Revised and in effect as of MAY 31, 2021
“We” or “us” in this policy refers to ALNAS, Inc. the data controller of your information. We are located at 1775 Tyson’s Blvd. 5th Floor, McLean, VA 22102, United States. While we collect and process your data to provide you with our Services as indicated in our Terms of Service, ultimately you control the data you share and are responsible for your content.
Information We Collect:
Your Registration Information. To fully use our services, you will need to register using our online registration form, where you will be required to provide us with your contact information and certain other personal information, namely, your first and last name, date of birth, email and/or phone number, and gender (for our Site).
Your Usage of Our Services:
The data we collect and retain about your use of our Services is primarily to provide you with an enhanced experience of our Services and for protection of your privacy.
Information We Collect and Analyze. We automatically track certain information about you based upon your usage of our Site and App to provide site features and functionality. This information may include the URL that you just came from, which URL you next go to, what browser you are using, your IP address, device information, login and logout data, and date and location preferences. We also use this information to conduct internal research on our users' demographics, interests, and behavior to better understand and serve our users. We compile and analyze this data on an aggregate and individual basis to provide us with information on how to enhance our Services. For this purpose we do our internal analysis, and also use UXCam, Google Analytics and Facebook Pixel.
Legal. We may retain some of your personal information to fulfill our legal obligations and for general business administrative purposes.
Cookies. We use "cookies" to provide you with an enhanced experience. Cookies are small files that can be used to track a user's steps or automatically generate a user's password. Some features of our Site and App may only be available through the use of a cookie. Among other things, cookies allow you to enter your password less frequently during a session. Cookies can also help us provide information which is targeted to your interests. Cookies are stored on your hard drive, not on our Site or through our App. Most, but not all, cookies are automatically deleted at the end of a session. You may decline our cookies if your browser permits, although your use of the Site may then be restricted (as noted above).
Your Posts. If you choose to post messages on our Site or App, we will collect such information about you as you may choose to disclose pursuant to your activities on the Site or App. You are able to edit or delete posts on the Site and App. We reserve the right to delete a post or posts if they are in violation of our policies or the law.
Your Correspondence. If you send us e-mails, letters or other personal correspondence, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect such information into a file specific to you.
We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies, you may visit https://support.apple.com/en-us/HT208108.
Our Use of Your Information
Promotional Use. We use personal information about you to enhance our marketing and promotional efforts, and to improve our content and services. These efforts can be targeted particularly to you or used to develop capabilities for all our users as a whole.
Administrative Notices. We may use your e-mail address to contact you regarding administrative notices and communications relevant to your use of the Site and App.
Complaints and Dispute Resolution. We use information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to resolve disputes, troubleshoot problems and enforce our Terms of Service.
We commit to investigating and resolving complaints about our collection or use of your personal information. To make a complaint, contact us at firstname.lastname@example.org.
Clearly state the following to help us address the issue effectively:
1. The specific data privacy complaint (please provide as much detail as possible including country, your understanding of the data privacy infringement and issues, redress requested);
2. Your full name and how we can contact you;
3. Any previous correspondence on this specific data privacy issue.
Our Disclosure to Third Parties:
We use practices that are consistent with standards in our industry to protect your privacy. We cannot, however, promise that your personally identifiable information or private communications will remain private. For example, third parties may unlawfully intercept or access transmissions or private communications on our Site. We do not sell or rent any personally identifiable information about you to any third party. The following describes some of the ways that your personally identifiable information may be disclosed.
Law Enforcement. We may disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us to legal liability.
Advertisers. We may disclose aggregate information about our users to advertisers and for other marketing and promotional purposes. However, we do not disclose any personally identifying information to any of these entities.
ALNAS.NET Site. Throughout the Site and App, you are identified by your User ID. While your email address is not disclosed automatically by us anywhere through the Site or App, if you choose to do so we take no responsibility over unsolicited emails you may receive. Although our pages are coded with robot exclusion headers, others may attempt to automatically collect your e-mail address from our Site or App. We describe how to change your User ID in your user settings. Even if your User ID is not your e-mail address, your User ID can be used to identify you and your activities throughout the Site and App.
Based on the privacy options you choose for public and internal ALNAS.NET disclosure, other people can see your user information and activities on the Site and App, and user information related to accounts on Supported Platforms which you connected to ALNAS.NET. If you wish to keep your user information private, please follow the prompts that enable you to do so when choosing the settings for each Supported Platform.
Third Party Suppliers. We use third party suppliers to assist us in providing our Services to you. We impose contractual restrictions on the use by our third-party suppliers of information concerning you so that they are specific to providing our Services, and we do not permit third-party suppliers to sell your information to other third parties. Our suppliers currently include Amazon Web Services and CacheFly CDN, Agora, IDmission (https://www.idmission.com/company/privacy-policy/) and Banuba (http://banubafilters.com/privacy-policy/).
Use Limited to Site or App-Related Communications. Because of the nature of the services offered on ALNAS.NET, ALNAS.NET allows you to access other users' contact information. You may use such information only for ALNAS.NET-related communications. ALNAS.NET-related communication expressly excludes unsolicited commercial messages. In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances can you disclose personally identifiable information about another user to any third party without our consent and the consent of such other user after adequate disclosure by you to such other user. Note that law enforcement personnel, are given different rights with respect to information they access.
No Spam. ALNAS.NET and our users do not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add a ALNAS.NET user to your mail list (e-mail or physical mail) without their express consent after adequate disclosure.
Third-Party Apps and Supported Platforms. You should be aware that ALNAS.NET acts as an intermediary between our users and the various platforms and Third-Party Apps. In some cases, the information published on ALNAS.NET which is on the various platforms or Third-Party Apps is not within ALNAS.NET custody or control. Any content shared by you through these platforms or Third-Party Apps that is not under the control or custody of ALNAS.NET will be accessible to third parties or possibly the public, as this content is now under the control of the operators of the Supported Platforms and/or the Third-Party Apps.
Business Transfers. In the event of a merger, acquisition, sale or transfer, reorganization of ALNAS.NET, bankruptcy or other similar transaction we may have to sell or transfer some of our assets which may include personally identifiable information. If we plan to do so, we will seek your consent and you will have the option to opt out of such a transfer.
Disclosures You Make to Third Parties:
The following provisions apply to users and non-users who interact with ALNAS.NET outside the United States:
- If you are located in a country embargoed by the United States, or are on the U.S. Treasury Department's list of Specially Designated Nationals you will not engage in commercial activities on ALNAS.NET (such as advertising or payments) or operate a Platform application or website. You will not use ALNAS.NET if you are prohibited from receiving products, services, or software originating from the United States.
Since we collect some of your personal information to provide you with our Services we recognize that you have rights with respect to that information. You can always delete information from your personal profile information, ask us to delete your personal information for you or your account as a whole.
Additionally, based on where you live you have certain rights in relation to the information we collect. You can ask us to provide you with your personal information we have collected in an easily accessible format, you can request that we correct inaccuracies related to your Personal Information, add comments or explanations to records about you, refrain from collecting or using your personal information for certain purposes, and provide your personal information to a third party. In making such requests please email us at email@example.com. We will comply with such requests consistent with the applicable laws and will respond without undue delay within 30 days.
Also related to where you live you can ask us about whether and why we have your personal information, how we obtained your personal information, what we have done with your personal information, to whom we have communicated your personal information, where your personal information has been stored, processed or transferred, how long we will retain your personal information, or how that retention period will be determined, and the safeguards in place to protect your information when it is transferred to third parties or third countries. Please send your requests to firstname.lastname@example.org. Once you submit a request we will respond without undue delay within 30 days.
In different jurisdictions, you may also have the right to complain to a data protection authority about our collection and use of your information. Please contact your local data protection authority if you have such concerns.
We will make every effort to comply with your requests under this section, but depending on the laws that apply to your personal information we may not be able to do as you request. If ALNAS.NET is unable to fulfil your request we will explain your legal rights, and the reason for our refusal and any recourse you may have.
To protect the privacy of others and to fulfil our legal obligations, ALNAS.NET reserves the right to take reasonable steps to verify member identity prior to granting access or processing changes or corrections.
ALNAS.NET retains information of registered users as long as the account is active and the information is needed to provide our Services or fulfill our legal obligations. Should you wish to delete your account or request that we no longer use your information notify us at email@example.com and we will respond to your request within 30 days. Your data will be retained to the extent we need to comply with legal obligations.
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