Last Revised: January 12, 2024
Introduction
Aleada Consulting (“Aleada”, “us”, “we” or “our”) is a privacy and data protection consulting firm based in the heart of Silicon Valley. As privacy professionals, we respect your privacy.
Scope
This Privacy Notice (“Notice”) describes how we collect, use, share, and process personal data; what rights and choices you may have with respect to your personal data; how you may contact us; and how we protect your personal data when you:
- Visit our website (https://www.aleada.co/), (“Website Visitors”);
- Access or use our products or services (collectively, our “Services”) as an Aleada prospective, current, or former client (“Clients”);
- Interact with us through our marketing activities, including registering for, attending, or otherwise participating in our events, tutorials, social media pages, or webinars (“Participants in Marketing Activities”); and
- Interact with us in a business context, such as a vendor representative for a vendor that provides services to Aleada (“Business Contacts”).
This Notice does not cover:
- Aleada employees – Please contact info@aleada.co to learn more about our privacy practices regarding the personal data of our employees.
- Job applicants – Please contact info@aleada.co to learn more about our privacy practices regarding the personal data of job applicants.
Quick Reference
This Privacy Notice is organized in the following sections:
- Introduction
- Scope
- Our Products and Services
- Information We Collect, How We Collect It, and How We Use It
- How We Disclose Your Personal Data
- Cookies and Other Tracking Technologies
- Your Privacy Choices
- International Data Transfers
- Data Retention
- How We Protect Your Data
- Minimum Age Requirements to Use Our Services
- Updates to this Notice
- Contact Us
Our Products and Services
Aleada provides privacy consulting services for organizations. For example, we help organizations build personal data inventories, update their privacy notices, create consent mechanisms, and more. We only provide services to organizations; we do not assist individuals with their individual privacy needs. For more information about our Services, please see our website at https://www.aleada.co/services.
Information We Collect, How We Collect It, and How We Use It
Personal data
Personal data is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal data does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records.
The personal data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services you use, your location, and applicable laws.
Sensitive personal data
Sensitive personal data is a category of personal data, which includes more sensitive information such as health data or a social security number. We do not collect your sensitive personal data when you visit our website, use our Services, participate in our Marketing Activities, or provide us with business-to-business services. Please do not send us your sensitive personal data through any free-form channels, such as our Contact Us form or to our email address.
Personal data we collect automatically
Website Visitors
When you visit our Website, we collect certain personal data automatically from your device through cookies and other technologies (see “How we use cookies, tags, and other technologies,” below for more information). This data is aggregated and anonymized. We collect the following personal data:
- Identifiers, such as your IP address;
- Approximate geolocation data, such as your city-level location (we do not collect precise geolocation data); and
- Internet or other electronic network activity information, such as how you interact with our Website, including the pages you access and links you click, your browser type, and your device’s operating system.
Collecting this data helps us to better understand our Website visitors, where they come from, and what content on our Website is relevant to them. We use this personal data to:
- Conduct internal analytics, including learning about Website traffic and activity;
- Secure and support our Website; and
- Improve and manage Website functionality, quality, and user experience.
Clients, Participants in Marketing Activities, and Business Contacts
When we send you emails, we collect the following personal data automatically:
- Internet or other electronic network activity information, such as how you interact with our emails, including whether you opened the email message we sent.
Collecting this data helps us to better understand our target audiences, and what content in our emails is relevant to them. We use this personal data to:
- Conduct internal analytics, including learning about email traffic and activity.
We don’t collect personal data about you automatically through our other (non-email, non-website) Marketing Activities.
Personal data you provide to us directly
Website visitors
We collect personal data you provide directly to us voluntarily through the online forms on our Website (for example, when you sign up for Aleada’s newsletter, schedule a free consultation, or use the Contact Us form). We collect the following personal data:
- Identifiers, such as your first and last name, personal phone number, and personal email address;
- Professional information, such as your job title, company name, corporate phone number, and corporate email address; and
- Any other personal data that you voluntarily choose to provide to us.
We use this personal data to:
- Communicate with you to respond to your inquiries, requests, and/or send important notices via email, such as providing you with a consultation or sharing updates about our Website and Services;
- Send marketing emails about our Services;
- Notify you about webinars and events; and
- Send newsletter emails and industry updates.
Clients
We collect personal data you provide directly to us voluntarily when you use our Services or when you email us. We collect the following personal data:
- Identifiers, such as your first and last name, signature, and preferred mailing address;
- Professional information, such as your job title, company name, corporate phone number, and corporate email address;
- Audio and video information, such as when you participate in a videoconferencing call or webinar with your audio and video on;
- Billing information, such as invoice amounts and payment information (e.g., corporate bank account information); and
- Any other personal data that you voluntarily choose to provide to us.
We use this personal data to:
- Provide you with our Services;
- Communicate with you to respond to your inquiries, requests, and/or send important notices, such as providing you with a consultation, sharing updates about our Website and Services, or sending a thank you message;
- Send marketing emails about our services;
- Notify you about webinars and events; and
- Send newsletter emails and industry updates.
Participants in Marketing Activities:
We collect personal data you provide directly to us voluntarily through our Marketing Activities. We collect the following personal data:
- Identifiers, such as your first and last name, personal phone number, and personal email address;
- Professional information, such as your job title, company name, corporate phone number, and corporate email address;
- Internet or other electronic network activity information, such as how you interact with our social media pages (e.g., Aleada’s LinkedIn, Twitter, YouTube, Facebook, Instagram pages), including “liking” our posts or comments you add to our posts;
- Audio and video information, such as when you participate in a videoconferencing call or webinar with your audio and video on; and
- Any other personal data that you voluntarily choose to provide to us, such as your social media profile information.
We use this personal data to:
- Communicate with you to respond to your inquiries, requests, and/or send important notices via email, such as providing you with a consultation or sharing updates about our Website and Services;
- Send marketing emails about our Services;
- Notify you about webinars and events; and
- Send newsletter emails and industry updates.
Business Contacts:
We collect personal data you provide directly to us voluntarily when you use our Services, when we use your services, or when you email us. We collect the following personal data:
- Identifiers, such as your first and last name, signature, and preferred mailing address;
- Professional information, such as your job title, company name, corporate phone number, and corporate email address;
- Audio and video information, such as when you participate in a videoconferencing call or webinar with your audio and video on;
- Billing information, such as invoice amounts and payment information (e.g., corporate bank account information); and
- Any other personal data that you voluntarily choose to provide to us.
We use this personal data to:
- Provide you with our Services;
- Use your services;
- Communicate with you to respond to your inquiries, requests, and/or send important notices, such as providing you with a consultation, sharing updates about our Website and Services, or sending a thank you message;
- Send marketing emails about our services;
- Notify you about webinars and events; and
- Send newsletter emails and industry updates.
Personal data we collect from third parties
Website Visitors
We do not solicit your personal data from third parties when you visit our Website.
Clients
Third parties sometimes send us your personal data when making a referral. In those instances, we collect the following personal data:
- Identifiers, such as your first and last name; and
- Professional information, such as your job title, company name, corporate phone number, and corporate email address.
With legal or public authorities
We use this personal data to:
- Offer our services to you.
Participants in Marketing Activities
We do not solicit your personal data from third parties when you participate in our Marketing Activities.
Business Contacts
Third parties sometimes send us your personal data when making a referral. In those instances, we collect the following information:
- Identifiers, such as your first and last name; and
- Professional information, such as your job title, company name, corporate phone number, and corporate email address.
We use this personal data to:
- Inquire about your services;
- Discuss potential partnerships; and
- Offer our services to you.
How We Disclose Your Personal Data
We disclose your personal data as required by law and as part of our business practices. We only share personal data on a need-to-know basis where appropriate safeguards and contractual arrangements are in place, and as described below in this section.
To summarize, we generally follow these principles:
- We do not sell (or “share,” as defined by California law, such as for targeted advertising) your personal data, whether you are a Website Visitor, Client, Participant in Marketing Activities, or Business Contact.
- We keep Client personal data confidential, unless one of the scenarios described below applies.
Service providers
We disclose your personal data to service providers that require access to your data for the uses described in this Notice or for purposes you have requested. These service providers are authorized to use your personal data only as necessary to provide us services. If you interact with service providers through our Services, we may facilitate the transfer of your personal data for those Services.
Third parties
Aleada does not sell or share information about you to third-party advertisers for advertising or marketing.
With your consent, we may disclose your personal data when making a referral.
Certain third-party services, websites, or applications you use or navigate to from our Website may have separate user terms and privacy policies independent of this Notice. This includes websites owned and operated by our clients or partners.
We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statements of each third-party service, website, and application before use.
In a business transfer or transaction
We may disclose or transfer personal data about you as part of a corporate business transaction, if there is a merger or acquisition, divestiture, sale of company assets, or in the event of insolvency, bankruptcy, or receivership. In these cases, we may transfer personal data to third parties as a business asset.
We may disclose personal data to third parties, including government authorities, for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:
- To comply with laws, regulations, legal process or to respond to lawful requests;
- To enforce or apply agreements, or initiate, render, bill, and collect for products and services (including disclosure to collection agencies to obtain payment);
- To protect the rights, interests, property, or safety of Aleada, our clients, and others;
- In connection with claims, disputes, or litigation;
- To protect you or others from fraudulent, abusive, or unlawful use of these services, and other fraudulent activity; and
- In an emergency.
Cookies and Other Tracking Technologies
We use certain technologies on our Website to provide you with an experience tailored to your needs. This section provides an overview of:
- The types of cookies on our Website;
- Other technologies we use to provide our Website; and
- How you can manage your preferences.
Cookies
We use cookies to help us understand how visitors interact with the features on our Website and to improve Website performance. These cookies help us to understand how visitors arrive at our Website; monitor Website usage; and secure, manage, and improve our Website.
We use cookies to collect the following information when you visit our Website:
- Your internet browser type;
- Your device’s operating system;
- IP address;
- Broad geographic location (i.e., city-level location);
- The domain name from which you accessed our Website; and
- Your interactions with our Website (for example, the date and time you visit our Website, the pages you visit, the time you spent on our Website, and the number of times you return to our Website).
Categories of cookies
We use the following categories of cookies on our Website:
- Strictly Necessary Cookies, which are essential for our Website to function correctly. These cookies ensure your security while you browse our Website. These cookies do not collect personal data and do not track browsing habits.
- Functional Cookies, which allow enhanced functionality and personalization when you use our Website. They may be set by us or our Website’s service providers.
Other technologies
In addition to cookies, we use the following technologies on our Website:
Tags
Tags are transparent images embedded on our Website which share information with us about your activities on our Website. Tags allow us to load necessary features in our Website (such as fonts, webpage layout, videos, and photos) and analyze user experiences on our Website.
Analytics tools
Analytics tools let us measure and understand how users interact with our Website. These tools may use many of the same technologies explained above, like cookies and web beacons. Note that this data is collected on an aggregate basis and does not directly identify you.
Changing your preferences
Most web browsers can be set to detect or reject cookies. You can block performance, functionality cookies, and other technologies by changing the settings on your browser. Strictly necessary cookies are always active on our Website and cannot be turned off.
You can still use our Website if you block or delete our cookies, but your ability to access certain Website features may be limited.
Do Not Track
Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit, indicating you do not wish to be tracked. Our Website does not respond to browser DNT signals. Instead, you can use your browser’s cookie controls to manage data collection and use.
Your Privacy Choices
Privacy options
As a small organization, Aleada is not subject to most privacy laws that provide privacy rights. However, as part of our commitment to privacy, we offer you the following privacy options:
- Access: You can request access to the personal data we collect about you. We’ll provide this information in a structured, machine-readable format.
- Correct: You can request correction of your personal data, where it is inaccurate or incomplete.
- Delete: You can request that we delete any of your personal data we have collected.
- Non-Discrimination: We do not treat anyone differently for exercising any of the options described above.
- Appeal: If we deny your privacy request, you can submit an appeal by sending an email to info@aleada.co.
Exercising your privacy options
If you wish to exercise any of the above options, please contact us at info@aleada.co.
You may also opt out of receiving our marketing emails by clicking the “Unsubscribe” link within each email. If you are a Client and opt out of receiving marketing messages, you will continue to receive transactional communications from us regarding our Services.
You may also authorize an individual to submit a verifiable consumer request relating to your personal data. If you wish to use an authorized agent to submit a request to opt-out on your behalf, you must provide the authorized agent written permission signed by you. We may deny a request from an authorized agent if the agent cannot provide us with your signed permission demonstrating that the agent is authorized to act on your behalf.
We fulfill requests within 45 days of receiving your request (except in rare cases where we need an extension, in which case we will tell you why we need the extension and fulfill the request within 90 days). Please note that your request may be limited in certain cases, for example if complying with your request would conflict with any of the following:
- Federal, state, or local law;
- Regulatory inquiries;
- Subpoenas; or
- Exercising or defending legal claims.
Please note we require you to verify your identity before we respond to any of your requests, such as by verifying your email address.
California Shine the Light Law
Under the California Shine the Light law, California residents may request information about whether a business has disclosed personal data (as defined in that law) to any third parties for their direct marketing purposes. Please note, we do not share personal data for direct marketing purposes.
International Data Transfers
Aleada is controlled and operated in the United States. If you use our Website or provide us with your personal data, you consent to the collection, processing, and transfer of your data in and to the United States.
If you are located outside the United States, you understand that the data you provide to us will be transferred to Aleada in the United States, which may not have privacy and data protection laws equivalent to the country in which you reside. If you do not want your personal data to be transferred to the United States, please do not submit any information to us or use our Website.
To the extent required by applicable law, Aleada will take measures to protect cross-border transfers of your data.
Data Retention
Aleada retains your personal data for as long as necessary for us to comply with legal obligations, resolve disputes, enforce rights, or as is reasonably necessary for business. We retain information necessary for the purposes of maintaining business records.
To determine how long we keep your personal data, we take into account the amount, nature, and sensitivity of personal data. We consider the potential risk of harm from the unauthorized use or disclosure of your personal data. We also consider the business purpose and legal requirements for holding your personal data, and whether we can achieve our business purpose through other means.
How We Protect Your Data
We use reasonable and appropriate physical, technical, and administrative safeguards to protect your data from unauthorized use, access, loss, misuse, alteration, or destruction. We require service providers acting on our behalf or with whom we share your data to provide such security measures under industry standards.
Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our services, please contact us at info@aleada.co. For your own security, please do not send us any sensitive personal data.
Minimum Age Requirements to Use Our Services
Aleada targets its Services to businesses. We do not target our Services to individual consumers, including children. We will never knowingly request or collect personal data from any child. If you are under 18 years old, please do not send us your information or use our Website.
Upon notification that a child has provided us with personal data, we will delete the child’s personal data from our records. If you believe we might have any information from a child, please contact us at info@aleada.co.
Updates to this Notice
We periodically update this Notice. When we make changes, we will notify you by updating this Notice and the date at the top of this page. If you do not agree to the changes made to this Privacy Notice, we recommend that you stop using our Website. We encourage you to review this Notice for updates each time you use our Website.
Contact Us
Please email us at info@aleada.co if you have questions about this Notice or about Aleada’s privacy practices.