Updated: July 12, 2022
Introduction and Overview
Hello Alice leverages technology responsibly to provide the best experience for small business owners. To do this, we need to understand your usage habits and activities to make the best possible recommendations to help your business grow. We view privacy as a critical part of the value that we deliver to our customers. The Hello Alice Trust & Compliance principles describe Hello Alice’s values regarding our processes for managing the data our customers entrust to us.
Scope of this Privacy Statement
Hello Alice is an online resource platform operated by Circular Board LLC, a company headquartered in the State of California in the United States (“we,” “us,” “our,” and “Hello Alice”). As a financial services and technology company, we provide this Privacy Statement (which we’ll refer to as “Privacy Statement”) to explain how we and our related sites and applications (collectively our “Platform”) collect, use, share or otherwise process information when you interact with us and our offerings, services and experiences including accelerator workshops and modules, videos, graphics, educational documents, exercises, including various reference and communications tools, forums, products, and personalized content (our “Services”), or when businesses provide us with your information. From time to time, we may develop new Services. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Privacy Statement. This Privacy Statement applies to all Hello Alice websites, applications, and offerings.
Hello Alice determines the purposes and means of the processing of personal information, as described in this Privacy Statement, and therefore acts as ‘data controller’ (or equivalent/similar terms) for purposes recognized by certain data privacy laws. We may share your personal information with partner companies, and conduct processing activities as controllers or joint controllers for the purposes set out in this Privacy Statement.
In certain circumstances, there may be more than one data controller processing your information. For example, a grant program partner may also act as a data controller. In these situations, we act as an independent data controller over our processing activities – meaning that we make determinations over how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable information privacy laws. Hello Alice is not responsible for the processing of other data controllers and you should contact them directly for questions on how they process your personal information and for exercising your privacy rights in relation to such processing.
Your Acceptance of this Privacy Statement
By using our Platform or Services and submitting information you agree that we may use and disclose your information according to the terms of this Privacy Statement. 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.
“Owner” means any person or entity that is registered with us to use the Service.
“Personal Information” means any information that describes, relates to, 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. It also includes information about you that you submit to the Platform, transaction information relating to you and information about you that we receive from third parties.
“Platform” The Hello Alice Platform consists of all of the websites and applications through which Hello Alice offers its Services and encompasses the Hello Alice registered accounts, loyalty program, credit card, and marketplace. Information collected through the Hello Alice Services is maintained by us in the Platform.
“Services” means the offerings, services and experiences made available by Hello Alice through the Platform.
“Visitor” means, depending on the context, any person who visits our Platform, 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 an Owner or a Visitor.
Information We Collect
This section applies to the Personal Information we collect and process through the provision of the Services. The personal information that we receive about you depends on the context of your interactions with Hello Alice, how you configure your account and the choices that you make, including your privacy settings. Personal information that we receive from you may also depend upon what services, functionalities or experiences you use, your location and applicable law.
When you elect to use one or more of our Services and choose to share Personal Information with us, or bring over Personal information from third parties (such as a bank or loan provider), we centralize all your Personal Information in the Platform. This includes Personal Information such as your credentials; your name and contact details; payment information; information about your activities, behavior, your interests and preferences (including purchase history with Hello Alice); insights about your finances, business or preferences; the content you enter about you in our Platform; and information we have collected about you from third-party sources as more fully described below.
Information You Provide To Us
- Creating an account. We collect Personal Information when you create an account, interact with the Hello Alice Platform or activate a credit card. Personal information may include your name, job title, organization, location, phone number, email address, profile photo, billing information (your payment information), usernames and credentials.
- Identification information. We collect Personal Information to verify your identity, including your name, social security number, social insurance number, driver’s license numbers, government-issued identification details, for example to verify your identity in order to distribute grant funds or process a credit card application.
- Customer support, product research, training and feedback. We may collect Personal Information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, subscribe to marketing, attend our events, participate in product research or training or otherwise interact or communicate with us.
- Social and community content. We receive content you post on our social media pages.
- Business and financial information. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information.
- Third-party service content. We receive information about you when you sign into a third-party service with your account or when you connect your account to a third-party service. For example, you may choose to connect your account with your bank accounts or social media platforms. To sync your financial account information, we must access your financial account information.
- Expert advice. The Hello Alice Platform provides opportunities for you to connect with live experts, including, for example, mentors or workshop facilitators. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts and the guidance provided to you.
- Required information. Some services and experiences in the Hello Alice Platform require you to provide information for it to function. If you do not wish to provide the required information, you may not be able to use certain features.
Information We Collect Automatically
- Location information. Certain features in the Hello Alice Platform may collect your precise location information, device motion information, or both, if you grant permission to do so in your device settings. For example, if you use our time-tracking service.
- 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 or Platform, which may include the dates and times you access the Platform, your browsing activities (such as what portions of the Service you used, session duration, links clicked, non-sensitive text entered, and mouse movements), and details about any communications with which you interact. 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.
- Online behavioral data. We may automatically collect certain information about your use and interactions with our Platform, partners’ websites or e-commerce stores, social media websites, and marketing campaigns that we or our partners organize, including device information (such as your IP address and unique device IDs), page view information and search results, links and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.
Information We Collect From Third Parties
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.
- Employment and Staffing Services. If you choose to submit an application for employment through the Platform you will be redirected to our third party staffing services provider. Your information is submitted directly to this service provider who shares it with us.
- Your service providers. If you choose to sync a non-Hello Alice account/service with your account, we will receive information from that account/service according to your settings with that account/service. For example, if you connect a point of sale application to your account, we may receive details of your business’s sales records.
- Supplemental information and identity verification providers. Service providers who help us verify your identity, the specifics of your business and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third-party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider or email provider.
- Customer Support providers. Service providers who provide us with information about you or your interaction with the Hello Alice Platform for troubleshooting purposes. For example, we may obtain support information or technical issues you have raised with these third parties.
- Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your personal information.
- Communication providers & social networks. We or our third party service providers may collect information from email providers, communication providers and social networks, including to monitor public discussion about our brands. Where we are legally required, we ask for your permission to collect this information.
- Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our credit card, grant program, conferences or live events.
- Publicly-available and third-party sources. We collect information from publicly available and other third-party sources, such as open government databases.
Cookies and Tracking Technologies
We may use various commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to automatically collect and store certain device and usage information (as discussed above) when you interact with Hello Alice so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experience. 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.
We may allow selected third parties to place cookies through the Platform to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Platform to perform analytic or marketing functions. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.
How We Use Your Information
We use the collected information for our general commercial purposes such as to improve our Platform and Services, to grow our business and to offer our own or third-party products or services that we think you may find of interest.
We may process Personal Information where you have given your informed consent to such processing, for example where you have signed up to one of our mailing lists or to respond to your inquiries. Where you have provided your consent for our processing of Personal Information, such consent may be withdrawn at any time.
Where your consent is not mandatory, we may process Personal Information on the following lawful bases:
- We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefits of the Hello Alice Platform and operate our business;
- The processing is in our legitimate business interests (in those jurisdictions where legitimate business interest is a legitimate basis for processing) such as operating our businesses, improving and developing the Hello Alice Platform, communicating with you, marketing our offerings and services and personalizing your experience, and to detect illegal activities; or
- We need to comply with legal requirements, including applicable laws and regulations.
We may use the Personal Information we collect or receive about you in reliance on our legitimate interests for the following purposes:
- To exchange funds, either for distribution of funds (e.g. grants) or to collect money owed to us by you for services delivered. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
- To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service.
- Evaluate your eligibility for financial or other marketing offers, products and services
- To execute and customize our credit card and loyalty programs
- Provide features to you, such as your free credit reports and scores
- Connect you with experts and other users
- Communicate with you, such as sending you electronic notifications concerning your financial privacy
- Provide you with support and resolve disputes
- Authenticate your identity, including through the use of Biometric Data
- Manage event registrations and attendance, including sending related communications to you
- Processing transactions and or payments, such processing payments or transactions, fulfilling orders, and conducting settlement, billing, processing, clearing, or reconciliation activities.
- 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.
- 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 Owners. Our data analytics projects use data from Hello Alice accounts, including Personal Information, to provide and improve the Service. We use information like your spending habits and purchase history, so we can make more informed predictions, decisions, and products for our Owners. For example, we use data from Hello Alice accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Owners.
- 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.
- To personalize the Service, content and advertisements we serve to you in reliance on our legitimate interests in supporting our marketing activities and providing certain features within the Service. We may use your Personal Information to deliver marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, where your consent is not required or in accordance with your marketing preferences.
We will process Personal Information for the following purposes as necessary for our compliance with legal obligations to which we are subject, including:
- Preventing or detecting fraud; and
- Ensuring compliance with any applicable laws, regulations, codes and ordinances, for example, in response to a binding request from a court or regulatory body, where such request is made in accordance with the law.
How We Share Your Information
We may share and disclose your Personal Information with our subsidiaries or Affiliates and to the following types of third parties for the purposes described in this Privacy Statement.
- Our service providers or agents: Sometimes, we share your information with our third-party service providers or agents working on our behalf for the purposes described in this Privacy Statement. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions such as advertising, marketing and sales efforts. 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 an Owner, 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/.
- When you connect with a Hello Alice Platform partner. You may be provided with offers, products, and services from third-party companies who integrate through our Marketplace, credit card or loyalty program (“Platform Partner”). If you choose to interact with a Platform Partner, apply for their services or offerings or otherwise link or sync your account to a Platform Partner’s product or service, you consent and direct Hello Alice to share your information, including personal information, to the Platform Partner providing the service or offering. For example, when we send your personal information to partners in order to process credit card applications, when we send your application information directly to our partners, or when we send you to the partner’s site for you to provide the information directly to them. In some cases, if you click through to go to a Platform Partner’s site, you will automatically be sending your personal information to that Platform Partner. When this happens, you will still have to submit your application on the Platform Partner’s site. Remember that any information you provide to a Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
- For research. With appropriate controls, we may share information with third-parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that would not allow any individual to be identified.
- For joint features, sales, promotions and events. We may share your information with third-parties companies who are jointly providing features, sales initiatives, promotions or events with us.
- With financial services providers. In connection with our financial products, we may share personal information with banks, credit bureaus and loan services providers, and payment card association members. We may also share your personal information with other companies, lawyers, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.
- When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.
- For legal reasons. We may share your information with third-parties for legal reasons without your consent, and as permitted by law, including:
- When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process
- To protect the rights, property, or safety of the Hello Alice Platform, our credit card, loyalty program, our customers or others
- To protect or defend against attacks
- To enforce, remedy, or apply our Terms of Service or other agreements
- To prevent fraud, cybersecurity attacks or illegal activity
- With regulatory agencies, including government tax agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or the Hello Alice Platform, or in required institutional risk control programs.
- For corporate transactions. We may share your information with third parties and their agents or professional advisors in the case of a sale, merger, consolidation, liquidation, reorganization, financing, or acquisition. In that event, the recipient will be subject to our obligations under this Privacy Statement, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Hello Alice Site.
We may also share anonymized, aggregated information with selected third parties for statistical or other purposes.
No sale of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third parties for the business purposes described in this Privacy Statement.
Accessing Your Information & Choices
At Hello Alice, we believe that you have the right to access information that pertains to you, and your business. If another person has input or processed information in the Hello Alice Platform about you or on behalf of you, or your business (and we are processing such information as data controller), you may ask to receive a copy of such information by contacting us at [email protected].
If you are an Owner you may manage your individual account, update, amend, correct or delete information and manage your profile settings within the dashboard provided through the Hello Alice platform, or you may contact us directly by emailing us at [email protected].
You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us. 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.
You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Platform may be impaired and certain features may not function at all.
If you prefer not to have their data used for data analytics purpose, you can opt out of data analytics projects at any time by emailing us at [email protected].
If you provided consent for us to collect or process Personal Information, 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.
To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights (e.g. during grant or credit application). If we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.
Unless you specifically ask us to delete your personal information or business information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the Hello Alice Platform and successfully run our business. However, even if you request a deletion, we may be required to maintain your information for as long as necessary to:
- comply with our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us);
- to exercise, establish or defend legal claims; and/or
- to protect against fraudulent or abusive activity on our service.
This means we may keep different information for different periods. If your account is canceled because you’ve not used it in a long time, we may delete this information immediately.
There may be occasions where we are unable to fully delete, anonymize, or de-identify your information due to technical, legal, regulatory compliance or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.
Your California Privacy Rights. California residents with an established business relationship with us are permitted by California law once a year to request information about the manner in which we shared certain categories of information with others for their marketing purposes during the prior calendar year. We do not share your personal information with third parties for their direct marketing use unless we have your permission.
California Consumer Privacy Act (“CCPA”) Notice. At this time Hello Alice is not required to comply with the CCPA. We will update this Privacy Statement when we qualify for coverage under the CCPA.
When offering services to its Owners, 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 Owners 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 Owner with whom you have a direct relationship.
We do not transfer Personal Information for monetary consideration. If you would like to tell us not to sell your information in the future please email us at [email protected] with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.
Data Processing and Cross-Border Data Transfers
Our Platform is maintained on servers located in the United States, and Personal Information submitted is stored on our servers in the United States. If you are visiting our Platform from outside the United States, please be advised that your information is transferred to our U.S. servers. Disclosing your personal information to us pursuant to this Privacy Statement is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Statement are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information.
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. Owners must keep their username and password secure, and never disclose it to a third party. Because the information in an Owner’s Hello Alice account is private, account passwords are hashed, which means we cannot see an Owner’s password. We cannot resend forgotten passwords either. We will only provide Owners with instructions on how to reset them.
While we strive to protect your information, no method of data transmission or storage is 100% secure, and we cannot ensure or warrant the security of your information.
- If you suspect a website or mobile app is pretending to be from Hello Alice(also known as “spoofing”), do not enter personal information. Instead, please make an inquiry through customer support. You can also email us at [email protected].
- If you receive an email that claims to be from us, but you are not sure or think it is suspicious, do not click on any of the links in the email. Instead, forward it to us at [email protected] and delete it.
- If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at [email protected].
The Hello Alice Platform is not designed nor intended to be attractive to use by children under the age of 13. We do not knowingly collect information from children under the age of 13. If you are under 13 please do not submit any information to us.
Changes To This Privacy Statement
We may change this Privacy Statement at any time and from time to time. The most recent version of the Privacy Statement is reflected by the version date located at the top of this Privacy Statement. All updates and amendments are effective immediately; we will endeavor to provide notice of material changes by any means, including, but not limited to, by posting a revised version of this Privacy Statement with an updated effective date or by other notice on the Hello Alice Sites. We encourage you to review this Privacy Statement often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this Privacy Statement are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Statement that was in effect on each respective date you visited the Hello Alice Site.
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. Compliance and Information Security Officer
1275 4th Street #176
Santa Rosa, CA. 95404