Privacy Policy

Effective Date: August 17, 2025
Last Updated: August 17, 2025

1. Introduction

Altture ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website https://altture.com or engage our consultancy services anywhere in the world.

By accessing our website or using our services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our website or use our services.

2. Information We Collect

2.1 Information You Provide to Us

We may collect personal information that you voluntarily provide to us when you:

  • Contact us through our website or via email

  • Request our consultancy services

  • Subscribe to our newsletters or marketing communications

  • Participate in surveys or provide feedback

  • Apply for employment with us

  • Enter into contracts or agreements with us

This information may include:

  • Name and job title

  • Company name

  • Email address

  • Telephone number

  • Mailing address

  • Professional information and qualifications

  • Payment and billing information

  • Tax identification numbers

  • Any other information you choose to provide

2.2 Information Automatically Collected

When you visit our website, we may automatically collect certain information about your device and usage, including:

  • IP address

  • Browser type and version

  • Operating system

  • Access times and dates

  • Pages viewed and navigation patterns

  • Referring website addresses

  • Device identifiers

  • Location data (country/region level)

  • Log data and analytics information

2.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Business partners and clients

  • Professional references

  • Public databases and professional networks

  • Credit reference agencies

  • Marketing partners

  • Social media platforms

3. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Consent: Where you have given clear consent for us to process your personal data

  • Contract: Where processing is necessary for the performance of a contract with you

  • Legal Obligation: Where we need to comply with a legal obligation

  • Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests

  • Vital Interests: Where processing is necessary to protect someone's life

  • Public Task: Where processing is necessary to perform a task in the public interest

4. How We Use Your Information

We use the information we collect to:

  • Provide, operate, and maintain our consultancy services

  • Process transactions and send related information

  • Respond to inquiries and provide customer support

  • Send administrative information, updates, and security alerts

  • Fulfill legal and regulatory requirements

  • Conduct due diligence and conflict checks

  • Market our services (with your consent where required)

  • Analyze usage patterns and improve our services

  • Protect against fraudulent or illegal activity

  • Enforce our terms and conditions

  • Defend our legal rights and interests

5. Disclosure of Your Information

5.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

  • Cloud storage and hosting providers

  • Payment processors

  • Email service providers

  • Analytics providers

  • Professional advisors (lawyers, accountants, auditors)

  • IT support and security providers

5.2 Legal Requirements

We may disclose your information where required to:

  • Comply with applicable laws, regulations, or legal processes

  • Respond to lawful requests from public authorities

  • Protect and defend our rights or property

  • Prevent or investigate wrongdoing

  • Protect the personal safety of users or the public

  • Protect against legal liability

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or control of your personal information.

5.4 Consent

We may disclose your information to any other third party with your prior consent.

6. International Data Transfers

As we provide consultancy services worldwide, your information may be transferred to, stored, and processed in countries other than your country of residence. These countries may have data protection laws different from those in your country.

We implement appropriate safeguards for international transfers, including:

  • Standard Contractual Clauses approved by relevant authorities

  • Adequacy decisions where applicable

  • Your explicit consent where required

  • Other lawful transfer mechanisms under applicable law

By using our services, you acknowledge and agree to the transfer of your information to facilities and third parties as described in this Privacy Policy.

7. Data Security

We implement administrative, technical, and physical security measures designed to protect your personal information, including:

  • Encryption of data in transit and at rest

  • Regular security assessments and audits

  • Access controls and authentication measures

  • Employee training on data protection

  • Incident response procedures

  • Regular backups and disaster recovery plans

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

8. Data Retention

We retain personal information for as long as necessary to:

  • Provide our services

  • Comply with legal obligations

  • Resolve disputes

  • Enforce our agreements

  • Meet regulatory requirements

Retention periods vary based on the type of information and purposes for processing. We typically retain:

  • Contract records: 7-10 years after contract termination

  • Financial records: As required by tax and accounting laws

  • Marketing data: Until consent is withdrawn or 3 years of inactivity

  • Website analytics: 26 months

  • Employment applications: 12 months (unless hired)

9. Your Rights and Choices

9.1 Rights Under GDPR (European Economic Area, UK, Switzerland)

If you are located in the EEA, UK, or Switzerland, you have the right to:

  • Access your personal data

  • Rectify inaccurate or incomplete data

  • Erase your data ("right to be forgotten")

  • Restrict processing of your data

  • Data portability to receive your data in a structured format

  • Object to processing based on legitimate interests

  • Withdraw consent at any time

  • Lodge a complaint with a supervisory authority

9.2 Rights Under CCPA/CPRA (California)

If you are a California resident, you have the right to:

  • Know what personal information we collect, use, and disclose

  • Delete your personal information (subject to exceptions)

  • Opt-out of the sale of personal information (we do not sell personal information)

  • Non-discrimination for exercising your rights

  • Correct inaccurate personal information

  • Limit use of sensitive personal information

9.3 Rights Under Other Jurisdictions

We respect privacy rights under applicable laws in all jurisdictions where we operate, including but not limited to:

  • LGPD (Brazil)

  • PIPEDA (Canada)

  • Privacy Act (Australia)

  • POPIA (South Africa)

  • PDPA (Singapore)

  • Other applicable privacy laws

9.4 Exercising Your Rights

To exercise any of these rights, please contact us using the information in Section 16. We will respond to your request within the timeframe required by applicable law (typically within 30 days).

10. Cookies and Tracking Technologies

10.1 Types of Cookies We Use

  • Essential Cookies: Necessary for website functionality

  • Analytics Cookies: Help us understand how visitors use our website

  • Preference Cookies: Remember your settings and preferences

  • Marketing Cookies: Used to deliver relevant advertisements (if applicable)

10.2 Managing Cookies

You can manage cookies through your browser settings. Note that disabling certain cookies may affect website functionality. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

10.3 Do Not Track Signals

We do not currently respond to Do Not Track browser signals. However, you can manage tracking through cookie settings and privacy preferences.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information to them.

13. Marketing Communications

13.1 Opt-In/Opt-Out

Where required by law, we will only send marketing communications with your explicit consent. You can opt-out of marketing communications at any time by:

  • Clicking the "unsubscribe" link in our emails

  • Contacting us directly

  • Updating your preferences in your account settings

13.2 Transactional Communications

You cannot opt-out of transactional communications related to your account or our services, including security updates and legal notices.

14. LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

14.1 No Warranties

THE COMPANY PROVIDES THIS WEBSITE AND SERVICES "AS IS" WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.

14.2 Limitation of Damages

IN NO EVENT SHALL ALTTURE, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION, LOSS OF PROFITS, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATED TO:

  • YOUR USE OR INABILITY TO USE OUR SERVICES

  • ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SERVERS AND/OR ANY PERSONAL INFORMATION STORED THEREIN

  • ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM OUR SERVICES

  • ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT MAY BE TRANSMITTED THROUGH OUR SERVICES

  • ANY ERRORS OR OMISSIONS IN ANY CONTENT

  • ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT

14.3 Cap on Liability

OUR TOTAL LIABILITY TO YOU FOR ANY DAMAGES ARISING OUT OF OR RELATED TO THIS PRIVACY POLICY OR OUR SERVICES SHALL NOT EXCEED THE AMOUNT YOU HAVE PAID US IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO LIABILITY, OR ONE HUNDRED DOLLARS ($100), WHICHEVER IS GREATER.

14.4 Basis of the Bargain

YOU ACKNOWLEDGE THAT THESE LIMITATIONS ARE AN ESSENTIAL ELEMENT OF THE AGREEMENT BETWEEN US AND THAT IN THE ABSENCE OF SUCH LIMITATIONS THE TERMS OF THIS PRIVACY POLICY WOULD BE SUBSTANTIALLY DIFFERENT.

15. INDEMNIFICATION

You agree to defend, indemnify, and hold harmless Altture, its affiliates, licensors, and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors, and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to:

  • Your violation of this Privacy Policy

  • Your violation of any third-party rights

  • Your violation of any applicable laws or regulations

  • Any misrepresentation made by you

  • Your use or misuse of our services or website

16. DISPUTE RESOLUTION

16.1 Binding Arbitration

ANY DISPUTE ARISING OUT OF OR RELATED TO THIS PRIVACY POLICY OR OUR SERVICES SHALL BE RESOLVED THROUGH BINDING ARBITRATION, RATHER THAN IN COURT, except that you may assert claims in small claims court if your claims qualify.

16.2 Arbitration Rules

Arbitration shall be conducted in accordance with the rules of the American Arbitration Association (AAA) or International Chamber of Commerce (ICC) for international disputes. The arbitration shall be conducted in English.

16.3 Location

Arbitration shall take place in [New York, New York] unless otherwise agreed. For international disputes, arbitration may be conducted virtually.

16.4 Class Action Waiver

YOU AGREE THAT DISPUTES WILL BE RESOLVED ON AN INDIVIDUAL BASIS AND WAIVE YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION, CLASS ARBITRATION, OR ANY OTHER CONSOLIDATED PROCEEDING.

16.5 Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of [Delaware, United States], without regard to its conflict of law provisions. For international clients, local mandatory laws may apply.

17. SEVERABILITY

If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be replaced with a valid provision that comes closest to the intent of the original.

18. ENTIRE AGREEMENT

This Privacy Policy constitutes the entire agreement between you and Altture regarding the subject matter hereof and supersedes all prior and contemporaneous agreements, understandings, negotiations, and discussions, whether oral or written.

19. FORCE MAJEURE

We shall not be liable for any failure or delay in performance under this Privacy Policy which is due to fire, flood, earthquake, pandemic, governmental action, war, terrorism, or other unforeseeable cause that is beyond our reasonable control.

20. ASSIGNMENT

We may assign our rights and obligations under this Privacy Policy to any successor in interest, affiliates, or in connection with a merger, acquisition, or sale of assets. You may not assign your rights or obligations under this Privacy Policy without our prior written consent.

21. COMPLIANCE WITH LAWS

We reserve the right to disclose your information as required by law and when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Changes will be effective immediately upon posting to our website with an updated "Last Updated" date. For material changes, we will provide notice through:

  • Email notification to registered users

  • Prominent notice on our website

  • Other legally required methods

Your continued use of our services after changes constitutes acceptance of the updated Privacy Policy.

23. NO WAIVER

Our failure to enforce any right or provision of this Privacy Policy shall not be considered a waiver of those rights. Any waiver must be in writing and signed by an authorized representative of Altture.

24. PRIVACY OFFICER

We have appointed a Privacy Officer responsible for overseeing our privacy practices and compliance with this Privacy Policy and applicable laws.

25. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Altture
Privacy Officer
[Insert Physical Address]
Email: privacy@altture.com
Phone: [Insert Phone Number]

For EU/UK residents, you may also contact our Data Protection Officer at: dpo@altture.com

Supervisory Authority Contacts

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority:

  • EU: Your local Data Protection Authority

  • UK: Information Commissioner's Office (ICO)

  • California: California Privacy Protection Agency

  • Other Jurisdictions: Your local privacy regulator

26. ACCESSIBILITY

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you need this policy in an alternative format, please contact us.

27. RECORD KEEPING

We maintain records of our processing activities and privacy compliance measures as required by applicable laws. These records are available for inspection by regulatory authorities as required.

BY USING OUR WEBSITE OR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

Last Reviewed: August 17, 2025
Version: 1.0