ALOSANT PRIVACY POLICY

Last Revised Date: Oct 8, 2018

1. INTRODUCTION

This Privacy Policy describes how Alosant LLC treats data and information that Alosant collects and receives from you through Alosant branded or developed websites (collectively, “Websites”) as well as Alosant branded or developed applications (collectively, “Applications”) that run on computing devices such as laptops, mobile devices and tablets.

Alosant respects your privacy and is committed to treating your information responsibly. To that end, Alosant has developed this Privacy Policy for the purpose of providing full disclosure concerning its collection, use and sharing of information that is gathered during your interaction with the Websites and the Applications. This Privacy Policy describes, among other things, the types of information collected about you when you visit the Websites and use the Applications; how your information may be used and when it may be disclosed; how you can control the use and disclosure of your information; and how your information is protected.

We will strive to process your personal data lawfully, fairly, and in a transparent manner that complies with the General Data Protection Regulation (“GDPR”) as specified by the European Union. Your personal data will be collected for specified, explicit and legitimate purposes that align with the services you have requested and not further processed in a manner that is incompatible with the requested services. Our processing of your data shall be limited to that which is adequate, relevant and limited to what is necessary to provide you the requested services. Once we have processed or stored your data we will use reasonable efforts to assure your personal data is accurate, up to date, and eliminate inaccuracies we find or you notify us exist. We do not, however, assert, claim, or ensure the personal data you provide or is provided by others to us is accurate. We will use industry standard practices to for no longer than is necessary to provide you with requested services, or personal data may be stored for longer periods insofar as the personal data will be required for financial or legal reasons, or remains part of our normal archiving process when such data shall remain offline and not available to the public, or processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with GDPR Article 89(1). We implement industry standard practices to provide security and protect the confidentiality of your personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. We periodically update our standard practices which can be obtained upon request.

We will process your personal data when you provide consent in compliance with all State and Federal laws, when the processing is necessary to provide you the service you requested, to protect your vital interests or that of someone else, when necessary to accomplish a task in the public interest, and when necessary for us to perform standard business and technical processes where such processes do not override your rights or that of a minor. If we must process or store your personal information for any other reason we will notify you and request your consent if such consent is required.

Although Alosant endeavors to maintain appropriate physical and electronic procedures and safeguards to protect personal information that is collected by and through the Websites and the Applications, Alosant cannot guarantee the confidentiality of such information. Accordingly, by using the Websites and the Applications, you understand that (i) you are doing so at your own risk and (ii) Alosant cannot promise that collected information will never be disclosed in a manner that is inconsistent with this Privacy Policy.

Should you have any questions regarding this Privacy Policy, or if you believe that Alosant is not abiding by this Privacy Policy, please contact the Privacy Administrator at the address set forth in Section 14, below.

2. SCOPE OF PRIVACY POLICY; ACCEPTANCE

This Privacy Policy applies to information collected about you ‑ and from you – by and through the Websites and the Applications. We will collect information in order to provide you with notices about events and services taking place within that community. We provide additional information and community feedback as well as other information and services in support of this larger service.

Your use of the Websites and the Applications constitutes your consent to Alosant’s collection and use of such information in accordance with the terms hereof. Each time you access, browse or use the Websites or the Applications, you signify your acceptance of the Privacy Policy (in its then-current form). If you do not accept this Privacy Policy, you are not authorized to use the Websites or the Applications and must discontinue use of the Websites and the Applications immediately.

3. INFORMATION THAT ALOSANT COLLECTS

During our normal course of business we do not collect, process, or store personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, health data, or data concerning a natural person’s sex life or sexual orientation. Should such personal data come into our possession or be processed by us from other sources, including you providing such data, we will erase this type of data upon your request or maintain such data upon your request with explicit consent by you. Only with your consent or for compelling reasons enumerated in GDPR Chapter 2 Article 2(2) or as compelled by law will we collect, store, or process such data.

You understand and acknowledge that providing personal data may be a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as obliged to provide personal data to access the site, services, or software and may be denied as the result of a failure to provide such data.

Alosant collects two (2) types of information by and through the Websites and the Applications: Personal Information and Non-Personal Information.

  1. Personal Information. Personal Information is information that tells Alosant specifics about you. The types of Personal Information that Alosant may collect include, without limitation: your name and contact information (such as your postal address, zip code, phone number and e-mail address); your password; your gender; the number and/or ages of members of your household; information about relating to product preferences; personal interests; household income; and areas of interest on the Websites.

Alosant may collect Personal Information from (and about) you in a variety of different ways. For example, when you register on a Website or Application, you submit Personal Information to Alosant. Similarly, when you use the Websites or the Applications to create or update a profile, register for events, or communicate or interact with Alosant and/or its representatives, you are providing Alosant with Personal Information. Alosant may also acquire Personal Information about you from publicly available sources, social media platforms (e.g., Facebook) and other third parties that may share information as permitted in their privacy policies.

Also note that Alosant may combine Personal Information about you with information available from other sources (e.g., social media platforms, analytics services [see Section 5.B, below], offline records or publicly available information). If the combined information is maintained, used or shared by Alosant in a manner that associates it with your name or contact information, Alosant will treat such information as Personal Information.

  1. Non-Personal Information. Non-Personal Information refers to data and information that does not personally identify you as the individual to whom the data or information relates. Non-Personal Information may include, without limitation:

Alosant may choose to receive and record Non-Personal Information on its server logs from your browser, as well as through other analytics in relation to the Websites and the Applications. Alosant may also obtain Non-Personal Information about you ‑ either directly or through inference ‑ from social media platforms, third parties and other lawful sources.

  1. Information Obtained from Another Source. Alosant will notify you within one month after obtaining information about you from another source, which may be a source offering publicly available information or a private source which you have given us permission to access. If we communicate with you using information we obtained from a third-party we will notify you at the time of communication that we have obtained such information.

  2. Right to Erasure of Data. You have the right to obtain from us the erasure of personal data concerning you without undue delay and we will have the obligation to erase personal data without undue delay when: (i) your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw your consent on which the processing is based providing there is no other legal ground for the processing or retaining of your personal data; (iii) you object to the processing and there are no overriding legal or legitimate grounds for the processing; (iv) we have inadvertently or unlawfully captured or processed your personal data; (v) your personal data must be erased in order to comply with a legal order issued by a court of proper jurisdiction or to comply with a statute to which we are subject; (vi) your personal data has been collected in relation to the offer of information society services referred to in GDPR Article 8(1). Where we have made your personal data public and are obligated to erase the personal data, we will, after taking account of available technology and the cost of implementation, take reasonable steps, including technical measures at our disposal, inform others which are processing or storing your personal data that you have requested the erasure by such others of any links to, or copy or replication of, your personal data. You acknowledge that such public information may never be completely erased despite our efforts. We may not be able to erase your information, specifically when continued processing or storage is necessary for: (i) exercising the right of freedom of expression and information; (ii) compliance with a legal obligation which requires processing or storage where such legal obligation stems from a legal order issued by a court of proper jurisdiction or compliance with a statute to which we are subject; (iii) reasons of public interest in the area of public health as specified in the GDPR; (iv) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with those specified in the GDPR; (v) or to assert, exercise, or defend legal claims.



4. USE AND DISCLOSURE OF INFORMATION

We will process and store your personal data while you continue to use the requested services and, upon termination of your use of the requested services, we will erase your personal data from active repositories and, through the normal course of business and technical processes, erase your personal information from archives and backup storage. We will employ industry standard practices as to removal from archive and backup storage which may impact the length of time the data is kept or the criteria used to determine the length of time. However, where such data is required for financial or legal compliance we may not be able to erase your data.

The information Alosant collects will vary depending upon how you use the Websites and the Applications. Data may be captured based on your user profile and your interaction in the site and such data may be utilized by algorithms to enhance your user experience or supplement personal data. Alosant’s use and disclosure of the collected information will vary depending on the type of information Alosant receives – i.e., Personal Information vs. Non-Personal Information.

If we intend to further process the personal data for any purpose other than that for which the personal data was obtained, we will provide you with information on that other purpose and with any relevant further information prior to the further processing. You will have the right to obtain from us information as to whether your personal data is being processed, and if so, (i) be informed of the purpose of the processing; (ii) be informed of the categories of personal data processed; (iii) be informed of the recipients or categories of recipient to whom the personal data have been or will be disclosed, if any; (iv) be aware, if possible, of the time period for which the personal data will be stored, or, if not possible, the criteria used to determine that time period; (v) be afforded the existence of the right to request from us, or a third-party, rectification or erasure of personal data or restriction of processing of your personal inform, or object to such processing; (vi) have the right to submit a complaint to us or the appropriate third-party; (vii) have the right to request the source of any information not collected directly from you; (viii) be notified if your personal data is utilized by algorithms to enhance your user experience or supplement personal data; and (ix) the right to obtain a copy of the personal data undergoing such processing and you agree to pay a reasonable fee if requested for a copy of your personal data being so processed providing obtaining such a copy does not adversely affect the rights and freedoms of others.

However, we may not provide notice as to third-party obtained information if providing such information would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in GDPR Article 89(1) or in so far as the obligation referred to in GDPR Article 14(1) is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases we will take appropriate measures to protect your rights, freedoms and legitimate interests, including making the general information publicly available but not identifying you specifically.

We may use Personal Information and Non-Personal Information as follows:

  1. Personal Information. Alosant may use your Personal Information to:

By using the Websites and/or the Applications, you authorize Alosant to transmit email and direct mail to you, call you, send push notifications to your device, send you text messages, and otherwise contact you concerning these matters. You may, at any time, cancel such notifications. However, these notifications form part of the core serve we provide and cancelation may reduce the usefulness of our software and services.

If we disclose information to a third-party we will notify you before or at the time of disclosure. Alosant may intentionally disclose your Personal Information only in the following instances:

      1. Disclosures You Have Requested. Alosant will provide your Personal Information to those entities and individuals that you have specifically designated (using the Websites, the Applications or otherwise) to receive your information so that said entities and individuals can perform in accordance with your directives/wishes, contact you to address your questions and requests, etc. However, the Company is not responsible for the collection or maintenance of such information once it is in the hands of the designated entit(y/ies) or individual(s).

      2. Disclosures to Which You Have Consented. Alosant may disclose your Personal Information if you have consented (whether expressly or implicitly) to said disclosure. By way of example only, if (i) you elect to participate in a sweepstakes sponsored by Alosant and (ii) the official rules of the sweepstakes declare that Alosant may publish the names of (and other information regarding) the sweepstakes entrants and/or winners, then, by virtue of your decision to participate in the sweepstakes, you are deemed to have consented to the official rules and the disclosure of your Personal Information in accordance with the rules.

      3. Disclosures to Trusted Third Parties. Alosant may provide your Personal Information to third-parties who work on behalf of or with Alosant, provided that (i) the disclosure is necessary or otherwise convenient in connection with assisting Alosant in its operations and (ii) said operators work under confidentiality or similar agreements. We may share your personal data with third-parties, such as social media, payment processing, and software support service providers which will provide you with their privacy policies and terms and conditions for use.

      4. Disclosures under Special Circumstances. Alosant may store and disclose your Personal Information (i) as allowed or required by applicable law (including making disclosures in order to respond to subpoenas, court orders or legal process) and (ii) to establish or exercise Alosant’s legal rights or defend against legal claims as necessary or advisable to protect the rights, safety or property of Alosant ‑ or others ‑ and to conform to legal or regulatory requirements. Additionally, Alosant may store and disclose your Personal Information when Alosant believes it is necessary to share such information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the TERMS OF USE applicable to the Websites, or as otherwise required by law.

  1. Non-Personal Information. Alosant may use your Non-Personal Information in several ways including, but not limited to:

Alosant may use, share or disclose your Non-Personal Information only with your permission or to provide critical services which you have requested. For example, Alosant may disclose your Non-Personal Information to employees, consultants and other professionals who Alosant reasonably believes need such information in order to perform the tasks described in this Section 4.B. Additionally, Alosant may combine your Non-Personal Information with other non-personal information collected by Alosant and will only share the aggregated data with service companies and product providers for marketing and research purposes when you have given us explicit permission to do so.

5. USE OF COLLECTION TECHNOLOGY AND ANALYTICS SERVICES

  1. Collection Technology. Non-Personal Information may be collected by Alosant using a variety of Collection Technology. As used in this Privacy Policy, “Collection Technology” refers to cookies, web beacons, pixels, gifs, tags and other tools that collect information in similar ways. Collection Technology may store a piece of data on your browser or device, while other forms of Collection Technology may identify your browser or device and collect information through other means. When you visit the Websites or use the Applications, your browser or device may be exposed to Collection Technology, and Collection Technology may be stored on your browser or device. Alosant may access, retrieve and use the Non-Personal Information generated and stored by the Collection Technology on your browser or device. You may delete and/or refuse the use of certain Collection Technology by selecting the appropriate settings on your browser. And, you are not barred or precluded from using the Websites or the Applications if you choose to delete and/or refuse such Collection Technology. However, please note that some parts of the Websites and/or the Applications may not work properly if you elect to delete and/or refuse Collection Technology.

  2. Analytics Services. Alosant may use third-party analytics services to facilitate the compilation, tracking and analysis of information that is accumulated using Collection Technology. For example, Alosant may use Google Analytics to measure, analyze and report on data gathered through Collection Technology to assist Alosant in understanding and optimizing use of the Websites. Information and data collected through Alosant’s use of analytics services shall be used and shared by Alosant solely in conformance with this Privacy Policy. However, please be advised that third-party analytics services are governed by their own privacy policies, and Alosant has no control over the scope, limitations or requirements of these policies. Should you have any questions regarding Alosant’s use of analytics services, please contact the Privacy Administrator at the address identified in Section 14 of this Privacy Policy.

  3. Artificial Intelligence. We may use automated processing, including artificial intelligence, machine learning, and other techniques to process your data. We will not use any type of automated processing if such processing produces legal effects concerning you or similarly significantly affects you unless such processing is: (i) necessary for entering into, or performance of, a contract between the you and us; or (ii) authorized by the State of Montana or US law to which we are subject and which also establishes measures to safeguard the your rights, freedoms, and legitimate interests; or results from your explicit consent. In the case of (i) or (iii), we will implement reasonable measures to safeguard your rights, freedoms, and legitimate interests, and, where and when possible, involve human intervention on our part to express your point of view and to contest the decision. In the case of the most sensitive data, such as race, ethnicity, gender, and the like, we will provide industry standard measures to safeguard your rights, freedoms, and legitimate interests.

6. PROTECTION OF INFORMATION

Alosant is committed to protecting your Personal Information. Accordingly, Alosant has adopted commercially reasonable technical, administrative and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access and alteration. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure (e.g., third party “hackers” may unlawfully intercept or access information or confidential transmissions). Alosant wants you to feel confident using the Websites and the Applications; but, as indicated in Section 1, above, Alosant cannot ensure or warrant the security of any information you transmit to Alosant and any such transmission is done at your own risk.

7. LINKS TO THIRD-PARTY WEBSITES

The Websites and/or the Applications may contain links to websites, applications, services, notices and the like provided by other companies and/or individuals. These links are provided solely as a convenience to viewers of the Websites and users of the Applications and not as an endorsement of the contents of such links. Although Alosant endeavors to provide links only to websites, etc. maintained by reputable entities and organizations, you should be aware that these third parties might be able to gather information from and about you if you visit their websites, etc. In these cases, those third parties will use such information in accordance with their own privacy policies, which may differ substantially from this Privacy Policy. Alosant strongly encourages you to read the privacy policies of these third parties. Alosant assumes no liability for the privacy practices of such other websites, etc. and is not responsible for the availability or content of any off-site pages or any other websites, etc. linked to the Websites or the Applications. Your linking to off-site pages or other websites, etc. is at your own risk.

8. CORRECTION OF PERSONAL INFORMATION

Alosant endeavors to keep your Personal Information current and accurate. You have the right to obtain from us without undue delay rectification of inaccurate personal data concerning you. Taking into account the purposes of our processing of your information and our regular business and technical processes, you have the right to supply incomplete personal data, including by means of providing a supplementary statement. Accordingly, Alosant appreciates your courtesy in providing Alosant with notice of any changes to your Personal Information via e-mail, telephone or postal mail at the addresses shown in Section 14, below. However, you have the right to request access to and rectification or erasure of personal data, or restriction of processing concerning your data, or to object to processing as well as the right to data portability.

You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format of our choice and have the right to provide such information to any party of your choosing without restriction or hindrance from us. If practicable, and at our sole discretion, we may provide your personal data to a third-party you have explicitly designated in writing. Receiving your data has no impact or relationship to decisions you may make regarding erasure of your personal data nor adversely affect the rights of others.

You may at any time opt-in to have your Personal Information used by Alosant for mailings, calls, etc. by notifying Alosant via e-mail, telephone or postal mail at the addresses shown in Section 14, below. If, subsequent to opting in, you elect not to receive any future contacts from Alosant, we will endeavor to remove your name from all of contact lists within ten (10) business days. However, information is sometimes difficult ‑ if not impossible ‑ to remove from all data sources and, accordingly, Alosant can only promise to remove you from any lists that Alosant controls using industry standard techniques.

9. CHILDREN

The safety of children is very important to Alosant, and Alosant is committed to protecting the privacy of children. In this regard, (i) the Websites and the Applications are directed to persons 18 years of age or older and (ii) Alosant does not knowingly collect information from children under the age of 18.

If you provide Personal Information to Alosant through the Websites or the Applications, you represent and warrant to Alosant that you are 18 years of age or older, or of the legal age as legally specified in your jurisdiction. If you are under the age of 18 and not of the legal age within your jurisdiction to provide Personal Information, you may visit, browse and use the information on the Websites or the Applications, but you may not submit any Personal Information to/through the Websites or the Applications and you represent and warrant to Alosant that you have the permission of your parent or legally designated guardian to use the Websites and the Applications. If Alosant becomes aware that you, or any user of the Websites and/or the Applications, is under the age of 18 and has provided Personal Information, Alosant will remove said information from its files and repositories within thirty (30) days unless complexity and number of requests is excessive, in which case the time period may be extended up to two additional months. In such case, you, or the subject, will be notified of the timetable for removal of Personal Information. No fee shall be charged for removal of this type of information.

10. NOTICE TO RESIDENTS OF SPECIFIC JURISDICTIONS

Residents of specific jurisdictions which may have specific rights outside or beyond those of the GDPR are entitled to request information about Alosant’s compliance with specific jurisdictional standards. You may make such a request by sending an e-mail or letter to Alosant at the following address:

Privacy Administrator
Alosant LLC
5 W MENDENHALL ST STE 202
BOZEMAN, MT 59715
E-Mail: info@Alosant.com

11. PRIVACY POLICY EFFECTIVENESS

This Privacy Policy shall apply only to individual consumers and solely to information collected by or through the Websites and the Applications.

12. CHANGES IN PRIVACY POLICY

This Privacy Policy may be revised from time to time in the sole discretion of Alosant. Alosant displays a “Last Revised Date” on the upper left corner of the Privacy Policy for you to know when there has been a change in the Privacy Policy. Accordingly, you should check the Privacy Policy on a regular basis for Alosant’s most current privacy practices. Each time you access, use or browse the Websites and/or the Applications, you signify your acceptance of the then-current version of this Privacy Policy. Any changes in this Privacy Policy will take effect upon posting.

Alosant will use information collected by and through the Websites and the Applications in accordance with the version of the Privacy Policy in effect as of the date the information was collected. If, at any point, Alosant decides to use Personal Information in a manner that is materially different from that stated at the time it was collected, Alosant will provide you with notice or have other communications with you in the manner and to the extent required by law.

13. GOVERNING LAW

This Privacy Policy shall be governed by and shall be construed in accordance with the GDPR and the laws of the State of Montana unless otherwise specified. Where conflicts exist between the GDPR and the State of Montana law, the GDPR shall prevail.

14. QUESTIONS OR CONCERNS

If you have any questions or concerns about this Privacy Policy, please contact Alosant at:

Privacy Administrator
Rancho Mission Viejo Community Services Organization (“Alosant”)
Todd Beebe, General Manager
Gateway Place, Ste. E-3
Rancho Mission Viejo, CA 92694
E-Mail: ask@rmvAlosant.com