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This is the general privacy policy (“Privacy Policy”) for Alen and/or its corporate affiliates (whether existing now or in the future) (hereinafter referred to collectively as “Alen” or “we”). Except where Alen posts a separate privacy policy, this Privacy Policy applies to all information we collect or acquire from and about consumers: (i) through any media, channels and platforms, whether online, offline, via mobile and wireless platforms, or otherwise, and whether existing now or in the future, as well as Alen-branded applications that operate on or in connection with third party social media sites and platforms, such as apps for Facebook, Twitter, LinkedIn, and Google/YouTube (all the foregoing, hereinafter referred to as the “Alen Interactive Platform” or “Site”); and (ii) via other collection, acquisitions and marketing channels (e.g., direct mail, paper and phone enrollments, cross-sell programs, affiliate marketing, and our Business Partners (as defined in Section 2 below).

We are committed to respecting your privacy and recognize your desire to protect the Personally Identifiable Information (as defined in Section 1 below) you share with us. This Privacy Policy describes the types of information we may collect from and/or about you (whether via the Alen Interactive Platform or otherwise), the treatment of such information, and the choices you have regarding your information. 

This Privacy Policy constitutes part of the terms and conditions (such as official rules) that govern your participation in any and all events and activities offered or sponsored by us.

Notice To California Residents – Your California Privacy Rights:

Effective January 1, 2005, under California Civil Code Section 1798.83 (known as the “Shine the Light” law), if an individual who is a California resident has provided personal information (as such term is defined by the Shine the Light law) to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s personal information to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what personal information was shared and with whom it was shared. A business may comply with this law by: (1) having EITHER a published privacy policy of not sharing a customer’s personal information for third-parties’ direct marketing use unless the customer has first affirmatively opted in to such sharing OR a published privacy policy of not sharing a customer’s personal information for third-parties’ direct marketing use if the customer has opted out to prevent his/her personal information from being shared for direct marketing use; AND (2) notifying the customer of his/her right to opt out and providing a cost-free means for the customer to exercise that right.

Any request for a disclosure required under this law should be sent to us via email at service@alen.com. Please note that under this law, we are not required to respond to a customer’s request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email address designated above.

Types of Information We Collect

1.1 Personally Identifiable Information. 

“Personally Identifiable Information” or “PII” means information relating to an identified or identifiable individual. 
We may also collect PII from third party sources, such as: (1) third party sites or platforms, in the event that you link or associate your Alen profile to that third party site or platform or import your contacts from that third party account; (2) friends or family members, if they have provided your information to Alen or through the Alen Interactive Platform; or (3) through the use of cookies and similar technologies (see Section 5 below for more information).

1.2  Other Information. 

We may collect other information that cannot identify or be linked to an individual (and is therefore, not PII). For example, we may collect traffic data pertaining to the Alen Interactive Platform, such as total page views in a given time period, total impressions per ad, average amount of time that visitors spend on the Alen Interactive Platform (or a part thereof) each time they visit, average amount of time that visitors spend on each page of any one or more parts of the Alen Interactive Platform, and percentage of visitors from a certain geographical area. 

We typically collect this information through the use of cookies and similar technologies. 

In addition, we will use the information about you that we obtain in connection with SMS/text messaging in accordance with this Privacy Policy. We collect the following personal information about you in the context of our SMS/text messaging marketing and other programs, including notifications regarding the status of purchases from us: your name, mobile phone number, and texting preferences (opt-ins and opt-outs), as well as information you share with us during SMS/text message exchanges with us. We use this information to manage our SMS/text messaging program, including to send you text messages. This may include SMS/text messages related to your shopping cart on our website when you have not completed a purchase. You may opt out of receiving SMS/text messages at any time by replying “stop” to one of our SMS/text messages. In addition, your wireless carrier may collect data about your wireless device usage in connection with SMS/text messages, and its practices are governed by its own policies.

What We Do With The Information

As a general matter, subject to applicable privacy laws, we use the PII collected from and/or about you in the following ways:

2.1 Our Own Use of Information

2.1.1  Transactional, Administrative, and Customer Relation Purposes: If you provide PII to us as part of a direct interaction, we will process and use your PII for all purposes related to that activity, including communicating and interacting with you in relation to that activity. 

For GDPR purposes, we use your PII in the context of these transactional, administrative, and customer relation purposes pursuant to any contracts we have with you, any consent we’ve received from you, or our legitimate interests in: (1) improving our products and service; (2) administering and maintaining operations of the Alen Interactive Platform; (3) offering, marketing and advertising products and services; (4) administering and managing transactions and relationships with you; and (5) personalizing user experiences.

2.1.2 Marketing & Advertising Purposes: 

(a)  Interest-based advertising on the Alen Interactive Platform: We may use your PII to provide to you interest-based ads (i.e., ads potentially relevant or tailored to your interests) about products and services of Alen and/or our Business Partners (as defined in Section 2.2.1 below). For example, we show ads inside and/or alongside the videos you watch on Alen.com. Sometimes, these ads are based on the topics or subject matters of the videos you are watching. However, to make these ads as relevant as possible for you, we may infer your viewing interests based on videos you have previously viewed on Alen.com, and may use this information to associate your browser with relevant interest categories and show you ads relevant to your inferred interests. For example, if your prior viewing habits on Alen.com suggest that you are affected more by a certain type of environmental pollutant than others, you might see more ads related to products that we consider to be more useful for such pollutants.

For GDPR purposes, we use your PII for interest-based advertising pursuant to your consent (when we are required by law to obtain it) or our legitimate interests, such as: (1) offering, marketing and advertising products and services; and (2) personalizing user experiences.(b)  Email marketing: If you provide your email address or mailing address to us (such as by joining one of our mailing lists), we may use such address to send you product and service offers, promotions, and advertisements from us and/or from our Business Partners in accordance with applicable anti-spam legislation. For instance, if you are a consumer from Canada or the European Economic Area (“EEA”), we will ensure to either obtain your prior express consent, or that your consent can be implied under the applicable marketing laws. See Section 3.2 below regarding how to opt out of our email marketing.

For GDPR purposes, we use your PII for email marketing pursuant to your consent (when we are required by law to obtain it) or our legitimate interests, such as: (1) offering, marketing and advertising products and services; and (2) personalizing user experiences.

2.1.3. Market Research Purposes: We may use PII to conduct market research and analysis for ourselves as well as for our Business Partners.

For GDPR purposes, we use your PII for market research pursuant to our legitimate interests in: (1) improving our products and service; and (2) offering, marketing and advertising products and services.

2.1.4 Data Aggregation: We may combine your PII with other users of the Alen Interactive Platform to generate aggregate information that reflects activities, habits, preferences, interests, etc. about our users as a group. In addition, we may take PII and remove certain data elements to “anonymize” or “pseudonymized” your information, in accordance with applicable laws. We use this aggregated data to better understand our users and how they interact with our products and services.

For GDPR purposes, we aggregate your PII pursuant to our legitimate interests in: (1) improving our products and service; and (2) personalizing user experiences.

2.1.5 Other Uses: In the event of any other purposes for which we wish to use your PII that are not listed above, or any other changes we propose to make to the existing purposes, we will notify you by amending this Privacy Policy in accordance with the Section titled “Changes to this Privacy Policy” below.

2.2 Disclosure to Third Parties Outside Alen

2.2.1 Disclosure to our Business Partners and Co-Sponsors: Subject to privacy laws that may apply in your jurisdiction, we may disclose, sell, and otherwise provide PII to third parties outside Alen with whom we do business (hereinafter referred to collectively as “our Business Partners”) so that they may directly market and advertise their products and services including, without limitation, retail stores, finance, real estate, insurance, travel, automotive, telecommunications, technology, electronics, health, beauty, food, beverage, sports, leisure and entertainment goods and services to you. See Section 3.2 below regarding how to opt out of such information sharing.

2.2.2 Disclosure to our Service Providers: We may disclose PII to our outside vendors and contractors who need to access such information in order to perform services (including, without limitation, transaction/payment processing, order fulfillment, contest/sweepstakes administration and prize fulfillment, data research and analysis, data collection and processing, data storage, data security, hosting and technical support for the Alen Interactive Platform, and marketing and advertising support) for us (hereinafter referred to collectively as “our Service Providers”).

Generally, we require that our Service Providers use your PII shared by us solely for the purposes of performing services for us and that they maintain the confidentiality, security and integrity of such PII and not further disclose the PII to others.

2.2.3 Disclosure under other circumstances: We may disclose PII to others if doing so is required by law or, in our good faith belief, is reasonably necessary to: (1) comply with legal process (including a court order or subpoena); (2) cooperate with law enforcement; (3) enforce this Privacy Policy and/or the Terms and Conditions for Use of Site; (4) respond to an emergency; or (5) protect the rights, property or safety of Alen, our users, and/or the public. 

2.2.4 Unrestricted disclosure of non-PII: We reserve the right to use, disclose, sell, or otherwise share information that is not PII. For example, unless prohibited by subject privacy laws that may apply in your jurisdiction, we may freely share non-PII with our Business Partners who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share non-PII with our Service Providers in order for them to perform services to us.

Information Access &Opt–Out

3.1 Information Access

If you have an active user account on the Alen Interactive Platform, you may access and update your user account information and preferences at any time (subject to the scheduled maintenance of the Alen Interactive Platform), by logging into your account and clicking on “My Account” and then changing your preference.

If you do not have an active account on the Site, or if you have provided your information to us offline, you may request to access, delete, update and correct your information as stored by us, by sending your request to us at service@alen.com. Your request will be processed as soon as possible.

3.2 Opt-Out

You can opt out of all our marketing uses (including email marketing, mobile email marketing etc.) of your PII as well as our sharing of your PII with our Business Partners for their marketing uses by sending your request via email at service@alen.com. We will endeavor to honor your request no later than 30 days after receipt (or within such applicable time period as required by law). To ensure timely processing of your request, please expressly state in your email or mail that you wish to opt out of all further uses and sharing by Alen of your personal information for marketing purposes. Your opt out election, once processed by us, will stop, on a going-forward basis, all further marketing uses and sharing of your PII by Alen.

In addition, with respect to certain marketing uses of your PII, you may exercise your opt-out choice through the following alternative methods: Our email / mobile email marketing (i.e., sending marketing emails (including our newsletters) to your Internet email account or your mobile email account):

Use the opt-out means (e.g., an “unsubscribe” link) provided in a marketing email that you have previously received from us.

3.3 Additional Rights for EEA Individuals

If you are located in the EEA, you may have the following additional rights under the GDPR: (1) The right to access the information we hold about you, which is described in Section 3.1 above; (2) The right to request the correction of inaccurate information we hold about you. You can correct some of this information in your account settings; (3) In some circumstances, the right to request that we delete your information, or stop processing it or collecting it; (4) The right to stop direct marketing messages, which is described in Section 3.2 above, and to withdraw your consent for other processing activities for which you have given us your consent; (4) The right to request that we transfer your information either to you or a third party; and (5) The right to complain to your data protection regulator.

If you want to exercise your rights, please contact us at service@alen.com and we will provide you certain reasonable services. We may charge you a reasonable fee if you request additional copies of your PII or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why. 

Data retention

We will retain your PII for as long as your account is active or as needed to provide you products or services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 

Protecting Children

We take special care to protect the safety and privacy of children. All products and services of Alen are intended for general audiences and are NOT directed to children. We do not knowingly permit children under 16 to register on the Alen Site for any product or service. We do not knowingly collect or solicit Personally Identifiable Information about children under 16.
Children under 16 should always ask their parents or guardians for permission before providing any Personally Identifiable Information to anyone online or through mobile devices. If you are a parent or legal guardian, we urge you to participate in your child’s online and mobile activities and to use parental control or other Internet and/or mobile filtering technology to supervise your child’s access to the Internet.

Cookies & Similar Technologies

We may collect information about your computer or device by using cookies and similar technologies. A “cookie” is a small file that is stored on the hard drive of your computer. Cookies are created when a user's browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. 

We use both Session cookies and Persistent cookies on the Alen Site. Session cookies are temporary files that are erased when you close your browser. When you restart your browser and go back to the site that created the cookie, the website will not recognize you. Persistent cookies are files that remain on your hard drive until you erase them or they expire. How long a cookie remains on your browser depends on how long the visited website has programmed the cookie to last. 

We also use Advertising cookies. These cookies will collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We might sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

Third Party Pixels and Cookies

When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Data Security

Protecting the security of your Personally Identifiable Information that you share with us is of the utmost importance to us, and we implement technical and organizational measures designed to protect your information in accordance with applicable laws. 

Links to Third Party Sites, Services or Products

The Alen Interactive Platform contains links to sites operated and maintained by third -parties, as well as links to products and services (including software) provided by third-parties. 

Note to International Users

Alen is committed to complying with this Privacy Policy and data protection laws, including those outside of the United States, that apply to our collection and use of your PII. Certain of Alen’s affiliates are located in the United States, and we recognize that the laws in the United States may be different and, in some cases, not as protective as the laws of other countries, including those located in the EEA. By providing us with your PII and using our Site, you acknowledge that your PII will be transferred and processed in the United States. If you would like to know more about how we protect your PII when we transfer it across borders, you can contact us using the information in the Section titled “Changes to this Privacy Policy” below.

Changes to this Privacy Policy

From time to time, we may change this Privacy Policy in whole or in part, to accommodate new technology, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. If you are a registered user or member of the Alen Interactive Platform (e.g., any of our social networking services), we may notify you of material changes to this Privacy Policy via email and/or may ask you to affirmatively acknowledge and consent to such changes (e.g., by checking a box or clicking a button) at the time of your next account login on the Alen Interactive Platform.

Contact Us

We welcome your questions and comments about this Privacy Policy or how we process your PII. Please contact us using the information below and we will respond to you as soon as reasonably possible. For purposes of the GDPR, Alen is the data controller of Personally Identifiable Information collected under this Privacy Policy. For information about our processing activities, please contact our Privacy Officer at service@alen.com.

Effective Date of Privacy Policy

This Privacy Policy originally became effective as of November 2015 and was last updated on September 2020.