ICO registration reference: ZA242407
Alphakinetic respects the privacy of your personal information and this policy sets out what personal information we collect, what we do with it and your choices and rights. When we refer to our Services we include any software applications that you are entitled to use on desktop, web or mobile platforms and / or any consultancy services that we may be engaged in. When we refer to “we”(or “us” or “our”) that means Alphakinetic Limited and any of the companies in our group Virtus Partners Holdings LLC.
How this policy applies
This policy describes where we are a controller of your data, i.e. what we do with personal information that we collect and use for our own purposes such as your account information and information about how you use our Services, including information you submit to our support channels.
If you are a user of our services then we also act as a processor of your data where we host and process data on your behalf (referred to as Customer Data in our standard terms of service). This policy does not describe what we do with Customer Data because we will process this data specifically based on your instructions and this may differ from between customers depending on their privacy policies.
If you’re someone who doesn’t have a relationship with us, but believe that a user of our services has entered your data into our systems then you’ll need to contact that individual or organisation for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).
The personal data we collect
We class personal data as any information that can be identified as being about you, this includes:
- Information like your name, email, address, telephone numbers, support queries etc that we need to provide services to you
- Technical information such as IP addresses, details about your browser, network or device including language and other regional settings as well as information about how you use our services including timestamps, loading times and errors
- Information received from Third Parties such as publicly available materials or other Service Providers that you have given us permission to interact with
How we collect your data
We obtain personal information from various sources. We do this in three main ways:
- You provide some of it directly by using our services
- We record some of it automatically when you use our services which may include Cookies if you are using our Services through a web browser
- Occasionally we receive some of it from third parties like when we receive information from connected systems such as Bloomberg
How we use your data
We mostly use the personal information we obtain about you to operate our software, provide you with any services you have requested and to manage our relationship with you. We may also use your data to:
- Support you either by providing technical support or by email / phone
- Customise and / or improve our services
- Communicate with you, including by sending you Service related emails
- Ensure the security and integrity of our Services
- Manage our vendor and partner relationships
- Enforce our Terms of Service and other legal terms and policies
How we process your data
Where we collect personal data, we’ll only process it for the above purposes in the following cases:
- Where we have your consent
- To perform a contract with you and we need your personal information to provide the services or products requested by you or to respond to your inquiries
- Where we have legitimate interests to process the personal data and they’re not overridden by your rights
- Where necessary for the purposes of a third party’s legitimate interests, such as connectivity to Third Parties that are required to provide you with our Services.
- In accordance with a legal obligation such as to comply with tax and other government regulations
If we don’t collect your personal data, we may be unable to provide you with all our services.
How we share your data
There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:
- other companies in the group
- Service providers that perform services on our behalf. For example, we may use third parties to help us provide customer billing on our behalf or assist with data storage.
- Regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure
- Business transfers. If we're involved in an actual or proposed reorganisation, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.
- Other people where we have your consent.
When we share data, it may be transferred to, and processed in, countries other than the country you live in order to provide our services, this is also set out in our contractual terms and conditions. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA.
Where your personal data is transferred outside the EEA and is subject to the European General Data Protection Regulation (“GDPR”), it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
How we Secure your data
We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network and testing for and protecting against network vulnerabilities.
How we retain your Data
The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements).
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria.
You also have rights to:
- Know what personal data we hold about you, and to make sure it’s correct and up to date
- Request a copy of your personal data, or ask us to restrict processing your personal data or delete it
- Object to our continued processing of your personal data
You can exercise these rights at any time by sending an email to firstname.lastname@example.org.
If you’re not happy with how we are processing your personal data, please let us know by sending an email to email@example.com. We will review and investigate your complaint, and try to get back to you within a reasonable time frame.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with the Information Commissioner’s Office (https://ico.org.uk).