Privacy Policy

Discover our privacy policy that is there to protect you

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.

This Privacy Policy will help you understand what we do with the information that we collect when you visit our websites (www.alohi.com, www.fax.plus or www.sign.plus), download and use our mobile applications (FAX.PLUS and SIGN.PLUS), and engage with us in other ways such as customer support.

Throughout this Privacy Policy, when we refer to “Websites”, we mean any of our websites, and by “Apps”, we mean any of our web and mobile applications that reference or link to this policy.

If we refer to “Services”, we mean our Websites, Apps, softwares, services, and products.

This Privacy Policy, as well as our cookie policy, are incorporated into and are subject to our Terms of Service (“Terms of Service”) all of which, together, are referred to as our Terms.
By using our Websites, Apps, and/or our Services you confirm that you acknowledge, understand, and accept the terms of this Privacy Policy.

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.

Data controller
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
1228 Plan-les-Ouates
Switzerland

How we collect Personal Data
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”):

Personal information which you provide voluntarily
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, and iTunes.
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.

Information collected automatically
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.

Cookies: Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, customize your experience and preferences, allowing you to access and use our Services without re-entering your username and/or password, to understand which areas and features of our Services are most popular and count visits. For additional information about cookies, please read our Cookie Policy, which forms part of this Privacy Policy.

Why do we process Personal Data
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:

  • Performance of our Services: In particular, this includes maintenance of our customer database, management of customer accounts, invoicing, verification of your details, provision, and performance of Services, and operation of our technical infrastructure.
  • Websites and applications maintenance: To manage our Websites and Apps. This includes identifying any issues or implementing improvements and letting you know about any changes to our Websites or Apps.
  • Customer support: In particular, to respond to your inquiries and requests in various ways (including email, telephone, text message, or social media); this includes responses to questions and concerns, provision of requested demos, provision of technical support, and general customer support tasks (such as maintaining and updating your contact information, conducting feedback surveys), to provide, improve, protect, and promote our Services.
  • Service quality and data security: In particular, this includes planning and control of server and network capacities, technical fault diagnosis, troubleshooting, and security audits. This also includes the evaluation, improvement, and development of new products, Services, functions, and customer interfaces, quality control and improvement of customer support, analysis and assessment of the use of our Websites and Apps to make them more user-friendly, statistical analysis of customer behavior to understand how you use our Services.
  • Security: This involves the prevention of breaches including preventions and investigations or fraud monitoring.
  • Management of our finances: This includes sales, corporate audits, and supplier management.
  • Marketing: We may send you newsletters by email and/or mobile app push notifications, for example regarding new product features and releases, where you have provided us your contact details in the context of a sale of our Services. We ensure that you will only receive such newsletters regarding our own Services, and you may unsubscribe at any time using the unsubscribe link in the emails. Your refusal to provide your Personal Data for marketing purposes will not have any impact on the entering into or performance of the contract. We do not use your mobile phone number to send commercial or marketing messages nor do we sell your Personal Data for any purpose.
  • Compliance with legal requirements: In particular, this includes compliance with the applicable laws and provisions, response to requests by the competent courts and authorities, and the assertion, exercise, or defense of legal claims.

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.

Legal grounds for processing
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.

Information that we do not collect
We do not collect emails, addresses, or other contact information from our Users’ mobile address book or contact lists.

Transfer of Personal Data to third parties
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:

  • Payment processors engaged by us to securely handle payments that are industry-leading and PCI-compliant.
  • Providers of security and fraud prevention services who we use to identify automated software agents that might disrupt our services or to prevent misuse of our APIs.
  • Other service providers who perform services on our behalf for example email delivery, hosting services, customer relationship management, communication, and collaboration tools.

In the event of a merger, sale, or bankruptcy
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.

Third-party advertisements
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.

Social Media and Third-party Websites
Our Websites contain links that direct you to our dedicated pages on social networks such as LinkedIn, Facebook, and Twitter, in order to connect you with the content displayed on these social media platforms.

If you interact with our Websites or social media pages, for example by clicking on the “Like” or “Share” icon, this information will also be transmitted directly to the social media service provider’s server and be stored there.

We encourage you to read the privacy policy of the relevant social media platform or website for information regarding the purpose and scope of the collection of your personal data by the relevant service provider, the further processing and use of such personal data by the relevant service provider, as well as the related rights and settings to enable the protection of your personal data.

International transfers of Personal Data
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, and iTunes 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.

Duration of Personal Data retention and storage
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.

Your rights regarding your Personal Data
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:

Access
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.

Correction
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.

Erasure
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.

Restricted processing
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.

Data portability
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.

Right to object
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.

Withdrawal of consent
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.

Our commitment to children’s privacy
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.

Protection of your Personal Data and data breach
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.

Data disclosure
As mentioned above, we may use your Personal Data if we think it is necessary for security purposes, to investigate possible fraud or other violations of this Privacy Policy and/or attempts to harm other users of our Websites, Apps, and/or Services. Hence, we may use your Personal Data to investigate, respond to and resolve complaints and issues relating to our Websites, Apps, and/or Services.

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.

Categories of personal information we collect

Category

Collected in the past 12 months

Identifiers:
E.g. name, address, unique personal identifier (UID), Internet Protocol address, email address, cookie information or other similar identifiers

YES

Personal Information categories listed in the California Customer Records statute Cal. Civ. Code § 1798.80(e)
E.g. Name, address, or telephone number

YES

Protected classification characteristics under California or federal law
E.g. date of birth, gender

YES

Commercial information
E.g. products or services purchased, purchase history, transaction information, financial details, payment information

YES

Biometric information
E.g. fingerprints

NO

Internet or other similar network activity
E.g. information on your interaction with a website or application

YES

Geolocation data
E.g. your device location data

YES

Audio, electronic, visual, thermal, olfactory, or similar information
E.g. Images

YES

Professional or employment-related information
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

YES

Educational information
E.g. student information

NO

Inferences drawn from other personal information
E.g. a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes)

NO


Your rights under the CCPA
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.

Notice concerning Do Not Track
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.

EU Representative
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

Contact
If you have any questions or concerns, you can contact us as follows:

By visiting the following website: alohi.com/gdpr-eu-rep

Or

By using the contact form at Contact Us

Data protection officer
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: [email protected]

Changes and updates to this privacy notice
This Privacy Policy may be revised periodically, without prior notification, and this will be reflected by the “date last modified” below. You shall be notified of any change to the Privacy Policy through a notice on the Website home page. Your continued use of our Websites, Apps, and Service constitutes your agreement to this Privacy Policy and any amendments. If you do not agree to the new terms, please do not use the Websites, Apps, and/or Services, or our dedicated pages on social media.

Date Last Modified:
This Privacy Policy was last modified on December 21, 2021