Effective Date: October 1, 2020. Alva10 and it’s associates (collectively, “Alva10”, “us” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Alva10's business activities, like conferences and events, and client services, and on websites, applications, and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers.

Information we collect

Alva10 may collect personal data in the course of its business activities, including in connection with some client services. The personal data collected varies and may include information that you provide, such as your name, mailing address, email address, telephone number, and background information required to apply for a job.

We may also automatically collect information about the devices you use to interact with our Site. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

Alva10 may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities. We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Alva10, in compliance with applicable law.

Use of information

Alva10 uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Alva10’s agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you. Alva10 and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Alva10 and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you.

Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.

DISCLOSURE OF PERSONAL DATA: 

data recipients & international data transfers

Personal data collected in the course of Alva10 business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Alva10 affiliates and their personnel, as well as to our third party service providers located outside the US, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Alva10 and our partners outside of the US. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

Alva10 will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Alva10 may provide access to your personal data to third party service providers engaged by Alva10 to provide services related to the Sites as well as related to Alva10’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys, or communicating with you.

In addition, we may disclose information about you:

•  If we are required to do so by law or legal process; 
•  To law enforcement authorities or other government officials; 
•  When we believe disclosure is necessary or appropriate to prevent physical harm or financial
loss or in connection with an investigation of suspected or actual illegal activity; 
•  If disclosure is necessary to protect the vital interests of a person; 
•  To protect our property, services and legal rights; 
•  To prevent fraud against Alva10, our subsidiaries, affiliates and/or business partners; 
•  To support auditing, compliance, and corporate governance functions; or
•  To comply with any and all applicable laws.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

User forums

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Alva10 is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

Link to third party sites

Alva10 may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Alva10 of the third party, the third party website, or the information contained therein, and Alva10 shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

Social Networking

The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Alva10.

By associating your social network account with Alva10, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with third parties and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider

Security

Alva10 has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Alva10 personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. However, Alva10 cannot guarantee that unauthorized persons will not obtain access to your personal data despite these precautions.

Data retention

Alva10 retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Alva10 will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.

Children

The Sites are not intended for or directed at children 16 years of age or younger, and Alva10 does not intentionally collect or maintain personal data about anyone under this age.

Your rights

Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at hello@alva10.com.

Unsubscribe

If you have registered for Alva10 newsletter or alerts, or you receive invitations to survey or events from Alva10 and you prefer not to receive future email communications from us, please write to hello@alva10.com to unsubscribe from all Alva10 communications.

Your California privacy rights

If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to hello@alva10.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by Alva10, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed.

In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about Alva10’s collection, use, disclosure, and sale of personal data about you including: 

• The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information, 
• The categories of sources from which we have collected that information in the preceding 12 months,
• The commercial or business reason(s) we have collected, used, or disclosed that information, and
• The categories of third parties to whom we have disclosed information in the preceding 12months.
• In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months.

You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at hello@alva10.com. When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. Alva10 will not discriminate against you based on your exercise of any of these rights.

Consent; changes to Privacy Policy

By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

Contact US

If you have any questions about our Privacy Policy or if you would like to communicate with our legal advisors at Mintz Levin, please contact us at:
                                          Alva10, LLC
                                          Mintz Levin
                                          One Financial Center
                                          Boston, MA
                                          617.542.6000

Privacy Policy


Effective Date: October 1, 2020. Alva10 and it’s associates (collectively, “Alva10”, “us” or “we”) understand that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how we handle and protect your personal data in connection with Alva10's business activities, like conferences and events, and client services, and on websites, applications, and communications that post a link to this Privacy Policy (collectively, “the Sites”), in our capacity as data controllers.



Alva10 may collect personal data in the course of its business activities, including in connection with some client services. The personal data collected varies and may include information that you provide, such as your name, mailing address, email address, telephone number, and background information required to apply for a job.

We may also automatically collect information about the devices you use to interact with our Site. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

Alva10 may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities. We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Alva10, in compliance with applicable law.



Alva10 uses your personal data to fulfill your requests for information, process your requests to participate in conferences and events, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyze the Sites’ performance and functioning, publish your letters to the editor or comments, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Alva10’s agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you. Alva10 and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Alva10 and its service providers may collect information about whether you open or click any links in the knowledge, research or event communications that we send to you.

Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.




Personal data collected in the course of Alva10 business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Alva10 affiliates and their personnel, as well as to our third party service providers located outside the US, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Alva10 and our partners outside of the US. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

Alva10 will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Alva10 may provide access to your personal data to third party service providers engaged by Alva10 to provide services related to the Sites as well as related to Alva10’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys, or communicating with you.

In addition, we may disclose information about you:
















In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.



You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Alva10 is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.



Alva10 may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Site. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by Alva10 of the third party, the third party website, or the information contained therein, and Alva10 shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.



The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Alva10.

By associating your social network account with Alva10, you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with third parties and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.



Alva10 has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Alva10 personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. However, Alva10 cannot guarantee that unauthorized persons will not obtain access to your personal data despite these precautions.



Alva10 retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for  analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Alva10 will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Privacy Policy.



The Sites are not intended for or directed at children 16 years of age or younger, and Alva10 does not intentionally collect or maintain personal data about anyone under this age.



Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at hello@alva10.com.



If you have registered for Alva10 newsletter or alerts, or you receive invitations to survey or events from Alva10 and you prefer not to receive future email communications from us, please write to hello@alva10.com to unsubscribe from all Alva10 communications.



If you are a California resident under the age of 18, and a registered user of any of the Sites where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to hello@alva10.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

As required by the California Consumer Privacy Act (CCPA), this Privacy Policy describes the categories of personal data collected, processed, and disclosed by Alva10, the categories of sources for that data, and the business or commercial purposes for which that data is collected, processed, and disclosed.

In addition, under California law, you may have the right (up to two times in any 12-month period) to request more information about Alva10’s collection, use, disclosure, and sale of personal data about you including:















You may also have the right to request deletion of personal data about you that we have collected or maintain, which we will honor subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized agent would like to exercise your privacy rights, please contact us at hello@alva10.com. When we process your request, we require you to provide certain personal data about you in order to verify your identity in accordance with requirements under CCPA. This may include your first and last name, email address, physical address, telephone number, and information about your relationship with us or other information needed to verify your identity. Alva10 will not discriminate against you based on your exercise of any of these rights.



By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.



If you have any questions about our Privacy Policy or if you would like to communicate with our legal advisors at Mintz Levin, please contact us at:
                                          Alva10, LLC
                                          Mintz Levin
                                          One Financial Center
                                          Boston, MA
                                          617.542.6000

Information we collect

Use of information

DISCLOSURE OF PERSONAL DATA: 

data recipients & international data transfers

•  If we are required to do so by law or legal process; 
•  To law enforcement authorities or other government officials; 
•  When we believe disclosure is necessary or appropriate to prevent physical harm or financial
loss or in connection with an investigation of suspected or actual illegal activity; 
•  If disclosure is necessary to protect the vital interests of a person; 
•  To protect our property, services and legal rights; 
•  To prevent fraud against Alva10, our subsidiaries, affiliates and/or business partners; 
•  To support auditing, compliance, and corporate governance functions; or
•  To comply with any and all applicable laws.

User forums

Link to third party sites

Social Networking

Security

Data retention

Children

Your rights

Unsubscribe

Your California privacy rights

• The categories of personal data about you that we have collected in the preceding 12 months and the categories of sources of that information, 
• The categories of sources from which we have collected that information in the preceding 12 months,
• The commercial or business reason(s) we have collected, used, or disclosed that information, and
• The categories of third parties to whom we have disclosed information in the preceding 12months.
• In addition, upon receipt of a verifiable request from you establishing your identity, you may have the right to know about the specific pieces of personal data that we have collected about you and/or shared with third parties in the preceding 12 months.

Consent changes to Privacy Policy

Personal data collected in the course of Alva10 business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Alva10 affiliates and their personnel, as well as to our third party service providers located outside the US, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Alva10 and our partners outside of the US. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

Alva10 will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties’ own marketing purposes or otherwise, except as follows. Alva10 may provide access to your personal data to third party service providers engaged by Alva10 to provide services related to the Sites as well as related to Alva10’s business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys, or communicating with you.

In addition, we may disclose information about you:










In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.