Our Commitment to Privacy
Alacra, LLC, previously Alacra, Inc., (“ALACRA”) is committed to protecting your privacy. This policy sets forth the privacy and data protection policy of ALACRA and describes, among other things, how ALACRA collects, uses, handles and discloses personal information.
ALACRA (and its affiliated companies, Hiperos, LLC and Opus Global, Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, https://www.privacyshield.gov/list.
ALACRA is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
For unresolved privacy complaints of European Union individuals, Alacra has further committed to cooperate with an independent dispute mechanism established by European Union Data Protection Authorities and to provide this recourse free of charge. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for further information.
The Information We Collect and Receive
ALACRA operates various world wide websites, including, but not limited to, www.alacra.com, www.alacrastore.com,pulse.alacra.com, www.researchrecap.com, www.alacrawiki.com and www.alacrablog.com (the “Site(s)”), which enable individuals to access, purchase and/or download business information and data. When you browse or access an ALACRA Site, ALACRA may collect the following types of information:
- Information you provide directly, including personal information, when you register or make an online order; inquire about ALACRA products or business development opportunities; request ALACRA sales, support or other services; subscribe to an ALACRA service; elect to receive e-mail, information or other alerts from ALACRA; or send us e-mail messages. For example, as a result of these actions, you might supply us with such information as your name, address, company name, e-mail address, telephone number, credit card information and anything else you choose to include in an e-mail message to our customer service department.
- Passively collected information, including through the use of “cookies” described below, such as IP addresses, web browser and operating system information, date and time of visits, and the web pages your Internet browser visits when browsing an ALACRA Site; and
- Aggregate, non personally-identifiable information, such as the number of hits per week or per web page.
The ALACRA Sites are general audience web sites and are not directed to children. It is our intention to adhere to the Children’s Online Privacy Protection Act, and ALACRA does not knowingly collect personally identifiable information about children under the age of thirteen (13).
ALACRA also provides professional services to business clients (the “Services”). Some of these services occasionally require that ALACRA, pursuant to a contract with such business clients, process such clients’ data for the purpose of fulfilling the contracted services. The client data processed by ALACRA may include personally identifiable information about a client’s customers or other individuals. This information is collected, supplied and/or controlled by ALACRA’s business clients, not by ALACRA. ALACRA’s business clients, and not ALACRA, are responsible for providing or maintaining the accuracy or completeness of the data or information provided to ALACRA as part of the contract to provide professional Services.
“Cookies” are small text files that store information about your interactions with a particular website, either temporarily (known as a “temporary” or “session” cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a “permanent” or “persistent cookie”). Cookies can make it easier to use a website by allowing servers to access certain information quickly. The Sites may use both session/temporary cookies and persistent/permanent cookies to store information that allows us to offer you better customer service and to navigate through a Site with ease. To make a Site easier to use, we combine information collected via cookies with personally identifiable information. Note that if you configure your browser to reject cookies, you might not be able to access important functions or areas of a Site or enjoy certain conveniences at a Site.
The Way We Use Information
ALACRA uses personal information collected online in the following ways:
- For information you provide online, either directly through our Sites or through e-mail messages, relating to the purchase, download or ordering of products, or requests for support or services, we use the information to engage in and process transactions with you, respond to your inquiries and requests, and provide customer service activities.
- For information you provide online, including actions or clicks from hyperlinks, we use the information to notify you of relevant new products, to notify you of promotional activities, and to analyze and notify you of products most appropriate for you by customizing future communications and web pages in accordance with communication preferences you have established with ALACRA.
- For some information you provide online, we use the information for in-house research to improve our understanding of customer needs and product development, build marketing profiles, and aid strategic development. All results of such research and analysis will by anonymized or aggregated and will not reveal any personal information or other personal facts about individual users.
- For some registration, e-mail and use data you provide, we may direct you to particular web pages, customize the web pages you see, or otherwise increase the relevance of the information you receive.
- For information about web pages visited, page hits per week, and the like, we use this information internally to improve the design of our web pages.
- For information submitted using the online job application process, we may use and disseminate this information internally as necessary to consider your application and to contact you regarding our decision.
- When you visit an ALACRA Site, you always have a choice as to whether you wish to provide your personal information to ALACRA. By choosing not to provide your personal information, you can “opt out” of having any such information (i) disclosed by ALACRA to a non-agent third party; or (ii) used by ALACRA for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. Please note, however, that if you choose not to provide certain personal information to ALACRA, you may be prevented from making a purchase or taking advantage of other features and benefits of an ALACRA Site. Also, should ALACRA directly collect sensitive personal information from individuals through one of its Sites, to the extent applicable and required by the EU-U.S. Privacy Shield Framework, ALACRA will offer individuals the choice to opt-in to having their sensitive personal information (i) disclosed to a non-agent third party; or (ii) used for a purpose other than the purpose for which it was originally collected.
Where ALACRA receives data and information, including personal information of individuals, in furtherance of the Services it provides to its business clients, ALACRA processes such data and information solely in accordance with the applicable contract and solely on behalf, and for the benefit, of that business client. ALACRA does not in any manner access or use any information or data, including personal information of individuals, it processes pursuant to such contracts with its business clients as part of its own business. Further, ALACRA does not inform individuals about the purposes for which their personal information is collected and used by such business clients, but rather relies on its business clients to provide any required notices.
When We Share Customer Information
ALACRA will not rent, sell or otherwise disclose personal information with other people or companies, except under the following circumstances:
- We may share your personal information for business purposes only on a need-to-know basis and only with: (i) our own employees; (ii) business partners; (iii) ALACRA subcontractors, consultants, and third-party service provider companies that have agreed to safeguard such information in a like manner to the way that ALACRA safeguards such information and that have signed confidentiality agreements with ALACRA; and (iv) other entities authorized to have access to such information under applicable laws or regulations. ALACRA does not share non-public individually identifiable information with third-party marketers;
We will not use or share information in ways unrelated to those described above without first notifying you and offering you a choice as to whether or not we may use your data in this different manner.
Our Commitment to Data Security
ALACRA takes reasonable and appropriate measures to maintain the confidentiality and integrity, and prevent the unauthorized use or disclosure, of an individual’s personal information. This includes maintaining a system of appropriate administrative, physical and technical safeguards to secure such information and periodically assesses new technology for improved methods of protecting information.
Links to Unaffiliated Third Party Websites
The Sites may contain links to unaffiliated third party websites. If you link to or otherwise visit any other websites managed by third parties, please review the privacy policies posted at those sites. ALACRA has no control over those websites and is not responsible or liable for the policies and practices followed by third parties.
How You Can Access or Correct Your Information
If you have created an online profile with ALACRA through one of our Sites, you can update or correct your profile or contact information by accessing your account or by contacting ALACRA.
Your California Privacy Rights
Beginning January 1, 2005 under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2005 will receive information regarding 2004 sharing activities).
To obtain this information on behalf of ALACRA, please send an e-mail message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response, where applicable.
48 Wall Street, 6th Floor
New York, New York 10005
Attn: Chief Privacy Officer