Updated: July 24, 2020
INFORMATION WE COLLECT THROUGH THE ALTO PLATFORM.
When you register on the 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 or qualified plan 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 and share 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 Notice.
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.
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.
Custodians and Transaction Counterparties: If you have an account with us, we may provide personally identifiable information about you to the custodian of your account assets, banks with which undirected cash may be deposited, and with counterparties to asset transfers and investment transactions you may direct us to conduct for your account. We do not control the use of your information by such third parties, which may be governed by separate privacy policies.
Agents, Consultants and Third Party Service Providers: Like other businesses, we utilize the services and products of other companies to perform certain functions to assist us in meeting business operations, compliance and other 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 connection with the performance of our services (for example, in filings with the Internal Revenue Service) and/or 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.
Changes to Personal Information and Unsubscribing. If your personal information changes, you may update it through the Site or by emailing firstname.lastname@example.org. If you no longer desire to use the services available through the Alto Platform, you may email us at email@example.com.
Personal Information Security. By utilizing the Alto Platform, you agree you are responsible for creating a strong password and maintaining adequate security and control of any and all IDs, passwords, hints, personal identification numbers (PINs), any other codes that you may use to access the Alto Platform. Any loss or compromise of the foregoing information and/or personal information may result in unauthorized access to your Alto User account by third-parties and the loss or theft of any property and/or funds held in your AltoIRA account(s). Alto assumes no responsibility or liability for, or duty to insure against, any loss that you may sustain due to compromise of your account login credentials through no fault of Alto. In the event you believe your Alto User account has been compromised or suspect that your password has been lost or stolen, you must immediately notify Alto at firstname.lastname@example.org or by phone at (877) 673-1557.
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.
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 Notice 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 Notice 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 Notice.
CHANGES TO POLICY
Please direct questions about this Privacy Notice to email@example.com.