ALLEY PRIVACY POLICY

 

Safeguarding your privacy is important to us. This Privacy Policy (“Policy”) describes our practices concerning the collection, use, and disclosure of personal and other information in connection with the websites that are located at www.alleynyc.com and (and all related domains). This Policy applies to all registered members of Alley (“Members”) and any other person who accesses our Site at any point for any amount of time (a “Visitor”), unless otherwise specified. By visiting our Site, you are agreeing to the terms of this Policy. Please carefully review this Policy.

WHAT PERSONAL AND OTHER INFORMATION WE COLLECT ABOUT YOU

Alley collects both “personal information” and “non-personal information” about Site users. For purposes of this Policy, “personal information” is information such as a name or email address that Alley can directly associate with a specific person without additional information. “Non-personal information” is information that Alley cannot directly associate with a specific person without the aid of additional information. When we combine non-personal information with personal information, we treat all of the combined information as personal information.

Collecting personal and non-personal information enables us to provide a better experience for our Members and Visitors. As discussed in more detail below, we collect this information for a variety of purposes, including protecting the security of the Site and our users, gauging the effectiveness of and improving our service and Site, distributing our newsletters, facilitating participation in specified activities, and promoting the Site and other products and services provided by Alley.

Personal Information: You can visit our Site without submitting any personal information. However, to become a Member you must provide personal information, including your name, telephone number, email address, unique password, postal address, payment information, and company name. If you become a Member of Alley, Alleyautomatically creates an Alley profile, and we might collect a variety of additional information from you, including your birthday, photograph, gender, job title, and/or industry. For Site activities that request personal information, you agree to provide accurate and current information about yourself. You also agree to the sharing of certain information through your Alley profile, as described below.

We may combine personal information collected through the Site with other information that we or third parties collect about you in other contexts – such as our communications with you via email or phone or your member or company profile. We will treat such combined information as personal information and protect it in accordance with this Policy.

We may retain personal information for an indefinite amount of time to preserve our database and to comply with various federal and state laws.

Surveys, Sweepstakes, and Events: From time to time, Alley may ask Site users to participate in surveys or provide opportunities to participate in sweepstakes or events. Such surveys, sweepstakes, and events may be used to collect both personal and non-personal information. Participation in these activities is completely voluntary, and you therefore have a choice whether or not to disclose your information. For each contest, sweepstakes, and/or special event, we will post on the Site applicable rules for the event, and if necessary, post any supplemental terms and conditions or privacy provisions. To the extent there is a conflict between those privacy provisions and this policy, the privacy provisions for the specific event will govern.

Weblog Data: When you use the Site, Alley automatically receives and records certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g. your city, state or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.

Cookies: We also may use cookies on the Site. Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site and the link you used to leave the Site. If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer or device. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

Web Beacons: We also may use an application known as a “web beacon” (also known as a “clear gif” or a “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email. We do not disclose to non-service-provider third parties any personal information that we collect in connection with web beacons. However, other websites that you may link to through the Site also may use web beacons, so you should review other website operators’ privacy policies to determine the type and extent of tracking devices used, and the information shared.

Third-party online tracking and behavioral advertising: We also may partner with certain third parties to collect, analyze, and use some of the personal and non-personal information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from Alley. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “How we share personal and non-personal information with third parties”).

HOW WE USE THE PERSONAL AND NON-PERSONAL INFORMATION THAT WE COLLECT

Alley uses the information that we collect for a variety of purposes. If we have personal information about you, we may use it, for example: to respond to your questions or requests concerning the Site or other services offered by Alley or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you; to deliver confirmations, account information, notifications, and similar operational communications; to populate your Alley profile; to improve your user experience and the quality of our Site and services; to comply with legal and/or regulatory requirements; and to manage our business.

We use the non-personal information that we collect for such purposes as: counting and recognizing users of the Site; analyzing how users navigate the Site and use various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and Services; enabling additional website analytics and research concerning the Site; and managing our business. Alley may link non-personal information gathered using cookies and web beacons with personal information. In that event, we will treat the combined information as personal information.

We also may use the personal and non-personal information that we collect to send you promotional communications including emails or postal mail about the products and services offered by Alley or our partners. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by sending an email to privacy@alleynyc.com with “optout” in the subject line. Promotional emails also will have instructions for opting out of that type of communication in the future.

HOW WE SHARE PERSONAL AND NON-PERSONAL INFORMATION WITH THIRD PARTIES

We share your personal and non-personal information with other parties for a variety of purposes as described below.

Automatically-created Alley profile. When you become an Alley Member, we automatically create a profile for you that contains such personal information as your name and company. This profile is accessible to all other Alley members, as is any other information that you manually add to your profile. By becoming an Alley member, you consent to the creation and sharing of your profile.

Analytics and online behavioral advertising. We partner with certain third parties to collect the non-personal information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set or access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

The site also enables third-party tracking mechanisms to collect your non-personal information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Site to target online ads for Alley services to you on non-Alley websites. In addition, our third-party advertising networks might use information about your use of the Site to help target non-Alley advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

Third-party service providers and business partners: Alley also uses other third-party service providers to help us manage and improve the Site and other Alley services. These service providers may collect and/or use your personal or non-personal information to assist us in achieving the purposes discussed above in the section entitled “How we use the personal and non-personal information we collect.” For example, we use third parties to host and manage the Site, to help us target and implement our email communications and direct mailings, to help us process credit card and other payments, and to help us manage our relationships with the people and companies that use our services.

We also may share your personal or non-personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

For the convenience of our Members and Visitors, we may offer a list of helpful website links provided by other entities and/or persons. Alley does not endorse or recommend, nor is it liable for, the products or services of any websites not owned or operated by Alley. When you visit other websites, you also will be subject to the privacy policies and terms of usage agreements, if any, of those website operators.

Direct sharing of information through third-party websites and services: The Site may enable you to share personal and other information through websites or online services operated by third parties. If you choose to use such features, you may disclose your personal information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by Alley, Alley is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and non-personal information will be subject to the privacy policies of the third party websites or services, and not this Policy.

Third-party plug-ins. The Site may integrate certain third-party plug-ins. Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.

Third-party marketing: If you opt in to receive marketing emails from third-parties, Alley will provide your personal information to third parties, so that those third parties may directly contact you about non-Alley products and services. If you later choose to opt out of receiving marketing emails from third parties, please contact the third party directly and/or follow the instructions at the bottom of their marketing emails.

Legal Purposes: We also may use or share your personal or non-personal information with third parties when we believe, in our sole discretion, that doing so is necessary:

·       to comply with applicable law or a court order, subpoena, or other legal process;

·       to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations or our terms and conditions, or situations involving threats to our property or the property of physical safety of any person or third party;

·       to establish, protect, or exercise our legal rights or to defend against legal claims; or

·       to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated Information: From time to time, Alley also may share de-identified and aggregated information about Site users, such as by publishing a report on the trends in usage of the Site. Similarly, the information that Alley collects through surveys will be disclosed in de-identified and aggregate form, unless the privacy policy for that particular survey specifies otherwise.

SECURITY

Alley requires our employees to protect all information collected through the Site. Only employees with specific authorization have access to databases containing users’ personal information. Alley uses commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information.

REVIEWING AND UPDATING YOUR INFORMATION

If you want to learn more about the personal information that Alley has about you, or you would like to update or change that information, please contact us by email at privacy@alleynyc.com.

INFORMATION FOR SITE USERS FROM OUTSIDE THE UNITED STATES

The personal and non-personal information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. Alley may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or in other countries. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or providing any personal or non-personal information to us, you expressly consent to such transfer and processing.

CHILDREN’S PRIVACY

This Site is not directed to children under the age of 13 and Alley will never knowingly collect personal or other information from anyone it knows is under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using the Site or sending any information about themselves to anyone over the Internet.

CHANGES TO THIS POLICY

Alley will review its data security measures and this privacy policy from time to time and may make changes to the Site or to its privacy practices. In that case, Alley may need to revise this Policy to reflect those changes. Alley will post all such changes on the Site, so we encourage you to review this Policy periodically.

QUESTIONS OR COMMENTS

If you have any questions or comments regarding our Policy, please mail or email us at:

Privacy Director
Alley, LLC
500 7th Avenue 17A
New York, NY 10018
Email: 
privacy@alleynyc.com 



Effective Date: August, 12, 2015