This policy applies to:
- Alto Industries, Inc. and our affiliates (“Alto Industries,” “we,” “us,” “our”).
- Alto Industries’ online properties, including our websites, and websites or mobile applications that link to it, and our social media pages or handles.
- Alto Industries’ products and services, including our audio sharing and listening service Jam (collectively with the above, “Services”).
This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
We may change this Policy from time to time. If we do, we will notify you by posting the updated version.
Information We Collect
Jam connects content creators with listeners, and to facilitate those connections we need to collect information from both. We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Services together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.
Information you give us
Listeners and Content Creators may provide the following information to us directly:
- Contact information, including name, pseudonym, email address, and telephone number, which is also used to register an account.
- Payment information, including credit card information.
- Content you may include in survey responses.
- Information contained in your communications to us.
- Information you make available to us via a social media platform.
- Any other information you submit to us.
Additionally, Content Creators may provide the following information:
- Audio or visual data, audio clips, text, and/or video content that you voluntarily provide for distribution to listeners.
- Any other content you submit.
Information we collect automatically
We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Services.
- Device information, including IP address, device identifiers, device type, device operating system, and details about your web browser.
- Analytical information, including details about your interaction with our website, app, and electronic newsletters, including the third-party web pages you came from and those you go to.
- Diagnostic information, including web traffic logs, such as the pages you visit, the time and date of your visit, and the time spent on each page; technical information related to certain errors, for example, technical details about your device, details about the error shown, and other technical information related to the problem.
- Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf.
The following is a list of our partners who collect the information described above. Please follow the links to find out more information about the partner’s privacy practices.
|Partner||Information Type Collected|
We may collect data about text messages that you send us, such as time and date, and whether you interacted with links received in text messages. We create business records when you otherwise interact with the Services.
Information We Collect From Other Sources
We may collect the following information about you from third-party sources.
- Contact information and information about your interests and purchases from consumer data providers.
- Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly.
- Information about your interaction with ads that we place on third party websites, from online advertising companies.
- If you decide to invite others to the Services (e.g., by using the “find-a-friend” feature), we will collect your and the other person’s names, email addresses, and/or phone numbers to send an email or text message and follow up with the other person. You agree that you will obtain the other person’s consent before giving us his or her contact information. You also agree that you will not send us the contact information of a minor. We will inform any other person you invite that you gave us his or her information in the invitation email.
How We Use Your Information
We may use any of the information we collect for the following purposes.
- Publish content: To distribute the content that content creators submit to us for the purpose of publication. Our lawful basis for processing personal information in connection with this purpose is to fulfil our contractual obligation to content creators.
- Service functionality: To provide you with our products and services, including to enable access to our Services, take steps to enter a contract for sale or for services, process payments, fulfill orders, send service communications, and conduct general business operations, such as accounting, recordkeeping, and audits. Our lawful bases for processing personal information in connection with this purpose are to perform our agreement with you, our legitimate business interests, or your consent.
- Service improvement: To improve and grow our Services, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing. Our lawful basis for processing personal information in connection with this purpose is our legitimate business interests.
- Personalization: To offer you recommendations and tailor the Services to your preferences. Our lawful basis for processing personal information in connection with this purpose is our legitimate business interests.
- Advertising and marketing: To send you marketing communications, personalize the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising. We may share your information with business partners, online advertising partners, and social media platforms for this purpose. Our lawful basis for processing personal information in connection with this purpose is our legitimate business interests. We will seek your consent where necessary to send you marketing communications or use non-essential cookies.
- Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal. Our lawful basis for processing personal information in connection with this purpose is our legitimate business interests and to comply with law.
- Legal compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements. Our lawful basis for processing personal information in connection with this purpose is to comply with law.
How We Share Your Information
We may share any of the information we collect with the following recipients.
- Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:
- Supporting Service functionality, such as vendors that support customer service and customer relationship management, subscription fulfillment, application development, postal mailings, payment processing, and communications (email, fax).
- Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
- Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
- Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.
- Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- Information technology vendors, such as entities that assist with website design, hosting and maintenance, provision of servers, data and software storage, error logs, and network operation.
- Marketing vendors, such as entities that support distribution of marketing emails.
- Business partners: From time to time, we may share your contact information with other organizations for marketing purposes.
- Government entities/Law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights, or the safety of our employees, our customers, or other individuals.
- Other businesses in the context of a commercial transaction: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information as described in this policy.
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Your Options and Rights Regarding Your Information
Your Account. Please visit your account page to update your account information.
Email unsubscribe. If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications.
Ad Choices. You have options to limit the information that we and our partners collect for online advertising purposes.
- The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
- You may use our cookie settings menu.
- You may contact us directly.
If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you.
If you delete your cookies, you may also delete your opt-out preferences.
Jurisdiction-specific rights. You may have certain rights with respect to your personal information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.
Special Information for Job Applicants
When you apply for a job with us, we may collect information from you, including:
- Information you provide in connection with your application.
- Information that you make available in your social media accounts.
- Information about you that is available publicly.
- Information that you authorize us to collect via third parties, including former employers or references.
In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.
Other Important Information
We may store information about you for as long as we have a legitimate business need for it.
Cross-border data transfer
We may collect, process, and store your information in the United States and other countries. The laws in the United States or other countries regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.
Information about children
The Services are intended for users aged thirteen and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us with any concerns.
Privacy Disclosures for Specific Jurisdictions
European Economic Area, United Kingdom, and Switzerland
We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”).
Your rights: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for EEA data protection authorities are available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. The U.K. authority is the Information Commissioner’s Office. The Swiss authority is the Federal Data Protection and Information Commissioner.
If you are located in the EEA, U.K., or Switzerland, you have the following rights.
- Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
- Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
- Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
- Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise or defense of legal claims; or if your request to object to processing is pending evaluation.
- Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
- Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.
Please contact us to exercise these rights.
Your California Privacy Rights; “Shine the Light” Law We do not share your personal information with third parties for those third parties’ direct marketing purposes.
California Consumer Privacy ActThe California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.
Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of personal information we collect and the purposes for which we use personal information. The following table summarizes the categories of personal information we collect, the categories of sources of that information, and whether we disclose or sell that information to service providers or third parties, respectively. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described in “how we use information.”
|Category||Information Type||Source||We disclose to:||We sell to:|
|Identifiers||Contact information or personal characteristics (name; email address; postal address; telephone number)|
Social media handles
|You; our social media pages||Service Providers||Not sold|
|Financial Information||Payment card data|
Bank account information
|You||Service Providers||Not sold|
|Commercial Information||Transaction information |
Billing and payment records
|You||Service Providers||Not sold|
|Geolocation Information||Coarse (information that describes location at ZIP code-level or less precision)||You; our analytics and advertising partners||Service Providers||Not sold|
|Internet or Electronic Network Activity Information||IP address|
Device identifier (e.g., MAC)
Advertising identifier (e.g., IDFA, AAID)
Information provided in URL string (e.g., search keywords)
Cookie or tracking pixel information
Information about your interaction with our website, app, email correspondence, or products
Diagnostic information (e.g., crash logs, performance data)
|You; our analytics and advertising partners||Service Providers||Not sold|
|Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information||Call recordings |
|You||Service Providers||Not sold|
|Inferences Drawn About You||User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||You; our analytics and advertising partners||Service Providers||Not sold|
|Content of Communications||Contents of phone calls, emails, or text messages|
|You||Service Providers||Not sold|
|Contacts||List of contacts that you supply to us|
List of contacts we collect from your device with your permission
|You||Service Providers||Not sold|
Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.
Entities to whom we “sell” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us.
Your rights under the CCPA
- Opt out of sale of personal information: You have the right to opt out of the sale of your personal information to third parties. We do not sell information to third parties. Please be aware that your right to opt out does not apply to our disclosure of personal information to service providers.
- Know and request access to and deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with to whom we sell or disclose it. You also have the right to request in certain circumstances that we delete personal information that we have collected directly from you. Please contact us to exercise these rights.
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.
Contact information, submitting requests, and our response procedures
Mail: 775 E Blithedale Ave, Ste 112, Mill Valley, CA 94941
Making a request to exercise your rights
Submitting requests: You may request to exercise your rights by submitting the form on this page or making a request using the contact information above.
If you are a California resident, you may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf.
We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.
We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.