If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 4.
From time to time, we may develop new services. If the introduction of these new services results in any modification to the way we collect or process your Personal Information, we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
1. The Basics
A. About Hello Alice
Hello Alice is an online resource platform operated by Circular Board LLC, a company headquartered in the State of Texas in the United States (“we,” “us,” “our,” and “Hello Alice”).
Our Platform enables our owners (“users”,”owners”) to, among other things, register and interact with personalized workshops, learning modules, and communities. We also provide other related products to help our owners track and personalize their activities.
B. Key Terms
“Owner” means any person or entity that is registered with us to use the Service.
“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
“Visitor” means, depending on the context, any person who visits any of our Hello Alice Sites, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.
“you” and “your” means, depending on the context, either a Owner or a Visitor.
2. Privacy for Business Owners
This section applies to the Personal Information we collect and process from Owners or potential Owners through the provision of the Service. If you are not an Owner, the Visitors section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Owners and potential Owners.
A. What Information Do We Collect?
The Personal Information that we collect depends on the context of your interactions with Hello Alice, your Hello Alice owner and business profiles, your Hello Alice settings, the product features you use, your business status, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up for a Hello Alice account and use the Service, consult with our customer service team, send us an email, make a purchase, or communicate with us in any other way.
This information may include:
- Business owner contact information (name, job title, organization, location, phone number, email address, and country);
- Marketing information (such as your profile preferences);
- Account log-in credentials (such as your email address and password when you sign up for an account with us);
- Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support questions we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
- Payment information (including your credit card numbers and associated identifiers and billing address).
Service Usage Data may include:
- Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, viewfinder size, and other information about your system and connection.
- Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
- Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used, session duration, links clicked, non-sensitive text entered, and mouse movements). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service.
(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant recommendations, resources and content to you and to develop and provide you with more relevant features.
B. What Do We Use Personal Information For?
We may use the Personal Information we collect or receive about you in reliance on our (and where applicable, our Owners) legitimate interests for the following purposes:
- To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include improving the navigation and content of the Service and sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to Section 5 below.
- To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features. This includes adding features that compare Members’ email campaigns, using data to suggest other publishers your Contacts may be interested in, or using data to recommend products or services that you may be interested in or that may be relevant to you or your Contacts. Some of these suggestions are generated through analysis of the data used in our data analytics projects, as described below.
- To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Members. Our data analytics projects use data from Hello Alice accounts, including Personal Information of Contacts, to provide and improve the Service. We use information like your sending habits and purchase history, so we can make more informed predictions, decisions, and products for our Members. For example, we use data from Hello Alice accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Members. If you or your Contact prefers not to have their data used for this purpose, you can alter the settings on your account (as described here) to opt out of data analytics projects, or your Contact can opt out of data analytics projects at any time by visiting this page or emailing us at [email protected] As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.
- To combine and anonymize data about our Members and our Member’s use of the Service in order to create aggregate, anonymized statistics which we may use to provide certain features within the Service and for promoting and improving the Service in reliance on our legitimate interests.
C. Cookies and Tracking Technologies
We and our third-party partners may use various technologies to automatically collect and store certain device and usage information (as discussed above) when you interact with Hello Alice, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. Web beacons allow us to collect information such as your IP address, browser, email client type, and other similar data as further described above. We use this information to measure the performance of our platform and to provide analytics information and enhance the effectiveness of our Service, and for the other purposes described above.
D. Your Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information.
- You can manage your individual account and profile settings within the dashboard provided through the Hello Alice platform, or you may contact us directly by emailing us at [email protected] Hello Alice takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.
- The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.
- Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
3. Privacy for Visitors
This section applies to Personal Information that we collect and process when you visit the Hello Alice Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section, “you” and “your” refer to Visitors.
A. What Information Do We Collect?
(i) Information you provide to us on the Hello Alice Sites or otherwise: Our Hello Alice Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Service. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Services, take part in surveys, subscribe to marketing, apply for a role with Hello Alice, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, or via a phone call with one of our employees. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.
The Personal Information we collect may include:
- Business contact information (such as your name, phone number, email address and country);
- Professional information (such as your job title, institution or company);
- Nature of your communication;
- Marketing information (such as your contact preferences); and
- Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.
The information we collect automatically includes:
- Device information: such as your IP address, your browser, operating system, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited, the web browser you used (software used to browse the internet) including its type and language), and viewfinder size and scripts errors.
- Usage data: such as information about how you interact with our emails, Hello Alice Sites, and other websites (such as the pages and files viewed, session duration, links clicked, searches, non-sensitive text entered, mouse movements, operating system and system configuration information and date/time stamps associated with your usage).
B. Use of Personal Information
We may use the information we collect through our Hello Alice Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:
- To provide, operate, optimize, and maintain the Hello Alice Sites.
- To send you marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
- For recruitment purposes if you have applied for a role with Hello Alice.
- To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
- To manage the Hello Alice Sites and system administration and security.
- To manage event registrations and attendance, including sending related communications to you.
- To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
- To improve the navigation and content of the Hello Alice Sites.
- To identify any server problems or other IT or network issues.
- To process transactions and to set up online accounts.
- To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
- To help us provide, improve and personalize our marketing activities.
- To facilitate the security and continued proper functioning of the Hello Alice Sites.
- To carry out research and development to improve our Hello Alice Sites, products and services.
- To conduct marketing research, advertise to you, provide personalized information about us on and off our Hello Alice Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
- To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
- To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Hello Alice Sites and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
C. Public Information & Third-Party Websites
- Blog. We have public blogs on the Hello Alice Sites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at [email protected] If we are unable to remove your information, we will tell you why.
- Social media platforms and widgets. The Hello Alice Sites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Hello Alice Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Hello Alice Site. We also maintain presences on social media platforms, including Facebook, Twitter, Instagram, Linkedin and Clubhouse. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
D. Cookies & Tracking Technology
E. Other Data Protection Rights
Depending on the country in which you reside, you may have the following data protection rights:
- To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by visiting this page or by emailing [email protected]
- You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
- Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences.
4. General Information
A. How We Share Information
Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.
In connection with our Service, we use a third-party service provider, Segment, Inc. We use Segment’s API, which allows us to build features into our Hello Alice application to enable us to govern our customers data. If you are a Member, Segment may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Segment’s privacy practices, please visit https://segment.com/legal/privacy/
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(v) Any other person with your consent.
We may also share anonymized, aggregated information with selected third parties for statistical purposes.
B. Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the “Questions and Concerns” section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your Hello Alice account.
C. Our Security
We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page available here. If you have any questions about the security of your Personal Information, you may contact us at [email protected]
Hello Alice accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s Hello Alice account is private, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.
D. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Service.
- Whether our Members have the ability to access and delete the data within their Hello Alice accounts.
- Whether our Members would reasonably expect that we would retain the data until they remove it or until their Hello Alice accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
E. California Privacy
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Members, Hello Alice acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Members in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Member with whom you have a direct relationship.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
F. Do Not Track
G. Changes To This Policy
H. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send an email to [email protected]. You may also contact us by postal mail at:
Circular Board LLC d/b/a Hello Alice
Attn. Privacy Officer
1275 4th Street #176
Santa Rosa, CA. 95404