Effective date: 14 March 2024
When you use Altering, you’re trusting us to handle your personal information with care. We take that trust seriously.

This Privacy Policy describes how Altering Ltd collects, uses, discloses, and protects your personal information when you use our Altering app or altering.io.

1. CONTACTING US

If you have general questions about your account or how to contact customer service for assistance, please email us at hello@altering.io.

For questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact by email at hello@altering.com

The data controller of your personal information is Altering Ltd.  Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

2. INFORMATION WE COLLECT

a. Information You Provide to Us

You may provide the following types of information to us:
- Identifiers, such as name, contact details, and Apple ID;
- Payment information, such as credit card number, for your purchase (which is stored and processed by our third-party payment processor or directly by the third-party app store);
- Commercial information, such as:
   - a record of the content on our website and app that you experience;
   - details about your purchases and other business interactions with us;
- Information about your interests and preferences;
- Rough geolocation (inferred from your IP address);
- Internet or other electronic network activity information, as described in the Cookies and Other Technology section below; and
- Inferences based on any of the above. 

b. Cookies and Other Technology

Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use. 

c. Information From Third Parties

We may also receive personal information from third parties, including our service providers, affiliates, and partners such as analytics and advertising partners, payment processors, third-party app stores, and other Altering users. We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

3. USE OF INFORMATION

We and our service providers use the information described above for the following purposes:
- Manage and improve our website and app generally;
- Process your registration and verify your information;
- Customize content, preferences, and advertising on our website and app, across the Internet and elsewhere;
- Send you confirmations, updates, security alerts, and support and administrative messages;
- Conduct sales and marketing;
- Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;
- Protect against, identify, investigate, and respond to misuse of our website or app or other unlawful behavior;
- Address legal requirements;
- Establish, exercise, or defend our legal rights; and
- Create aggregated or de-identified information.

4. DISCLOSURE OF INFORMATION

We may disclose your information as follows:

- To vendors and service providers: We disclose information to companies that provide services to us, such as providers that host or operate our website or app, analyze data, or provide customer service, data storage, marketing, analytics, security, or fraud prevention.
- To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Altering.
- In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
- For the protection of Altering and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
- In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
- In other situations: We may also disclose your information in other situations where legally permitted.  We may use and disclose appropriately aggregated or de-identified information for any purpose.

5. YOUR RIGHTS AND CHOICES

a. Marketing Communications

You can unsubscribe from Altering marketing emails by clicking the unsubscribe link in a marketing email or contacting us at hello@altering.io.

b. Cookies and Other Similar Technologies

You can make certain choices regarding the use of cookies and similar technologies. We recommend doing so by clicking the “Cookie Preferences” link in the footer of our website, adjusting your preferences, and clicking “Save Settings.  If you replace, change, upgrade or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you may need to use this opt-out tool again.

You may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain websites may not function as expected.

c. Rights Regarding Your Information

Depending on your jurisdiction, you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:
- Provide you access to or a copy of certain personal information.
- Correct or update personal information.
- Delete certain personal information.
- Restrict or opt you out of certain uses of your information (right to object).
- Withdraw any consent that you previously provided.
- Provide you with certain details regarding the processing of your information.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the app to you, so we can’t delete it while still providing you with the app.

We may take reasonable steps to verify your identity before responding to certain requests, which may require verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

If you wish to exercise any privacy rights, or raise a complaint about our handling of your personal information, please contact us as described at the top of this Privacy Policy.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law. 

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Residents of California, Virginia, Nevada, and a growing number of other jurisdictions have a right to opt out of what the laws in those states call a “sale” of personal information, as well as to opt out of certain uses and disclosures of personal information for certain targeted advertising purposes. To exercise those rights, they can visit our Your Privacy Choices page and follow the instructions there.

6. DETAILS FOR CALIFORNIANS

This section applies only to California residents, and it deals only with information that is subject to the California Consumer Protection Act (CCPA). Data about individuals who live outside California may be handled differently.

Altering is not a data broker and does not sell your personal information to third parties for payment. However, as with many online companies, Altering partners with third parties to manage our advertising on other platforms. For that purpose, we may disclose limited personal information to third parties for our cross-context behavioral and targeted advertising purposes and this activity may fall under broader concepts of “selling” and/or “sharing” under the CCPA.

We have noted in the table below what categories we have “sold” and/or “shared” in the last twelve (12) months.

CATEGORYCOLLECTED“SOLD” / “SHARED
A. Identifiers.Name, alias, mailing address, unique personal identifier, online identifier, IP address, email (personal and/or work), account name, telephone number, password, account credentials, National Provider Identifier (NPI), driver’s license / government ID number (if provided for identity verification), or other similar identifiersNoNo
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Name, signature, mailing address, telephone number, driver’s license / government ID number (if provided for identity verification), payment card number, employment, employment history, bank account information, medical information, and health insurance informationNoNo
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military statusNoNo
D. Commercial information.Payment history, balances, Products or Services purchased or consideredNoNo
E. Biometric information.Sleep, health, or exercise dataNoNo
F. Internet or other similar network activity.Browsing history, search history, information on how you interact with our websiteNoNo
G. Geolocation data.Approximate location based on information like IP addressNoNo
H. Sensory data.Audio recordings, voicemails, photographsNoNo
I. Professional or employment-related information.Employer, job title or role, work contact informationNoNo
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Student identification numberNoNo
K. Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesNoNo
L. Sensitive personal information.Password, health information, payment information, racial and/or ethnic origin, information concerning your sexual orientation, and gender identityNoNo
7. INTERNATIONAL DATA TRANSFER

We are headquartered in the United Kingdom, and recipients of the data disclosures described in this Privacy Policy are located in the United Kingdom and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in this Privacy Policy) operate, pursuant to the laws of such countries. However, this Privacy Policy applies to Altering’s operations worldwide. To the extent that personal information is transferred from the European Economic Area (“EEA”)  to any non-EEA members of our group or third-party processors who handle the information solely on our behalf, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EEA and UK data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as set out below.

8. DATA RETENTION
We keep your information until we determine it is no longer than necessary for the purposes described in this Privacy Policy and we are not legally required to retain it for longer.

9. PROTECTION OF INFORMATION

To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Privacy.

10. CHILDREN UNDER 13

If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us personal information, please contact us at hello@altering.io so that we can delete it.

11. UPDATES AND CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.