Alotten Privacy Policy
This Privacy Policy became effective on April 17, 2023.
Introduction
This Privacy Policy (“Privacy Policy”) explains how Alotten, Inc. (either the “Company” or “Alotten”) collects, uses, and discloses your personal information, including the categories of personal information we process and the purposes for which we use it.
This Privacy Policy applies to any personal information you provide to Alotten and any personal information we collect when you:
- Use any service we provide (each, a “Service”)
- Contact or communicate with us
- Visit or use our websites or applications
- Visit an Alotten location
- Attend events or seminars involving Alotten
This Privacy Policy may be supplemented by additional privacy statements, data processing terms or agreements, or other relevant notices.
This Privacy Policy does not apply to your use of any third-party sites linked from or accessed in connection with our websites or Services.
Collecting Your Information
Types of Information We Collect
The personal information we collect varies depending on the nature of our Services and how you interact with us. If we collect sensitive personal information (such as payment details), it is done strictly where relevant and in accordance with applicable law.
The information we collect may include:
1. Contact Details
- Name, email, postal address, social media handle, and phone number
2. Unique Identifiers
- Passport number, National ID, National Insurance Number, or pension scheme reference number
3. Demographic Information
- Date of birth, age, gender, race, ethnicity, photo, and marital status
4. Employment Information
- Job title, employee number, employment status, salary, benefits, employment history, qualifications, and affiliations
5. Health Information
- Medical records, health status, benefits information, and medical assessment outcomes
6. Financial Information
- Credit history, bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits, national insurance contributions, bank account details, and tax information
7. Marketing & Communication Preferences
- Interests and preferred language
8. Online Information
- IP address, browser type, operating system, device information, and usage data collected from visiting our websites
9. Events Information
- Attendance details and feedback from events
10. Background Checking Information
- Inclusion on a sanctions list, disqualified directors' list, previous criminal offenses, or politically exposed persons (“PEPs”) status
11. Comments & Feedback
- Social media interactions, survey responses, and feedback on Services
12. Account Login Credentials
- Username, password, password hints, and security-related information
13. Payment Information
- Credit or debit card number and bank account details
Sources of Information
We collect personal information from the following sources:
- Directly from You – When you request a Service, visit an Alotten location, attend events, apply for a job, or provide feedback.
- From Your Organization – If your employer or affiliated organization provides information for service access.
- Automatically – When you use our Services, visit our websites, or engage with us online (via cookies, web beacons, and tracking technologies).
- From Third Parties – Recruitment agencies, insurers, credit reference agencies, medical professionals, government bodies, and business partners.
Failure to Provide Information
If you do not provide necessary personal information, we may be unable to offer Services and may need to terminate your access immediately.
Information You Provide About Others
If you provide information about third-party individuals (such as employees, dependents, or emergency contacts), you should ensure they are aware of how Alotten will use their information.
Information Relating to Children
Our Services are not directed to children, and we do not knowingly collect data from children. If information about a child is required (e.g., for a beneficiary in an insurance policy), it must be provided by a parent or guardian.
Processing Your Information
We use your personal information for the following purposes:
- Providing Services to you and other clients, partners, or employees
- Compliance & Risk Management – Due diligence, credit checks, sanctions screening, and fraud prevention
- Processing Payments
- Communicating With You – Responding to inquiries and feedback
- Market Research – Evaluating promotional effectiveness and service improvements
- Regulatory Compliance – Legal obligations, dispute resolution, and audits
- Business Transfers – Sharing data during mergers, sales, or restructuring
- Recruitment – Evaluating applications and hiring decisions
- Product & Service Development – Improving offerings based on customer interactions
- Marketing & Outreach – Offering related products or services
Legal Grounds for Processing
We rely on the following legal bases to process your personal information:
1. Performance of a Service Contract
- Necessary to fulfill our obligations under an agreement with you.
2. Legal & Regulatory Obligations
- Required to comply with licensing and regulatory requirements.
3. Legitimate Interests
- Business operations, customer relationships, security, and service improvements.
4. Consent
- When legally required, such as for marketing communications.
5. Substantial Public Interest
- Preventing fraud, public health concerns, or criminal investigations.
Accuracy of Your Information
You should notify us of any changes to your personal information to ensure accurate service delivery.
Sharing Your Information
We may share your personal information with:
- Internal Alotten Teams – For service management and administration
- Service Providers & Business Partners – To support service delivery
- Law Enforcement & Regulatory Bodies – To comply with legal requirements
- Successors of the Business – In the case of mergers, acquisitions, or restructuring
International Data Transfers
- If your data is collected in the UK or EEA, we may transfer it outside these regions with adequate safeguards in place.
Retention of Your Information
- We retain personal data only as long as necessary for service provision and legal compliance.
Information Security
We have implemented appropriate security measures to protect your personal data from unauthorized access or misuse.
Your Rights
You have the following rights under data privacy laws:
- Right to Access – Request a copy of your data
- Right to Correction – Request updates to inaccurate information
- Right to Erasure – Request deletion of your data
- Right to Restrict Processing – Limit how we use your data
- Right to Object – Stop us from using your data for specific reasons
- Right to Data Portability – Transfer your data to another service provider
- Right to Lodge a Complaint – Report concerns to a regulatory body
Direct Marketing
We may send you marketing communications about relevant products and services. You can opt out at any time.
Automated Decisions
If a fully automated decision affects you (e.g., loan eligibility), you have the right to request human intervention.
Complaints
If you have concerns about how we process your data, contact legal@alotten.com or your local data protection regulator.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. You should review it regularly to stay informed.
Contact Us
For any questions or concerns, contact:
📧 legal@alotten.com