Privacy Policy

Updated: April 9, 2018

AltoIRA.com is a website (“Site”) operated by Alto Solutions, Inc., a Delaware corporation (“Alto,” “we” or “us”) which allows you (“User,” “you,” or “your”) to open and manage self-directed individual retirement accounts (SD-IRAs) and alternative investments made through SD-IRAs. The infrastructure, software and services that support the Site are referred to herein as the “Alto Platform.” This privacy policy applies to the Alto Platform. All investments held in an SD-IRA account opened through AltoIRA.com are maintained by a Custodian, whose services are governed by a separate privacy policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT IS A REQUIRED PREREQUISITE TO YOUR REGISTRATION AND USE OF THE ALTO PLATFORM.

INFORMATION WE COLLECT THROUGH THE ALTO PLATFORM.

Personal Information. When you register on this Site, we collect and store personally identifiable information, including your name, address, email address, password, social security number, driver’s license number, certain pre-existing IRA account information, and other non-public information. Alto may request additional information from you or third parties to validate or supplement this information.

We will also collect payment information, such as credit card, bank account, or other account information that you enter on the Alto Platform. If you do not provide this information you will not be able to use the Alto Platform.

We may also ask you for information to process account applications, consent forms, payment directions, investment instructions and documentation, transaction history and account activity. We will use your personally identifiable information only to operate, improve and provide our services.

By voluntarily providing us with your personally identifiable information, you consent to our use of it consistent with this Privacy Policy.

Other Information.

Non-Personal Data: When you interact with the Alto Platform, we automatically receive and store certain non-personally identifiable information. This information alone, such as information collected through cookies (described in greater detail below), cannot presently identify you. If we combine this data with other information that can identify you, we will treat it like personally identifiable information. The Alto Platform may use such information and pool it with other information to track, for example, the total number of visitors to our Site, and the domain names of our visitors' Internet service providers.

Cookies: In operating the Alto Platform, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately.

For example, we use cookies when you log in to your Alto User account to ensure you are authenticated in all the screens you interact with and so we do not need to ask you for your password on each page. We also use cookies to ensure integrity of data across accounts. Once you log out or close your browser, this cookie expires and no longer has any effect. We also use longer-lasting cookies for purposes such as to pre-fill your e-mail address when you return to the Site. Users can control the use of cookies at the individual browser level. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please note that if you turn cookies off it may limit your use of the Site.

Google Analytics: We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to administer, support, and understand how visitors use the Site and to improve the Site. Google Analytics uses cookies to provide this service. For more

information on how Google uses this data, please go to www.google.com/policies/privacy/partners/.

Do Not Track: Except to the extent required by law, your use of Do Not Track features in your browser will not affect our collection of information.

USE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION.

We will use your personally identifiable information to communicate with you in the following ways:

  • To operate the Alto Platform and respond to your inquiries or requests for information.
  • To communicate with you by email. All communications will be communicated to you through the Alto Platform or by email.
  • To send service related announcements. For instance, when you register to open an Alto account or change your password, or if our service is temporarily suspended for maintenance, we may send you an email.
  • To send service feature related announcements of ourselves or our partners. You may opt out of receiving marketing communications in accordance with applicable law.

If you opt out of receiving communications by email, you must deactivate your Account.

DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION.

We do not sell and we will maintain reasonable measures so as not to disclose information we collect from or about you, except as specifically authorized by you, or, without further notice to you, in the following circumstances:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personally identifiable information may be included in any transferred assets.

Agents, Consultants and Third Party Service Providers: Like other businesses, we sometimes hire other companies to perform certain functions to assist us in meeting business operations needs. When we employ another entity to perform a function of this nature, we provide them with the information that they need to perform their specific function.

Legal Requirements: We may disclose your personally identifiable information in response to a lawful request by law enforcement or otherwise if required by law, or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of AltoIra.com, (iii) act in urgent circumstances to protect the personal safety of users of the Alto Platform or the public, or (iv) protect against legal liability.

USE OF GENERAL INFORMATION / TRACKING TECHNOLOGIES.

Alto may convert personally identifiable information into general information by excluding information that is personally identifiable. General information may include cookies, tags, scripts, Internet service providers, and other system information. Alto or its service providers may use such general information in order to analyze trends, administer the Site, and track visitor and user movement to, from and around the Site.

You acknowledge that general information belongs to Alto and that Alto has the right to use such general information as it determines in its sole discretion.

USER RESPONSIBILITIES.

Changes to Personal Information and Unsubscribing. If your personal information changes, you may update it through the Site or by emailing help@altoira.com. If you no longer desire to use the services available through the Alto Platform, you may email us at help@altoira.com.

OTHER COMMUNICATIONS.

SECURITY.

When you enter personally identifiable information on the Site we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect personal information submitted to us, both during transmission and once we receive it. However, please be mindful that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

MINORS.

You must be 18 years of age or older to register on the Site and maintain an account with us. The Site and the Alto Platform are not directed to children who are under 13 years of age and we do not knowingly collect, use or disclose personally identifiable information from children under the age of 13.

LINKS TO OTHER WEBSITES.

This Privacy Policy applies only to the AltoIRA.com website. The Site may contain links to other websites that are not operated or controlled by us (“Third Party Sites”). The policies and procedures described in this Privacy Policy do not apply to Third Party Sites or their privacy or data practices. The links on the Site do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies and practices before interacting with them. When you click on a link, logo or other item, please note that you may no longer be on the Site and will no longer be subject to this Privacy Policy.

CHANGES TO THIS POLICY.

We may amend this Privacy Policy from time to time without notice except as may be required by law. The most current version of this Privacy Policy will be posted on this Site. Your continued use of the Site or the Alto Platform will constitute your agreement to the revised Privacy Policy.