Privacy Policy
Welcome to the website (the “Site”) of Alt Platform, Inc. (“Alt,” “we,” “us,” or “our”). Alt is designed to enable registered users (“Users”) to store, buy, list, sell, share, and otherwise manage their alternative assets (“Assets”) and to communicate and transact directly with other Users about Assets (collectively, including the Site and any related mobile application, the “Service”).
This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any Personal Information to Alt, please review this Privacy Policy carefully and contact us if you have any questions.
We provide a supplementary notice for users based in the European Union and the United Kingdom below. US-based users may have additional privacy rights described in the “Notice of Additional Privacy Rights” section below.
Users who apply for ALT Advance to borrow cash against their assets, should review our GLBA Privacy Notice for an explanation of how we handle the information we collect in connection with their application and loan.
1. PERSONAL INFORMATION WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:
Personal Information You Provide: We collect the following categories of Personal Information from you when you sign up for an Alt account, enter payment information to transact on the Site, and otherwise use our Site and Services:
- Identification Information. We collect your name, email address, phone number, mailing/billing addresses, date of birth, Social Security number, and government identification documents (i.e., your driver’s license, passport, or state identification card). Please see the “Third-Party Service Providers” section below for additional information regarding how Persona, our third-party service provider, handles this information.
- Financial Information. Our payment processor(s) will collect the information necessary to process your payments, such as your full name, email address, and financial information. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers. Please see the “Third-Party Service Providers” section below for additional information regarding how Circle, our third-party payment service provider, handles this information.
- Biometric Information. When you verify your identity through the Service, our identity verification provider may collect a photo of your face and use facial geometry data derived from that photo to verify your identity.
- Communication Information. We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.
- Commercial Information. We may retain a history of the products you browse and/or purchase using the Service.
- Demographic Information. We collect your age, gender, and income level.
- Social Media Information. We have pages on social media sites like Instagram, Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Internet Activity Information. When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log Information. Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies Information. Please see the “Cookies” section below to learn more about how we use cookies.
- Device Information. Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information. We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. Email Open/Click Information. We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
Further details on your internet activity information is include in the section on “Cookies” below.
2. HOW WE USE PERSONAL INFORMATION
We may use Personal Information for the following purposes:
- To provide the Service of managing your portfolio of alternative assets and communicating and transacting directly with other Alt customers;
- To verify your identity in order for you to buy and sell using the exchange;
- To provide a personalized customer experience on the Service;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To analyze how you interact with our Service;
- To maintain and improve the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks;
- To send marketing communications which we think will be of interest to you; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or phone number, we may use that information to send you messages. You may opt out of receiving emails or SMS messages by following the instructions contained in each promotional email we send you, or replying "STOP" to SMS messages. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
3. COOKIES
Site Cookies. We may place small files, known as “cookies” onto your computer to collect personal information about how you use our Site.
A cookie is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
Types of Cookies we use. The Site uses different types of cookies as set out below. Please see your Cookie Settings (from our cookie banner) for more information regarding the specific cookies used and their duration:
- Strictly Necessary Cookies: Necessary for the Site to function. You can set your browser to block or alert you about these cookies, but if you do so, some parts of the Site will not work.
- Functionality Cookies: Used to provide certain functionalities, such as to embed content on the Site or improve the Site’s security or functionalities.
- Performance Cookies: Used to compile aggregated statistics about use of the Site (such as number of page views or visitors and time spent on each page). This helps us improve the way the Site works.
The specific types of cookies we use are details as follows:
Name: intercom-session-ve1g9jld, intercom-id-ve1g9jld
Source: Intercom
Purpose: Functionality
Description: Enables users to access their intercom conversations and have data communicated to them on logged out pages. See Intercom’s cookie policy here.
Duration: intercom-session: 1 wk intercom-id: 9 months
Name: _hp2_id.1343788008, _hp2_ses_props.1343788008
Source: Heap
Purpose: Analytics/performance
Description: Used by Heap to generate user sessions for analytics tracking. See cookie policy here.
Opt out: See here.
Duration: _hp2_id.1343788008: 13 months _hp2_ses_props.1343788008: 30 minutes
Name: _gid, _ga, _gcl_au, __ssid, _gat_gtag_UA_186220399_1
Source: Google Analytics
Purpose: Analytics/performance
Description: Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here.
Opt out: You can block the cookie’s collection of data regarding your use of this website (including your IP address) as well as the processing of this data by Google, by downloading and installing the browser add-on found under the following link: http://tools.google.com/dlpage/gaoptout?hl=en. As an alternative to the browser add-on, you can go to https://tools.google.com/dlpage/gaoptout in order to opt out from being tracked by Google Analytics within this website in the future. An opt-out cookie will be stored on your device, which means that you will have to click this link again if you delete your cookies.
Duration: _gid: 24 hours, _ga: 2 years, _gcl_au: 3 months __
ssid: 4 years, _gat_gtag_UA_186220399_1: 1 minute
Name: _delighted_web
Source: Delighted
Purpose: Functionality
Description: Used to determine when to show a delighted survey to the user. See here for cookie policy.
Duration: 10 years
Name: ajs_user_id, ajs_anonymous_id
Source: Segment
Purpose: Analytics/performance
Description: Used by segment to collect usage data for analytics purposes. See here for privacy policy.
Duration: 1 year
Name: _fbp
Source: Meta
Purpose: Analytics/performance
Description: Used to track ad conversions from Meta. See here for more details.
Duration: 3 months
Name: _dd_s
Source: datadog
Purpose: Analytics/performance
Description: Cookie used to group all events generated from a unique user session across multiple pages. It contains the current session ID, whether the session is excluded due to sampling, and the expiration date of the session. See here for more details.
Duration: The cookie is extended for an extra 15 minutes every time the user interacts with the website, up to the maximum user session duration (4 hours).
Name: _rdt_uuid
Source: Reddit
Purpose: Analytics/performance
Description: Used to track conversion from users clicking on ads on Reddit and coming to Alt. See here for more details.
Duration: 3 months
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
Your Choices. You can decide whether to accept or reject cookies other than strictly necessary cookies. You can exercise your cookie preferences when you first arrive at our Site. You will see a notice about our use of cookies, providing you with the opportunity to learn more and to choose which types of cookies you wish to allow to access your device before accepting cookies. You can also change these settings at any time by going to your cookie preferences . If you are based in the European Union or the United Kingdom, please note that our lawful basis for setting cookies other than strictly necessary cookies is your consent, which you can provide in the way described above.
You can also restrict, block or delete cookies by modifying your browser settings. On most web browsers, you will find a “help” section on the toolbar, which should provide information on how to be notified when you are receiving a new cookie and how to turn cookies off.
For more information on cookies and how they can be managed and deleted please visit http://www.allaboutcookies.org/ or http://www.networkadvertising.org/choices/.
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
Alt does not sell your Personal Information. In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:
- Vendors and Service Providers. To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, identity verification services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information.
- Business Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
- Legal Requirements. If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
5. DATA RETENTION
We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.
6. CHILDREN
Our Service is not directed to children who are under the age of 18. Alt does not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to Alt through the Service please contact us and we will endeavor to delete that information from our databases.
7. THIRD-PARTY SERVICE PROVIDERS
We use Circle to facilitate financial transactions on our Service, and Persona to facilitate identity verification for fraud prevention.
When you engage in a financial transaction, you direct us to share certain information with these service providers, and you will provide other information—such as your identity and financial information—directly to them. We do not record or maintain this information.
For more information on how transactions are handled, or to understand the data security and privacy practices of these service providers, please refer to the privacy notices of Circle and Persona.
8. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by Alt, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
9. Job Applicants
When you visit the “Careers” portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. We may also collect diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information (a) to provide improved administration of the website, (b) as otherwise necessary to comply with applicable laws, (c) to respond to subpoenas or warrants served on Alt, and (d) to protect and defend the rights or property of Alt or others.
10. SECURITY
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Alt via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
11. Do Not Track
Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
12. YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can contact us to request updates or corrections to your Personal Information.
13. CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
14. CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@alt.xyz.
14. NOTICE TO EU AND UK USERS
The information provided in this “Notice to EU and UK Users” section applies only to individuals based in the European Union and the UK.
Controller. Alt Platform, Inc. is the controller of the Personal Information covered by this Privacy Policy for purposes of EU and UK data protection legislation which includes the General Data Protection Regulation (or “GDPR”) and the GDPR in such form as incorporated into the laws of the UK.
Data Protection Representative. We have appointed VeraSafe as our representative in the UK for data protection matters. To make an enquiry, please contact VeraSafe using the contact form: https://verasafe.com/public-resources/contact-data-protection-representative. Alternatively, you may call VeraSafe at +44 (20) 4532 2003, or write to VeraSafe at: VeraSafe United Kingdom Ltd, 37 Albert Embankment London SE1 7TL United Kingdom. Please note that you can also contact us at privacy@alt.xyz. if you have any questions about how we handle your Personal Information.
Legal Basis for Processing. We use your Personal Information only as permitted by law. Our legal bases for processing the Personal Information described in this Privacy Policy are described in the table below. Please note that where we rely on our “legitimate interests” as the legal basis for processing your Personal Information, we do not use your Personal Information for these activities where our interests are overridden by the impact on the individual.
Processing Purpose: Service delivery
Legal Basis: The processing is necessary to perform our contract with you or will be necessary for our legitimate interests.
Processing Purpose: Verifying your identity
Legal Basis: These activities will be necessary for our legitimate interests.
Processing Purpose: Responding to inquiries, comments, feedback and questions
Legal Basis: These activities will be necessary for our legitimate interests.
Processing Purpose: Analyzing how you interact with our Service
Legal Basis: These activities will be necessary for our legitimate interests.
Processing Purpose: Maintaining and improving the Service
Legal Basis: The processing is necessary to perform our contract with you or will be necessary for our legitimate interests.
Processing Purpose: Developing new products and services
Legal Basis: These activities will be necessary for our legitimate interests.
Processing Purpose: Preventing fraud, criminal activity, or misuses of our Service, and ensuring security of IT systems, architecture, and networks;
Legal Basis: These activities will be necessary to comply with a legal obligation or our legitimate interests.
Processing Purpose: Marketing and advertising
Legal Basis: We will either rely on your consent or, if not, these activities will be necessary for our legitimate interests.
Processing Purpose: Complying with legal obligations and legal process and protecting our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties
Legal Basis: These activities will be necessary to comply with a legal obligation or our legitimate interests.
Use for New Purposes. We may use your Personal Information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive Personal Information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
If you provide us with any sensitive personal information when you use our Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.
Retention. We retain Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data Transfers. We are headquartered in the United States. To provide our services and operate our Site, it is necessary for us and our Third-Party Service Providers to process Personal Information in the United States. .Note that the United States may not provide the same level of protection to your Personal Information as in the EU or the UK. Please note, however, we will ensure your Personal Information is kept confidential and secure and where required to do so under European Union data protection laws we will implement appropriate safeguards (for example, implementation of the European Commission approved standard contractual clauses and/or the UK government approved international data transfer agreement). Please contact us if you require any further information from us with regards to data transfers.
Your Rights. EU and UK data protection laws may give you certain rights regarding your Personal Information. If you are located in the EU or the UK, you may ask us to take the following actions in relation to your Personal Information that we hold:
- Access. Provide you with information about our processing of your Personal Information and give you access to your Personal Information.
- Correct. Update or correct inaccuracies in your Personal Information.
- Delete. Delete your Personal Information.
- Portability. Transfer a machine-readable copy of your Personal Information to you or a third party of your choice.
- Restrict. Restrict the processing of your Personal Information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Information that impacts your rights.
- Withdrawing Consent. If the processing of your Personal Information is based on your consent, please note that you have the right to withdraw it any time by contact us using the contact details provided in this Privacy Policy.
You may submit these requests by email to privacy@alt.xyz. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. Please note that if you wish to complain about how we handle your Personal Information, you may submit a complaint to your local data protection regulator. You can find your data protection regulator here: https://edpb.europa.eu/about-edpb/board/members_en. If you are based in the UK, your local data protection regulator will by the UK Information Commissioner’s Office, which can find details about here: https://ico.org.uk/.
15. NOTICE OF ADDITIONAL PRIVACY RIGHTS
Certain US states provide consumers with additional privacy rights that are set out in this section. We provide these rights to the extent we are required to do so by applicable state laws.
These rights do not apply to information we collect in connection with your application for and obtaining an ALT Advance loan.
You may have the following privacy rights:
- Information. You can request information about how we have collected and used your Personal Information during the past 12 months. We have made this information available without having to request it by including it in this Privacy Policy.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Correction. You can request that we correct the Personal Information we maintain about you if the information is inaccurate or out of date.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt out of sale of your Personal Information. We do not sell Personal Information. Like many businesses, we use cookies and other technologies for analytics and other purposes. We offer instructions on how to limit online tracking in the “Cookies” section above.
- Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, to withdraw your consent.
You are entitled to exercise the rights described above free from discrimination.
Please note that the state laws limit these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
How users can exercise their rights
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
- Emailing privacy@alt.xyz
- Writing to us at ALT Networks, Inc, at 2261 Market Street #4019, San Francisco, CA 94114.
- Right to opt out of sale of personal information. We do not sell Personal Information. We offer instructions on how to limit online tracking in the “Cookies” section above.
- Identity verification. We will need to confirm your identity and residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Authorized agents. Users can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.