Please read this Privacy Notice carefully. It provides important information about your personal information and tells you about your rights under applicable privacy laws.  If you have any questions, comments, or concerns regarding this Privacy Notice and/or our data practices, please contact us via email at privacy@alloy-advisors.com.

By accessing our website or using any of our SERVICES (as defined below), or submitting information in connection with your use of our website or any of our services, you acknowledge and agree that you have read this Privacy Notice.

TABLE OF CONTENTS

1. Introduction
2. Changes to this Privacy Notice
3. Information We Collect
4. Children’s Privacy
5. Sensitive Data
6. Alloy’s Purposes for Collecting and Using Personal Information
7. Sharing Personal Information
8. Cookies & Related Technologies; Targeted Advertising
9. Marketing Communications
10. Your Choices
11. External Websites
12. Data Retention
13. Data Security and Protection
14. California Privacy Rights – Shine the Light
15. Notice to Users Outside the United States
16. How to Contact Us

1.    Introduction

Alloy Advisors LLC, a Delaware limited liability company (hereinafter, “Alloy”, “we”, “our” or “us”) owns and operates the website located at www.alloy-advisors.com (the “Site”).

When we refer to the “Services” throughout this Privacy Notice, we mean the Site and any other products, websites, services, and/or applications provided by us and that include a link and/or reference to this Privacy Notice, and any related services and/or new features and/or functionality provided by us through or in connection with any of the foregoing.

Our Services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes.  This Privacy Notice describes Alloy’s data collection, use, protection, and privacy practices with respect to information and data we may collect in connection with the Services and the Alloy business.

2.     Changes to this Privacy Notice

Alloy reserves the right to update or modify this Privacy Notice at any time.  Except for material changes as described below in this Section, all updates and modifications to this Privacy Notice will be effective from the day they are posted online at www.alloy-advisors.com/privacy.  If we make any material changes to this Privacy Notice, we will post a prominent notice of any such changes on our Site.  Material changes to this Privacy Notice will become effective on the date set forth in the notice, and all other changes will become effective from the day they are posted on our Site.  It is your responsibility to regularly visit and review this Privacy Notice.

If you do not agree to any updates or modifications to the Privacy Notice, cease all use of the Services.  Your continued use of the Services after the applicable effective date of the revised Privacy Notice, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.

3.     Information We Collect

How and what personal information we collect in connection with the use of the Services depends on how and why you use the Services.

The term “personal information” or “personal data” means any information about an individual from which that person may be identified.  For example, it may include a person’s name, telephone number, email address, or payment information, and in some jurisdictions, IP address.  It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).

When you access and use our Services, we collect information directly from you as explained in the Section Information Provided Directly by Users, and in certain circumstances, we may automatically collect certain information when you access and/or use the Services as explained Information Collected Automatically.  In addition, the instances where we may receive information from third parties is described here.

Please be advised that we may ask you to update your information from time to time in order to keep it accurate.  Additionally, if you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and, without us having to take any further steps required by data protection laws, that we may collect, use and disclose such information for the purposes described in this Privacy Notice. For example, you should ensure the individual concerned is aware of the terms detailed in this Privacy Notice and that they have not objected or do not object to you sharing their information with us.

a.     Information Provided Directly by Users

• Request for Contact:  If you request us to contact you for the rendering of possible services, we will collect contact and other information such as your name (first and last), email address, phone number, business address, and the name of your employer, your occupation and/or profession.

• Surveys, Feedback, Communications & Support: We collect the information, data, content, documents and/or materials you provide to us when you fill out forms, answer surveys, or contact us (such as your feedback, requests for support, or other communications with us).

b.    Information Collected Automatically

We and/or our authorized third-party Service Providers or agents automatically collect technical and/or analytics information, using the cookies and similar technologies as described in Section 8 below, about how users use and/or interact with the Services (collectively, “Usage Information”), which may include (but is not necessarily limited to) identifiers, commercial information, and internet activity information such as IP address (or proxy server), information about the device and/or platform (e.g., iOS or Android) used by you to interact with and/or access the Services, mobile device number, device and application information, device event information, crash data, and log files and data, identification numbers and features, your approximate location (as determined through your IP address), browser type, plug-ins, integrations, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, websites, apps and/or ads that referred you to the website, advertising and language preferences, operating system type and version, system configuration information, date and time stamps associated with your usage, and frequency of visits to the websites, and details of which of our products and product versions you are using.

c.     Information Collected from Third Parties or Sources Outside the Services

In some instances, we may process personal information from third parties, which consists of:

• Service Providers: We receive information from our Service Providers (as defined in Section 7.a below), such as our cloud or hosting service providers, customer support providers, and our analytics providers.
• Marketing and Advertising Providers: We may receive information from entities who perform advertising and/or marketing functions for Alloy, which may include, but is not necessarily limited to, business contact information included in potential customer and/or lead lists we may receive.
• Third Party Services: If you use any products, services, software, content, and/or features that Alloy has integrated with, and/or has otherwise made accessible for use through, the Services (collectively, “Third Party Services”), we may receive information about you from the providers of such Third Party Services related to your use thereof in connection with the Service.  Information that is shared with us through Third Party Services is used by us as described in this Privacy Notice.  Note that the Third Party Services you choose to interact with and/or use are not our Service Providers. The applicable providers of Third Party Services may use personal information differently than we do and we do not control their use of your information.  Please review the privacy notices for the Third Party Services that you use in connection with the Services.
• Other Third Parties & Sources: We may receive data and information from third party partners, and/or other data licensors and/or providers that we have a relationship, including information collected from publicly available sources, such as online business profiles, social media accounts, and/or webpages, which may include your name, or a publicly available business address, and related activity on such profiles, social media accounts, and/or webpages.
• Social Media Interactions: If you interact with us through any of our pages or feeds on any social media sites or platforms, such as through LinkedIn and/or any Meta platforms, we may collect information such as your name, username, demographic information, contact information such as email address, location, interests, and publicly posted data such as your social media activity.

d.    Aggregated Data

With the personal information and other data (including, Usage Information) collected by us, we may process “Aggregated Data”, such as statistical or demographic data.  Aggregated Data may be derived from personal information, but is not considered personal information under the law if it does not directly or indirectly reveal your identity.  If we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information, which will be processed in accordance with this Privacy Notice.

4.     Children’s Privacy

Alloy does not target the Services to persons under the age of 18, nor does Alloy knowingly collect personal information of persons under the age of 13.  Therefore, we ask you not to provide us with personal information of persons under the age of 13.  If we learn that personal information of persons under the age of 13 has been collected on or through the Services, then we may deactivate the account or otherwise terminate access to the Services and/or make the user content inaccessible.

5.     Sensitive Data

Alloy does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetics, or biometric data to use the Services.

6.     Alloy’s purposes for collecting and using Personal Information

Depending on how you use the Services, we use your personal information in the following instances:

• To host and provide the Site;
• To perform and provide the Services to you and to our other customers,
• To enable Third Party Services that you connect or use in connection with the Services;
• To personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service;
• To maintain, enable, upgrade, update, improve, and/or enhance the Services, and develop new features, functionality, and/or other products and services;
• To conduct analytics related to the Services, such as to understand how they are being used and where improvements may be needed;
• Provide customized advertisements, content, and information. Where required under applicable law, we will only provide you with tailored content with your opt-in consent;
• Deliver direct marketing communications to you regarding products and services of ours and/or third parties that we may think are of interest to you;
• Respond to your queries and requests, or otherwise communicate directly with you;
• Detect any fraudulent or illegal activity against you, our other customers and users, and/or Alloy;
• For our business transfers;
• To keep you updated about changes to policies related to the Services (including this Privacy Notice);
• To comply with a legal or regulatory obligation (for example, keeping records of our sales for tax compliance)
• Provide information to regulatory bodies when legally required, and only as outlined below in Legal Obligations and Security.

7.     Sharing Personal Information

Aside from disclosing your information to those of our members, employees, contractors and agents who are authorized to process the information in order to provide the Services and who are committed to confidentiality, we disclose your personal information only to the third parties as described below.

a.     Our Service Providers

We share personal information with third parties that provide services to us that help us in the operation, provision, administration and management of the Services (“Service Providers”), and to otherwise operate our business.  Depending on how you use the Services, the following categories of third parties collect data on our behalf or receive personal information:

• Hosting providers,
• Analytics providers,
• Providers of business operations and communication tools,
• Other third-party service providers that help us provide features and functions for the Services (e.g., customer support providers), and
• Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

For a list of all Service Providers we use, please contact us via email at privacy@alloy-advisors.com. We require all Service Providers to respect the security of your personal information and to treat it in accordance with the law.

b.    Third Party Services

When you interact with and/or use Third Party Services, certain information may be exchanged between Alloy and the provider of the applicable Third Party Service.  Note that the Third Party Services you choose to interact with and/or use are not our service providers. The applicable providers of Third Party Services may use personal information differently than we do and we do not control their use of your information.  Please review the privacy notices for the Third Party Services that you use in connection with the Services.

c.     Business Transfers

We may also share data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice.

d.    Affiliates and Subsidiaries

Personal information that we collect about you may be shared with the members, employees, contractors, and agents of Alloy and any affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Services that we offer to you. We obligate the members, employees, contractors and agents of Alloy and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.

e.     Legal Obligations and Security

Regulatory and Government Bodies – Compliance with Law

We may disclose your information to regulatory agencies and official government bodies, as required to comply with or satisfy any laws, rules, or regulations applicable to Alloy.

Required Disclosures – Responding to Legal Orders

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States. Under such circumstances, unless prohibited by applicable law, we will attempt to provide you with prior notice that a request for your personal information has been made in order to give you an opportunity to object to the disclosure.  We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual.  In cases where we receive a non-disclosure order, we will notify you when it has expired or once we are authorized to do so.

Exigent Circumstances & Enforcement/Protection of Our Rights

Your information, including the contents of all of your online communications in our Services and between you and Alloy may be accessed and monitored as needed to provide our Service and may be disclosed to law enforcement, regulatory agencies, official government bodies, and other third parties, as we, in our sole discretion, believe necessary or appropriate:

• To enforce our rights under our terms of use, terms of service, customer agreements and/or any other terms and conditions applicable to the use of the Services;
• In connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us or our affiliates, partners and/or agents to legal liability; and/or
• If we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person.

f.      With Your Consent

There may be situations where you are asked to consent to share personal information with third parties for additional reasons not included in this Privacy Notice.  In such event, we will only share such personal information if we have received your prior consent and only for the purposes as listed in the request to share such information.

Except where otherwise required by applicable law, your consent for the use and/or disclosure of your personal information in specific situations will continue in full force and effect until you revoke that consent, which you may do by contacting us via email at privacy@alloy-advisors.com.  For the avoidance of doubt, the revocation of consent shall only apply to the use the information after our receipt and processing of such request (which we shall process promptly and in accordance with applicable law), and not to any use or disclosure prior to such revocation in compliance with your consent.

8. Cookies & related technologies; targeted advertising

Cookies

We or authorized third parties may collect certain information by automated means using cookies (which are small data files that are placed on your computer or mobile device that are set by us or by third parties when you visit a website or other online service) and a range of technologies similar in function to the traditional cookies described above, such as pixel tags, also called web beacons or single-pixel tags/gifs, local or web storage, and embedded scripts (all such technologies described above, collectively, “Cookies”).  Cookies collect information such as Usage Information, and are designed to that gather information about your interaction with a website or email, such as, the pages visited, links you clicked and/or whether or not an email was opened.  Alloy uses Cookies for purposes such as to provide content or features on the Services, to help us remember you and your preferences, and improve your user experience by making the Services more efficient and relevant to you. You can find more information about Cookies at: www.allaboutcookies.org.

Targeted Advertising

We may use third party advertising and analytics partners who use Cookies to gather analytics and information for targeted advertising of Alloy’s products and services.  These Cookies are designed to gather information from users of the Services and used to deliver advertisements more relevant to our users and their interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of our advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and/or that you have interacted with an advertisement and this information may be shared with other organizations such as advertisers.  Alloy may use these Cookies for purposes of:

• Advertising Alloy and our Services across the Internet;
• Tracking the performance and efficacy of our advertisement campaigns;
• Keeping track of how many visitors click on the advertisement;
• Keeping track of the advertisements you have already been shown so that you are not always shown the same ones; and
• Tailoring our marketing to better suit your needs and only display ads that are relevant to you.

For information regarding how you can manage your preferences with respect to these technologies, please see Cookies & Targeted Advertising below.

Third Party Analytics Providers, Tools and Advertising Partners

We may use certain third party analytics tools and advertising partners to help us gather certain Usage Information and to help us place advertisements as described above.  For a list of the current third party analytics and/or advertising Alloy uses please contact us at privacy@alloy-advisors.com.

Managing Preferences:  For information regarding how you can manage your preferences with respect to these technologies, please see Cookies & Targeted Advertising below.

9.     Marketing Communications

If you have not otherwise opted out (or with your consent where required by applicable law), or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Alloy business, our Services, and/or other products and services, that we think may interest you.  We carry out direct marketing by email and may also do so by physical mail.

If you no longer wish to receive marketing communications, you have the right at any time to opt out as further explained in Your Choices.

10.  Your Choices

a.     Accessing, Updating and Correcting Personal information

If you would like to correct or update certain personal information (such as your contact information), please contact us via email at privacy@alloy-advisors.com, and we will use reasonable efforts to correct and/or update such information.

b.    Direct Marketing

You may manage the receipt of marketing and non-transactional communications sent by email by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. To opt-out of marketing communications sent by physical mail, please contact us via email at privacy@alloy-advisors.com with your request.

We will use commercially reasonable efforts to process such requests in a timely manner.  Note that you cannot opt out of receiving transactional e-mails or communications related to the Services (e.g., requests for support), which, for clarification, are not marketing communications.

c.     Cookies & Targeted Advertising

Where required by applicable law, we will obtain your consent prior to setting Cookies (except for strictly necessary Cookies).  Most web and mobile device browsers automatically accept Cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a Cookie is set.

To learn more about Cookies, including how to manage Cookies and opt-out of Cookies being placed on your device, please visit http://www.allaboutcookies.org/manage-cookies/index.html.

While tracking is widespread over the internet, there are things you can do to minimize these activities with respect to browser Cookies.

Browser Settings & Do Not Track Preferences

• Browser Settings: You may alter the Cookie settings in your browser settings at any time. Some browser providers offer comprehensive help relating to cookie management in their products. You may elect to accept all or only certain Cookies. If you disable Cookies in your browser settings, however, you may find that certain portions or functionality of the Services will not work.
• Do Not Track Preferences: You may turn on the Do Not Track (“DNT”) setting in your browser, which will enable your browser to send a special signal to websites, analytics companies, plug in providers, and other web services you encounter while browsing to stop tracking your activity. To turn on your DNT signal, please visit  https://allaboutdnt.com/#adjust-settings.  Please note that not all companies will respond to or honor DNT signals and we do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use the Services.

Google Analytics Opt-Out:   You can download the Google Analytics opt-out browser add-on at: https://tools.google.com/dlpage/gaoptout/.

Web Beacons and Pixels:  You may avoid web beacons and pixels by disabling the functionality that allows remote images to load in your email account and refraining from clicking on any links in email messages.

Advertiser Specific Opt-Outs – Targeting/Advertising Cookies

• Google: https://www.google.com/settings/ads/anonymous
• Facebook: https://www.facebook.com/settings/?tab=ads
• LinkedIn Ads: https://www.linkedin.com/help/linkedin/answer/62931
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• DAA: You may use the Digital Advertising Alliance (“DAA”) consumer choice tools to apply opt-outs to interest-based advertising and other applicable uses of web-viewing data by DAA participating companies by visiting http://optout.aboutads.info/?c=2&lang=EN#completed.

• NAI: You may also manage opt-outs through the Network Advertising Initiative (“NAI”) opt-out tool at http://optout.networkadvertising.org/?c=1

11.  External Websites

On or through the Services we may provide or make available, for informational purposes only, links to other websites or resources with which we do not have a contractual relationship and over which we do not have control (“External Websites”).  Such links do not constitute an endorsement by Alloy of those External Websites, and are provided to you only as a convenience. By clicking on links to External Websites, the operators of the External Websites may collect your personal information. We are not responsible for the content or data collection practices of those External Websites, and your use of External Websites is subject to their respective terms of use and privacy policies.

12.  Data Retention</h4 id=””> Personal information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.

In order to determine the most appropriate retention periods for your personal information, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal information, and applicable legal requirements.

In some instances, we may choose to anonymize personal information instead of deleting it. When we choose to anonymize, we make sure that there is no way that the personal information can be linked back to any specific individual.

13.  Data Security and Protection

We have put in place reasonable security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to personal information to those members, employees, agents, contractors and the third parties who have a business need-to-know.

We also have procedures in place to deal with any suspected data security breach.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and while we take reasonable steps to provide secure services, by using the Services, you understand and assume the risks associated with your activities on the internet.

Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Services is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Services. To the fullest extent permitted under applicable law, we cannot and do not guarantee that information you post on or transmit to the Services will not be viewed by unauthorized persons.

14.  California Privacy Rights – Shine the Light

California residents who have provided us with personal information have the right (under California Civil Code§ 1798.83) to request and obtain from us, once each year, the details of any personal information we shared with a third party for that third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.

To request information about this sharing, you may submit a request via email to privacy@alloy-advisors.com with “Your California Privacy Rights” in the subject line, along with your first and last name, and complete mailing address (including street address, city, state, and zip code).

15.  Notice to Users Outside the United States

Alloy is based in the United States. The personal information that we collect is sent to and stored on servers located in the United States.  Such storage is necessary in order to process the information and provide our Services. If you are located outside of the United States, please be aware that your information, including your personal data, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere

16.  How to Contact Us

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us as follows:

By email at:     privacy@alloy-advisors.com; Subject Line: Privacy Request