longer than is necessary for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements. These requirements generally permit us to retain our borrower and investor files for a period of six years after the end of the borrowing/investing relationship (i.e. the date on which we no longer provide services to you as a borrower or investor). We may retain data for longer than this in certain circumstances, for example in the event of an ongoing dispute.
3. Information Choices
Depending on the situation, Altio may obtain consent to the collection of Personal Information in different ways. Express consent may be obtained verbally, online and/or in writing. Implied consent may be obtained through your use of our Website and related services, and/or when you approach us to obtain information, inquire about or request services from us. Altio will offer individuals the opportunity to choose (opt out) whether their Personal Information is to be used for any purpose other than what it was collected for. We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Altio, and you can limit the communications that Altio sends to you. If you visit our Website and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such Personal Information by contacting us and/or by changing your preferences on the Website. Please be aware that even after your request for a change is processed, Altio may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Website. Altio may retain information (including without limitation your account information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide Altio with requested information, you may not be able to use and/or access our Website.
4. Service Eligibility and Changes
4.1 Children and Minors
Altio does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us Personal Information, please contact us at info@Altiotech.com. By using the Website, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Website.
5. Other websites and services
6. How we protect information
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. Because the internet is not a completely secure environment, Altio cannot warrant the security of any information you transmit to Altio or guarantee that information on the Website may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. In addition, while we take reasonable measure to ensure that Service Providers keep your information confidential and secure, such Service Provider’s practices are ultimately beyond our control. We are not responsible for the functionality, privacy and/or security measures of any other organization. By using our Website, you acknowledge that you understand and agree to assume these risks.
8. How to contact us