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Effective date: 2024-09-13
1.1. ALFA CORPORATION - FZCO (hereinafter referred to as "ALFA CORPORATION", "Company", "us", "our" or "we") is dedicated to protecting the privacy rights of our users (hereinafter referred to as "User(s)", "you"). This Privacy Policy (hereinafter referred to as "Policy") describes how and why we collect, store, use, and manage the information, and data, including personal data, that you provide or we collect when you visit our website https://alfa-corporation.org (hereinafter referred to as "Site") or use any ALFA CORPORATION's application provided on any mobile platform (for example, iOS) (hereinafter collectively referred to as the "Service(s)"). It also tells you how you can access and update personal information and/or data and make certain choices about how personal information and/or data that you provide to ALFA CORPORATION is used.
1.2. Please note that the scope of this Policy is limited to information and data collected or received by ALFA CORPORATION through or in relation to your use of the Service. ALFA CORPORATION is not responsible for the actions of third parties, the content of third-party websites, the use of information or data you provide to third parties or any products or services they may offer. Any link to third-party websites does not constitute our sponsorship of, or affiliation with, such third parties.
1.3. ALFA CORPORATION acts as a Data Controller in relation to personal data that you provide to us.
1.4. By using our Services you agree to our Privacy Policy and confirm that you are at least 13 years old. We do not knowingly collect or solicit personal data from or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under the age of 13, please do not send any personal data to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal data from an individual under 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about an individual under the age of 13, please contact us by sending an email to contact@alfa-corporation.net
1.5. ALFA CORPORATION LTD as Data Controller does not and will not process any special categories of personal data.
1.6. From time to time, we can update this Privacy Policy. We may notify you about changes to this Policy by placing a notice via the Services or Site. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically check back and review this Policy so that you always know our current privacy practices.
2.1. We collect and combine different types of information and/or data (including personal data) together. Here you can find more about what information and/or data we collect about you when we collect it and what information and/or data we do not collect about you:
2.1.1. Registration, account, and sign-up information. We collect data in the course of your use of, or registration with ALFA CORPORATION. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal data. This type of personal data can include name (first name, last name, pseudonym or nickname) or email address (e.g., in cases when you request individual technical support or assistance, see "Customer enquiries" section).
2.1.2. Product/ service purchase. When you make a purchase, we provide you with third-party services for purchasing and your payment data (e.g. credit/debit card, billing information and delivery address) is not collected by us. Information about the user such as name (first name, last name, pseudonym or nickname), email address, telephone number and the purchased product is retained by us for further action on the product subscription.
2.1.3. From other sources. We, on occasion, combine data we receive online with other information, including usage information from our other websites and our online advertising and media. We also supplement or combine data with data from a variety of other sources or outside records, such as demographic and transaction history, and we use that combined data in accordance with this Privacy Policy.
Some types of other sources with which we share your data are:
2.1.4. Social media. You can engage with some of our content and offerings, such as videos, applications, and other offerings on or through third-party communities, forums, and social media websites, services, plug-ins, and applications ("Social Media Sites"). When you link to or interact with us or our content through Social Media Sites, you allow us to receive certain data from your social media account (e.g., your name, user ID, email address, profile photo, photos and videos, gender, date of birth, your list of friends and their contact details, people whom you follow and/or who follow you, the posts or the 'likes' you make). We also receive data from your interaction with our content (e.g., data regarding content viewed). Where permitted by law, by providing this data or otherwise interacting with our websites through Social Media Sites, you consent to our use of data from Social Media Sites in accordance with this Privacy Policy.
2.1.5. Location information. We have access to certain data about your location, such as your country or address, when you provide it to us directly or when we receive it via device information (such as an IP address). With your consent (where required by law), we may also collect data about your location (e.g. geolocation via a mobile device(s)) for the purpose of tailoring content specific to your area (such as area-based content packages), and match your device location to certain points of interest for purposes of interest-based advertising as described in this Policy. Please note, participation in this part of the Service is not a requirement for all our applications. You may at any time opt out from sharing your location by turning it off in the settings of your device.
2.1.6. Technical and usage information. We also collect certain technical and usage information such as your application data (via server log files and your user ID), access, session times and in-app purchases, device type, browser (if using our website), and operating system you are using, your Internet service provider and/or mobile carrier, unique device ID (persistent/non-persistent), device hardware type, IDFA or IDFV, MAC address, IP address, device and browser settings (if using our website), the webpages and apps you use, advertisements you see and interact with, and certain site usage information. This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for interest-based advertising as described elsewhere in this Policy. See the "Cookies and Other Technical Information" section for more information on how we may use these technologies to collect this data.
2.1.7. Customer enquiries. When you contact us through one of our customer helpdesks or customer support centres, we may collect and process the contents (including data) of your correspondence with us and/or your contact details.
2.1.8. Tracking Technologies. We and our marketing and outsourcing partners, affiliates, or analytics service providers use technologies such as cookies, beacons, scripts, and tags to identify User's computer/device and to "remember" things about your visit, such as your preferences or a user name (pseudonym or nickname). Information contained in a cookie may be linked to your personal data, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable all cookies apart from the cookies necessary for the functioning of the site and/or an app.
For collecting the above-mentioned data and making statistics and analysis we may use the following software and programs:
| Name | Registered Seat |
|---|---|
| Google Analytics, Google Ads, Google Tag, Firebase (Google LLC.) | 1600 Amphitheatre Parkway Mountain View, CA 94043, USA |
| Qonversion Inc. | 1160 Battery Street East, San Francisco, CA 94107, USA |
| Sentry (Functional Software, Inc.) | 45 Fremont St, 8th Floor, San Francisco, CA 94105, USA |
| Adjust GmbH | Saarbrücker Str. 37a, 10405 Berlin, Germany |
| Facebook Ads (Meta Platforms, Inc., Meta Platforms Ireland Limited) | 1601 Willow Road, Menlo Park, CA 94025, USA; Merrion Road, Dublin 4, D04 X2K5, Ireland |
| Apple Search Ads (Apple Inc.) | One Apple Park Way, Cupertino, CA 95014, USA |
| TikTok Ads (TikTok Pte. Ltd.) | 1 Raffles Quay, #26-10, South Tower, Singapore 048583 |
3.1. We use collected information and/or data (including personal data) for the following purposes:
3.1.1. Providing and marketing products and services. We use the information and/or data that we collect about you in order to analyze your use of our products, applications, services, and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalize, protect, and improve your experience and our offerings. For example, we use information and/or data that we collect from you to enable you to:
In addition to this, we use this information and/or data for us and our affiliates, business partners, and third parties to target, offer, market, or advertise products, programs, or services.
Lawful basis for processing including basis of legitimate interest:
3.1.2. Communicating with you. We use information and/or data that we collect about you to communicate with you, in order to:
Lawful basis for processing including basis of legitimate interest:
3.1.3. Third-party social networks. We use information and/or data that we collect about you when you interact with third-party social networking features to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third-party social network.
Lawful basis for processing including basis of legitimate interest:
3.1.4. Use of technical and usage information. We use technical and usage information to improve our design, functionality and content and to enable us to personalize your experience with our content and offerings. We use this information in order to:
Lawful basis for processing including basis of legitimate interest:
3.1.5. Compliance. We use information and/or data that we collect about our Users to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violating copyright or otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our Users and third parties.
Lawful basis for processing including basis of legitimate interest:
4.1. We share and disclose information and/or data (including personal data) for the following purposes:
4.1.1. Law enforcement bodies and courts. We disclose information and/or data when provided by law, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose information and/or data to third parties:
4.1.2. Change of control. We will transfer information and/or data regarding our Users in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.
4.1.3. Service providers. Our agents and contractors have access to information and/or data regarding our Users in order to carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, marketing, processing of payments, email and order fulfilment, administration of contests, research and analytics, and customer service.
4.1.4. Advertising networks. We share certain information and/or data regarding our Users with third parties to provide advertising to you based on your interests. For more information, please see the "Cookies and Other Technical Information" and "Ad Choices" sections below.
We use the data processing services of the following companies:
| Name | Registered Seat | Activity (data processing service) |
|---|---|---|
| Google Analytics, Google Ads, Firebase, Google Tag (Google LLC.) | 1600 Amphitheatre Parkway Mountain View, CA 94043, USA | Web analytics service that tracks and reports traffic on our website. Marketing services (provision of personalized marketing). |
| Qonversion Inc. | 1160 Battery Street East, San Francisco, CA 94107, USA | In-App subscription implementation and revenue analytics service provider, handling subscription management, receipt validation, and processing data for subscription-based monetization and user analytics. |
| Sentry (Functional Software, Inc.) | 45 Fremont St, 8th Floor, San Francisco, CA 94105, USA | Error monitoring and performance tracking service provider, handling and analysis of data for the purpose of application stability and performance monitoring, analyzing data on application errors and user experience. |
| Adjust GmbH | Saarbrücker Str. 37a, 10405 Berlin, Germany | Mobile marketing analytics and attribution platform, handling and analysis of data for the purpose of measuring app marketing performance, fraud prevention, and campaign optimization across multiple channels. |
| Facebook Ads (Meta Platforms, Inc., Meta Platforms Ireland Limited) | 1601 Willow Road, Menlo Park, CA 94025, USA; Merrion Road, Dublin 4, D04 X2K5, Ireland | Marketing provider, handling and analysis of data for the purpose of promoting a product and/or service, analyzing data on consumer behaviour and preferences, as well as creating and implementing marketing strategies to target specific audiences. |
| Apple Search Ads (Apple Inc.) | One Apple Park Way, Cupertino, CA 95014, USA | Marketing provider, handling and analysis of data for the purpose of promoting a product and/or service, analyzing data on consumer behaviour and preferences, as well as creating and implementing marketing strategies to target specific audiences. |
| TikTok Ads (TikTok Pte. Ltd.) | 1 Raffles Quay, #26-10, South Tower, Singapore 048583 | Marketing provider, handling and analysis of data for the purpose of promoting a product and/or service, analyzing data on consumer behaviour and preferences, as well as creating and implementing marketing strategies to target specific audiences. |
4.2. When sharing information with third parties, we ensure that they assume responsibilities no less than what is outlined in this Privacy Policy. We require these third parties to adhere to the information-sharing practices and standards described herein to uphold the same level of privacy protection.
4.3. When we share data with Meta Ireland Limited about users and the actions that they take on our Site and app, which we process subject to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), for the targeting our ad campaigns and ads delivery, Meta Ireland Limited is Joint Controller during Joint Processing of such data. For this purpose, we and Meta Ireland Limited have entered into the Controller Addendum to determine the respective responsibilities for compliance with the obligations under the GDPR concerning the Joint Processing. Full text of Controller Addendum and list of responsibilities are provided at: https://www.facebook.com/legal/controller_addendum.
Under Controller Addendum Meta Ireland Limited is responsible for enabling Data Subjects' rights under Articles 15-20 of the GDPR with regard to the Personal Data stored by Meta Ireland Limited after the Joint Processing.
You agree and consent that Meta Ireland Limited remains an independent Controller in accordance with Article 4(7) GDPR for any processing of such data that takes place after it has been transmitted to Meta Ireland Limited.
The information required by Article 13(1)(a) and (b) GDPR and further information on how Meta Ireland Limited processes Personal Data, including the legal basis Meta Ireland Limited relies on and the ways to exercise Data Subject rights against Meta Ireland Limited, can be found in Meta Ireland's Privacy Policy at: https://www.facebook.com/about/privacy.
4.4. When we share data with Meta Platforms, Inc. about users and the actions that they take on our Site and app which we process subject to the UK's Data Protection Act 2018 (the "UK GDPR") for the targeting our ad campaigns and ads delivery, Meta Platforms, Inc. is Joint Controller during the UK Joint Processing of such data. For this purpose we and Meta Platforms, Inc. have entered into the UK Controller Addendum to determine the respective responsibilities for compliance with the obligations under the UK GDPR with regard to the UK Joint Processing. Full text of the UK Controller Addendum and list of responsibilities are provided at: https://www.facebook.com/legal/terms/uk_controller_addendum.
Under UK Controller Addendum Meta Platforms, Inc. is responsible for enabling Data Subjects' rights under Articles 15-20 of the UK GDPR with regard to the Personal Data stored by Meta Platforms, Inc. after the UK Joint Processing.
You agree and consent that Meta Platforms, Inc. remains an independent Controller in accordance with Article 4(7) UK GDPR for any processing of data that takes place after it has been transmitted to Meta Platforms, Inc.
The information required by Article 13(1)(a) and (b) UK GDPR and further information on how Meta Platforms, Inc. processes Personal Data, including the legal basis Meta Platforms, Inc. relies on and the ways to exercise Data Subject rights against Meta Platforms, Inc., can be found in Meta's Privacy Policy at https://www.facebook.com/about/privacy.
4.5. For the avoidance of doubt, this Clause takes precedence over Clause 5.4 where the Personal Data relates to individuals living in the UK. In other cases Clause 5.3 (as applicable) takes precedence.
5.1. Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from Us, and our sharing of information and/or data relating to you with our trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at contact@alfa-corporation.net.
5.2. Ad Choices. We work with reputable third parties to present advertisements and engage in data collection, reporting, ad delivery and response measurement, and website analytics on our websites and applications and on third-party websites and applications. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from your device(s) and browser(s) (if using our website) in order to help serve advertising that will be more relevant to your interests on and off our sites and across your device(s) and browser(s) (if using our website). This type of advertising is known as interest-based advertising. For more information about interest-based advertising on your desktop or mobile browser (if using our website), and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please contact contact@alfa-corporation.net.
Also, you can access web mechanisms for exercising your choices, for instance: https://www.aboutads.info/choices.You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, and Android for Android devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
6.1. Cookies and other technologies:
6.1.1. We, and our affiliates, third-party service providers, and trusted partners send "cookies" to your device and use similar technologies in order to analyze and enhance your user experience with us, as well as for advertising purposes and social features.
6.1.2. Cookies are small text files placed in your browser (if using our website). We may also use pixels or "web beacons" that monitor your use of our website. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser (if using our website) that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.
6.1.3. We may also integrate "Software Development Kits" ("SDKs"), javascript or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app.
6.1.4. Our websites may use local stored objects ("LSOs") to provide certain content, such as video on demand, video clips, or animation, and better user experience.
6.2. We can use cookies and other technologies to help recognize your browser (if using our website) or device, maintain your preferences, provide certain features, and collect information and/or data about your online interactions with us, and your communication(s) with us. For example, when corresponding with you via HTML-capable email, web beacons and other technologies let us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with our content, and this information can be associated with Information previously collected.
6.3. We also use cookies and other technologies:
6.4. We use the following types of cookies and similar technologies:
6.4.1. Strictly necessary cookies or similar technologies. They are essential in order to enable you to move around our websites and apps and use their features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
6.4.2. Performance cookies or similar technologies. They collect information about how you use our websites and apps so that we can analyze traffic and understand Users' interactions. We may use third-party service providers such as Google Analytics, who may use their own cookies or similar technologies, for this purpose.
6.4.3. Functionality cookies or similar technologies. They allow our websites and apps to remember choices that you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide the services you have asked for.
6.4.4. Social media cookies or similar technologies. They are used when you share information using a social media sharing button or "like" button on our websites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The corresponding social network will record that you have done this. This information may be linked to targeting/advertising activities.
6.4.5. Advertising cookies or similar technologies. Some of our websites or apps may use third-party advertising networks to deliver targeted advertising. They may also have the capability to track your browsing across websites (if using our website), apps and Social Media Sites.
For more information about cookies and opt out options please contact contact@alfa-corporation.net.
7.1. We will only retain your personal data for as long as is necessary for the purposes described in this Policy. This means that our data retention periods will vary according to the reason for collection. Generally, your service-related personal data will be kept for as long as you remain our User (this way, in the event that you delete your account on the Services, we will immediately delete any personal data (with the exception of data specified in clause 8.2 of this Policy), provided under such account, including, but not limited to, your name, gender, profile picture, logs, and any information on and from social networks, linked to the such account).
In some circumstances, you can request the erasure of your personal data. This enables you to ask us to delete or remove personal data without a good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes: by analyzing anonymized data, we are able to build safe and valuable products and features, and better detect security threats all while protecting user identities. We can also safely share anonymized data externally, making it useful for others without putting the privacy of our users at risk.
7.2. Yet, some personal data relating to the provision of Services to you will be kept for a longer period, as long as necessary to comply with various finance- and tax-related legal obligations. After a retention period has elapsed, the personal data is securely deleted.
8.1. Under certain conditions, you have the right to ask us for a copy of your personal data, as well as to correct it, delete it or restrict its processing, and obtain the personal data that you provided to us in a structured, machine-readable format. You have the right to object to the processing of personal data on the basis of our legitimate interests. Where we have asked for your consent to process your personal data, you have the right to withdraw this consent at any time.
8.2. To exercise any of the above rights, please contact us at contact@alfa-corporation.net.
8.3. In addition to the above rights, as a resident of the EU/EEA you also have a right to lodge a complaint to your local supervisory authority.
8.4. In cases permitted by law we reserve the right not to allow access to your personal data or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal data even if you withdraw your consent.
9.1. We maintain servers around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data.
9.2. When we transfer your Information to our group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your personal data to third parties outside the EEA. You may obtain a copy of the documents we use to protect your personal data when it is transferred outside the EEA by contacting us via email at contact@alfa-corporation.net.
10.1. As a non-EEA resident controller, we have appointed a local representative in the EEA. Our local EEA representative can be contacted as follows:
ALFA CORPORATION LTD
Email: contact@alfa-corporation.net
10.2. If you have any questions about this Privacy Policy you can contact us at: contact@alfa-corporation.net.
Effective date: April 30, 2025
This Privacy Notice supplements the information contained in ALFA CORPORATION LTD's ("ALFA CORPORATION," "Company," "us," "our," or "we") Privacy Policy ("Site Privacy Policy"). It is specifically tailored to address the data privacy laws applicable to our interactions solely with visitors, Users, and other individuals residing in the United States, namely California, Colorado, Connecticut, Utah, Virginia, Illinois, Texas, and Washington ("consumers," "you," or "your"). By referring to both this Privacy Notice and the Site Privacy Policy, you gain a comprehensive understanding of our data processing practices.
Your privacy is of utmost importance to us. By using our applications and services, you acknowledge and consent to the terms outlined in this Privacy Notice and the Site Privacy Policy.
For this notice, all terms defined in applicable legislation shall have the same meaning when used herein. Any capitalized terms not defined within this document shall carry the meanings ascribed to them in the Company's Privacy Policy. In the event of any inconsistencies between this Privacy Notice and the Company's Privacy Policy, the provisions of this Privacy Notice shall prevail.
1.1. We may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").
1.2. In particular, we may collect the following categories of personal information from you within the last twelve (12) months:
A. Identifiers. Examples: name, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Personal information categories. Examples: name, signature, physical characteristics or description, address, and telephone number. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under U.S. laws. Examples: age, race, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity. Examples: Browsing history (if using our website), search history, and information on a consumer's interaction with a website, application, or advertisement.
F. Geolocation data. Examples: Physical location or movements.
G. Sensory data. Examples: Audio, electronic, visual, or similar information.
H. Inferences are drawn from other personal information. Examples: profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
1.3. Personal information does not include:
2.1. We may use or disclose the personal information we collect for one or more of the following purposes:
3.1. We may disclose your personal information to a third party for business purposes. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
3.2. In the preceding twelve (12) months, we may disclose the following categories of personal information for a business purpose:
3.3. We may disclose your personal information for business purposes to the following categories of third parties:
3.4. We may share your personal information for the following general purposes:
3.5. We have not sold any personal information.
The U.S. laws provide consumers with specific rights regarding their personal information. This section describes it. To guarantee full transparency and openness, we have outlined the primary rights and business obligations clearly and practically within this Privacy Notice for your easy understanding and practical utility:
| California (CCPA/CPRA) | Colorado (CPA) | Connecticut (CTDPA) | Utah (UCPA) | Virginia (VCDPA) | |
|---|---|---|---|---|---|
| Right to access/know | ✓ | ✓ | ✓ | ✓ | ✓ |
| Right to correct | ✓ (CPRA) | ✓ | ✓ | ✓ | |
| Right to delete | ✓ | ✓ | ✓ | ✓ | ✓ |
| Right to opt out | Sensitive Data | Profiling/Targeted ads | Profiling/Targeted ads | Profiling/Targeted ads | Profiling/Targeted ads |
| Right to portability | ✓ | ✓ | ✓ | ✓ | ✓ |
| Right to opt out of sales | ✓ | ✓ | ✓ | ✓ | ✓ |
| Opt in for sensitive data | ✓ | ✓ | ✓ | ||
| Automated decision-making | ✓ (CPRA) | Opt out | Opt out | Opt out | |
| Private right of action | Limited |
4.1. Right to Access/ Right to Know. You have the right to confirm whether and know the personal data we collected on you. You can exercise your right by reviewing this Privacy Notice, you may access and request a copy of the specific personal data collected by us about you. Once we receive and confirm your verifiable consumer request (see section 4.4 herein), we will disclose to you:
4.2. Right to Correction and Delete. You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data. You can exercise this right directly.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see section 4.4 herein), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to
4.3. Right to Portability. You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive and confirm your verifiable consumer request (see section 4.4 herein), we will provide this right to you.
4.4. To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
ALFA CORPORATION LTD
Email: contact@alfa-corporation.net
4.4.1. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
4.4.2. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
4.4.3. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
4.4.4. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
4.4.5. Response Timing and Format
4.4.5.1. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
4.4.5.2. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
4.4.5.3. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
4.5. Right to opt out from (i) selling Personal Data; (ii) Right to opt out from processing for Targeted Advertising; and (iii) Right to opt out from Profiling. You have the right to opt out of the processing of your Personal Data for the purposes of targeted advertising, its sale to a third party for monetary gain or other value, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer. You may authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).
4.5.2. To exercise the right to opt out, you (or your authorized representative) shall submit a variable notice to contact@alfa-corporation.net.
4.5.3. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
4.6. Right Against Automated Decision-Making. You have the right not to be subjected to decisions based solely on automated processing, including profiling, which significantly affects you. We understand the importance of human input in certain decisions that may impact you, and we are committed to upholding this right.
We want to assure you that our business prohibits making significant decisions about you based solely on automated processes without any human involvement. Human insight is an integral part of our decision-making processes to ensure fairness, transparency, and accountability.
For more details about how we handle your personal information, including the use of automated decision-making processes, please submit a variable notice to contact@alfa-corporation.net.
4.7. Private right of action. As a resident of certain U.S. states, you have the right to bring a private right of action for certain unauthorized access and exfiltration, theft, or disclosure of your personal information. You can initiate legal proceedings if your non-encrypted or non-redacted personal information is subject to unauthorized access and exfiltration, theft, or disclosure.
Before filing an action, you are required to provide us with written notice of the alleged actions, please submit a variable notice to contact@alfa-corporation.net.
We will not discriminate against you for exercising any of your rights. Unless permitted by the U.S. laws, we will not:
We are committed to protecting the privacy and security of our users' sensitive information. This section outlines our practices by applicable laws, including but not limited to the Illinois Biometric Information Privacy Act (BIPA), Texas Capture or Use of Biometric Identifier Act (CUBI), and Washington Biometric Information Privacy Act.
6.1. Information Collected. The data we gather as part of our services does not encompass biometric information, as photographs are expressly excluded from the category of data classified as biometric identifiers. We do not collect, store, and use biometric identifiers or biometric information, such as a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.
6.2. Consent. As we are not currently collecting any biometric identifiers or biometric information, your consent is not necessary at this time. We will seek additional consent if we intend to use your biometric information for any other purpose not mentioned herein.
6.3. Purpose of Collection. As we are not currently collecting any biometric identifiers or biometric information, we do not set any purpose other than what is explicitly stated in the Site Privacy Policy.
6.4. Retention and Deletion. As we are not currently collecting any biometric identifiers or biometric information, we do not establish a special retention and deletion rules and schedule than what is explicitly stated in the Site Privacy Policy.
6.5. Security Measures. As we are not currently collecting any biometric identifiers or biometric information, we do not set any additional measures. We implement industry-standard security measures to protect your information from unauthorized access, disclosure, alteration, and destruction. Our commitment to security includes encryption, access controls and other measures what is explicitly stated in the Site Privacy Policy.
6.6. Your Rights. You have the right to inquire about the types of information we hold about you, the purpose of its collection, and request its deletion. For inquiries or requests related to your information, please contact us directly (please see Section 8 for more inquiries).
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice via the Services or on the Site and update the Privacy Notice's effective date. Your continued use of our websites, apps and Services following the posting of changes constitutes your acceptance of such changes.
8.1. If you have any questions or comments about this Privacy Notice, how the Company collects and uses your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under U.S. laws, please do not hesitate to contact our representative responsible for personal information as follows:
ALFA CORPORATION LTD
Email: contact@alfa-corporation.net
8.2. If you have any questions about this Privacy Notice or our Privacy policy, you can contact us at contact@alfa-corporation.net.