This privacy statement was last updated on May 25, 2018. Alconost, Inc. and its affiliates (collectively, “Alconost”) have created this privacy statement in order to disclose its information gathering and dissemination practices for its website located at https://alconost.com/ (“Website”) and the services offered and provided through the Website (“Services”).
Table of Contents
Background Information Word from Alconost
- Information We Collect
- Information We Collect Through the Website
- User Content
- Providing Information to Alconost
- User Account
- Third Party Websites
- Third Party Applications
- Information Relating to Children
- California Online Privacy Protection Act Notice
- Cookies and Web Beacons
Use and Disclosure of Information
- How your Information is Used
- Disclosure of Information to Third Parties
- Disclosure of Information to Other Users
- Securing the Transmission and Storage of Information
- Choices Available to You
Rights of European Users under the GDPR
- Data Controller
- Data Processor
- Legal Basis for Processing
- GDPR Rights:
- Retention Policy
- Cross Border Data Transfers
- Data Protection Officer
- Privacy-Related Inquiries and Complaints
- description of the types of personally identifiable information (yours and that of third parties) collected through the Website and Services;
- how the collected personally identifiable information is used;
- with whom the collected personally identifiable information may be shared;
- the choices available to you regarding the collection, use, and distribution of such information;
- security procedures that are in place to protect against the loss, misuse, or alteration of personally identifiable information under Alconost’s control; and
- instructions how you can access and correct inaccuracies in the information collected about you.
A note about the Website and Services: some of our Services, data centers, service providers, affiliates or operating partners and servers may be located in other countries. As such, the Website and Services may be subject to the laws of numerous countries and jurisdictions, some of which may require us to disclose certain information about our users. We are committed to keeping your information private, while still complying with all applicable laws in jurisdiction in which we operate.
Should you have any concerns or believe that there are problems or issues relating to compliance with the policies outlined in this PrivacyPolicy, please notify us by e-mail at: firstname.lastname@example.org
A Word from Alconost
INFORMATION WE COLLECT
Information We Collect Through the Website
This Website does not collect personally identifiable information from your computer when you browse the Website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your e-mail address, or any other personally identifiable information.
When you use the Website, Alconost or trusted third parties authorized by Alconostmay also collect certain technical and routing information about your computer (also known as environmental variables) to facilitate your use of the Website and the Services enabled thereby. When you browse the Internet, your Internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to Alconost every time you access content on one of our internet domains. Examples of such information include the URL of the particular Web page you visited, the IP (Internet Protocol) address of the computer you are using, or the browser version that you are using to access the Website. All of this information may be collected by Alconost and used to help improve our offerings to you.
Providing Your Information to Alconost
You never have to provide personally identifiable information to Alconost. However, should you choose to withhold certain required information, Alconost may not be able to provide you with some or all of the Services. Some of the information we ask you to provide may be identified as mandatory or optional. If you do not provide the mandatory information with respect to a particular activity, you may not be able to engage in that activity or make such a purchase. Alconost will inform you of the mandatory or optional nature of the requested or required information.
Alconost is the sole owner of the information it gathers on the Website and Services. Alconost will only share your information with outside parties in ways that are described in this privacy statement or if we are required to do so by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law, cooperate with law enforcement agencies, or comply with a legal process served on us and otherwise to comply with any current or future laws and regulations applicable to Alconost.
When you submit personal information to Alconost through the Website, you understand and agree that this information may be transferred across national boundaries and may be stored and processed in any of the countries in which Alconost and its affiliates and subsidiaries maintain offices. You also acknowledge that in certain countries or with respect to certain activities, the collection, transferring, storage, and processing of your information may be undertaken by trusted vendors of Alconost. Such vendors are bound by contract not to use your personal information for their own purposes or provide it to any third parties.
When registering for a User Account or otherwise contacting Alconost in connection with your interest in purchasing Alconost products or services, Alconost may ask you to provide certain information. Such information may include your name, e-mail, and other personally identifiable information. It is completely optional for you to register for a User Account or engage in activities requiring a User Account or provide any personal identifiable information. However, certain information and proper identification may be required in order for you to engage in a business relationship with Alconost.
Once you create a User Account, you will be deemed a Registered User. You may also request to change information associated with you User Account by contacting us at email@example.com
If you wish to deactivate your User Account, you may contact us at firstname.lastname@example.org. When you deactivate your personal account, all information stored and maintained as part of your account may be retained for archival, backup and record purposes.
Third Party Websites
The Website may contain links to websites owned and operated by third parties. These links are presented for your convenience and information. Alconost does not control these third party websites and is not responsible for their privacy practices or content. Alconost does not control the information collection and distribution policies on such websites other than those that are under the control of Alconost itself. Content on third party websites may not reflect products, services, and/or information provided by Alconost. Third parties may also set their own cookies and/or use web beacons, which may be used to identify some of your preferences or to recognize you if you have previously had contact these third parties. Alconost does not control the use of such technology by third parties, the information they collect, or how they use such information. You should direct all concerns regarding any third party website to the site administrator or webmaster of such website
Alconostalso uses third party advertising companies to serve ads when you visit the Website. These companies may use general information about your visits to the Website as well as other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and your choices as to not having your information used by these companies, please direct such concerns to the respective company’s administrator or webmaster.
Third Party Applications
Information Relating to Children
The Children's Online Privacy Protection Act (COPPA) was passed by the U.S. Congress in November 1998. COPPA provides parents with specific rights regarding their children's privacy. For additional information and resources on COPPA, please visit the Federal Trade Commission Web site at http://www.ftc.gov/. The Alconost Website and any Software or Services available on that site are not directed at children under 13 years of age and, therefore, COPPA does not apply. However, we recognize that children under the age of 13 may potentially access this Website and subscribe to the newsletter, purchase Software and Services, or download software programs. The collection of information is covered above. Parents and Legal Guardians may request from us to review, delete or stop the collection of the personally identifiable information of their child. You may do so by contacting us by letter (using the address information provided at the bottom of this page) or email to email@example.com.
California Online Privacy Protection Act Notice
Alconost does not track users over time and across third party websites to provide targeted advertising and therefore does use do not track (DNT) signals. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
Alconost does not authorize the collection of personally identifiable information by third parties and third parties cannot collect this information unless you provide it to them directly.
Cookies and Web Beacon
The Website uses “cookie” and “web beacon” technology. “Cookies” are short pieces of data generated by a web server that a website stores on a user’s computer. Certain pages on our Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable us to customize our Website and offerings to your needs and provide you with a better online experience with us. In addition, cookies are used to:
- measure usage of various pages on our Website to help us make our information; more pertinent to your needs and easy for you to access;
- identify and categorize the internet webpages from which the visitor came to the Website and observe the browsing patterns; and
- provide functionality such as online orders, Alconost services and other functionality that we believe would be of interest and value to you.
In addition, the service providers we use to serve and host our advertisements, and/or deliver our e-mails use session and persistent cookies, to track the number of times the Website is accessed and whether the site was accessed from an advertisement. There are no cookies in the advertisements or e-mails. A cookie is placed on your computer only if and when you click on an advertisement or open the e-mail. The cookie generated from the advertisement or e-mail does not contain any personally identifiable information and will remain on your hard drive until you delete it.
You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
Web beacons are used in combination with cookies to help website operators understand how visitors interact with their websites. A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. As opposed to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. These web beacons are not tied to personally identifiable information. The use of a web beacons allows the site to measure the actions of the visitor opening the page that contains the web beacon. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited at a website. Alconost uses the information provided by web beacons to develop a better understanding of how the Website’s visitors use the Website, and to facilitate those visitors' interactions with the Website. Alconost may make the aggregate data obtained from web analytics (including from our third party analytics providers, if applicable) publicly available. If this data is made available, none of the information will be personally identifying information or potentially-personally identifying information.
USE AND DISCLOSURE OF INFORMATION
How Your Personal Information is Used
Alconost collects information from you in order to record and support your participation in the activities provided by Alconost. We may use your e-mail address to send a confirmation e-mail when you sign up for a User Account and, if necessary, may use other information you provide to contact you for help to process the purchase or service you have selected. Your personal information also may be used to keep you informed about new services, service upgrades, special offers, and other Services.
As described above, Alconost may collect information about your use of the Website and Services. This information is collected in aggregate form, without identifying any user individually. Alconost may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.
Disclosure of Information to Third Parties
Although we will always strive to guard your identity, we may disclose your personally identifiable information without your permission in limited circumstances. We will only do so if we have a good-faith belief that disclosure is reasonably necessary to (1) comply with laws, regulations, or government requests or (2) to investigate or protect against harmful activities to our guests, visitors, associates, or property (including the Website or Services), or to others. If we are required by law enforcement or judicial authorities to provide your personally identifiable information, we will only do so upon receipt of appropriate documentation. We may also disclose your information to investigate violation of and enforce our Terms of Service. Please know that we do not take this responsibility lightly. Your privacy is of paramount importance to us.
Alconost does use the services of third parties, such as e-mail service providers, purchase, shipping and order processing merchants and marketing companies that act as independent contractors on behalf of Alconost. These parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose Alconost specifies. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of personal information to entities outside of the Alconost’s affiliates for their use without your approval.
Change in Control
In the event that all or substantially all of Alconost’s stock and/or all or substantially all assets are transferred or sold to another entity, Alconost may transfer personally identifiable information to the acquiring entity. If, as a result of such a business transition, your personally identifiable information will be used in a materially different manner, you will be given choice consistent with our policy regarding notification of changes.
Securing the Transmission and Storage of Information
CHOICES AVAILABLE TO YOU
You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the Services dependent upon the collection of this information and you will be given an opportunity to “opt-in” and make your preference choices for any items that are optional and which are not prerequisite for our rendering such Services.
You can choose at any time to opt out of receiving emails from Alconost by clicking the unsubscribe link at the bottom of any email you receive from Alconost or by contacting Alconost directly at firstname.lastname@example.org. If you elect to opt out, we will not, as applicable, share your personal information with third parties or send you emails. However, we may continue to use your personal information for internal purposes, to enhance your user experience or as necessary to administer the site or comply with applicable law.
We reserve the right to send a one-time registration confirmation email, and infrequent service alert messages to users to inform you of specific changes that may impact your ability to use a service that you have previously signed up for, regardless of email contact opt-in status. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of any applicable licensing, warranty and purchase agreements.
Alconost is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing Service if you have asked us not to do so, and issuance of these types of communications is rare.
If you wish to opt out of receiving emails, the sharing or retention of any personal identification information, or otherwise change your personal preferences, you must contact Alconost at email@example.com.
To ensure that your request is honored, you must provide Alconost with information sufficient for us to accurately identify and access your records. The information we require is your full name, address and the email address you provided to Alconost when you requested Services or Software. Alconost reserves the right to contact you to verify that we have accurately identified your record.
Rights of European Users under the GDPR
Alconost complies with the principles of 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”). If you are a natural person (“Qualified Individual”) of the European Union within the meaning of the GDPR, you are afforded certain additional rights by the GDPR as further described within this section.
When and if Alconost receives your personal information directly from you through its Website, it performs the functions of a Data Controller, as defined by the GDPR, and has the ability to determine how personal data is collected, for what purposes, and how this data is to be processed. As the controller, Alconost has implemented many technical and operational measures to ensure the most complete protection of personal data processed through its Website, and Services.
Legal Basis for Processing
Art. 6(1) a. of the GDPR serves as the legal basis for processing operations for which we obtain consent for a processing purpose. If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, when processing operations are necessary to provide a service, the processing is based on Article 6(1) b. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) c. If the processing of personal data may be necessary to protect your vital interests or of another natural person, then the processing is based on Art. 6(1) d. Finally, processing operations could be based on Article 6(1) f., if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by your fundamental rights and freedoms under the GDPR.
Right of Confirmation
You may obtain confirmation of whether or not your personal data is being processed. If you wish to exercise your right of confirmation, you may contact Alconost and/or its Data Protection Officer.
Right of Access
You may obtain from information about your stored personal data at any time and a copy of this information. If you wish to exercise your right of access, you may contact Alconost, and/or its respective Data Protection Officer.
Right to Rectification
You may request the rectification of inaccurate personal data. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, by means of providing a supplementary statement. If you wish to exercise your right of rectification, you may contact Alconost and/or its respective Data Protection Officer.
Right to Erasure (Right to be Forgotten)
You may request the erasure of your personal information by contacting Alconost and/or its respective Data Protection Officer. Furthermore, you may delete your User Account information by accessing your User Account settings page on the Applications. Please note that while any changes you make will be reflected in active user databases within a reasonable time, we may retain all information you submit for the prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, such as for archiving purposes within the public interest.
Right of Restriction of Processing
You have the right to restrict processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
- The data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right to Data Portability
You may request to receive your personal data in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without interference.
Furthermore, you may have the personal data transmitted directly from one controller to another, where technically feasible and does not adversely affect the rights and freedoms of others.
Right to Object to Automated Decision Making
You may object to decisions based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you, as long as the decision is not is necessary for entering into, or performance of, a contract between you and Alconost; or is not authorized by European Union or Member State law to which you are subject; or is not based on the data subject’s explicit consent.
Right to Objection to Processing
You may object to the processing of your personal data, unless there are legitimate grounds for the processing within the public interest, or for the establishment, exercise or defense of legal claims.
If Alconost processes personal data for direct marketing purposes, you shall have the right to object at any time to the processing of your personal data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to Alconost to the processing for direct marketing purposes, then we will no longer process the personal data for these purposes.
- Right of Confirmation
We only retain the personally identifiable information about you for as long as your User Account remains active or for a limited period of time as long as we need it to provide you with services or otherwise fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, archival purposes, resolve disputes, and enforce our agreements.
Cross Border Data Transfers
If and when sharing of information sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions, where the Applications allow for users to be located in the European Union, their personal information is transferred to countries outside of the EU. We use EU Standard Contract Clauses or other suitable safeguards to permit data transfers from the EU to other countries. The Standard Contractual Clauses commit companies transferring and receiving your personal information to protecting the privacy and security of your data.
EU/US Privacy Shield
Alconost commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable. Alconost also complies with the advice given by the panel and/or Commissioner with regard to data transferred from the EU or Switzerland.
Data Protection Officer
Name: Alexander Murauski
PRIVACY-RELATED INQUIRIES AND COMPLAINTS
If you are a Qualified Individual, you may lodge a complaint with the data protection supervisory authority in the country where you live if you are unsatisfied with how your complaint is handled by Alconost.
Please note that if you provide Alconost with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), Alconost cannot guarantee that your most recent privacy preference will be honored.
Copyright © 2018 Alconost Inc. All rights reserved. The Website, Services, and all documentation are the copyrighted property of Alconost Inc. and/or its licensors and protected by copyright laws and international intellectual property treaties. Alconost and related logo, and all related Product and service names, design marks and slogans are the trademarks and/or registered trademarks of Alconost Inc. and/or its affiliates. All other product and service marks contained herein are the trademarks of their respective owners. Any use of the Alconost Inc. or third party trademarks or logos without the prior written consent of Alconost Inc. or the applicable trademark owner is strictly prohibited.