SCOPE

Respecting your privacy is important to Alpha Ledger Technologies, Inc. This Privacy Statement is issued on behalf of the Alpha Ledger group of companies, so references to “Alphaledger”, “AL”, “we”, “us” or “our” are references to the relevant company in the Alpha Ledger group responsible for processing your personal data. This Privacy Statement describes the personal data that Alphaledger collects from you when you access any of our products or services, visit any Alphaledger website, contact us or request further information regarding a product or service. It also describes how your personal data is used and processed by Alphaledger and for what purposes we process it. This Privacy Statement should be read together with any other privacy notice or statement that we provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This Privacy Statement supplements the other notices but does not override them.

PERSONAL DATA WE COLLECT ABOUT YOU

We will collect, use, store, and transfer different categories of personal data about you as follows:

Personal Identity Data

In order to better provide you with products and services offered on our Site, Alphaledger may collect personally identifiable information, such as your:

• First and Last Name
• Mailing Address
• E-mail Address
• Phone Number

If you purchase Alphaledger's products and services, we collect billing and credit card information. This information is used to complete the purchase transaction.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Alphaledger's public message boards, this information may be collected and used by others.

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Professional Contact Data

This is the data that allows us to contact you, and includes your email address, postal address, and telephone number.

Technical Data

This includes your internet protocol (IP) address (which helps us to determine the location of the device you use to connect to our systems and to determine the number of devices simultaneously accessing the product), your username and password, and the information which we obtain on your technical profile through our use of cookies on your browser. For further information on Alphaledger’s use of cookies, see section 8 of this Privacy Statement.

Professional Profile Data

This is data that you may provide to us about your job role, function and business focus.

Alphaledger Relationship Data

This is data we obtain from our interactions with you, and includes details of any calls you have made to our help desk, visits made to you by our staff, marketing materials you have received, your email communication with our staff, data about your preferred activities for marketing events or the Alpha Ledger events you have attended, and your preferences in receiving marketing communications from us.

Product or Subscription Usage Data

This is data we obtain about your usage of our products and services, including when and which products you have used, subscribed for or are enabled to access, and the content and functionality you have used in those products and services.

Publicly Available Information

This includes data we obtain from directories, websites, public records or media sources.

Personal Data Collected from Third Parties

This is data we obtain from Alphaledger affiliates or third parties, including for example KYC (know-your-client) information regarding your employment status and the results of any regulatory screening processes, and could also include conference lists and financial services directories.

Referrals

This is data we obtain from other Alphaledger companies or through our Alphaledger website or other Alphaledger clients.

Surveys, Competitions, Prize Draws

This is data you provide us with when you participate in our competitions, prize draws or surveys.

Please note that if you fail to provide us with personal data which we are obliged to collect by law, or under the terms of a contract that we have in place with you, then we may not be able to provide our products and services to you, but will notify you if this is the case at the time.

PURPOSES FOR WHICH WE WILL USE PERSONAL DATA

We process personal data for the following purposes:

Account Setup and Administration

We use personal data in order to set up your access to a product or service that you have subscribed for and to manage invoicing and payments.

Provision of Service

We use the personal data we collect about you to provide you with our products and services and to assist you in your use of these. This includes providing any necessary operational assistance, support and training, and alerting you to product changes or maintenance periods.

Sales and Marketing

We will from time to time use the personal data we collect about you to contact you by e-mail, post or telephone with information about Alphaledger, the products and services you use, other Alphaledger products and services similar to those you use and events that might be of interest to you or your organization. If you submit an enquiry to us on our website or make an enquiry in person at one of our events, then we will use the personal data that you provide to us to respond to your enquiry, and to contact you about any products or services that you confirm to us that you are interested in hearing about. You may ask us to refrain from sending you marketing messages at any time as described in the "Your Choices" section of this Privacy Statement.

Product Development and Improvement

We will occasionally use the personal data we collect about you to ask you to participate in surveys and questionnaires to improve, customize and enhance our products and services. In addition, we can use the data, combined in aggregate form with the personal data we have collected about other users of our professional financial and media products, for statistical purposes, or to plan and implement developments of, and enhancements to, our products and product range.

Compliance Checks and Regulatory Record-keeping

We also use personal data to conduct know-your-client (KYC) and other compliance checks on our clients, and conduct system monitoring which Alphaledger is required by law to carry out. We will also need to retain certain personal data for regulatory record-keeping purposes.

Please see the European Specific Legal Disclosures section for the legal basis on which we process the personal data of individuals based in the EU.

SHARING PERSONAL DATA

We do not sell or otherwise disclose the personal data we collect about you, except as described here.

Alpha Ledger Group Companies

We share personal data with other companies within the Alpha Ledger group of companies acting as joint controllers who are based in the United States in order to provide operational and system administration services.

Third Party Providers of Content

We will share personal data with third-party content providers that you have subscribed to where it is necessary for them to confirm that a user is entitled to access their content and to evaluate and manage how that content is used in our services.

Collaboration Products

Some of our products, such as messaging or trading products, require you to submit information about yourself in order to participate in the collaboration services provided by that product. Some of those products display the information you have submitted to other participants. At the point at which you submit your personal data, we will tell you more about how that information will be used and shared within the product and, where applicable, your choices in respect of that use.

Third Parties

We use other companies as data processors to process certain personal data on our behalf, including service providers who have access to your personal data in order to assist us in our administration of the services. For example, we use:

• Customer relationship management software providers, such as Hubspot, in order to assist with the provision of our services and to contact you;
• Subscription management providers, such as FinRegAlert, who facilitate our distribution of some of our educational/knowledge materials;
• KYC and regulatory screening providers who assist us with meeting our compliance obligations, such as Accelus Org ID.

Third parties that have access to personal data are required by us and by applicable law to protect it in a manner consistent with this Privacy Statement.

Disclosure for Legal Purposes

We will provide access to your personal data when legally required to do so including, without limitation, to cooperate with regulatory and other government investigations or other legal proceedings.

Third party recipients of your personal data are only permitted to use it for the purposes of performing services on our behalf and in accordance with our instructions. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws.

We may disclose or transfer any information we have about you to third parties in connection with any sale, transfer or merger of all or a portion of our business or assets. Should such a sale, transfer or merger occur, the transferee(s) may use information you have provided in a manner that is consistent with this Privacy Statement.

SECURITY

We maintain appropriate administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data you provide to us. We also limit access to your personal data to those employees, agents and contractors and other third parties who have a business need to access your data. They will only process your information in accordance with our instructions and are subject to a duty of confidentiality.

COOKIES

The Alphaledger website may use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Alphaledger pages, or register with Alphaledger site or services, a cookie helps Alphaledger to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Alphaledger website, the information you previously provided can be retrieved, so you can easily use the Alphaledger features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Alphaledger services or websites you visit.

YOUR CHOICES

You may contact us to access the personal data you provide to us and to ask us to update, correct, or delete it from our databases, where it is legally permissible for us to do so. You may also request that we cease using your personal data for marketing purposes. If you do not wish to receive marketing emails and /or marketing materials from Alphaledger about the products and services we provide, or if any of your contact details are incorrect, please contact us at:
Email: privacy@alphaledger.com

CHANGES TO THIS PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES

This Privacy Statement may be updated periodically. We will indicate below when it was most recently updated and inform you, in this Privacy Statement, through email and/or a notice on the appropriate Alphaledger website, of any significant changes.

Last updated: 8 November 2019

It is important that the personal data that we hold about you is correct and up-to-date, so please notify us of any changes to your personal data during your relationship with us.