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PRIVACY POLICY

I. Introduction

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This Privacy Policy and Cookie Statement (“Privacy Policy”) describes how we process your Personal Information.

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By accessing, visiting, or using the Website, you acknowledge your understanding of this Privacy Policy. If you do not agree with the contents of this Privacy Policy, you should not access, visit, and/or use the Website.

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This Privacy Policy may be modified at any time without prior notice to you. Your continued access, visitation and/or use of the Website will constitute your acceptance of any changes or revisions to this Privacy Policy.

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II. Definitions of Terms Used in this Policy

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“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.

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“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Website.

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“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.

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“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.

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“We,” “Us,” “Our,” and “Altaira,” whether capitalized or not, means Altaira Strategic Partners and its affiliates.

“Website,” whether capitalized or not, means this website.

“You” or “Your,” whether capitalized or not, means all those who access, visit, and/or use the Website.

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III. Categories of Your Personal Information that We May Acquire

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We may collect, obtain, or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:

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  1. Identifiers, such as your name, date of birth, signature, postal address, ZIP code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.

  2. Certain characteristics protected by applicable law, such as gender, marital status, nationality, and country of origin.

  3. Commercial information, such as purchase history.

  4. Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.

  5. Geolocation data, such as the physical location of your Device.

  6. Professional or employment-related information, such as occupation, employment history and record, and resume.

  7. Government issued identification numbers (e.g., social security number, driver’s license number, passport number, or state identification card number).
     

IV. How We Acquire Your Personal Information

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Personal Information You Provide. We may receive Personal Information directly provided by you. For example, if you contact us through the Website, you may provide your contact information.

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Personal Information Automatically Collected. We may automatically collect certain information, some of which may be deemed Personal Information. The information collected may include information about your Device and geographic location of you and/or your Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.

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Personal Information Acquired from Third Parties. We may acquire your Personal Information from third parties. For example, we may purchase or otherwise acquire Personal Information from third-party consumer data suppliers/resellers, data aggregators, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, business contact databases, government entities, and our affiliates and other related entities.

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V. How We Use Your Personal Information

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Administering the Website. We also use and share your Personal Information for any lawful purpose in connection with administering the Website, including for customer service and Website maintenance and improvement.

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VI. Sharing of Your Personal Information with Third Parties.

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Third Parties with Whom We May Share Your Personal Information. We may disclose your Personal Information to the following categories of third parties:

  • Third-Party Businesses

  • Affiliates

  • Governmental and law enforcement officials

  • Persons involved in an acquisition of our business or assets
     

Third-Party Businesses. We may sell, share, and transfer Personal Information to the following types of Third-Party Businesses:

  • Advertising and marketing agencies to market goods and services;

  • Consumer data suppliers/resellers, data enrichment providers, and aggregators; and

  • Businesses that assist us with providing services.
     

In all such cases, your Personal Information may be used by us and by such Third-Party Business(es) for their own purposes, each pursuant to its own policies.
 

Affiliates. We may share your Personal Information with our affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section VII.
 

Marketing Communications. We may use your Personal Information to communicate with you about services we offer.

Health, Safety, and Legal Requests. We may share your Personal Information to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also use Personal Information to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.
 

Transfer or Sale of Our Business. If Altaira is involved in a business transaction, including the purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization, or financing involving Altaira, we may share your Personal Information in connection with such transaction. We may also share your Personal Information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.
 

VII. Cookies and Related Technologies

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We may place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies, locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third-Party Businesses may independently or in conjunction use Local Device Storage in connection with the Website in a way that collects Personal Information for the purposes described in the respective privacy policies. Your Device or browser may include an option that allows you to disable Local Device Storage.

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VIII. Transfer of Your Personal Information Among Jurisdictions

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Your Personal Information may be processed, transferred to, and maintained on servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as those applicable to your jurisdiction. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

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IX. Protection of Your Personal Information

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Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, Personal Information.

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No Liability for Breach. Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. By using the Website, you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.

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Breach Notification. If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.

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X. Notice to California Customers – Your Privacy Rights

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Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Information.

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California residents have the following rights under the CCPA:

  1. The right to know the ways in which we collect, use, share, disclose, and otherwise process your Personal Information;

  2. The right to know the specific pieces of your Personal Information that we hold;

  3. The right to request the deletion of your Personal Information, subject to several exceptions;

  4. The right to opt out of the sale or sharing of your Personal Information;

  5. The right to correct inaccurate Personal Information that we hold; and

  6. The right not to be unlawfully discriminated against for exercising these rights.
     

We may take reasonable steps to verify your identity before fulfilling your request to know or delete your Personal Information that we hold. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.
 

Exercising Your Rights Under the CCPA. California residents, as well as authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at info@altairastrat.com or by calling us at 212-396-8686.
 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us to:
 

  1. Complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty conducted in accordance with federal law, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
     

Response Timing and Procedures
 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
 

We will deliver our written response by mail or electronically, at your option.
 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
 

Categories of Personal Information We Disclose
 

We may disclose your Personal Information to a third party for a business purpose. In the preceding 12 months, we have not disclosed any Personal Information for a business purpose
 

Categories of Personal Information We Sell
 

In the preceding 12 months, we have not sold any Personal Information for a business purpose.
 

Do Not Track
 

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third-party ad networks, social networks, and analytic companies. We do not currently take actions to respond to DNT signals, because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.
 

XI. Inquiries
 

If you have any concerns or questions about any aspect of this Privacy Policy, please feel free to contact by email at info@altairastrat.com.
 

Please include your name and contact information in your request.

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