Privacy Policy
Your privacy is important to us. It is Alpaco ApS' policy to
respect your privacy and comply with any applicable law and
regulation regarding any personal information we may collect
about you, including across our website, our platform and
other sites we own and operate.
Personal
information is any information about you which can be used to
identify you. This includes information about you as a person
(such as name, address, and date of birth), your devices,
payment details, and even information about how you use a
website or online service.
In the event our site
contains links to third-party sites and services, please be
aware that those sites and services have their own privacy
policies. After following a link to any third-party content,
you should read their posted privacy policy information about
how they collect and use personal information. This Privacy
Policy does not apply to any of your activities after you
leave our site.
This policy is effective as of 5
October 2021.
Last updated: 5 October 2021
Information We Collect
Information we collect falls into one of two categories:
“voluntarily provided” information and “automatically
collected” information.
“Voluntarily provided”
information refers to any information you knowingly and
actively provide us when using or participating in any of our
services and promotions.
“Automatically collected”
information refers to any information automatically sent by
your devices in the course of accessing our products and
services.
Log Data
When you
visit our website, our servers may automatically log the
standard data provided by your web browser. It may include
your device’s Internet Protocol (IP) address, your browser
type and version, the pages you visit, the time and date of
your visit, the time spent on each page, and other details
about your visit.
Additionally, if you encounter
certain errors while using the site, we may automatically
collect data about the error and the circumstances surrounding
its occurrence. This data may include technical details about
your device, what you were trying to do when the error
happened, and other technical information relating to the
problem. You may or may not receive notice of such errors,
even in the moment they occur, that they have occurred, or
what the nature of the error is.
Please be aware
that while this information may not be personally identifying
by itself, it may be possible to combine it with other data to
personally identify individual persons.
Device Data
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
Data we collect can depend on the individual settings of your
device and software. We recommend checking the policies of
your device manufacturer or software provider to learn what
information they make available to us.
Personal Information
We may ask for personal information — for example, when you subscribe to our newsletter or when you contact us — which may include one or more of the following:
Transaction data refers to data that accumulates over the
normal course of operation on our platform. This may include
transaction records, stored files, user profiles, analytics
data and other metrics, as well as other types of information,
created or generated, as users interact with our services.
Legitimate Reasons for Processing Your Personal
Information
We only collect and use your personal information when we have
a legitimate reason for doing so. In which instance, we only
collect personal information that is reasonably necessary to
provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
We may combine voluntarily provided and automatically
collected personal information with general information or
research data we receive from other trusted sources. For
example, If you provide us with your location, we may combine
this with general information about currency and language to
provide you with an enhanced experience of our site and
service.
Security of Your Personal Information
When we collect and process personal information, and while we
retain this information, we will protect it within
commercially acceptable means to prevent loss and theft, as
well as unauthorized access, disclosure, copying, use, or
modification.
Although we will do our best to
protect the personal information you provide to us, we advise
that no method of electronic transmission or storage is 100%
secure, and no one can guarantee absolute data security.
You
are responsible for selecting any password and its overall
security strength, ensuring the security of your own
information within the bounds of our services. For example,
ensuring any passwords associated with accessing your personal
information and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need
to. This time period may depend on what we are using your
information for, in accordance with this privacy policy. For
example, if you have provided us with personal information as
part of creating an account with us, we may retain this
information for the duration your account exists on our
system. If your personal information is no longer required for
this purpose, we will delete it or make it anonymous by
removing all details that identify you.
However, if
necessary, we may retain your personal information for our
compliance with a legal, accounting, or reporting obligation
or for archiving purposes in the public interest, scientific,
or historical research purposes or statistical purposes.
Children’s Privacy
We do not aim any of our products or services directly at
children under the age of 13, and we do not knowingly collect
personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
Your Rights and Controlling Your Personal
Information
Your choice: By providing personal information to
us, you understand we will collect, hold, use, and disclose
your personal information in accordance with this privacy
policy. You do not have to provide personal information to us,
however, if you do not, it may affect your use of our website
or the products and/or services offered on or through it.
Information from third parties:
If we receive personal information about you from a third
party, we will protect it as set out in this privacy policy.
If you are a third party providing personal information about
somebody else, you represent and warrant that you have such
person’s consent to provide the personal information to us.
Marketing permission:
If you have previously agreed to us using your personal
information for direct marketing purposes, you may change your
mind at any time by contacting us using the details below.
Access:
You may request details of the personal information that we
hold about you.
Correction: If you
believe that any information we hold about you is inaccurate,
out of date, incomplete, irrelevant, or misleading, please
contact us using the details provided in this privacy policy.
We will take reasonable steps to correct any information found
to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination:
We will not discriminate against you for exercising any of
your rights over your personal information. Unless your
personal information is required to provide you with a
particular service or offer (for example processing
transaction data), we will not deny you goods or services
and/or charge you different prices or rates for goods or
services, including through granting discounts or other
benefits, or imposing penalties, or provide you with a
different level or quality of goods or services.
Downloading of Personal Information:
We provide a means for you to download the personal
information you have shared through our site. Please contact
us for more information.
Notification of data breaches: We will comply with laws applicable to us in respect of any
data breach.
Complaints: If you believe
that we have breached a relevant data protection law and wish
to make a complaint, please contact us using the details below
and provide us with full details of the alleged breach. We
will promptly investigate your complaint and respond to you,
in writing, setting out the outcome of our investigation and
the steps we will take to deal with your complaint. You also
have the right to contact a regulatory body or data protection
authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of
communications (including marketing communications), please
contact us using the details provided in this privacy policy,
or opt-out using the opt-out facilities provided in the
communication. We may need to request specific information
from you to help us confirm your identity.
Use of Cookies
We use “cookies” to collect information about you and your
activity across our site. A cookie is a small piece of data
that our website stores on your computer, and accesses each
time you visit, so we can understand how you use our site.
This helps us serve you content based on preferences you have
specified.
Please refer to our Cookie Policy for
more information.
Business Transfers
If we or our assets are acquired, or in the unlikely event
that we go out of business or enter bankruptcy, we would
include data, including your personal information, among the
assets transferred to any parties who acquire us. You
acknowledge that such transfers may occur, and that any
parties who acquire us may, to the extent permitted by
applicable law, continue to use your personal information
according to this policy, which they will be required to
assume as it is the basis for any ownership or use rights we
have over such information.
Limits of Our Policy
Our website may link to external sites that are not operated
by us. Please be aware that we have no control over the
content and policies of those sites, and cannot accept
responsibility or liability for their respective privacy
practices.
Changes to This Policy
At our discretion, we may change our privacy policy to reflect
updates to our business processes, current acceptable
practices, or legislative or regulatory changes. If we decide
to change this privacy policy, we will post the changes here
at the same link by which you are accessing this privacy
policy.
If the changes are significant, or if
required by applicable law, we will contact you (based on your
selected preferences for communications from us) and all our
registered users with the new details and links to the updated
or changed policy.
If required by law, we will get
your permission or give you the opportunity to opt in to or
opt out of, as applicable, any new uses of your personal
information.
Additional Disclosures for General Data Protection
Regulation (GDPR) Compliance (EU)
Data Controller / Data Processor
The GDPR
distinguishes between organisations that process personal
information for their own purposes (known as “data
controllers”) and organizations that process personal
information on behalf of other organizations (known as “data
processors”). We, Alpaco ApS, located at the address provided
in our Contact Us section, are a Data Controller with respect
to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we
have a legal right to do so. In which case, we will collect
and use your personal information lawfully, fairly, and in a
transparent manner. If we seek your consent to process your
personal information, and you are under 16 years of age, we
will seek your parent or legal guardian’s consent to process
your personal information for that specific purpose.
Our
lawful bases depend on the services you use and how you use
them. This means we only collect and use your information on
the following grounds:
Consent From You
Where you give us consent to collect and use your personal
information for a specific purpose. You may withdraw your
consent at any time using the facilities we provide; however
this will not affect any use of your information that has
already taken place. You may consent to providing your email
address for the purpose of receiving marketing emails from us.
While you may unsubscribe at any time, we cannot recall any
email we have already sent. If you have any further enquiries
about how to withdraw your consent, please feel free to
enquire using the details provided in the Contact Us section
of this privacy policy.
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us,
or in order to take preparatory steps prior to our entering
into a contract or transaction with you. For example, if you
purchase a product, service, or subscription from us, we may
need to use your personal and payment information in order to
process and deliver your order.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests,
such as for us to provide, operate, improve and communicate
our services. We consider our legitimate interests to include
research and development, understanding our audience,
marketing and promoting our services, measures taken to
operate our services efficiently, marketing analysis, and
measures taken to protect our legal rights and interests.
Compliance with Law
In some cases, we may have a legal obligation to use or keep
your personal information. Such cases may include (but are not
limited to) court orders, criminal investigations, government
requests, and regulatory obligations. If you have any further
enquiries about how we retain personal information in order to
comply with the law, please feel free to enquire using the
details provided in the Contact Us section of this privacy
policy.
International Transfers Outside of the European Economic
Area (EEA)
We will ensure that any transfer of personal information from
countries in the European Economic Area (EEA) to countries
outside the EEA will be protected by appropriate safeguards,
for example by using standard data protection clauses approved
by the European Commission, or the use of binding corporate
rules or other legally accepted means.
Your Rights and Controlling Your Personal Information
Restrict: You have the right to request that we
restrict the processing of your personal information if (i)
you are concerned about the accuracy of your personal
information; (ii) you believe your personal information has
been unlawfully processed; (iii) you need us to maintain the
personal information solely for the purpose of a legal claim;
or (iv) we are in the process of considering your objection in
relation to processing on the basis of legitimate
interests.
Objecting to processing: You
have the right to object to processing of your personal
information that is based on our legitimate interests or
public interest. If this is done, we must provide compelling
legitimate grounds for the processing which overrides your
interests, rights, and freedoms, in order to proceed with the
processing of your personal information.
Data portability: You may have the right to request a copy of the personal
information we hold about you. Where possible, we will provide
this information in CSV format or other easily readable
machine format. You may also have the right to request that we
transfer this personal information to a third party.
Deletion:
You may have a right to request that we delete the personal
information we hold about you at any time, and we will take
reasonable steps to delete your personal information from our
current records. If you ask us to delete your personal
information, we will let you know how the deletion affects
your use of our website or products and services. There may be
exceptions to this right for specific legal reasons which, if
applicable, we will set out for you in response to your
request. If you terminate or delete your account, we will
delete your personal information within 90 days of the
deletion of your account. Please be aware that search engines
and similar third parties may still retain copies of your
personal information that has been made public at least once,
like certain profile information and public comments, even
after you have deleted the information from our services or
deactivated your account.
Additional Disclosures for California Compliance
(US)
Under California Civil Code Section 1798.83, if you live in
California and your business relationship with us is mainly
for personal, family, or household purposes, you may ask us
about the information we release to other organizations for
their marketing purposes.
To make such a request,
please contact us using the details provided in this privacy
policy with “Request for California privacy information” in
the subject line. You may make this type of request once every
calendar year. We will email you a list of categories of
personal information we revealed to other organisations for
their marketing purposes in the last calendar year, along with
their names and addresses. Not all personal information shared
in this way is covered by Section 1798.83 of the California
Civil Code.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell
websites that you do not want to have your online activities
tracked. At this time, we do not respond to browser “Do Not
Track” signals.
We adhere to the standards outlined
in this privacy policy, ensuring we collect and process
personal information lawfully, fairly, transparently, and with
legitimate, legal reasons for doing so.
Cookies and Pixels
At all times, you may decline cookies from our site if your
browser permits. Most browsers allow you to activate settings
on your browser to refuse the setting of all or some cookies.
Accordingly, your ability to limit cookies is based only on
your browser’s capabilities. Please refer to the Cookies
section of this privacy policy for more information.
CCPA-permitted financial incentives
In accordance with your right to non-discrimination, we may
offer you certain financial incentives permitted by the CCPA
that can result in different prices, rates, or quality levels
for the goods or services we provide.
Any
CCPA-permitted financial incentive we offer will reasonably
relate to the value of your personal information, and we will
provide written terms that describe clearly the nature of such
an offer. Participation in a financial incentive program
requires your prior opt-in consent, which you may revoke at
any time.
California Notice of Collection
In the past 12 months, we have collected the following
categories of personal information enumerated in the
California Consumer Privacy Act:
For more information on information we collect, including the
sources we receive information from, review the “Information
We Collect” section. We collect and use these categories of
personal information for the business purposes described in
the “Collection and Use of Information” section, including to
provide and manage our Service.
Right to Know and Delete
If you are a California resident, you have rights to delete
your personal information we collected and know certain
information about our data practices in the preceding 12
months. In particular, you have the right to request the
following from us:
The categories of personal
information we have collected about you;
To exercise any of these rights, please contact us using the
details provided in this privacy policy.
Shine the Light
If you are a California resident, in addition to the rights
discussed above, you have the right to request information
from us regarding the manner in which we share certain
personal information as defined by California’s “Shine the
Light” with third parties and affiliates for their own direct
marketing purposes.
To receive this information,
send us a request using the contact details provided in this
privacy policy. Requests must include “California Privacy
Rights Request” in the first line of the description and
include your name, street address, city, state, and ZIP
code.
Contact Us
For any questions or concerns regarding your privacy, you may contact us using the following details:
Copyright 2021, Alpaco ApS
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