Last Update: August 31st, 2022

PRIVACY POLICY#

ENTRY INTO FORCE: 16TH AUGUST 2022

Along with the this PRIVACY POLICY (along with the DATA PROCESSING AGREEMENT and DATA PROCESSING STATEMENT where applicable) constitutes the entire personal data protection policy (hereinafter "Privacy Policy") for the product or service provided by ALTOGIC, INC.

We appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.

Before accessing or using www.altogic.com, please ensure that you have read and understood our Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

If you have any queries about this Privacy Policy or data protection in general, please contact: [email protected]

1. GENERAL INFORMATION#

  1. This Privacy Policy was drawn up by ALTOGIC, INC. a company registered at 1401 Pennsylvania Ave, Unit 105, Wilmington, 19806, County of New Castle, Delaware, USA ("Altogic", "we," "us" or "our") who is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share and protect data that identifies or is associated with you ("personal data") in relation to our website www.altogic.com (as well as any other media form, web application, media channel, mobile website or mobile application related, linked, or otherwise connected thereto) including the services offered on such website (hereinafter collectively the "Platform" or "Site"), and your choices about the collection and use of your information.
  2. This Privacy Policy will enter into force on the date stated above. If this document is updated, we will notify you of the revised versions through our regular channels. For more information regarding updates please see the section titled "Updates to the Privacy Policy" below.
  3. As Altogic is a company residing and operating in Delaware, USA, it is subject to any and all federal and state laws applicable to Delaware entities. Please note that this Privacy Policy was prepared in line with "Delaware Online Privacy and Protection Act." (80 Del. Laws, c. 148, § 1) as it is the main applicable data protection law. Recognizing the global nature of the Internet, throughout the Privacy Policy, reference has been made to other jurisdictions and regulations which may be applicable to some users. However, we hereby expressly state that any such reference was made for ease of understanding of users and those persons who choose to access the Site from other locations do so on their own initiative and does not mean or imply that Altogic is subject to the laws and regulations of said jurisdiction.
  4. Hereinafter, any person who is registered to the Site shall be referred to as "Member". Any person who visits the Site without registration shall be referred to as "User". Altogic hereby acknowledges its Data Controller status in terms of Members and Users of the Platform.
  5. Altogic provides a backend application development and execution platform to its Members. Therefore, Members of the Site are developers or designers who intend to use the Altogic services to develop their backend applications which they open to use of third-party end-users ("End Users").
  6. This Privacy Policy applies to all the products and services provided on the Site to Members and Users by Altogic as the Data Controller. If you are an End User of any application developed and/or operated by a Member, please note that apart from any personal information which may be processed as a result of your specific visit to the Site, Altogic only processes your personal data as a "data processor" and Altogic Member whose application you use as an End-User may be processing your personal data as "data controller". Please refer to your Data Controller's privacy policy for specific information on the processing of your personal data by Members.
  7. Altogic concludes a valid Data Processing Agreement with all Members of the Platform as a condition of membership and does not control the processing of End-User personal data.
  8. Please note that this Privacy Policy has been prepared in line with Altogic's Terms of Use available at https://www.altogic.com/terms and Altogic does not intend for the Site to be used by persons who are prohibited from using the Site as per its Terms of Use. In terms of the collection of personal data, we would like to stress that we do not knowingly solicit data from children under 18 years of age. As stated in our Terms of Use, by using the Site, you represent that you are at least 18. If we learn that personal data from users who are under 18 years of age has been collected due to their misrepresentation during Membership, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

2. WHAT IS PERSONAL DATA?#

  1. "Personal Data" used throughout this Privacy Policy means in short personally identifiable information of Users and Members of Altogic Site that is collected online by Altogic from User/Member and maintained by Altogic in an accessible form, including a first and last name, a physical address, an e-mail address, a telephone number, a Social Security number, or any other identifier that permits the physical or online contacting of the User/Member, and any other information concerning the User/Member collected by Altogic from User/Member and maintained in personally identifiable form in combination with any identifier described in this paragraph.

3. ON WHAT BASIS DO WE COLLECT OR USE PERSONAL DATA?#

  1. Data protection laws require that we meet certain conditions before we are allowed to use your personal data in the manner described in this Privacy Policy. To use your personal data, we will rely on one of the following conditions, depending on the activities we are carrying out:
    1. You have given us consent;
    2. Processing is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual.
    3. Processing is necessary in order to enter into or perform a contract with you
    4. Processing is necessary for compliance with our legal obligations
    5. Processing is necessary for legal claims
    6. Processing is necessary for substantial public interest.
  2. Below you will find detailed information on the basis that we collect and use your personal data. If we look to use your personal data for any other purpose not covered in this privacy notice, we will let you know about any proposed new purposes before using your personal data in this way.
  3. Consent
    1. We ask that you provide affirmative and informed consent to the use of your personal data as described in this Privacy Policy when you access the Site and participate in the Services.
    2. We do not collect personal data for the purpose of sale of such information in a way that specifically identifies the individual (i.e., we don't sell Member information).
    3. We may provide you with marketing information about our services or products where you have indicated your consent for us to do so (to the extent that we are required to collect consent under data protection laws). We may contact you by mail or email, phone and electronic notifications (where you have agreed to those methods of communication) to provide you with the information on your requested service or product. We may also provide you with information, special offers, research, promotions, and similar products and services. Where you have indicated your consent to us doing so, we may also pass your details to our group companies. You may change your marketing preferences at any time from your account settings.
    4. We will also provide you with access to, or transfer your personal data at your written request, provided that we aren't legally restricted from doing so or otherwise prevented from doing it due to circumstances beyond our reasonable control.
    5. If we are relying solely on your consent to process your personal data, you may withdraw your consent to our processing of your personal data at any time; however, withdrawing consent may result in your inability to continue using some or all of the services in the Site. Please note that the withdrawal of your previous consent this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  4. Legitimate Interest
    1. Sometimes our collection and use of your personal data may not depend on your informed consent but our legitimate interests. It is in our legitimate interests to collect your personal data as it provides us with information that we need to provide our services to you and to make our Platform available.
    2. This requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with access to the Platform, against the interests you have as a citizen and the rights you have under Data Protection Law (for example, to not have your personal data sold to third party marketing companies without your knowledge).
    3. The outcome of this balancing test will determine whether we may use your personal data in the ways described in this privacy notice. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.
    4. Our legitimate interests are: managing our business and relationship with you or your company or organization; understanding and responding to inquiries and Member and User feedback; understanding how our Members and Users use the Platform; identifying what our Members and Users want and developing our relationship with you, your company or organization; improving our Platform and offerings; managing our supply chain; developing relationships with business partners; sharing data in connection with acquisitions and transfers of our business.
  5. Contractual Performance
    1. Please note that when you become a Member of the Site or any other communication platforms thereof (Altogic Community, Altogic Discord channel, etc.) you enter into a contractual relationship with Altogic via the Terms of Use and Data Processing Agreement which you accept. This contractual relationship necessitates the processing, use and storage of your personal data for the purpose of fulfilling our contractual obligations and/or facilitating our contractual rights. Therefore, at this stage the contractual relationship itself becomes the legal basis of our processing of your personal data.
    2. In short, we are permitted to hold and process some of your personal data because it is necessary to do so in order to provide you access to, and to enable you to make use of, the Platform. Without this personal data, we could not provide you with access to the Platform.
  6. Legal Obligations and Legal Claims
    1. We are permitted to process your personal data where it is necessary for compliance with our legal obligations. We are also permitted to process your personal data where it is necessary to establish, pursue or defend a legal claim.
    2. We may disclose your personal data to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose personal data when we believe in good faith that such disclosure is required by and in accordance with the law.
  7. Substantial Public Interest
    1. We are permitted to process your personal data where it is necessary for reasons of substantial public interest, on the basis of data protection laws.

4. USE OF COLLECTED DATA#

  1. We use your personal data to help us provide and support (the services on) our Platform. This section provides you with details of what personal data we use and why we use it.
  2. What Data Do We Use?
    1. We collect information directly from you and in some instances from third party service providers whom you authorize to share your information with Altogic.
    2. Depending on whether you are a User or Member, personal data collected from you will differ. As explained above, if you only visit the Site without becoming a Member you are categorized as a User. The only personal data collected from User's are explained the in the Section titled "Cookie Policy" below.
    3. Naturally, we collect more personal data from you when you sign up to the Platform as a Member. As a Member you more personal data including:
      1. contact information such as your username, email address;
      2. user picture or "avatar" (in case it contains your personally identifiable information);
      3. details of your correspondence with us;
      4. technical information, such as your Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform and traffic data, cookies data, web logs and other communication data, and details of the resources that you access, as well as your sessions records, which we collect from you when you access the Platform; and
      5. any other information you provide to us.
    4. When you use your membership and account information with third party service providers, we will receive certain profile information about you from your service provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture as well as other information you choose to make public on such service provider platform. We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on our Site. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policies to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and apps. As of the entry into force of this Privacy Policy, our Site offers you the ability to register and login using your Google account.
    5. For registering as a Member on our platform, the provision of a username, email (which may contain your first and/or last name,) and password is mandatory: if relevant data is not provided, then you will not be able to create an account. Alternatively, you may login using third party service providers as explained above. For subscribing to any of our paid Services or participation in the Marketplace, the provision of payment and address information is mandatory: if relevant data is not provided, then we will not be able to receive your payment, send you an invoice and process the transaction. All other provisions of your identifier information (real name, alias or user name, postal address, telephone or mobile contact number, job title, company name, profile picture) are optional. For example, if you do not provide us with your phone number, we would not be able to call you to provide you with more information about the products you may be interested in.
    6. You are able to view and update much of the information collected about you through your account settings. Please note that if you sing in using a third-party service provider, we cannot allow you to change your email address information.
    7. We automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information which may lead to your identification. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes. Please refer to section titled "Cookie Policy" and the sub-section titled "Service Providers Processing Data on Our Behalf" for more information on automatically collected personal data.
    8. As a Member, please remember that if you use the Site to develop and operate an application which collects personal data about other people, you represent that you have read and understood the Data Processing Agreement and agree to be bound by the conditions thereto. In these instances, as the Data Controller of such data you further represent that the individuals to whom this data relates have been informed of and understand the reason(s) for obtaining the data and the manner in which this information will be used and disclosed, and have consented to such use and disclosure.
    9. When this product/service was designed, the possibility that it would be used to process special categories of personal data or data regarding criminal convictions and offences was not taken into account. In fact, our Terms of Use specifically state that Members shall not use the Site for any purpose or in any manner involving transmitting protected health information to Altogic unless you have received prior written consent to such use from Altogic. It is up to the Member to determine whether or not it will use the aforementioned product or service to process such data.
  3. Why Do We Use Your Data?
    1. Service provision: we use the information to carry out and administer the platform which enables you as Members to develop and/or operate the backend software of applications. For the purpose of service provision, we use your personal information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement, and to address issues such as malicious use of the Services.
    2. Communication: sending emails, newsletters, and other messages to keep you informed of the Platform. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link. We also use the personal data to deal with inquiries and complaints made by you relating to the Platform and to address your questions, issues, and concerns;
    3. Site monitoring: to check the Platform and our other technology services are being used appropriately and to optimize their functionality for the purpose of administering and improving our Services.
    4. Platform optimization: improve, test, and monitor the effectiveness of our Platform and diagnose or fix technology problems;
    5. Managing suppliers: we use information to manage suppliers who deliver services to us;
    6. Easy access: to help you efficiently access your information after you sign in and to remember information so you will not have to re-enter it during your visit or the next time you visit the Platform;
    7. Statistics: monitor metrics such as total number of visitors, traffic, demographic patterns, and patterns in our test results (on an anonymized and aggregated basis);
    8. Development: develop and test new products and features.
  4. If we plan to use your personal data in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled "Updates to the Privacy Policy".

5. COOKIE POLICY#

  1. We use cookies on our Site to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve the Site.
  2. A cookie is a commonly used automated data collection tool. Cookies are small text files that are placed on your computer or device by websites that you visit or HTML-formatted emails you open, in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Site.
  3. We use persistent cookies to save your login information for future logins to the Site. We use session cookies to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and then close your browser.
  4. You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may be unable to access certain parts of our Site or to receive certain Services.
  5. Your browser may feature a preference which alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track ("DNT") signal. Please note that our Site may not recognize or take action in response to DNT signals from your browser.

6. WHERE WE STORE YOUR DATA#

  1. Altogic is hosted, stored and processed by Altogic's sub-processor, Amazon Web Services ("AWS"), leveraging AWS data centers which are (unless otherwise stated) located within the continental United States. Processing of the information collected about you is only undertaken for the purposes described in this Privacy Policy.
  2. The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the UK. It may also be processed by staff operating outside the EEA or the UK who work for us or for one of our suppliers or partners. Such staff or subcontractors maybe engaged in, among other things, the processing of your payment details or the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing outside of the USA, EEA or the UK.
  3. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred where the recipient is bound by contractual clauses requiring the confidentiality and protection of personal data.
  4. Our Site is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site from outside the EEA or the UK. This means that where you chose to post your data on our Site, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the EEA or the UK may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

7. DISCLOSURE OF YOUR PERSONAL DATA#

  1. We do not sell, lease, rent or give away the information collected about you without your permission. We only disclose your information as described below. If we disclose your information, we require those we share it with to comply with adequate privacy and confidentiality requirements, and security standards.
  2. We may disclose your personal data to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose personal data when we believe in good faith that such disclosure is required by and in accordance with the law. In certain instances, it may be necessary for Altogic to disclose the information that we've collected about you to government officials or otherwise as required by applicable law. No personal data will be disclosed to any law enforcement agency or governmental agency except in response to:
    1. A subpoena, warrant or other process issued by a court of competent jurisdiction;
    2. A legal process having the same consequence as a court-issued request for information, in that if Altogic were to refuse to provide such information, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process; or
    3. Where such disclosure is necessary for Altogic to enforce its legal rights pursuant to the laws of the jurisdiction from which such information was gathered.
  3. We may also disclose your personal data, subject to appropriate confidentiality protections, in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.
  4. The Site may contain links to third party websites. When you click on a link to any other website or location, you will go to another site, and another entity may collect personal or anonymous data from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that this Privacy Policy does not apply to these outside websites or content, or to any collection of your personal data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
  5. Service Providers Processing Data on Our Behalf
    1. We may use contractors and service providers to process the information collected about you on our behalf for the purposes described in this Privacy Policy. We contractually require service providers to keep information secure and confidential and we do not allow our data processors to disclose your information to others without our authorization, or to use it for their own purposes. However, if you have an independent relationship with these service providers their privacy statements will apply.
    2. Google Analytics (Google Inc.): This third-party service enables Altogic to monitor and analyze the Site traffic. Google Analytics is a web analysis service provided by Google Inc. Google utilizes the information collected to track and examine the use of the Site to prepare reports that may be used for optimization of the Site. Information collected for this purpose is cookies and usage data. Place of processing of Google Inc is the US. Please check the Google privacy policy at https://policies.google.com/privacy?hl=en for more information. Opt-out option is also available as a browser add-on at: https://support.google.com/analytics/answer/181881?hl=en
    3. Altogic Discord Channel : If you use the Altogic Discord channel, please note that during your communications with Altogic or other Members, certain personal data will be processed by the third-party website. This website is owned and operated by Discord, Inc. and accessible to third parties. Place of processing of Discord Inc. is the US. Please check the Discord privacy policy at https://discord.com/privacy for more details.
    4. Altogic Community: The Altogic Community support and interaction platform is hosted by a third-party If you become an Altogic Community member, your communication, interaction and feedback on shall be visible to Altogic and other Members registered at the Altogic Community. This website is owned and operated by CircleCo, Inc. Place of processing of CircleCo, Inc. is the US. Please check the CircleCo, Inc. privacy policy at https://app.circle.so/privacy for more details.
    5. Session recording: We use a session replay, performance monitoring, and product analytics tools used to create the ideal web and mobile product experience for users of Altogic. Using this tool, we analyze any and all session bugs and user issue and are able to make sure that they do not occur again. For these purposes we use LogRocket (owned by Logrocket, Inc.): Place of processing of Logrocket Inc. is the US. LogRocket's privacy policy is available at https://logrocket.com/privacy/. However, please note that LogRocket functions as a data processor for Altogic (Data Controller), therefore for any questions regarding our use of this tool, please contact us using the information provided at the end of this Privacy Policy.

8. RETENTION OF YOUR PERSONAL DATA#

  1. We will retain your personal data for as long as needed to fulfill the purpose for which we collected it and for a reasonable period thereafter in order to comply with audit, contractual, or legal requirements, or where we have a legitimate interest in doing so. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  2. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  3. We may retain aggregated or de-identified data indefinitely or to the extent allowed by applicable law. We may retain personal data preserved in automatically generated computer back up or archival copies generated in the ordinary course of our information technology systems procedures.
  4. All retained personal data will remain subject to the terms of this Privacy Policy. Please note that if you request that your personal data be removed from our databases, it may not be possible to completely delete all of your personal data due to technological or legal constraints, though we will use reasonable efforts to do so.
  5. No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the member's account, unless as necessary to comply with our legal obligations, resolve disputes, prevent and detect fraud, and enforce our agreements.

9. SECURITY POLICY#

  1. The security of your personal data is important to us. We use commercially reasonable efforts to store and maintain your personal data in a secure environment. We also take technical, contractual, administrative, and physical security steps designed to protect any and all personal data you provide. We have implemented procedures designed to limit the dissemination of your personal data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you in this Privacy Policy.
  2. Please note that you are also responsible for helping to protect the security of your personal data. For instance, never give out the credentials you use in connection with accessing the Site, so that other people will not have access to your personal data. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services. To help you identify any unauthorized access to your account, your account settings provide you with an "Account Security" and "Security Log" tab. " Account Security" tab allows you to view a list of devices that have logged into your account. You can sign out any sessions that you do not recognize. If you lost your phone/device or left yourself logged in on a public computer, then you can also sign out everywhere except your current session. " Security Log" tab allows you to view a historical set of records that provide information on the sequence of activities that have affected your account and profile information. Using security logs, you can view all changes that have been made to your account and profile.
  3. We are not liable for disclosure of data due to errors in transmission, unauthorized access or acts by third parties, or omissions or acts beyond our reasonable control. Although we employ commercially reasonable measures of security, we also cannot guarantee that your personal data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards by persons or systems with malicious intent.
  4. In the event we become aware of a security breach that could result in your personal data being disclosed in a manner that is not authorized under this Privacy Policy, we will notify you via e-mail (or other communication channel you have provided to us) if we can and use other means (such as posting a notice on our Site) to try to alert you as appropriate.
  5. We have implemented the following security measures to protect its product or service:
    1. The data centers, where Altogic has servers, are equipped with camera surveillance and visitor registration systems and are ISO:27001:2013 certified. Please be advised that unless otherwise stated, the Site and all its contents (including any content generated by Member applications) is hosted in servers located primarily in the United States of America. If you access the Site from any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United States of America, then through your continued use of the Site, you are transferring your data to the United States of America, and you agree to have your data transferred to and processed in the United States of America. Please be advised that Altogic may also store data in reputable third-party data centers in different locations around the world, and this provision shall apply equally if your data is stored in such data centers. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these locations/countries where Altogic stores data may not necessarily have data protection laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.
    2. The (database) servers can be accessed only via Altogic's trusted network locations.
    3. Procedures are in place, which means only authorized personnel have access to the personal data. A non-disclosure and confidentiality agreement ensures this still applies when a member of staff leaves the company.
    4. All mobile carriers (such as laptops, USB sticks and portable HDs) of Altogic are encrypted.
    5. Our web servers and database servers are firewall-protected.
    6. All data within Altogic will be stored as securely as possible.
    7. Encryption will be used when possible.
    8. All data will be transmitted with the highest possible form of encryption that is supported.
  6. We regularly revise the security measures outlined in this Privacy Policy to ensure that we are always fully prepared and up to date with regard to data protection.

10. MANAGING YOUR ALTOGIC MEMBER STATUS AND ACCOUNT#

  1. Username: Altogic Members are required to assign themselves a username that uniquely identifies you on Altogic. Your username may contain personal data such as your real name, surname or other identifier. You can change your Altogic username at any time. However, please beware that if you change your username, your old username becomes available for anyone else to claim. Most references to your Member profile under the old username automatically change to the new username.
  2. Deactivating Your Account: Deactivating your account will stop all services for applications that you own, meaning that all environments of owned applications will be moved to "deactivated" status and will not accept any incoming RESTful api requests. Your design and application data at your environments will not be impacted and your data will be kept intact. After deactivation, you will automatically signed out from all your sessions and you will not be able to sign in again to your account until you reactivate it again during sign in.
  3. Deleting Your Account: Deleting your account will stop all services for applications that you own, permanently delete all owned application and design data and profile information. For applications in which you are a team member (not owner) some information, like messages you sent to other team members, comments you have added to design entities and your action logs, may still be visible after you delete your account. Once you delete your account, there is no going back. Please be certain. We will be sorry to lose you.

11. DATA LEAK PROTOCOL#

  1. In the unfortunate event that something does go wrong, Altogic will follow the following data breach protocol to ensure that data subjects are notified of incidents.
  2. A relevant internal data breach procedure is in place. Altogic will set up a team in order to analyze the cause, the impact and the affected Members and Users. Depending on the outcome of this analysis, Members/Users will be notified as soon as possible.Members shall be notified within 24 hours of Altogic's learning of the data leak if possible. If required by any applicable law, Altogic shall also notify any applicable Data Protection Authority about the leak.
  3. Altogic will provide highly detailed information about:
    1. The nature of the breach, including a description of the incident, the nature of the personal data or categories of affected data subjects, an estimate of the number of affected data subjects and databases that may be affected, as well as an indication of when the incident occurred;
  4. Any measures already taken by Altogic in order to stop the breach;
  5. Any measures to be taken by the affected data subjects (what can the affected data subjects themselves do, such as "keep an eye on your e-mails, change your passwords", etc.);
  6. Any measures to be taken by Altogic in order to prevent a future breach.

12. UPDATES TO THE PRIVACY POLICY#

  1. We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Entry Into Force" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes on the Site or by directly sending you a notification through the Site. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your personal data.

13. QUESTIONS AND REQUESTS ABOUT YOUR PERSONAL DATA#

  1. As a Member or User of Altogic you may request the following from Altogic as Data Controller;
    1. Access to your personal data.
    2. Rectification or deletion of your personal data.
    3. A restriction on the processing of your personal data.
    4. Object to the processing of your personal data.
    5. A transfer of your personal data (data portability) in a structured, machine readable and commonly used format.
    6. Withdraw your consent to us processing your personal data, at any time
  2. Please not that withdrawing your consent is only effective provided that consent is the only basis for the processing of relevant personal data. Similarly, even if you request the deletion of any personal data, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  3. Please note that if you are the end-user of any application developed and/or operated by a Member, as Altogic is only the data processor in such situations, you must direct any request relating to your personal data to the relevant data controller (Member).
  4. You can make a request in relation to any of the above rights by writing to us at the contact address given at the end of this Privacy Policy. We will respond to such queries as soon as reasonably possible and deal with requests we receive from you, in accordance with the provisions of any applicable data protection law.

14. CONTACT US#

  1. You can contact us via post or email.

    1. Via post:

      Altogic, Inc.

      Attn: Privacy

      1401 Pennsylvania Ave, Unit 105,

      Wilmington, New CastleCounty

      DE 19806

      United States

    2. Via email:

    [email protected] with "Privacy" in the subject line

  2. If you are a Member, you can also contact us through the Feedback tab in your Accounts.

  3. If your letter or email involves one of the requests listed above in the section titled "Questions and Requests About Your Personal Data", we may ask you to verify your identity before fulfilling your request depending on the method of your request.