Last Updated: January 1, 2020
EU-U.S. Privacy Shield Framework
What Information We Collect; the Purpose of Collection and Use
We collect the following categories of information. Subscribers 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.
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 receive our newsletter. 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.
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-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 our third party bank processors operating as our agent (See, Onward Transfers to Third Parties).
Other Information: In addition to the Contact Information, Service Information and Billing Information, we may collect or receive the following information:
- From Your Activity.In an ongoing effort to improve the Site and the Services, we automatically collect certain information when visitors visit the Site and when Subscribers and End Users use the Services. This information consists of IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site visitors visit, and similar information concerning your use of the Site and the Services.
- From Web Beacons. A “Web Beacon” is an object embedded in a web page, which allows website operators to check whether a user has viewed a particular web page or an email, and which typically are invisible to the user. AlphaPoint may use Web Beacons on its Site and in its emails to count users who have visited particular pages or viewed emails, and with respect to AlphaPoint’s Services. Note that Web Beacons are not used to access personal information. They are used purely to compile aggregated statistics about Site and the Services usage. Web Beacons collect only a limited set of information including a Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. While you may not decline Web Beacons, you may render them ineffective by declining all Web Beacons or modifying your browser settings to provide notifications each time a Web Beacon is tendered – allowing you to accept or decline Web Beacons on an individual basis.
For Google Analytics, please visit: https://www.google.com/analytics
For Google Adwords, you can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
Aggregate Data. In an ongoing effort to better understand our users and the Site and the Services, we may analyze your information in aggregate form and also merge it with other data to use for our reporting, planning, development, operating, maintaining, managing, and improving the Site and the Services and for promotional purposes. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Service and the Site to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
Opt-In to Certain Onward Transfers
We will not transfer your personal information to a third party controller without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent.
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 firstname.lastname@example.org.
In each instance, please allow us a reasonable time to process your response.
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: email@example.com. Please allow us a reasonable time to process your request.
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.
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.
Access to Personal Information
Should you choose to unsubscribe from any mailing lists for which you registered, you may do so by following the instructions on how to unsubscribe provided in all AlphaPoint communications.
Retention of Personal Information
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 Privacy Shield, your decision to provide such data to us, or allow us to collect such data it 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 firstname.lastname@example.org.
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.
If you have any queries about the privacy statement or to report a privacy issue, please contact us in one of the following ways: