Privacy Policy
Version: February 10, 2023
Alyce ("we," "us," "our," and "Alyce") is the gifting platform to empower our business Customer’s sales personnel and marketers to start and foster quality conversations and interactions with their customers and prospective customers.
This privacy policy (“Privacy Policy”) explains how we collect, use, transfer, and store Personal Information. If you have questions, we ask and urge you to reach out to us at any time by email: privacy@alyce.com.
TABLE OF CONTENTS
I. Definitions
II. If You Are An Alyce Website Visitor
II.A. Information We Collect About Alyce Website Visitors
II.B. Use of Personal Information Collected About Alyce Website Visitors
II.C. Cookies and Tracking Technologies Used With Alyce Website Visitors
III. If You Are A Gift Recipient
III.A. Information We Collect About Gift Recipients
III.B. Use of Personal Information Collected About Gift Recipients
III.C. Cookies and Tracking Technologies Used With Gift Recipients
IV. If You Are An Alyce Customer Using The Subscription Service
IV.A. Information We Collect About Our Customers
IV.B. Use of Personal Information Collected About Our Customers
IV.C. Cookies and Tracking Technologies Used With Our Customers
V. How and Why We Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors
VI. Public Information and Third-Party Websites
VII. Additional Information For Non-US Customers, Gift Recipients, And Alyce Website Visitors
VII.A. International Transfers
VII.B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
VII.C. Your Choices and Opt-Outs
VIII. Additional Information For California Residents
VIII.A. CCPA Rights
VIII.B. Notice of Right to Opt-Out of the Sale of Personal Information Under the CCPA
VIII.C. Exercising Your CCPA Rights
VIII.D. Other California Privacy Rights
IX. Additional Information For Everyone
IX.A. Data Protection Rights Generally
IX.B. Data Security
IX.C. Data Retention
IX.D. Do Not Track
IX.E. Information from Children Under 13 Years Of Age
IX.F. Changes to this Policy
IX.G. Questions and Concerns
I. Definitions
In this privacy policy, these terms have the following meanings:
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- "Gift Recipient" is a person that Alyce’s Customer may contact through our Subscription Service to deliver a gift invitation.
- "Customer" means any person or entity that is party either to Alyce’s Subscription Agreement as available on the Alyce Site(s) or another contract(s) with Alyce and includes that person’s or entity’s authorized Alyce users.
- "Personal Information" generally means any information that identifies or can be used to identify a specific individual. Examples of Personal Information may include, but are not limited to, combinations of first and last name, date of birth, email address, gender, job title, or other identifiable demographic information. This may include data of a Gift Recipient, Customer, their prospects, or Site Visitors.
- “Subscription Service” has the meaning given to it in our Subscription Agreement, as available on Alyce Site(s).
- "Alyce Site(s)" means www.alyce.com and all subpages.
- "Visitor" means any person who visits any of our Alyce Sites or otherwise engages with us at our events or in connection with our marketing or recruitment activities but does not include a person who is a Gift Recipient or a person who otherwise enters the Alyce Sites via gift invitation code or link.Other Capitalized terms not defined herein have the meaning set forth in Alyce’s Subscription Agreement as available on Alyce Site(s).
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II. If You Are An Alyce Website Visitor
This section applies to Personal Information that we collect and process when you visit the Alyce Sites, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices.
II.A. Information We Collect About Alyce Website Visitors: We may collect or receive the following information from Visitors or from third-party service providers.
(i) Information Visitors provide to us on the Alyce Sites or otherwise: Our Alyce Sites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and Subscription Service. For example, we may ask Visitors to provide certain Personal Information when they express an interest in obtaining information about us or our Subscription Service, take part in surveys, subscribe to marketing, apply for a role with Alyce, or otherwise contact us. We may also collect Personal Information from Visitors in person when they attend our events or trade shows, visit our offices (where Visitors will be required to register as a visitor and provide us with certain information that may also be shared with our service providers) or via a phone call with one of our sales representatives. Visitors may choose to provide additional information when communicating with us or otherwise interacting with us, and we may keep copies of any such communications for our records.
The Personal Information we collect about Visitors may include:
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- Business contact information (such as name, phone number, email address and country);
- Professional information (such as job title, institution or company); Device information;
- Marketing information (such as contact preferences); and
- Any other information Visitors choose to provide to us when completing any ‘free text’ boxes in our forms.
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(ii) Information we collect automatically through the Alyce Sites: When Visitors visit our Alyce Sites or interact with our emails, we use cookies and similar technologies such as pixels or web beacons, alone or in conjunction with cookies, to collect certain information automatically from the Visitor’s browser or device. In some countries, including countries in the EEA, this information may be considered Personal Information under applicable data protection laws. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement available here.
The information we collect automatically includes:
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- Device information: such as IP address, browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which the Visitor linked to us (“referring page”), the name of the website the Visitor chose to visit immediately after ours (called “exit page”), information about other websites the Visitor has recently visited and the web browser used (software used to browse the internet) including its type and language)
- Usage data: such as information about how Visitors interact with our emails, Alyce Sites, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with Visitors’ usage).
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II.B. Use of Personal Information Collected About Alyce Website Visitors
We may use the Visitor information we collect through our Alyce Sites and in connection with our events and marketing activities (alone or in combination with other data we collect from third-party service providers) for a range of purposes, including:
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- To respond to Visitors’ inquiries and requests, and to provide information and access to resources or services that Visitors request from us.
- To process transactions and to set up accounts.
- To manage event registrations and attendance, including sending related communications to Visitors.
- To register Visitors to our offices, including for security reasons, and to manage non-disclosure agreements that Visitors may be required to sign.
- For recruitment purposes if Visitors have inquired about or applied for a position with Alyce.
- To send Visitors marketing information, product recommendations and non-transactional communications about us, in accordance with their marketing preferences, including information about our products, services, promotions or events.
- To provide, operate, optimize, and maintain the Alyce Sites and Subscription Services, including to administer the Alyce Sites, Subscription Services, and systems and security.
- To improve the navigation and content of the Alyce Sites.
- 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 Alyce Sites.
- To carry out research and development to improve our Alyce Sites, products and services.
- To conduct marketing research, advertise to Visitors, provide personalized information about us on and off our Alyce Sites, and to provide other personalized content based on Visitors’ activities and interests.
- 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.
- 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 protect against misuse or abuse of our Alyce Sites and Subscription 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.
- To comply with applicable law and for fraud prevention and monitoring.
- To meet or address legal requirements, including compliance with applicable laws, court orders, valid discovery requests, valid subpoenas, and other applicable legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding, and for the establishment, exercise, or defense of legal claims. To comply with valid legal process.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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II.C. Cookies and Tracking Technologies Used With Alyce Website Visitors
We use cookies and similar tracking technologies to collect and use Personal Information about Visitors, including to serve interest-based advertising. For further information about the types of cookies and tracking technologies we use, why, and how to control them, please see our Cookie Statement available here.
To the extent that these tracking technologies are considered a “sale” under the CCPA’s broad definition of the term, you have the right to opt-out of these tracking technologies. More information on opting out is in Section VIII.D, “Notice of Right to Opt-Out of the Sale of Personal Information Under the CCPA”.
Section V, “How and Why we Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors,” contains additional information about how and why we may share your information. Sections VI, “Public Information and Third-Party Websites,” VII, “Additional Information For Non-US Customers, Gift Recipients, And Alyce Website Visitors,” VIII, “Additional Information For California Residents,” and IX, “Additional Information For Everyone,” contain other information that may be relevant to you.
III. If You Are A Gift Recipient
Our Subscription Service is intended for use by Alyce’s Customers. As a result, for the Personal Information we collect from our Customers pursuant to the Subscription Agreement, we act as a processor on behalf of our Customers. Alyce is not responsible for our Customers’ privacy or security practices, which may differ from those set forth in this privacy policy. Please check with individual Customers about their respective policies or public privacy statements governing that Customer’s processing and protection of Personal Information.
Alyce acts as a data controller with respect to the information Gift Recipients provide directly to Alyce or that Alyce collects in connection with Gift Recipients’ access to and use of the Alyce Sites.
Please see Section II, “If You Are An Alyce Website Visitor,” for additional information about how we may collect Personal Information when you visit the Alyce Sites and how we may use that Personal Information.
III.A. Information We Collect About Gift Recipients
We collect or receive Gift Recipient information directly from Gift Recipients, from our Customers, or from third-party service providers. The Personal Information that we collect or receive about Gift Recipients broadly falls into the following categories:
(i) Information we receive about Gift Recipients from our Customers: A Customer may provide Personal Information about Gift Recipients to us through the Subscription Service. When a Customer uploads contact information or integrates the Subscription Service with another website or service (or when a Gift Recipient signs up for a Customer’s distribution or marketing list), the Customer may provide us with certain contact information or other Personal Information about the Gift Recipient, such as name, email address, work address, and work title. We process information we receive from our Customer as a processor for our Customer, and how we collect, use, or share this information is subject to, and governed by, the Customer’s publicly available privacy statement.
(ii) Information we collect from Gift Recipients directly: We collect certain Personal Information when Gift Recipients interact directly with Alyce or the Alyce Sites. For example, when you use a gift invitation code or link to enter into the Alyce marketplace, we collect information, such as the Gift Recipient’s name, address, email address, gift details, marketplace interactions, and meeting booking information. We may also collect information when Gift Recipients submit inquiries, request to receive information from us, or otherwise communicate with Alyce. How we collect, use, and share information we collect directly from Gift Recipients is described in Section III.B, “Use of Personal Information Collected About Gift Recipients” and in Section V, “How and Why We Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors”.
(iii) Information we collect automatically: When the Gift Recipient interacts with an email campaign received from a Customer using the Subscription Service, we may collect information about the Gift Recipient’s device and interaction with the email in connection with the Subscription Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below and in more detail in our Cookie Statement available here. How we collect, use, and share information we collect automatically is described here, in Section III.B, "Use Personal Information Collected About Gift Recipients”, and in Section V, “How and Why We Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors”.
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- Device information: We may collect information about the device and applications a Gift Recipient uses to access emails sent through our Subscription Service, such as their IP address and device data.
- Usage data: It is important for us to take steps to ensure the security and reliability of the Subscription Service we provide. Therefore, we also may collect usage data about Gift Recipients’ interactions with campaigns (and/or emails) sent through the Subscription Service, which may include dates and times a Gift Recipient accessed campaigns (and/or emails) and Gift Recipient browsing activities (such as what pages are viewed and which emails are opened).
- We also may collect information regarding the performance of the Subscription Service, including metrics related to the deliverability of emails and other electronic communications that our Customers send through the Subscription Service. This information allows us to improve the content and operation of the Subscription Service and facilitate research and perform analysis into the use and performance of the Subscription Service.
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(iv) Information we collect from other sources: We may collect information about Gift Recipients from third-party data sources, such as social media platforms and third-party data providers. Information we collect about Gift Recipients from other sources includes, for example, information about personalized gifts to recommend for a Gift Recipient. How we collect, use, and share information we collect about Gift Recipients from other sources is described in Section III.B, “Use of Personal Information Collected About Gift Recipients” and in Section V, “How and Why We Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors”.
III.B. Use of Personal Information Collected About Gift Recipients
We may use the Personal Information we collect or receive about Gift Recipients, other than the Information we receive about Gift Recipients from our Customers, for the following purposes:
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- To respond to Gift Recipients’ online inquiries and requests, and to provide Gift Recipients with information and access to resources or services that they have requested from us.
- To manage event registrations and attendance, including sending related communications to Gift Recipients.
- To process transactions and to set up online accounts.
- To provide, support and improve the Subscription Service. For example, this may include sharing Gift Recipient information with third parties in order to provide and support our Subscription Service, including to provide Customers with personalized gift recommendations for Gift Recipients, or to make certain features of the Subscription Service available to our Customers. For further information about how we share information, refer here.
- To provide a Customer with Personal Information about the Gift Recipients to whom the Customer gave a gift or recommendations about a gift to offer to a Gift Recipient. For further information about how we share information, refer here.
- To facilitate the security and continued proper functioning of the Alyce Sites and Subscription Service.
- To provide, operate, optimize, and maintain the Alyce Sites and Subscription Service.
- To send Gift Recipients marketing information, product recommendations and non-transactional communications about us, in accordance with their marketing preferences, including information about our products, services, promotions or events.
- To manage the Alyce Sites, Subscription Service, and system administration and security.
- To improve the navigation and content of the Alyce Sites.
- To compile aggregated statistics about site usage and to better understand the preferences of our Gift Recipients.
- To perform data analytics. Our data analytics projects use data from Alyce accounts, including Personal Information, to provide and improve the Subscription Service. We use information, like Gift Recipients’ gift or donation history, marketplace interactions and interests derived therefrom, and meeting activity so we can make more informed predictions, decisions, and products for our Customers.
- To help us provide, improve and personalize our marketing activities.
- To carry out research and development to improve our Alyce Sites, products and services.
- To conduct marketing research, advertise to Gift Recipients, provide personalized information about us on and off our Alyce Sites, and to provide other personalized content based on Gift Recipients’ activities and interests.
- 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.
- 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 protect against misuse or abuse of our Alyce Sites and Subscription 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.
- To enforce compliance with applicable law and for fraud prevention and monitoring.
- To meet or address legal requirements, including compliance with applicable laws, court orders, valid discovery requests, valid subpoenas, and other applicable legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding, and for the establishment, exercise, or defense of legal claims.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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III.C. Cookies and Tracking Technologies Used With Gift Recipients
We and our third-party partners may use various technologies to automatically collect and store certain device and usage information (as discussed above) when Gift Recipients interact with a Customer’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Customers. When Gift Recipients receive and engage with a Customer’s campaign, web beacons track certain behavior such as whether the email sent through the Subscription Service was delivered and opened and whether links within the email were clicked. Web beacons allow us to collect information such as IP address, browser, email client type, and other similar data as further described above. We use this information to measure the performance of our Customers’ email campaigns, and to provide analytics information and enhance the effectiveness of our Subscription Service, and for the other purposes described above.
We also use cookies and similar tracking technologies to collect and use Personal Information, including to serve interest-based advertising.
To the extent that these tracking technologies are considered a “sale” under the CCPA’s broad definition of the term, you have the right to opt-out of these tracking technologies. More information on opting out is found in Section VIII.C, “Notice of Right to Opt-Out of the Sale of Personal Information.”
For further information about the types of cookies and tracking technologies we use, why, and how to control them, please see our Cookie Statement available here.
Section V, “How and Why we Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors,” contains additional information about how and why we may share your information. Sections VI, “Public Information and Third-Party Websites,” VII, “Additional Information For Non-US Customers, Gift Recipients, And Alyce Website Visitors,” VIII, “Additional Information For California Residents,” and IX, “Additional Information For Everyone,” contain other information that may be relevant to you.
IV. If You Are An Alyce Customer Using The Subscription Service
This section applies to Personal Information we collect about our Customers, including authorized Alyce users under a Subscription Agreement (or other similar master agreement) between Alyce and a Customer. Specifically, this section applies to a Customer’s use of the Subscription Service and addresses the Personal Information that Alyce collects about a Customer through the Customer’s use of their Alyce account and the Subscription Service.
Please see Section II, “If You Are An Alyce Website Visitor,” for additional information about how we may collect Personal Information when you visit the Alyce Sites and how we may use that Personal Information.
IV.A. Information We Collect About Our Customers
Through a Customer’s use of the Subscription Services, Customers may provide certain Personal Information to Alyce when provisioned with an Alyce account and the Customer uses the Subscription Service, consults with our customer success team, or sends us an email or communicates with us in any other way. We may collect or receive this information directly from the Customer or from third-party service providers with whom we contract. This information may include:
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- Business contact information (such as Customer’s name, job title, organization, location, email address, and country).
- Account log-in credentials (such Customer’s email address or username and password when Customer signs up for an account with Alyce Site(s)).
- Support data in connection with support queries we receive from the Customer.
- Device information: information about any device and applications the Customer uses to access the Subscription Service, such as IP address, operating system, browser ID, device ID, and other information about the Customer’s system and connection to Alyce Sites.
- Log data: We may collect and record data each time a device interacts with our web servers, including the nature of each access, originating IP address, and Customer activity in the Subscription Service (such as the date/time stamps associated with the Customer’s usage, pages and files viewed, searches and other actions taken (for example, features used), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also collect metadata and other information associated with files that a Customer uploads into our Subscription Service.
- Usage data: We may collect usage data whenever the Customer interacts with our Subscription Service, which may include the dates and times the Customer accesses the Subscription Service and the Customer’s browsing activities (such as what portions of the Subscription Service are used). We also collect information regarding the performance of the Subscription Service.
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IV.B. Use of Personal Information Collected About Our Customers
We may use the Personal Information that we collect or receive directly or indirectly from or for a Customer (alone or in combination with other data sourced from third-party service providers about Visitors, Gift Recipients, or otherwise) for the purposes identified below:
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- To provision gifts to Gift Recipients, to make donations, and to personalize the gifting experience.
- To bill and collect money owed to us by the Customer to perform our contract with the Customer for the use of the Subscription. This includes sending emails, invoices, receipts, notices of delinquency or account suspension.To communicate with the Customer about its account and provide customer support and to administer and support our Subscription Service.
- To enforce compliance with relevant master agreements, Order Forms, Statements of Work and applicable law.
- To meet or address legal requirements, including compliance with applicable laws, court orders, valid discovery requests, subpoenas, other legal proceedings and inquiries, as well as for fraud prevention and monitoring.
- 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, and for the establishment, exercise, or defense of legal claims.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support and improve the Subscription Service and providing certain features. When we share Personal Information with third parties, we take steps to protect the information in a manner that is consistent with our obligations under applicable privacy laws.
- To provide suggestions to the Customer and to provide tailored features within our Subscription Service that optimize and personalize the Customer’s experience.
- To perform data analytics projects to improve and enhance our products and services for our Customers. Our data analytics projects use data from Alyce accounts, including Personal Information. to provide and improve the Subscription Service.
- We may use Personal Information to deliver to Alyce Customers, 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 and this Privacy Policy.
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IV.C. Cookies and Tracking Technologies Used With Our Customers
We and our third-party partners may use various technologies to collect and store Subscription Service Usage Data when Customers use our Subscription Service (as discussed above), and this may include using cookies and similar tracking technologies. For example, we use web beacons in the emails we send on Customers’ behalf, which enable us to track certain behavior, such as whether the email sent through the Subscription Service was delivered and opened and whether links within the email were clicked. Web beacons allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data as further described above. We use this information to measure the performance of the Customer’s email campaigns, to provide analytics information, enhance the effectiveness of our Subscription Service, and for other purposes identified herein.
Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Statement available here.
Section V, “How and Why we Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors,” contains additional information about how and why we may share your information. Sections VI, “Public Information and Third-Party Websites,” VII, “Additional Information For Non-US Customers, Gift Recipients, And Alyce Website Visitors,” VIII, “Additional Information For California Residents,” and IX, “Additional Information For Everyone,” contain other information that may be relevant to you.
V. How and Why We Share Personal Information About Customers, Gift Recipients, and Alyce Website Visitors
For purposes of this section, "you" and "your" refer to Customers, Gift Recipients, and Alyce Website Visitors unless otherwise indicated.
We may share and disclose Personal Information about Customers, Gift Recipients, or Visitors to the following types of third parties for the purposes described in this Privacy Policy:
(i) To our service providers: We share information with our third-party service providers working on our behalf for the purposes described in this Privacy Policy. For example, we may share information with companies we’ve engaged to help us provide and support our Subscription Service or assist in protecting and securing our systems and services and other business-related functions.
Other examples include analyzing data, hosting data, engaging technical support for our Subscription Service, processing payments, order fulfillment, and delivering content and marketing, including to enable Alyce to provide personalized gift recommendations in connection with the Subscription Service.
(ii) To our Customers: We make available Personal Information about Customers and Gift Recipients to our Customers pursuant to the Subscription Services. The Personal Information about Customers that we provide to a Customer includes information we collect from that Customer or its authorized users under the Subscription Agreement with that Customer. The Personal Information about Gift Recipients that we provide to a Customer is the Personal Information we collected when Gift Recipients interact directly with Alyce or the Alyce Sites, such as the Gift Recipient’s name, email address, gift details, marketplace interactions, and meeting booking information and publicly available information related to Gift Recipients, such as information pertaining to their social media accounts, including information we may derive or observe from their social media profile, in order to assist the Customer in selecting a customized gift for Gift Recipients. We also make personalized gift recommendations to Customers based on information Alyce collects and observes about Gift Recipients from third-party providers and publicly-available data sources.
When we do provide or make Personal Information about a Gift Recipient available to a Customer, we only do so about Gift Recipients pursuant to the Subscription Services. We may do so directly to the Customer or indirectly through a marketing or customer-relationship platform that the Customer uses, for the Customer’s use. We do not make the information available to the platform for use by others, and we do not provide or make available Personal Information about Gift Recipients to Customers other than the Customer who provided the Gift Recipient with the gift. We do not share Gift Recipients’ home addresses or phone numbers with Customers.
(iii) To advertising partners: We may partner with third-party advertising networks, exchanges, and social media platforms to serve our advertising on other sites, and we may share Personal Information of Customers, Gift Recipients, and Visitors with them for this purpose. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to gather information about activities on the Alyce Sites and other sites in order to provide targeted advertising based on browsing activities and interests. For more information, including information on how to opt-out of certain advertising, please see our Cookie Statement available here.
(iv) To any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure of the Personal Information about a Customer, Gift Recipient, or Visitor 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) To a potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including any applicable rights to access and choice. We will provide notification of the change either by sending an email or posting a notice on our Alyce Site.
(vi) Any other person with your consent.
VI. Public Information and Third-Party Websites
- Blog: We have public blogs on the Alyce Sites. Please note that online forums may be publicly accessible and any information included in a comment on our blog may be read, collected, and used by anyone. We encourage exercising care in deciding what information and content to disclose on the areas of the Alyce Sites that are accessible to the general public.
- Social Media: Any information, communications, or materials submitted to us via a social media platform are not subject to this Privacy Policy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
- Links to third-party websites: The Alyce Sites may include links or otherwise provide access to other websites, mobile applications, or Internet locations, whose privacy practices may be different from ours. Alyce has no control over and is not responsible for these third-party sites, their content, or any goods or services available through the third-party sites. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
VII. Additional Information For Non-US Customers, Gift Recipients, And Alyce Website Visitors
VII.A. International Transfers
We offer services in the United States and Canada. Our servers and offices are located in the United States, so information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information, products, and services and/or to perform any requested transaction. By using any portion of the Alyce Sites, you acknowledge and consent to the transfer of your information to our facilities in the United States.
VII.B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)
If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information to perform our contractual obligations to you (if you are a party to our Subscription Agreement), or to take steps in response to information or inquiries you may submit prior to entering into a contract with us, or where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms (such as if you are an authorized user under our Customer’s Subscription Agreement with us). Our legitimate interests are described in more detail elsewhere in this privacy policy, but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Subscription Service and our Alyce Sites; and supporting our marketing activities.
In some limited cases, we may collect and process Personal Information to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
Where required by law, we will obtain consent to collect Personal Information.
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at privacy@alyce.com.
VII.C. Your Choices and Opt-Outs
Where consent is the basis of processing, you may at any time be able to withdraw the consent you provided for the processing of your personal information for the purposes set forth in this Privacy Policy by contacting us at privacy@alyce.com, provided that we are not required by applicable law or professional standards to retain such information. If you withdraw your consent, it 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. You can opt out of receiving marketing emails from Alyce at any time by clicking the "unsubscribe" link at the bottom of our marketing messages. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.
VIII. Additional Information For California Residents
VIII.A. California Consumer Privacy Act (CCPA) Rights
The CCPA provides California residents with specific rights regarding their Personal Information. Alyce currently affords such rights to all U.S. consumers, provided that, depending on the nature of your request, Alyce may refer you to a particular Customer where processing of Personal Information has taken place pursuant to our contract with a Customer in order to exercise your rights, consistent with applicable law. For individuals whose state of residence does not afford these rights, we offer them voluntarily and at our discretion, and we reserve the right to limit or revoke any such rights at any time, as may be permitted by applicable laws. This section describes your CCPA rights and Section VIII.C, “Exercising Your CCPA Rights,” explains how to exercise those rights:
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- Right to Know: You have the right to request what Personal Information about you we collect, use, disclose, and/or sell, as applicable, over the past 12 months as follows:
- the categories of Personal Information we collected and used about you;
- the categories of sources from which we collected the Personal Information about you;
- our business or commercial purpose for collecting or selling, as applicable, that Personal Information;
- the categories of third parties with whom we share that Personal Information;
- the specific pieces of Personal Information we collected about you; and
- if we disclosed your Personal Information for a business purpose or otherwise sold it, information regarding such disclosures, identifying the Personal Information categories that each category of recipient obtained.
- Right to Delete: You have the right to request the deletion of your Personal Information that is collected or maintained by us. If we receive and confirm your verifiable consumer request, we shall delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies or as otherwise required by law.
- Right to Opt-Out of Sale: You have the right to opt out from the sale of your personal information. The CCPA defines a “sale” as the disclosure of Personal Information for monetary or other valuable consideration. Under that definition, we “sell” personal information. Section VIII.B, “Notice of Right to Opt-Out of the Sale of Personal Information Under the CCPA,” has more information.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
- Right to Know: You have the right to request what Personal Information about you we collect, use, disclose, and/or sell, as applicable, over the past 12 months as follows:
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VIII.B. Notice of Right to Opt-Out of the Sale of Personal Information Under the CCPA
The CCPA defines a “sale” as the disclosure of Personal Information for monetary or other valuable consideration. Under that definition, we “sell” Personal Information by providing data back to our Customers. The CCPA also requires us to identify the categories of personal information that we have “sold” under the CCPA in the preceding 12 months. Based on our understanding of what may be considered a “sale,” we may have “sold” these categories of personal information in the preceding 12 months: identifiers (including name and email address), inference information (in the form of gift recommendations).
As a California resident, you have the right to opt out of the sale of your Personal Information. When you opt out, your Personal Information will no longer be sold to third parties for their own use. We do not sell your personal information to third parties for monetary consideration.
If you would like to opt-out of the sale of your information, please do so by submitting your information using the methods described in Section VIII.C, "Exercising Your CCPA Rights”.
The effectiveness of your opt-out request may be limited by our ability to make a connection between the cookies and/or pixels that we may collect and your identity, browser, device, and/or browsing session. For example, if you do not have an Alyce account or if you are not logged into your Alyce account, your request to opt-out of sale will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.
The CCPA also requires that we state that we do not have actual knowledge that we have sold personal information of individuals under 16 years of age.
VIII.C. Exercising Your CCPA Rights
To exercise any applicable CCPA rights described above, please submit a verifiable consumer request to us by either:
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- Emailing us at privacy@alyce.com; or
- Sending postal mail to: Alyce, Inc.; Attention: Privacy/Legal; 330 Cochituate Road, Framingham, MA 01701 United States.
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The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child, if applicable. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. The above rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
VIII.D. Other California Privacy Rights
California's “Shine the Light” law (Civil Code § 1798.83) permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@alyce.com or write us at: Alyce, Inc. Attention: Privacy/Legal 330 Cochituate Road, Framingham, MA 01701 United States.
If a Gift Recipient no longer wants to be contacted by one of our Customers through our Subscription Service, the Gift Recipient should unsubscribe directly from that Customer’s newsletter or contact the Customer directly to update or delete their data. If Gift Recipients contact us directly, we may either forward the request to the relevant Customer or provide you with the identity of the Customer to enable Gift Recipients to contact them directly.
IX. Additional Information For Everyone
IX.A. Data Protection Rights Generally
Depending on the country in which you reside, you may have the following additional data protection rights:
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- To access; correct; update; port; delete; restrict or object to our processing of your Personal Information.
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You can exercise these rights by emailing privacy@alyce.com. 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.
We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
Please note that, where we have received your information through our Customers, or where we are otherwise operating as a processor or service provider, we may refer you to the Customer with whom you have a direct relationship in order to implement your request, pursuant to applicable law.
IX.B. Data Security
We implement 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. Please be advised, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information.
In addition to sign-in with SSO, Alyce accounts require use of a username and password to log in. Customers must keep their username and password secure, and never disclose it to a third party. We will not resend forgotten passwords and will only provide instructions on how to reset them.
IX.C. Retention of Data
When we process Personal Information for our own purposes, we will retain that 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, when deciding how long to retain Personal Information, we take into account:
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- Whether the Personal Information is necessary to perform a contract with you;
- Whether the Personal Information is necessary to establish, exercise or defend legal claims;
- Whether we have your consent to retain the Personal Information; and
- Whether there is any other statutory or legal requirement to retain the Personal Information.
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If we have no ongoing legitimate business or legal need to process Personal Information, then we will either delete or anonymize it or, if this is not possible (for example, because the information has been stored in backup archives), securely isolate it from further use until it can be deleted.
Please note that where we process on behalf of our Customers, we will retain that Personal Information until they instruct us to delete it or terminate their services with us.
IX.D. Do Not Track
Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. Alyce adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.
IX.E. Information from Children Under 13 Years of Age
We do not knowingly collect information from individuals under the age of 13 years without parental consent. If you become aware that an individual under 13 years of age has provided us with Personal Information without parental consent, please contact us at privacy@alyce.com. If we become aware that an individual under 13 years has provided us with Personal Information without parental consent, we will take steps to remove the data as permitted by law.
IX.F. Changes to this Policy
We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Alyce Sites. We encourage you to review this Privacy Policy often to stay informed of changes. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy that was in effect on each respective date you visited the Alyce Site.
IX.G. 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 contact us by postal mail or email at: Alyce, Inc. 330 Cochituate Road, Framingham, MA 01701 Attn: Privacy/Legal or privacy@alyce.com.