Usage and Privacy Statement
ALPS Insights(TM) has created this usage and privacy statement (“privacy statement”) in order to demonstrate our commitment to privacy. Your right to privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed. This statement covers our primary website found at www.alpsinsights.com, as well as any other website we may have and disclose to you (all of which are referred to as “website”), as well as any features, widgets, plug-ins, applications, content, uploads and downloads of information and other services made available on our website.
Please see below for further information regarding the data we are exposed to and your rights in relation to the provision of such data.
Information Gathering and Usage
Your personal data
We intend to give you as much control as reasonably possible over your personal data as described in this privacy statement. In general, we collect and process personal data obtained from you in order to service your requests. Set out below is a list of the types of personal data we might collect from you and the purposes for which we would use it.
Types of information and purpose
In connection with your use of the website, we may be exposed to and collect personal data. Examples of personal data include: name, company, title, phone numbers, home and work postal and email addresses, IP addresses, device functionality (including browser, operating system, hardware, mobile network information); as well as the purpose of your contact (e.g., download a white paper) and preferences for contact.
Generally, we collect personal data from you when you volunatarily provide such information on our website or when we need this information in order to provide a service to you. In such instances, failure to provide your personal data may mean that we are not able to provide services you requested.
We also track how you use our website and interact with us, including information associated with any content you download or otherwise request from us, and information you provide when you use any interactive features of the website.
Where we process your personal information for direct marketing purposes, please be aware that you may object to our processing your personal data in this way at any time. If you do so, we will log your objection, stop processing your data for direct marketing purposes, and we will not contact you again.
In addition to any information that you choose to submit to us via our Service, we and our third-party service providers use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information.
Cookies and other tracking technology
We use various methods and/or technologies to collect non-personal and personal data from your visits to our website and your browser sessions to enhance your overall site experience and for statistical purposes such as cookies, web beacons, embedded scripts, browser fingerprinting, entity tags, UTM codes (i.e. a code that you can attach to a custom URL in order to track a source, medium, and campaign name), and recognition technologies that make assumptions about users and devices.
Types of Cookies on Our Services. We use the following types of cookies on our Services:
- Strictly Necessary Cookies: These cookies are essential because they enable you to move around on our website. For example, strictly necessary cookies allow you to access secure areas on our website. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our to work and they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so we can tailor our services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your visit to our website.
- Performance or Analytic Cookies. These cookies collect anonymous information about how you use our services on our website. For example, the cookies will collect information about the pages you view or click on while on our website or if you get an error message from certain pages. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.
- Advertising or Marketing Cookies. These cookies allow us to deliver relevant marketing and advertisements to you. They collect information about your interactions with our marketing activities (e.g., on the website or via emails) to determine what your interests and preferences are, and how effective such advertising or marketing campaigns are.
- How to Manage Cookies. Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:
- First-Party Cookies: You can enable, disable, or delete cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our website, and/or parts of the website may not work properly for you. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
- Third-Party Cookies: You can disable cookies from third parties by using your browser settings or, if available, directly opting-out of cookie collection with the third-party cookie service provider via their website.
If you’d prefer to restrict, block or delete cookies from this website or any other website, you can use your browser to do this. Each browser is different; so check online with the provider of your particular browser for instructions.
If you don’t wish to enable cookies, you’ll still be able to browse our website but certain cookie-dependent features will be unavailable to you.
Before collecting any personal data from you, we will generally ask you for your consent. We may request this consent in varying forms, such as, by asking you to tick a box on a form (or when visiting our website) or by asking you to provide a written or oral statement.
You may update your contact details and preferences or unsubscribe from any of the communications indicated above at any time by contacting our Contact Manager (email: firstname.lastname@example.org phone:833.706.2577).
Please note, however, that withdrawing your consent will not affect the lawfulness of processing based on the consent you grave prior to withdrawal.
Processing your data for our legitimate interests
In some cases, we will process your personal data for our legitimate interests, rather than seeking your consent. This is largely so that we can efficiently provide you with services without having to seek individual consent for everything we do (or where in some cases it might not be possible for us to seek your consent). We will, however, always provide you with information on our data processing activities on request and from time to time. For example, we may process your personal data:
- In order to provide you with the service you have requested;
- Where we want to market a new service to you; or
- Where a new form of processing would be more efficient.
Before undertaking such processing, we will consider your rights and freedoms and will only commence such processing where we do not think your rights will be harmed.
You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground. To exercise any of these rights above, please contact our contact manager (email: email@example.com phone: 833.706.2577).
We may share the personal data that you provide us to our service providers, to the extent necessary for the purpose of providing services to you. This may include the provision of your personal data to IT service providers, marketing platforms and legal advisors.
We may also provide your personal data (i) in the event that we sell any business or assets, in which case we will disclose your personal data to the prospective buyer of such business or assets; or (ii) if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets.
We will NOT otherwise use, share, disseminate, publish or disclose your personal data (except as may be required in response to litigation, investigations or other legally required disclosures).
We will access, use, preserve, transfer and disclose your information (including personal data) to third-parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend us or our policies, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of any third-party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we will use IP address or other device identifiers to identify users and will do so in cooperation with third-parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third-parties, all in our discretion, subject to applicable law. Where necessary in accordance with applicable law, such disclosures will be carried out without notice to you.
Where we store your personal data
We may transfer your personal data to, or store it in, a destination outside of the jurisdiction of the entity to which you provided it. Where we have to transfer your personal data to any other location, we will use appropriate approved safeguards, or we will seek your explicit consent. For further information, please do not hesitate to contact us using the details below.
Period for which we store your personal data
We will ensure that the period for which we store your personal data is limited to a strict minimum. We will store your personal data for no longer than is necessary for the purposes of providing the services you have requested and for legal compliance purposes. For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us using the details below.
Links to third-party websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We may offer free electronic newsletters or access to a free podcast or blog. We do not spam, sell or rent email addresses, and there’s an easy unsubscribe in every email you’ll receive. Alternately you may remove your address from our mailing lists by sending an email to firstname.lastname@example.org.
You may contact us at any time in order to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.
If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections we make to it.
In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:
- where you think data we hold about you are inaccurate, processing can be restricted while it is being rectified;
- where you object to our processing, (which is being carried out on the grounds that it is necessary in the public interest or for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests
- where processing is unlawful, but you oppose the erasure and request restriction of your data instead; and
- where we no longer need your personal data, but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.
You may ask to have the information on your account deleted or removed. We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal information of your request. However, we must keep track of certain transaction information, such as past purchases and similar information, for legal compliance purposes, so we may not be able to fully delete your information in certain circumstances.
Receiving/transferring your personal data
You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another person. Please note that if you choose to ask us to send your personal data to you or another party, this may impact our ability to provide the products and services you requested.
Where we are processing your personal information without your consent to pursue our legitimate interests, you may object to us processing your personal data. Where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.
You have the right to be informed of any automated decision-making, including profiling, used in connection with your personal data, and we will provide information about the logic we apply, as well as the significance and consequences of such processing.
For any of the requests listed above, please contact us at email@example.com or using the contact details below. We will make reasonable efforts to respond promptly and at the latest within one month. Our response to such requests may be limited to information under our direct control.
We work to limit access to personal data to employees and third-party agents, who we reasonably believe need to have access to such information to provide you with the information or services you request from us. Where information is provided to us via our website, in certain areas the information passed between your browser and our system is encrypted with secure sockets layer (“SSL”) technology to create a protected connection between you and our Site to ensure confidentiality.
We have security measures in place to help protect against the loss, misuse and alteration of the information under our control, however we cannot ensure the security of any information you transmit to us. While we work hard to incorporate commercially reasonable safeguards to help protect and secure all of your personal data, we cannot ensure the security of any information transmitted by you to us or guarantee that loss, misuse or alteration to data will not occur and personal data provided by you is done so at your own risk. .If you have any questions about our security, you can email us at firstname.lastname@example.org.
Children’s privacy protection
We do not target or provide services to children in our business, and our website is not intended for persons under the age of 16. We will not knowingly collect personal data from children and will delete such data upon discovery. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
If you do not wish to receive certain communications from us you may opt out by: (1) declining the service offered, (2) informing us at email@example.com that you no longer wish to receive such communications, or (3) following the opt out instructions that we include in each of our communications with you. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.
Notice to California Residents
Under California Civil Code Section 1798.83, California residents are entitled to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us at our firstname.lastname@example.org or the phone number available on our website. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Notice to Nevada Residents
We may elect to share information about you with third-parties for those third-parties’ direct marketing purposes. Nevada Revised Statutes §§ 603A.300-.360 permits Nevada residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and opt out of the sale of your personal information to third-parties for their direct marketing purposes. If this law applies to you, and you wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a Nevada resident and provide a current Nevada address for our response. To make such a request, please send an email to: email@example.com with “Nevada Privacy Rights” as the subject line or by writing the us at the Notice Address. You must include your full name, email address, and postal address in your request.
International Data Transfers
Our website is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including personal data, will be transferred to, and processed, stored and used in the United States in order to provide access to our website and to provide service to you. Where the General Data Protection Regulations (GDPR) applies and our processors of your personal data are located outside the European Economic Area, such transfer will only be to a recipient country that ensures an adequate level of data protection.
Additional Rights Provided to EU Individuals
Access and Portability: You have the right to ask us to access the information we hold about you, including personal data, and be provided with certain information about how we use your such information and who we share it with. Where you have provided your personal data to us with your consent, you have the right to ask us for a copy of this data in a structured, machine readable format and to ask us to share (port) this data to another data controller.
Right to deletion: In certain circumstances, you have rights under GDPR to ask us to delete the personal data we hold about you:
- where you believe that it is no longer necessary for us to hold your data including personal data;
- where we are processing your personal data on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
- where you have provided your personal data to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; or
- where you believe the personal data we hold about you is being unlawfully processed by us.
Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:
- where you believe the personal data we hold about you is inaccurate and while we verify accuracy;
- where we want to erase your personal data as the processing is unlawful, but you want us to continue to store it;
- where we no longer need your personal data for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- where you have objected to us processing your Personal data based on our legitimate interests and we are considering your objection.
In addition, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your Personal data unless we can demonstrate an overriding legitimate ground.
To exercise any of these rights above, please contact us at firstname.lastname@example.org.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals where there are overriding public interest reasons or where we are required by law to retain your personal data.
You can withdraw your consent at any time by contacting us at email@example.com.
Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority.
If you would like to get in touch with us with regards to your personal data, contact us at:
16 West Martin Street, Suite 9011
Raleigh, NC 27601
Changes in this Privacy Statement