Privacy Policy

Effective: December 16, 2024

This Privacy Policy (“Privacy Policy” and “Policy”) applies to the collection and use of Personal Information by ALOM (“Company”, or “we,” or “us,” or “our”). It describes ALOM’s practices regarding the collection, use, disclosure, and sale of Personal Information when you visit our websites or mobile applications (the “Sites”), when you communicate with us via email, when you register or attend our webinars or online events, and when you engage with us offline (collectively, “Services”). By accessing the Sites and using our Services, you agree to our collection and use of personal data as described herein and agree to our Terms of Use. This Policy does not apply to information we collect about ALOM employees.

Before submitting information to the Sites or Services or otherwise using the Services, please review this Privacy Policy carefully. BY USING OR ACCESSING THE SITES OR SERVICES AND/OR COMMUNICATING WITH ALOM BY MAIL, EMAIL, OR TELEPHONE, YOU INDICATE YOUR UNDERSTANDING AND ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY. You are responsible for submitting accurate information to us. If you prefer that we not collect your Personal Information to us, please do not submit it to us. WHEN YOU SUBMIT YOUR PERSONAL AND OTHER INFORMATION ON THE SITES OR THROUGH YOUR USE OF THE SERVICES, YOU HEREBY CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF SUCH INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THESE TERMS, DO NOT USE THE SITE OR SERVICES.

Please carefully read this Privacy Policy, as it may have changed since your last visit to the Site. Continued use of the Site or Services indicates your understanding and acceptance of any changes made to this Privacy Policy and posted to the Site.

1. Personal Information We Collect

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual, or particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.

We may collect your Personal Information when you visit our Sites, request information about our products or services, provide us with your information at a conference or other event, click through links on our Sites to watch or listen to archived events or presentations, or when you voluntarily provide information to us through our web portal, email or phone number. We also collect Personal Information when we purchase potential marketing leads from third parties.  We also may collect additional categories of Personal Information on behalf of our customers, for whom we act as a service provider.

The categories of Personal Information we may collect from these sources include the following:

• Personal identifiers: Name, physical or postal address, email address, telephone numbers, company name, account name and password, IP address or other unique identifier.
• Financial information: Credit and debit card information.
• Commercial information: Records of products and services purchased or considered, consuming histories or tendencies.
• Professional information: Job title, role, employer, employment history.
• Internet or other electronic activity information: Device and browser type, operating system, access times, domain name, your browsing and search history on our Sites (i.e., the actions taken in connection with the Site) and amount of time spent on the Sites, the website from which you arrived at our website, and information regarding your interaction with our Sites and our advertisements.
• Inferences drawn from any of the Personal Information identified above.

Cookies and Similar Technologies

ALOM may use cookies and similar technologies on our Sites and Services. Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device. However, without these identifier files you may not have access to many features that may make your browsing of our Sites smoother, and some of our services may not function properly.

When you visit our Sites, we may place a “cookie” or other online tracking devices (e.g. web beacons) that recognizes you. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with the Sites.  We may use cookies or similar tracking technologies to capture information about the use of our Sites, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy. You can also view Google’s currently available opt-out options.

Marketing

Where you have requested it, we may contact you by email to provide information regarding events, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing communications from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you wish to stop receiving marketing communications from us, please:

• send an email to [email protected]
  or

• send a letter to ALOM, Chief Privacy Officer, 48105 Warm Springs Blvd., Fremont, CA 94539, USA.

In your email or letter, please indicate the email address or name and postal address for which marketing communications should be discontinued. It is helpful to include information about the last mailing/contact received, including a brief description of the mailer or contact you received so that we can attribute it to the appropriate customer. There is no charge to opt out.

Third Party Websites

Our Sites may contain links to other third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our Sites.

2. How We Use Your Personal Information

We may use the Personal Information you give us to carry out the following purposes:

• To contact you and to respond to your requests and enquiries when you contact us.
• To provide goods or services to you, including to facilitate your participation in virtual or in-person meetings.
• To manage and maintain our relationships with you and for ongoing customer service.
• To enforce or defend our rights, ourselves, or through third parties to whom we delegate such responsibilities.
• To contact you to tell you about products and services offered by us as well as other promotions which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us.
• To contact you to tell you about products and services offered by us as well as other promotions which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us.
• For tailored advertising on third party sites either because of the website you are viewing, or based on your interests, which we have inferred from your information.
• To personalize your visit to the Site, to monitor or improve the Sites and to assist you while you use the Sites.
• To improve the operation of the Sites by helping us understand who uses the Sites.
• For business administration, including statistical analysis.
• To share data with policy, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including screening transactions, reporting suspicious activity and complying with production or court orders.
• To investigate and resolve complaints and manage regulatory matters, investigations and litigation.
• To monitor electronic communications for investigation and fraud prevention purposes, crime detection and prevention and investigation.
• To comply with any of our applicable legal or regulatory obligations. For example, if you are a business customer, we need to process your information to verify your identity and undertake necessary due diligence checks.

Please note that if you are a resident of the European Economic Area (“EEA”), the UK or Switzerland, you have a right to object to processing of your Personal Information where that processing is carried out for our legitimate interest.

3. How We Share Information About You

Disclosure of Personal Information

ALOM does not share or sell Personal Information about you with unaffiliated third parties for use in marketing their products and services. We may share Personal Information about you with the following entities:

• Service providers with which we (or our corporate affiliates) have a business relationship;
• Government agencies, other regulatory bodies, and law enforcement officials;
• Other organizations as permitted or required by law (for example, fraud prevention, subpoena or court order);
• Other third parties, as directed by you; and
• In connection with corporate business transactions, such as a merger or sale of business.

We may share your Personal Information with our corporate affiliates, including internal services providers which perform services or functions for ALOM and who may use your information for purposes similar to the purposes for which ALOM collects such information.

4. Data Privacy Framework Notice

ALOM complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. ALOM has certified through the Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. ALOM has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

ALOM remains responsible for the processing of Personal Information received under the DPF Principles and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

ALOM commits to resolve DPF Principles-related complaints about our collection and use of your personal information, and EEA, UK, and Swiss individuals with inquiries or complaints regarding this Policy should first contact ALOM at:

Email:  [email protected]

Mail: Office of the CPO

ALOM

48105 Warm Springs Blvd., Fremont, CA 94539

Phone: 1-800-500-9991 (toll-free)

In certain circumstances, you may invoke binding arbitration proceedings with ALOM. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, EU, UK, and Swiss individuals may contact or submit a complaint, at no cost, to ICDR-AAA DPF IRM Service, an alternative dispute resolution provider based in the United States that is able to conduct a binding arbitration proceeding between yourself and ALOM. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The Federal Trade Commission has jurisdiction over ALOM’s compliance with the DPF Principles.

5. Residents of the EEA, UK, and Switzerland

For the purposes of European, UK or Swiss data protection laws, ALOM is the controller of your Personal Information.

European, UK, and Swiss Privacy Rights

If you are a resident of the EEA, the UK, or Switzerland, you may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to:

• request access to Personal Information we hold about you;
• the correction of your Personal Information when incorrect, out-of-date or incomplete;
• request that we erase your Personal Information;
• opt-out of any marketing communications that we may send you and to object to us using/holding your Personal Information;
• request that we restrict the processing of your Personal Information (i.e., we would need to secure and retain the data for your benefit but not otherwise use it);
• withdraw your consent at any time; and
• the portability of your Personal Information (i.e., ask for a copy of your Personal Information to be provided to you, or a third party in a digital format).

We will respond to your request in writing or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and provide you with reasons. We may request proof of identification to verify your request.

You also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.

For more details in relation to your rights, including how to exercise them, please contact us:

Email: [email protected]

Mail: Office of the CPO

ALOM

48105 Warm Springs Blvd

Fremont, CA 94539

Phone: 1-800-500-9991 (toll-free)

Legal Basis for Processing Personal Information

We only use your Personal Information as permitted by law. When we process your Personal Information, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., provide the Services you requested)
• When we have a legitimate interest in processing your Personal Information to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of non-administrative communications).
• When we have your consent to do so (e.g., when you opt in to receive non-administrative communications from us). When consent is the legal basis for our processing your Personal Information, you may withdraw such consent at any time.

International Transfers Outside of the EEA, the UK or Switzerland

When you are based in the EEA, the UK or Switzerland, Personal Information collected from you, including via the Site, may be transferred to certain recipients located outside the EEA, the UK or Switzerland (e.g., the United States), which do not provide a similar or adequate level of data protection to that provided by countries in the EEA, the UK or Switzerland. When we transfer any Personal Information outside of the EEA, the UK or Switzerland, we will carry out the transfer in accordance with relevant data protection laws.

6. Residents of California and Other Applicable States

ALOM acknowledges that under data privacy laws in several states, including the California Consumer Privacy Act (CCPA, CPRA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Iowa Privacy Act (IPA), Utah Consumer Privacy Act (UCPA), Virginia Consumer Data Protection Act (VCDPA), and other US Privacy Laws as applicable, individuals have certain rights associated with their Personal Information and other information.

For business purposes, ALOM may collect, use, and share Personal Information about you as described in this Privacy Policy. Each category of data that may be used by ALOM or shared with third parties is categorically outlined in this Privacy Policy.

California consumers have the right to (i) request access to, know, limit use and disclosure of sensitive personal information, correct, and delete their personal information, (ii) opt-out of the sale of their personal information, and (iii) not be discriminated against for exercising one of their California privacy rights.

All individuals have the right to request access to and deletion of the information ALOM holds about them by contacting us via email at [email protected] or by mail to ALOM, Chief Privacy Officer, 48105 Warm Springs Blvd., Fremont, CA 94539, USA. In addition, California residents may also submit a request by calling direct toll free 1-800-500-9991.

ALOM does not sell the Personal Information of California consumers.

ALOM does not discriminate against individuals for exercising their privacy rights.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about certain categories of Personal Information a business has disclosed to third parties for direct marketing purposes in the preceding calendar year. For information, please contact us by sending an e-mail to [email protected], or by calling our toll-free telephone number at 1-800-500-9991.

California Do Not Track 

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. We do not track website visitors over time and across third party websites. At this time, our Sites do not respond to browsers’ do not track signals.

7. Managing Information of Users

Controlling Your Personal Information

If you tell us that you do not want us to use your Personal Data to contact you, we will comply with the applicable law. In certain cases, we will only contact you if instructed to do so. In either case, you may instruct us to stop sending you emails, newsletters, or other information. ALOM may, however, continue to use your Personal Information to contact you to service your account in conjunction with your use of the ALOM Services. Please note that if you use more than one name or e-mail address when communicating with ALOM or using the Sites or Services, you may continue to receive communications from ALOM to any name and/or email address not specified in you opt-out request. We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than (as specified in this Privacy Policy), or before we use it for a purpose other than (as specified in this Privacy Policy). To limit the use and disclosure of your Personal Information, please submit a written request to:

Email: [email protected]

Mail:  Office of the CPO

ALOM

48105 Warm Springs Blvd

Fremont, CA 94539

Phone: 1-800-500-9991 (toll-free)

Withdrawal of Consent

Where you have provided your consent for us to use or process your Personal Information, you can withdraw your consent at any time by emailing us at [email protected] or sending a letter to Office of the CPO, ALOM, 48105 Warm Springs Blvd, Fremont, CA 94539.

Please see the “Cookies” section for information about withdrawing your consent for cookies. We process your Personal Information for marketing purposes with your consent, and at any time after providing consent, you have the right to object to our processing of data about you in order to send you promotions, special offers, and marketing, and we will stop processing the data for that purpose. This option does not apply to communications primarily for the purpose of contracts, support, or other administrative and transactional notices.

Access Requests

Under applicable law, certain individuals have access to the Personal Information about them that ALOM holds and are able to correct, amend, or delete that information where it is inaccurate or has been processed in violation of the privacy principles. If you would like to modify or delete your Personal Information, please submit a request at [email protected] with clear instructions about what you would like modified or deleted. We will respond to your request within 30 days after a complete request is received. Please note that we cannot modify all information provided to us, such as anonymized data. We will comply with requests to modify information to the extent that we are able to do so.

Exercising Your Rights and How We Will Respond

To exercise any of your privacy rights, or to ask a question, please send an e-mail to [email protected], contact us at 1-800-500-9991, or use the contact details set out at the end of this Policy. To request a deletion, you may also use the Contact Us form by choosing Personal Information Removal in the I am interested in chooser and submitting the form.

For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

For requests to stop the sale of your Personal Information, we will comply no later than 15 business days after receipt of your request.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

8. Other Privacy Information

Retention of Personal Information

We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria used to determine the retention periods include: (i) how long the Personal Information is needed to provide our products and services; (ii) the type of Personal Information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

How We Keep Your Personal Information Secure

We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

International Residents

Personal Information collected from you, including via our Sites, will be transferred to the United States where the Sites are hosted. You hereby consent to the transfer of your Personal Information to the United States as described in this Privacy Policy. Please do not use the Sites if you do not agree to the transfer and processing of your Personal Information in the United States, which may not provide the same level of protection for your data as your home country.

9. Changes to This Policy

We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been updated and by updating the date of the Policy.

10. Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at [email protected] or 1-800-500-9991.

11. Personal Information of Minors

Our products and services are not directed to minors under the age of 13. We do not knowingly sell the Personal Information of minors under the age of 16. If you believe that we have collected information from a child under 16, please contact us at [email protected] so that we may delete the information.

12. Contact Us

If there are any questions regarding this Policy or if you wish to exercise any of your privacy rights, or request a copy of this Policy in another format you may contact us by sending an e-mail to [email protected], a letter to Office of the CPO, ALOM, 48105 Warm Springs Blvd, Fremont, CA 94539, by calling our toll-free telephone number at 1-800-500-9991, or by visiting our website at https://alom.com/contact-us/.