At Alohi SA, (“Company”, “we,” “us,” “our”) we recognize that our customers, visitors, users, and applicants (“you”, “your” or “user”), want to know what’s up with privacy.
We are committed to ensuring the security, availability, processing integrity, and confidentiality of our services and use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to via our Apps and you do so at your own risk. Using unsecured wifi or other unprotected networks to submit messages through our Service is never recommended.
If you do not agree with our practices, please do not use our Websites, Apps, and/or Services.
The aforementioned Websites, Apps, and Services are, unless otherwise indicated, owned and operated by Alohi SA.
Alohi SA has its place of business in Switzerland at the following address:
Route de la Galaise 34
We obtain the following types of information, which may include information that can be used to identify you as specified below (“Personally-Identifying Information”, or “Personal Data”):
User-Provided Information: You provide certain Personally Identifiable Information, such as your name, mobile phone number, email addresses, contact or authentication data, and other similar information to us when choosing to participate in various uses of our Services such as registering an account, receiving help through our customer support channels, requesting a demo, or participating in customer surveys. We also collect the content you create, upload, or receive from others when using our services.
Payment Data: We may collect data necessary to process your payment if you make purchases, such as the credit card number and the security code. All payment data is stored, and directly processed, by PayPal, Stripe, iTunes, and Google Play.
Credentials: We collect passwords and similar security information used for authentication and account access.
Logins: If you register with any existing account (e.g. Google), we notably receive your name or email address.
Log File Information: When you use our Services, our servers automatically record certain information that your web browser or mobile app sends to our servers. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed, and the order of those pages, the amount of time spent on particular pages and the date and time of your request.
We process the Personal Data that we receive within the scope of implementing our Websites, Apps, and Services.
When you sign up for an account (“Account”) with us or use our Websites, Apps, or Services, we process your Personal Data for the following purposes:
In certain circumstances, if we do not receive the required personal information (such as your mobile phone number which is essential to your use of our Services), you will not be able to use our products and we will not be able to provide you with Services or comply with legal obligations.
When processing your Personal Data e.g. for marketing purposes or when you register as a new user, we do so on the basis of your consent. Consent that has been given can be revoked at any time but has no effect on any data processing that has already been carried out based on such consent.
When processing your Personal Data for the purpose of the performance of our Services and customer support, we do so on the legal basis of the performance of the contract to which you are party, and/or in order to take steps at your request prior to entering into a contract.
When processing your Personal Data for the purposes of Websites and applications maintenance, service quality and data security, security, management of our finances, and exceptionally in case of marketing, we do so on the legal basis of our legitimate interest.
We do not collect emails, addresses, or other contact information from our Users’ mobile address book or contact lists.
We do not sell or share your Personally Identifiable Information (such as mobile phone number) with any other third-party companies for their commercial or marketing use.
Your Personal Data may be transferred to third parties when required for the purpose of providing Services or to fulfill our statutory tasks, or if you have expressly consented to this. In addition, Personal Data may be transmitted to third parties to provide proof in case of a payment dispute or if we are under obligation to do so by law or by an enforceable official or court order.
The types of third-party processors we may share elements of your Personal Data with include:
We may share your Personal Data, as part of a merger or acquisition of our Services by a third party entity, or change of control. Your Personal Data may be transferred to a successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of our assets, whether as a growing concern or as part of bankruptcy, liquidation, or similar proceeding, in which your Personal Data is amongst the assets transferred.
We are not fans of advertising. Our Products and Services are currently ad-free and we hope to keep it that way forever. We have no intention to introduce advertisement into the product, but if we ever do, will update this section.
We may offer you the ability to interact with or share information with third parties through the Services. For example, we may offer users the ability to log in to the Services via a third-party service like Google, or interact with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information with those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third-parties may use your information.
The third-party recipients of Personal Data can be in countries other than the country in which the data was originally collected, including destinations outside the European Economic Area (“EEA”) such as the United States or Switzerland.
When your data is transferred to countries outside of the EEA or Switzerland, we ensure that appropriate safeguards are in place and we comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA and/or Switzerland. We notably transfer your payment Personal Data (e.g. credit card number and security code) to PayPal, Stripe, iTunes, and Google Play in the United States, for the purpose of payment processing when you purchase our Services. In such cases, we enter into agreements with such third parties ensuring an adequate level of protection.
Our servers are located in Switzerland, which has one of the strongest data privacy protection laws.
We process and store your Personal Data to the extent that it is required to (i) provide you access to and use of our Websites and Products; (ii) download and use our Apps; (iii) perform the requested Services pursuant to our contractual obligations; and (iv) fulfill our legal obligations.
Under certain circumstances, your personal information will be securely stored and isolated from any further processing until deletion is possible. For example, when we have a legitimate interest in the storage of your Personal Data for as long as it is subject to retention requirements or storage for evidence, fraud prevention, or security purposes. Thereafter, your Personal Data will be deleted from our systems.
You have the right to access your Personal Data, to amend, delete, or restrict the processing of such data, and to withdraw consent to our processing of the data, right to object to our processing of your Personal Data, as well as the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format for the purpose of transfer to another office (known as data portability). Please note, however, that we reserve the right to enforce the restrictions required by law in cases where we are obliged to store or process certain Personal Data, have an overriding interest to do so (to the extent that we may call on it), or require it to assert claims.
Data access request fees may be charged if your requests are repetitive, excessive, or unfounded. We will inform you if your request may incur any costs for you. Please note that exercising your rights can conflict with contractual agreements, which can have consequences, such as the premature termination of our Services. In such cases, we will inform you in advance.
The exercise of such rights generally requires that you clearly prove your identity (e.g. with a copy of an ID card, if your identity cannot otherwise be clearly verified). You can exercise such rights by sending a request to our postal address, sending us a request via your Account, or by contacting us via our EU representative as explained further below if you are an EU-based citizen.
Below you can find more information about your rights in relation to your Personal Data:
You have the right to ask us for confirmation of whether we process any of your Personal Data belonging to you and, if so, further details thereof, as well as access to the Personal Data.
You have the right to have the Personal Data that we process corrected and/or completed. You can make changes to your personal details directly in your Account or you can contact us about correcting any incomplete or inaccurate information that we hold about you via the Contact Us link in your Account.
This enables you to ask us to delete or remove your Personal Data, provided that we are under no legal or official obligation to retain it. We may also keep some data in our files to prevent fraud. You may delete data associated with your Account, where you exercise your right to object processing (see below) by sending us your data deletion request via your Account.
You have the right to ask us to suspend the processing of your Personal Data under certain circumstances, in which case we will still be able to store your data but not use it. You may exercise such right to restrict data processing associated with your Account, by sending us a request via your Account.
Under certain circumstances, you have the right to receive the Personal Data provided by you in a structured, commonly used, and machine-readable format, and transmit such Personal Data to another company without restrictions from our side. You are also entitled to have this Personal Data sent directly from us to another company, if technically feasible. You can make this request by sending us a message via your Account.
Depending on your specific situation, you are entitled at any time to object to the processing of your Personal Data. You may ask us to stop processing your Personal Data by sending us a request via your Account.
In such a case, we will no longer process your Personal Data, unless we have compelling legitimate reasons for processing the data that outweigh your interests, rights, and freedoms, or if the Personal Data is processed for the purpose of asserting, exercising, or defending legal rights.
You have the right to object at any time to the processing of your Personal Data for marketing purposes.
You have the right to withdraw your consent to the processing of your Personal Data for one or more specific purposes at any time. This will not affect the legitimacy of any processing that took place before the withdrawal of your consent.
Every person affected has the right to legally enforce their claims or to submit a complaint with a data protection authority.
Protecting the privacy of young children is especially important to us. For that reason, we do not proactively collect or maintain Personally Identifiable Information or non-personally-identifiable information on our Websites, Apps, or Services from persons under 18 years of age, and no part of our Services is directed to or intended to be used by persons under 18.
If you are under 18 years of age, then please do not use our Websites, Apps, or Services at any time or in any manner. If we learn that Personally Identifiable Information of persons under 18 years of age has been collected on our Websites or Services, then we may deactivate the account and/or make the status submissions inaccessible and delete such Personally Identifiable Information.
The security of your Personal Data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use technical and organizational commercially acceptable means to protect your Personal Data against manipulation, partial or complete loss, and unauthorized access by a third party, we cannot guarantee its absolute security.
In the event of a data breach, or in the event that we suspect a data breach, we will (i) use our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach.
In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.
The Personal Data we hold may need to be disclosed when required by law, when requested by competent judicial and/or administrative authorities, or if we have good faith belief that disclosure is necessary to (i) investigate, prevent, or take action regarding suspected or actual illegal activities, or to assist government enforcement agencies; (ii) enforce our agreements with you; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of our Websites, Apps and/or Services; or (v) exercise or protect the rights and safety of our users, clients, personnel or others.
We will attempt to notify you of such requests for disclosures of your Personal Data when appropriate in our judgment and technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such requests when we believe, at our discretion, that the requests are too broad, vague, or lack proper authority. However, we do not commit to challenge every request.
Such disclosures would be made on the basis of compliance with our legal obligations.
California Consumer Privacy Act (CCPA) – Privacy Notice
If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”).
California residents have the right to know the categories of personal information we collect, the purpose for collecting such personal information (see the Section “Why do we process Personal Data” above) and the categories of third parties to whom the personal information (see the Section “Transfer of data to third parties” above) was shared for a business purpose.
This Privacy Notice is incorporated into and subject to our Terms of Service.
E.g. name, address, unique personal identifier (UID), Internet Protocol address, email address, cookie information or other similar identifiers
E.g. Name, address, or telephone number
E.g. date of birth, gender
E.g. products or services purchased, purchase history, transaction information, financial details, payment information
E.g. information on your interaction with a website or application
E.g. your device location data
E.g. Business contact details in order to provide our services, job title, work history, and professional qualifications if you apply for a job with us
E.g. student information
E.g. a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes)
Depending on the circumstance you have several rights with respect to your Personal Data:
The right to know: about the personal information we collect and we use it and share it
The right to delete: personal information collected (with some exceptions provided by law)
The right to opt-out: of the sale (collection or processing) of your personal information (Alohi does not sell any personal information).
The right to non-discrimination: for exercising your CCPA rights.
You can make a request to exercise these rights by contacting us directly via your Account. In certain cases, requests may require an ID verification to confirm your identity. Please note that exercising your rights can conflict with contractual agreements, which can have consequences, such as the premature termination of our Services.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers, to not have online browsing activities monitored and collected. We do not currently participate in any DNT frameworks that would allow us to recognize or respond to browser-initiated DNT signals.
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative in the EU. You can contact them regarding matters pertaining to data privacy.
If you want to make use of your data subject rights, please visit the following website: alohi.com/gdpr-eu-rep.
If you have any questions or concerns, you can contact us as followed:
Alohi SA is responsible for ensuring compliance with the applicable provisions on data protection. If you have concerns regarding data protection, you may send them to us at the following email: firstname.lastname@example.org