ALPHAPOINT PRIVACY POLICY
Updated Dec 28, 2023. Your continued use of our websites and services is your agreement to the updated policy.
Introduction
At AlphaPoint Corporation (together with its affiliates and subsidiaries, including, but not limited to, AlphaPoint Global Ltd. and AlphaPoint Global S.A. de C.V., “AlphaPoint”; with use of the words “Our”, “Us”, or “We” referring to AlphaPoint), we understand and respect our user’s need for privacy. This Privacy Policy (“Policy”) describes how we collect, use, chase, and process personal information; what rights and choices you may have with respect to your information; how you may contact us, and how we protect your information when you:
- Visit AlphaPoint’s website, such as www.alphapoint.com;
- Access or use products, services, and related applications offered by AlphaPoint (collectively, the “Services”)
- Interact with us in any way, including registering for, attending, or otherwise partaking in our events, tutorial, webinars (collectively, “Marketing Activities”)
The Site and Services are not directed to children under 18 years of age and we do not knowingly collect personal information from children under 18. If we learn that we have collected any personal information from children under 18, we will promptly take steps to delete such information. If you are aware that a child has submitted us such information, please contact us using the details provided below.
By visiting our Site, purchasing, accessing or using our Services, you are confirming that you are at least eighteen (18) years old and are agreeing to be bound by the terms of this Privacy Policy and the accompanying Terms of Use. If you do not agree, please do not use or access the Services.
EU-U.S. Data Privacy Framework
AlphaPoint complies with the EU-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. To learn more about the Data Privacy Framework program, and to view please visit https://www.dataprivacyframework.gov/s/
What Information We Collect; the Purpose of Collection and Use
We collect the following categories of information; and subscribers and users of our Services (“Subscribers”) authorize the collection, processing and transfer of such information, and assume contractual responsibility for providing notification to Subscriber’s customers who are end users of the Services and obtaining all consents as required under applicable laws and regulations.
Information You Provide Directly to Us
- Contact Information: We collect contact information on our Site from visitors and customers who wish to obtain information or support, to purchase our Services or engage in Marketing Activities. Contact information is provided via browser forms or online forms, and includes first name, last name, e-mail address, name of the organization, and country (“Contact Information”). This Contact Information is used by our sales, support and product teams to contact our Site visitors and customers, as appropriate, for the purpose of providing the requested information, support, Services, newsletters, or other news, materials or updates regarding our Services.
- Professional information –We collect professional information about you when you submit an inquiry through our Contact Us form, including company name, job title, role type, and company website.
- Service Information: In the course of performing our Services, we collect the following categories of information (collectively, “Service Information”).
- End User Information: End User means (i) Subscribers’ customers who are end users of our Services; and (ii) all customers of AlphaPoint’s other Subscribers who seek to enter into Transactions (as defined below) through the Services. We may collect limited End User information at the direction of our Subscribers. Where we have End User information, it is limited to IP addresses and e-mail addresses. Subscribers may, at their discretion, prefer to keep all End User information private consistent with their internal policies. Alternatively, Subscribers may utilize the functionality to collect limited private information (which is only accessible in a Subscriber’s environment). End User information is used to operate, maintain and improve the Services.
- Transaction Information: We collect transaction related information for transactions conducted by End Users through the Services (“Transactions”) but it is anonymized. Transaction information includes price, quantity, and any associated or supporting data related to the trade. Transaction information is used to provide the Services, facilitate the Transactions, provide support, and to operate, maintain and improve the Services.
- Billing Information: We collect billing and payment information which may include a purchase order number, an account number, credit card number, expiration date, billing zip code, bitcoin-, cryptocurrency- and digital assets-related information, instructions for wire transfers and/or ACH transfers (“Billing Information”) from Subscribers (and not End- Users). Billing Information is collected and processed by our third-party payment processor operating as our agent (See, Onward Transfers to Third Parties). AlphaPoint does not directly obtain or process any Billing Information; except in the case of ACH transfers in which case we obtain the Billing Information related to ACH transfers and send (not store) it to third party bank processors (See, Onward Transfers to Third Parties).
- Marketing Activities – When you engage with our Marketing Activities, we collect information provided by you, including through form submissions, email communications, or phone calls to inquire about AlphaPoint and our Services. We also collect information you provide to us when you participate in a survey, interact with us virtually or in person at an event, or via a phone call with one of our sales or customer support representatives (e.g., the nature of your communication, of your communication, your contact preferences, and any information you choose to provide to us when completing any “free text” boxes in our forms).
- Any information you voluntarily provide to us, such as when you submit an inquiry through our support portal (e.g., contents of a message or attachments that you send to us).
Information We Collect from Third Parties
We receive information about Subscribers from third parties that provide services. We limit our use of your personal information to the purposes described in this Notice. Personal information we receive from third parties includes:
- Contact information, such as name, email, address.
- Organization information, such as company name, job title, and company address; and
- Social Media information related to our Marketing Activities, such as URLs, profile pictures, and profile ID.
Information We Collect Automatically
When you use or interact with the Site and Services, we automatically collect or receive certain information about your device and usage of our Site and Services. This information includes:
- Usage information – We collect information about your usage and behavior on our Site and Services. This information includes browser type and settings, usage details (e.g., timestamps, frequency, and use pattern), language preferences, and device event information (e.g., system activity and hardware settings, application version, and amount of time spent on our Site), information about how you interact with our Services, Marketing Activities and Sites, (e.g., clicks, scrolls, mouseovers, internal links, pages viewed, searches, page response times, download errors, and date/time stamps associated with your usage), request information (e.g., speed, frequency), the site from which you linked to us (“referring page”), and the name of the website you choose to visit immediately after ours (“exit page”), and information about other websites you have recently visited and the web browser used.
- Device information – We collect information about your device automatically when you use our Site and Services. This information includes web browser and device characteristics, operating system, IP address, location, device type, Internet service provider, mobile network, system configuration information, model, model number, push notification tokens, and unique device identifiers, (e.g., your username and password).
Visit our Cookie Notice for additional information.
Onward Transfer to Third Parties
Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: customer service and marketing assistance, performing business, sales, and traffic analyses and analytics, supporting our website functionality, payment processors, and supporting other features offered through our Site and Services.
Opt-In to Certain Onward Transfers
We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. You may grant such consent by contacting us at privacy@alphapoint.com.
How We Share Information
AlphaPoint shares Subscriber personal information with third parties as required by law and as needed to deliver our Services, subject to appropriate safeguards and contractual arrangements.
Third-Party Service Providers
We share your information with third-party service providers that require access to your information to support our operations and delivery of Services. The third parties that AlphaPoint shares your information with include:
- Marketing partners for our Marketing Activities, such as developing, providing, and sending promotional and advertising materials that we think may be useful, relevant, valuable, or otherwise of interest to you. We may also publicly display comments and testimonials we receive from users.
- Cloud hosting providers to provide data storage and processing services.
- Analytics companies to perform analysis on our Marketing Activities and Services.
- Business Transfer
In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. - Disclosures to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Opt-Out for Direct Marketing
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: privacy@alphapoint.com. Please allow us a reasonable time to process your request.
Cookies and Other Tracking Technologies
When you visit our Site or interact with our Marketing Activities, we use cookies and similar technologies such as web beacons and web server logs, alone or in conjunction with cookies, to automatically collect certain technical information from your browser or device. For more information about how we use cookies and to learn how to manage cookies, please see our Cookie Notice.
How We Protect Your Information
We have implemented security policies, rules, and technical measures to protect and safeguard your personal information within our custody from unauthorized access, improper use or disclosure, unauthorized modification, as well as unlawful or unintended destruction or loss, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. You should keep in mind, however, that no internet transmission is 100% secure or error-free. In particular, e-mail sent to or from the Site and/or the Services may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail or other electronic means.
External Sites
Our Site may contain links to other sites, for instance regarding our partners or clients, or media coverage of AlphaPoint services. Other sites may also reference or link to our site. AlphaPoint encourages you to review the privacy and security policies of any externally linked websites that may be accessed through the Site. Please note AlphaPoint is not responsible or liable for the information collection and disclosure practices of any such external websites and for the privacy practices or content of such external sites. Please check the privacy policies of these external websites before you submit any personal information or other information to them.
Your Privacy Choices and Rights
Privacy Choices
You have certain choices and rights when it comes to how we collect and use your personal information. Below is a summary of those choices and rights, and how to exercise them.
- Opt-out of marketing communications: You may opt-out of receiving any marketing communications from us in the following ways:
- Email: Click the “Unsubscribe” link within each email or by contacting us as provided in our “Contact Us” section. If you are a Customer and opt out of receiving marketing messages, you will continue to receive transactional communications from us regarding our Services.
- Direct mail: Follow the opt-out process described in the direct mail communications, or by contacting us directly as provided in our “Contact Us” section.
- Managing Cookies and Other Tracking Technologies: To learn more about how to manage your cookie settings on our Site, please visit our Cookie Settings and Cookie Notice.
Access to Personal Information
Upon request to privacy@alphapoint.com, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.
Retention of Personal Information
We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.
Privacy Rights
Depending on where you are located, you may have certain rights in connection with your personal information that we obtain. These rights vary depending on your jurisdiction.
Important Notice to All Non-U.S. Residents
Our servers are located in the US and outside of the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US or other jurisdictions. Except in the case of data transfers under the EU-US Data Privacy Framework, your decision to provide such data to us, or allow us to collect such data through our Site and/or the Services, constitutes your consent to this data transfer.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact AlphaPoint via email at privacy@alphapoint.com .
In addition, AlphaPoint does not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.
European Economic Area, UK and Switzerland
We only collect your personal information if we have a legal basis for doing so. The legal basis that we rely on depends on the personal information concerned and the specific context in which we collect it. Generally, we collect and process your personal information where:
- We need it to enter into or perform a contract with you, such as to provide you with Services, respond to your request, or provide you with customer support;
- We need to process your personal information to comply with a legal obligation (such as to comply with applicable legal, tax and accounting requirements) or to protect the vital interests of you or other individuals;
- You give us your consent, such as to receive certain marketing communications; or
- Where we have a legitimate interest, such as to respond to your requests and inquiries, to ensure the security of the Site and Services, to detect and prevent fraud, to maintain, customize and improve the Site and Services.
If you have consented to our use of your personal information for a specific purpose, you have the right to change your mind at any time but this will not affect our processing of your information that has already taken place. You also have the following rights with respect to your personal information:
- The right to access, correct, update, or request deletion of your personal information;
- The right to object to the processing of your personal information or ask that we restrict the processing of your personal information;
- The right to request portability of your personal information;
- The right to withdraw your personal information at any time, if we collected and processed your personal information with your consent; and
- The right to lodge a complaint with your national data protection authority or equivalent regulatory body.
If you wish to exercise any of your rights under data protection laws, please contact us privacy@alphapoint.com.
Changes to this Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Site as soon as they go into effect. By accessing the Site and/or the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
Contact us
If you have any queries about the privacy statement or to report a privacy issue, please contact us in one of the following ways:
Email: privacy@alphapoint.com