Aldelo Privacy Policy

INTRODUCTION

Aldelo Systems, Inc., Aldelo, LP, Aldelo Pay, L.P., and Aldelo Ventures LLC (collectively, “Aldelo”, or“We”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect from you or that you may provide: (1) on the website (aldelo.com, aldelo.express, aldelopay.com, masareward.com, masa.express) or any other Aldelo website (our “Website”) or any of Aldelo’s services (including, without limitation, any desktop, cloud-based, or mobile applications, products or other services) (collectively, the Website and services are referred to as the “Services”); (2) in e-mail, text and other electronic messages between you and the Services; (3) through Aldelo’s mobile and/or desktop applications you download from the Services, through Aldelo’s mobile and/or desktop applications that are available for download from other third-party sources, or through such applications made available for your use through an authorized third party which provide dedicated non-browser-based interaction between you and Aldelo and/or the Services; (4) when you interact with Aldelo directly for the provision of Services; and (5) when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. This policy does not apply to information: (1) collected, processed, stored or hosted by Aldelo customers related to their use of Aldelo Services; or (2) collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy, and if you are between the ages of 13 and 18, you have your parent or legal guardian’s permission to use our Services and agree to this Privacy Policy. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of our Services after we make changes to this Policy is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

CHILDREN UNDER THE AGE OF 13

Our Services are not intended for children under 13 years of age and we do not knowingly collect Personal Information from children under 13 years of age. No one under age 13 may provide any Personal Information to or through the Services. If you are under 13, do not use or provide any information on the Services or on or through any of their features, use any of the interactive services, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under 13, please contact us at the telephone number or in writing to the addresses provided in the Contact Information section below.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information that identify, relate to, describe, reference, are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with users of our Services, (“Personal Information”). The following categories of Personal Information are provided by California law and we have provided examples of data to help explain each category. Aldelo does not necessarily collect all of the types of data listed as examples within each category:

Category: A. Identifiers
Example: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code section 1798.80(e))
Example: A name, signature, Social Security number, physical characteristics or description, address ,telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: C. Protected classification characteristics under California or federal law
Example: 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 status, genetic information (including familial genetic information).
Is this Data Collected? Aldelo does not collect this category of personal information.

Category: D. Commercial information
Example: Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: E. Biometric information
Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: F. Internet or other similar network activity
Example: Your internet connection (including your IP Address, operating system and browser type), the equipment you use to access our Services and usage details (including traffic data, location data, logs, and other communication data and resources accessed and used on the Services)
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: G. Geolocation data
Example: Physical location or movements.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: H. Sensory data
Example: Audio, electronic, visual, thermal, olfactory, or similar information.
Is this Data Collected? Aldelo does not collect this category of personal information.

Category: I. Professional or employment-related information
Example: Current or past job history or performance evaluations.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Category: J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.W. Section 1232g, 34 C.F.R. Part 99)
Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Is this Data Collected? Aldelo does not collect this category of personal information.

Category: K. Inferences drawn from other personal information
Example: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Is this Data Collected? Aldelo may collect this category of personal information in some of its products.

Personal Information does not include de-identified or aggregated consumer information, publicly available information, or information covered by certain sector-specific privacy laws (such as the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.)

We collect this information:

Directly from you when you provide it to us.
Indirectly from you, and automatically, as you use and navigate through the Services. Information collected automatically may include usage details, IP addresses and information collected through cookies. The technology we use for automatic data collection may include: cookies (or browser cookies), which are small files placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
From third parties, for example, our affiliates and business partners.

The information we collect on or through our Services includes:

Information that you provide by filling in forms on our Services on your own device or through a third-party device which information may be connected to your name, your business’ name, your account or business account, and/or e-mail address. This includes information provided at the time of registering to use our Services, subscribing to our Services, or requesting further services. We may also ask you for information when you report a problem with our Services.
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Details of transactions and processing you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before setting up a business account through our Services.
Your search queries on the Website.

Our Services do not have the functionality for User Contributions (defined below), but if you become able to provide information to be published or displayed (hereinafter, “posted”) on public areas of our Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”), we will update this Privacy Policy and notify you.

CALIFORNIA DO NOT TRACK DISCLOSURES

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The Services track customer purchase habits and purchase history at companies using Aldelo Services, and you may not opt out of such behavioral tracking as it is necessary for the operation of the Services. This data is used to for trend analysis, marketing opportunity identification, direct promotions such as special offerings (loyalty and rewards programs), and related purposes. We do not currently collect Personal Information automatically from third parties but may do so where customer purchase habits are integrated into Aldelo Services for analytics purposes.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES.

Some content or applications, including advertisements, on our Services are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information:

To present and provide our Services and content to you.
To provide you with information, products or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account and/or subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
To notify you about changes, updates, and upgrades to our Services or any products or services we offer.
To allow you to participate in interactive features on our Services and personalize your experience with our Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
Provide updates to the Privacy Policy or other terms of service.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Aldelo, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Aldelo’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information of consumers held by Aldelo is among the assets transferred.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please opt-out from such communications by writing to the address provided in the Contact Information section. However, please be aware that opting-out of such communications will prevent Aldelo from providing the Services to you and will result in termination of any contracts or subscriptions then in effect. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from Aldelo. If you do not wish to receive promotional offers from Aldelo, you can opt-out writing to us at the address provided below in the Contact Information section. However, please be aware that opting-out of such communications will prevent Aldelo from providing the Services to you and will result in termination of any contracts or subscriptions then in effect.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending a writing to Aldelo at the address provided in the Contact Information section below. However, please be aware that opting-out of such communications will prevent Aldelo from providing the Services to you and will result in termination of any contracts or subscriptions then in effect.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us a letter stating your request to the physical address provided below in the Contact Information section. However, please be aware that opting-out of such communications will prevent Aldelo from providing the Services to you and will result in termination of any contracts or subscriptions then in effect.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However the third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

REQUESTING CORRECTIONS TO YOUR PERSONAL INFORMATION

You can request changes to your Personal Information by calling us or sending us a letter at the physical address provided below in the Contact Information section to request corrections to any of your Personal Information that you have provided to us. Please include your e-mail address on the letter. By requesting that we modify your Personal Information, you understand and agree that we may keep the statistical information (including, without limitation, the number of transactions processed), however such information will not be connected to your name or other Personal Information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

DATA SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal and business information, we cannot guarantee the security of the information transmitted to or through our Services. Any transmission of personal or business information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

INTERNATIONAL TRANSFERS OF DATA

If you are located in a province, country, or other government jurisdiction outside of the United States, and if you choose to provide your personal information to Aldelo through our Services, please be aware that your Personal Information may be transferred to and maintained on computers located in the United States and the applicable privacy laws may not be as protective as those in your jurisdiction. If you choose to provide your Personal Information to Aldelo, you consent to the transfer, maintenance, and storage of such information in the United States and for Aldelo to process and use such information in accordance with this privacy policy.

CHANGES TO OUR PRIVACY POLICY

If we make material changes to how we treat our users’ personal information or this policy, we will update the privacy policy on our Website. The date the privacy policy was last revised or reviewed is identified at the bottom of this page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

REPORTING CLAIMS OF COPYRIGHT INFRINGEMENT

We take claims of copyright infringement seriously. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from the Services (including the Website) infringe your copyright, you may request removal of those materials (or access to them) from the Services by submitting written notification to our Copyright Agent (designated below). In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C section 512) (“DMCA”), the written notice (“DMCA Notice”) must include substantially the following:

Your physical or electronic signature.
Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Website or Services, a representative list of such works.
Identification of the material you believe to be infringing in a sufficiently precise manner to allow us to locate that material.
Adequate information by which we can contact you (including your name, postal address, telephone number and, if available, e-mail address).
A statement that you have a good faith believe that use of the copyrighted material is not authorized by the copyright owners, its agent or the law.
A statement that the information in the DMCA notice is accurate.
A statement, under penalty of perjury, that you are authorized to act on behalf of the copyright owner.

Our designated Copyright Agent to receive DMCA Notices is:
Jeff Moore
6701 Koll Center Parkway, Suite 150
Pleasanton, CA 94566
925-398-8929
masa-dmca@aldelo.com

If you fail to comply with all of the requirements under Section 512(c)(3) of the DMCA, your DMCA Notice may not be effective.
Please be aware that if you knowingly materially misrepresent that material or activity on the Services is infringing your copyright, you may be held liable for damages (including costs and attorneys’ fees) under Section 512(f) of the DMCA.

YOUR RIGHTS UNDER CALIFORNIA LAW

Disclosures of Personal Information to External Parties
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this privacy policy to the following categories of external parties:

To our subsidiaries and affiliates.
To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Aldelo’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Aldelo about our Services’ users is among the assets transferred.
To third parties as directed by you.
To third parties to market their products or services to you if you have consented to or not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Aldelo has disclosed the following categories of Personal Information as directed by you or to external parties for a business purpose (as “business purpose” is defined under Cal. Civil Code section 1798.140): (A) Identifiers, (B) Personal Information Categories listed in the California Consumer Records statute, (D) Commercial Information, (G) Geolocation Data, (I) Professional or Employment Related Information, and (K) Inferences drawn from other personal information.

Sales of Personal Information.
In the preceding twelve (12) months, Aldelo has not sold any categories of Personal Information (as “sale” is defined under Cal. Civil Code section 1798.140).

Consumer Rights under California Law
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and how to exercise those rights by submitting a consumer request (“Consumer Request”).

Access to Specific Information and Data Portability Rights. You have the right to request that Aldelo disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive a verifiable Consumer Request, and depending on your request, we may disclose to you (if applicable):
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purposes for collecting that Personal Information.
- The categories of Third Parties to whom we disclosed that Personal Information and the categories of Personal Information disclosed.
- The specific pieces of Personal Information we collected about you (also called a data portability request).

Deletion Request Rights. You have the right to request that we delete any of your Personal Information that we collected from and about you, subject to certain statutory exceptions. Once we receive a verifiable Consumer Request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We will explain if an exception applies and we are unable to comply with your deletion request.

Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA, unless permitted by law. We will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- Provide you a different level or qualify of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights. California Civil Code Section § 1798.83 permits users of our Services that are 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 write to us at the address provided below in the Contact Information section.

How to Submit a Consumer Request
To exercise your access, data portability, and deletion rights, please submit a Consumer Request to the contact information below. Only you, or a person or entity you authorize to act on your (or your minor child’s) behalf, may make a Consumer Request related to your (or your minor child’s) Personal Information. You may only make a Consumer Request for access or data portability two times within a twelve (12) month period. Please refer to our FAQ’s for more information regarding Consumer Requests.

We reserve the right to require you to provide additional information to enable us to ensure it is a verifiable Consumer Request. The Consumer Request must describe the request with sufficient detail that allows us to properly understand, evaluate and respond to it, and we may require information to allow us to reasonably verify that you are the person about whom we collected the Personal Information (or your authorized representative). 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. Making a verifiable Consumer Request does not require you to make an account with us. We will only use Personal Information provided in a verifiable Consumer Request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to verifiable Consumer Requests within forty-five (45) days after receipt. If we require more time (up to 45 days) we will inform you of the reason and extension in writing. If you have an account with us, we will deliver our written response(s) to that account. If you do not have an account with us, we will deliver our written response(s) by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable Consumer Request. If we deny (or cannot comply with) the Consumer Request, we will explain why. For data portability requests, we will select a format to provide your Personal Information that is readily useable. We do not charge a fee to process or respond to your Consumer Request unless such request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide you with a cost estimate before completing your request.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, or for opt-out requests, please submit in writing to: 6701 Koll Center Parkway, Suite 150, Pleasanton, CA 94566

You can also contact us using our customer service toll-free number located on aldelo.com/contact

Date Privacy Policy last Modified: July 8, 2024