Privacy Notice
Introduction
Overview
Alto Star Ltd, its affiliates and subsidiaries, (together Alto Star Ltd or we/us/our) respect your privacy and are committed to safeguarding your right to privacy and your personal data. This Privacy Notice aims at informing you about how we treat and protect your personal data when you use our products, services or share your information with us (collectively referred to as “Services”). This Privacy Notice applies to all Alto Star Ltd companies. Where applicable, this Privacy Notice may be complemented by the specific provisions described in the section “Country Specific Notices”.
Purpose of the Privacy Notice
This Privacy Notice aims to give you information on how Alto Star Ltd collects and processes your personal data through your use of this website or our Services, including any data you may provide through this website when you consent to marketing.
It does not apply to third-party websites, products, or services. For example: Alto Star Ltd may use third-party websites or tools to collect your personal data (for instance, publicly available data online or from due diligence vendors). Alto Star Ltd has no control on the treatment of your personal data by the third-party and will not accept any responsibility or liability for any processing of your personal data by the third parties where Alto Star Ltd is not the “controller” as defined by GDPR. We recommend that you read the relevant privacy policies of the third parties that you have transacted with or have business relationship with, to understand how they process your personal data.
Who We Are
Company Information
Company Name: Alto Star Ltd
Correspondence Address: 1 The Briars, Waterberry Drive, Waterlooville, Hampshire, United Kingdom, PO7 7YH
Telephone: +44 (0)7808 331638
Contact Details
Email: info@AltoStarAdvisory.com
Website: https://altostaradvisory.com/
LinkedIn: https://www.linkedin.com/company/alto-star-limited/
What Information We Collect
We may process, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Personally Identifiable Information
Name, Address, Phone Number, Title, email address, IP Address, Job Title
Financial Information
Bank, Bank account number, Payment details, transaction details
Specific Information
Any personal data relating to Regulatory and Privacy services provided, for example, types of personal data, retention limits, cookie information.
Communication Data
Email correspondence, phones calls, documents, plans, notes, and messages via electronic media
Other Data
From time to time you may share other personal data not listed here as a result of using our services. This data will be treated in accordance with GDPR regulations.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example: we may aggregate your personal data to calculate the percentage of users accessing our website.
Where we need to collect personal data by law, or under the terms of contact we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.
How We Collect Your Information
Direct Interactions
You may give us your identity and contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide to us when you:
- apply for our Services;
- subscribe to our marketing publications;
- give us feedback or contact us.
Automated Technologies
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy section for further details
Third Party or Publicly Available Sources
We will receive personal data about you from various third parties and public sources as set out below:
- advertising and marketing where you have expressed your interest and have provided us with your identity and contact data;
- via events organized by third parties where it has been made known to you that your personal data provided by you will be shared with us; or
- obtain information from public domain where you may have provided to the public domain.
How We Use Your Information
Purpose of the Processing
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purpose/Activity | Type of Data | Lawful Basis for Processing |
Providing and Managing services | Name, Address, Phone Number, Title, email address, IP Address, Job Title, personal date not defined here, but processed as part of the regulatory services provided | Performance of a contract with you |
Processing transactions and payments | Name, Address , Bank, Bank account number, Title, Payment details, transaction details | Performance of a contract with you |
Communications for services | Name, Address, Phone Number, Title, email address, Property preferences, personal date not defined here, but processed as part of the regulatory services provided | Performance of a contract with you |
Communications for Marketing or Website visitors | Name, Address, Phone Number, Title, email address, IP Address, Job Title | Consent |
Complying with legal obligations | Name, Address, Phone Number, Title, email address, IP Address, Job Title, Bank, Bank account number, Payment details, transaction details, correspondence, phones calls, documents, plans, notes, and messages via electronic media | Necessary to comply with a legal obligation |
Complaints and potential disputes | Name, Address, Phone Number, Title, email address, IP Address, Job Title, Bank, Bank account number, Payment details, transaction details, correspondence, phones calls, documents, plans, notes, and messages via electronic media, personal date not defined here, but processed as part of the regulatory services provided | Necessary to comply with a legal obligation, Necessary for our legitimate interests |
Marketing Communications
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can withdraw your consent at any time by contacting us. We will never share your personal data with third parties for the purpose of marketing without your express opt-in consent.
Withdrawing consent or opting out of marketing data will not result in your contact details being deleted if they are required to meet contractual or legal obligations, only removed from the marketing database. Please refer to the “Your Data Protection Rights” section for deletion of your personal data.
Disclosure of Your Information
Within the Company
Your data may be shared internally within the Alto Star Ltd companies. This data may be shared within the EU and UK.
With Third Parties
- Business partners, Service providers, contractors and participants to your transactions, such as Banks, Supervisory Authorities, and other parties connected to Regulatory compliance industires, as necessary (i) to process payments or provide our Services; (ii) to help our business partners resolve disputes; and (iii) to help our business partners in regard to performance analytic to better understand the uses of their products or services and to help in enhancing users’ experiences.
- Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business.
- Business partners and third parties to market their products or services to you if you have consented to these disclosures.
- For any other purposes that we disclose to you.
We may also disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as party of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
- To comply with any court order, law or legal process, including responding to any government or regulatory request.
- To protect the rights, property or safety of our business, our employees, our customers or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity and fraud protection.
We may, however, share non-personal data without restriction with third parties.
Legal Obligations
- Legal and regulatory authorities as required by law.
Data Security
Measures to Protect Data
Protecting your information and your privacy is extremely important to us. Being entrusted with some of your most valuable data, we have set high standards for data security. We have put in place appropriate security measures, technical and organizational to prevent your personal data from being accidentally lost, used or accessed, altered or disclosed in an unauthorized manner.
Data Breach Procedures
In the unlikely event of a Data Incident involving your personal data, we will contact you as soon as possible with full disclosure of the information relating to the incident and how we intend to resolve the breach.
Data Retention
Retention Periods
We retain your personal data in an identifiable format for the least amount of time necessary to fulfil our legal or regulatory obligations and for our business purposes. We may retain your personal data for a longer period when there is a specific legal requirement to do so, for example in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax, regulatory or reporting requirements.
Criteria Used to Determine Retention
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal data for statistical purposes in which case we may use this information indefinitely without further notice to you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your Data Protection Rights
Under certain circumstances, you have rights under the data protection laws in relation to your personal data, as follows
Access to Information
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
Correction of Information
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
Erasure of Information
This enables you to ask us to delete or remove your personal data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may, however, keep some of your data to comply with the law or for tax purposes but we will evaluate your request within applicable data protection laws
Restriction of Processing
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Data Portability
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. This right applies to information which you have provided consent for us to use or where we used the information to perform a contract with you.
Objection to Processing
In certain circumstances you can object to our processing of your personal data. You have the absolute right to object where we are processing your personal data for direct marketing purposes or where we use legitimate interest to process your data. You can exercise this right at any time by contacting us.
Rights Related to Automated Decision Making and Profiling
You have the right to object to decisions made solely based on automated processing, including profiling, which produces legal effects or significantly affects you. You can request human intervention, express your point of view, and contest the decision
You can request meaningful information about the logic involved in automated decision-making and profiling, as well as the significance and envisaged consequences of such processing for you.
Country-specific Notices
Notice relating to our operations under the California Consumer Privacy Act (“CCPA”)
Alto Star Ltds is providing the following supplemental information for individuals whose personal data (referred to as “personal information under CCPA) is collected or held by Alto Star Ltds in the State of California as defined in the CCPA.
Your California Privacy Rights
Right to access the personal data we hold about you
You may request, no more than twice in 12-month period, a copy of the personal data that we have collected about you.
Right to request the deletion of your personal data
Unless otherwise stated under the applicable law, you may request that we delete the personal data we have collected from you.
Non-discrimination
You have the right not to be discriminated against for exercising your rights under the CCPA.
No sale or sharing of your personal data
We do not sell or share any of your personal data, as those terms are defined under the CCPA.
How to exercise your California Privacy Rights
You can request to access or delete your personal data held by us by emailing us and submitting the Data Subject Request.
California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Virginia Consumer Data Protection Act and Utah Consumer Privacy Act
Alto Star Ltds may use de-identified data in some instances. Alto Star Ltds either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.
Cookies and Tracking Technologies
Alto Star Ltd takes users’ privacy very seriously and is committed to comply with the privacy laws and regulations on privacy in the electronic communications. For this purpose, we have developed the following notice which intends to give you all the keys to manage the cookies we collect while you visit our website
Types of Cookies
- Strictly Necessary cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
- Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
- Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance
- Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly
- Social Media Cookies: These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools
Purpose of the cookies
Alto Star Ltd intends to ensure that you enjoy your experience on our website. For this reason, when visiting our Alto Star Ltd website, cookies are installed on your device. When surfing on Alto Star Ltd website(s), data logs of your surfing activity may be collected with the purpose of understanding aggregate usage of features and pages. In the preceding 12 months, We do not knowingly sell or share the personal information of minors under the age of 16.
How long does Alto Star Ltd keep the cookies?
Cookies remain on your computer by default for no longer than is stated in the tables below and you can decide to delete all cookies anytime when going into your browser settings.
How do I change my cookie settings?
If you don’t agree with the use of such cookies or if you want to customize it and save your preferences, you can clear your cookies in your browser to limit or exclude their use.
Please note that these settings are only valid for the pages created and owned by Alto Star Ltd. When we embody link to external websites and that you click on these links you leave our website and therefore the settings and notice applying to our website no longer applies. You should consider the new website cookies notice and settings.
Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers.
You can generally disable the cookie feature on your browser without affecting their ability to use the Alto Star Ltd website(s).
To make sure you find out your way on how to change the settings, please visit your browser developer’s website.
To opt out of being tracked by Google Analytics across all websites, visit
http://tools.google.com/dlpage/gaoptout.
You can find more information on cookies by visiting www.allaboutcookies.org and www.youronlinechoices.com.
Cookie List
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Strictly Necessary Cookies | ||
Domain | Cookie Name | Expiry Date |
Not Applicable | Not Applicable |
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*Please Visit https://cookiepedia.co.uk/ for information about the above cookies
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
First Party
Our website does not use first party targeting cookies, if any targeting cookies are discovered on the site, it is without Alto Star Ltd’s knowledge. If targeting cookies are found please inform us at the privacy contact email, so we may request they be removed.
Third Party
Our website does not use Third party targeting cookies, if any targeting cookies are discovered on the site, it is without Alto Star Ltd’s knowledge. If targeting cookies are found please inform us at the privacy contact email, so we may request they be removed.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
First Party
Our website does not use first party performance cookies, if any performance cookies are discovered on the site, it is without Alto Star Ltd’s knowledge. If performance cookies are found please inform us at the privacy contact email, so we may request they be removed.
Functional Cookies
Functionality cookies are used to enhance the performance of a website. Without them, certain functions of the website may not be available. However, they are not vital for a website to run, but they allow to remember important information and user’s preferences.
First Party
Functional Cookies | ||
Host | Cookie Name | Expiry Date |
Not Applicable | Not Applicable |
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*Please Visit https://cookiepedia.co.uk/ for information about the above cookies
Third Party
Functional Cookies | ||
Host | Cookie Name | Expiry Date |
None | None | N/A |
*Please Visit https://cookiepedia.co.uk/ for information about the above cookies
Please Note, in general Alto Star Ltd does not collect cookies and none should be placed on your computer, hence no cookie banner to accept or reject. We regularly check to see if third parties have placed code on our site to place cookies on your computer. If you do have cookies placed on your computer as a result of third party activity please inform us immediately and we will take steps to have the code removed from our website
Children’s Privacy
Information on Collecting Data from Minors
Alto Star Ltd does not collect, process or store personal information of minors under any circumstances.
International Data Transfers
How Data is Transferred Internationally
When possible, the data we collect from you is stored and processed at data centres in your home country.
Alto Star Ltd will take all reasonable legal, technical and organizational measures to ensure that if your data is transferred outside of your home country, it will be treated securely and with an adequate level of protection compared to the level of protection offered in your home country.
We may share your personal data with Alto Star Ltd group of companies who are based outside of your home country. We may also share your personal data with partners, suppliers or sub-processors based outside of your home country.
We have taken specific steps, in accordance with the applicable data protection law, to protect your personal data. In particular, we will strive to restrict the transfer of your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Transfers of personal data outside of your home country will take place only where the organization receiving the personal data has provided us with adequate safeguards, and subject to a written agreement, in line with applicable data protection laws.
Under GDPR requirements, this is either via “Adequacy” as defined by the European commission or via “standard Contractual clauses” which can be found in your Data protection agreement as part of the contract between our parties.
Where consent is provided, we take this as permission to transfer data outside of the home country on the same protected basis we have already stated and we rely on the Adequacy or Standard contractual clauses with the parties outside the home country as the transfer mechanism
Changes to This Privacy Notice
How Changes Will Be Communicated
We will regularly review and update this privacy notice. Any changes or updates we make will be posted on this page. If you would like to know when the last update of this privacy notice is, please refer to the “Effective Data of Changes” ” directly below this statement
Effective Date of Changes
12th August 2024
How to Contact Us
Contact Information for Privacy Queries
Info@AltoStaradvisory.com
Complaint Procedures
Please write to us at Info@AltoStaradvisory.com and you will be contacted regarding your complaint
Exercise your Data Protection Rights
Please write to us at Info@AltoStaradvisory.com and include your contact details and the specific right you wish to exercise. We will request proof of identity to be provided before we can act on your request. In the event proof of identity is not provided we reserve the right to refuse to act upon your request.