US Privacy Statement
ALPI recognizes that privacy is a fundamental human right and further recognizes the importance of privacy, security, and data protection to our customers and partners worldwide. As an international organization, with legal entities, business processes, management structures, and technical systems that cross the Italian borders, we strive to provide protections across all of our operations that exceed legal minimums and to deploy consistent, rigorous policies and procedures. As used in this statement, terms such as “we,” “us,” “our,” and “Company” refer to ALPI-branded companies and current and future affiliates, as defined by local law (herein "ALPI"). Contact information for ALPI’s Privacy Office appears in the Exercising Your Rights & Contacting Us section below.
This Privacy Statement (sometimes known as Privacy Policy as prescribed by local law), informs you of our privacy practices and of the choices you can make and rights you can exercise in relation to your personal data, including information that may be collected from your online activity and interactions you have with ALPI offline, such as when you engage with our customer support representatives. This Privacy Statement applies to all of our services and is intended for our audience located in the United States, as well as ALPI-owned websites, and domains.
Throughout this document references to ‘’local law’’ or ‘’applicable law’’ refer to US Federal law, US State privacy laws, and local laws applicable to where you reside in the United States.
Our Privacy Principles
We have an accountability-based program, and we are committed to the following principles, which are based on internationally recognized frameworks and principles of privacy and data protection.
LAWFULNESS, FAIRNESS & TRANSPARENCY
We process personal data in accordance with local law and with transparency and fairness to you. Our data processing activities are conducted: 1) with your consent; 2) in order to fulfill our obligations to you; 3) for the legitimate purposes of operating our business, advancing innovation, and providing a seamless customer experience; or 4) otherwise in accordance with law.
NOTICE & CHOICE OF DATA USE
We are transparent and provide clear notice and choice to you about the types of personal data collected and the purposes for which it is collected and processed. We will not use personal data for purposes that are incompatible with these Principles, our Privacy Statement, or specific notices associated with ALPI Services.
DATA ACCESS
We provide you with reasonable access along with the ability to review, correct, amend, or delete the personal data you have shared with us.
DATA INTEGRITY & PURPOSE LIMITATION
We only process personal data for the purposes described at the time of collection or for additional compatible purposes in accordance with local law. We take reasonable steps to ensure that personal data is accurate, complete, and current and we only collect personal data which is relevant and limited to what is minimum necessary for the purposes for which it is collected. We will keep personal data for no longer than is necessary for the purposes for which it was collected and then, unless legally required to keep it longer, we will securely destroy it.
DATA SECURITY
To protect personal data against unauthorized use or disclosure we implement strong information security controls in our own operations.
ACCOUNTABILITY
As an accountable organization, we have appropriate policies and procedures that promote good practices, which, taken as a whole, allow us to demonstrate our capacity to comply with applicable privacy laws.
Personal data will only be shared with third parties and processors (often referred to as service providers or contractors) with whom we have a business relationship or manage or support certain aspects of our business operations on our behalf. All parties are obligated by contract, as required by law or regulation, to provide equivalent levels of protection and follow our ALPI’s privacy policies and practices for handling personal data. We are committed to resolving any concerns regarding your personal data.
International Data Transfers
As an international company, it is possible that any information you provide may be transferred to or accessed by ALPI entities worldwide to perform processing activities such as those described in this Privacy Statement in connection with our services. If we do so, we will address any applicable legal requirements on international transfers between countries.
How We Use Data
We collect, use, disclose, and otherwise process personal data as defined by applicable law to manage your relationship with ALPI. We use and otherwise process your data for the following business purposes:
CUSTOMER EXPERIENCE
Providing you with a seamless customer experience by maintaining accurate contact and registration data, delivering comprehensive customer support, through a number of mediums including emails and communicating with you about our products and services. TRANSACTION SUPPORT Assisting you in completing transactions and orders for our products or services, arranging shipments and deliveries.
ADMINISTRATIVE COMMUNICATIONS
Communicating with you about ALPI Services. Examples of administrative communications may include responses to your inquiries or requests, and communications required by law.
SECURITY
Maintaining the integrity and security of our website, preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your information. When you interact with us, we will also take reasonable steps to verify your identity, before granting access to your personal data.
RESEARCH & INNOVATION
Innovating new and existing new products, features and services using research and development tools and incorporating data analysis activities.
MARKETING AND ADVERTISING
Providing personalized promotional offers on ALPI Services through e-mail.
COMPLIANCE WITH LAW
Compliance with applicable laws, regulations, court orders, government, and law enforcement requests, to operate our services and products properly and to protect ourselves, our users, and our customers and to solve any customer disputes.
What Data We Collect
Personal data is any information that personally identifies you or from which you could be identified either directly or indirectly. We may collect your personal data through your use of ALPI websites or during interactions with ALPI or ALPI representatives.
The categories of personal data we collect from you depend on the nature of your interaction with us but may include the following:
INFORMATION COLLECTED ABOUT YOU
• Contact Data – We collect personal and/or business contact information including your first name, last name, mailing address, telephone number, email address and other similar data and identifiers.
• Demographic Data – We collect, or obtain from third parties, certain demographic data including, for example, country, gender, age, preferred language, and general interest data.
INFORMATION AUTOMATICALLY COLLECTED
• Website Browsing Data – We collect information about your visits to and your activity on our ALPI websites, including the content that you view and interact with. Some of this information is collected using cookies, web beacons, embedded web links and similar technologies.
• Anonymous or Aggregated Data – We collect anonymous answers to surveys or anonymous and aggregated information about how our ALPI website is used. In certain cases, we apply a process of de-identification or pseudonymization to your data to make it reasonably unlikely to identify you through the use of that data with available technology.
Please note: Some web browsers incorporate “Do Not Track” features, if it’s not your case, you can download and activate the plug-in in your browser if you don’t wish to be tracked.
INFORMATION FROM THIRD-PARTY SOURCES
• ALPI Partners – If you purchase ALPI from an ALPI partner, we may receive certain information about your purchase from that partner.
• ALPI Enterprise Customers – In order to provide certain ALPI Services at an enterprise level, your business contact data may be provided to ALPI by a designated entity within your business or enterprise.
IF YOU CHOOSE NOT TO PROVIDE DATA
You are not required to share the personal data that we request, however, if you choose not to share the information, as permitted by local law, in some cases we will not be able to provide you with some ALPI Services, certain specialized features or be able to effectively respond to any queries you may have.
Children’s Privacy
Unless otherwise stated for a specific product or service, ALPI websites are made for the general public and are not directed at children (as defined by the U.S. Children’s Privacy Protection Act, COPPA, and applicable local law).
How We Retain and Keep Your Data Secure
To prevent loss, unauthorized access, use or disclosure and to ensure the appropriate use of your information, we utilize reasonable and appropriate physical, technical, and administrative procedures to safeguard the information we collect and process. ALPI retains data as required or permitted by law and while the data continues to have a legitimate business purpose.
When collecting, transferring, or storing sensitive information such as financial information we use a variety of additional security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure.
We keep your personal data for as long as necessary to provide you with ALPI Services, for legitimate and essential business purposes, such as complying with our legal obligations, and resolving disputes. ALPI is committed to protecting the privacy of all personal data processed and aims to ensure that personal data is not kept for longer than is necessary for the purpose for which it was collected, held, and processed. The retention periods for ALPI held personal data vary depending on whether or not that data is held as part of a legally required business record.
Personal Data contained in records, including records relating to customer and vendor transactions, are maintained while active and as required by local law. Personal data contained in non-records is managed in accordance with the Personal Data Retention Policy, which sets retention limits. Following the expiration of the relevant retention period, information is permanently erased and destroyed in a manner where it cannot be reproduced.
At your request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data.
How We Share Data
We do not, and will not, sell personal data to third parties.
SHARING WITH ALPI COMPANIES
We may transfer your personal data to ALPI’s headgroup based in Italy for the purposes outlined in this Privacy Statement in the “How We Use Data” section. To ensure that your personal data is secure ALPI entities are contractually bound to comply with our privacy requirements. Furthermore, our privacy guidelines are communicated to all our ALPI employees as part of our mandatory training.
SHARING WITH SERVICE PROVIDERS & PARTNERS
We engage service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the US or in other global locations and may provide services such as customer support, sales pursuits on our behalf, product delivery, IT services, email service providers, data hosting, and support of ALPI websites. Our service providers and partners are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by ALPI.
COMPLIANCE WITH LAW We may also share your personal data when we believe, in good faith, that we have an obligation to: (i) respond to duly authorized information requests of law enforcement agencies, regulators, courts and other public authorities, including to meet national security or other law enforcement requirements; (ii) comply with any law, regulation, subpoena, or court order; (iii) investigate and help prevent security threats, fraud or other criminal or malicious activity; (iv) enforce/protect the rights and properties of ALPI or its subsidiaries; or (v) protect the rights or personal safety of ALPI, our employees, and third parties on or using ALPI property when allowed and in line with the requirements of applicable law.
Non-Discrimination Program
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on ALPI website may change or no longer be available to you as the data might be necessary to provide some functionalities or features.
ALPI Communications
You can make or change your choices regarding subscription or general communications from ALPI at the data collection point or by using other methods, which are described in this section. These options do not apply to communications primarily for the purpose of administering order completion, contracts, support, or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.
MARKETING & SUBSCRIPTION COMMUNICATIONS ALPI
marketing communications provide information about products and services. Marketing communications may include new product or services information, special offers, personalized content, or invitations to participate in public and private events and fairs. Subscription communications include email newsletters that may be expressly requested by you or which you consented to receive.
You may opt out of receiving these general communications by selecting the email’s “Opt-out” or “Unsubscribe” link or following the instructions included in each email communication.
COOKIES AND CHOICES
ALPI provides you with choices about the setting of cookies and other automatic data collection tools through our Cookie Preferences Center. You can adjust your preferences by visiting our Cookie Preferences Center.
Exercising Your Rights & Contacting Us
Your Privacy Rights
You have the right to ask us for a copy of any personal data that you have provided to us or that we maintain about you and to request an explanation about the processing, which will detail the categories of personal data, the categories of sources from which the personal data is collected, the purposes for collecting or sharing personal data and the specific pieces of personal data ALPI has collected about you. In addition, you have the right to withdraw any consent previously granted or to request correction, amendment, restriction, anonymization, or deletion of your personal data; and to obtain the personal data you provide with your consent or in connection with a contract in a structured and to ask us to transfer this data to another data controller. You also have the right to object to the processing of your personal data in some circumstances.
How to Exercise Your Privacy Rights and Make Your Privacy Requests
To exercise your rights, or if you have any questions or concerns about this US Privacy Statement and our privacy practices, our collection and use of your information or a possible data breach, you can, or by entrusting an authorized agent, submit your privacy requests by writing to us at the address below:
ALPI S. p. A.
Viale della Repubblica, 34
Modigliana (FC)
47015
ITALY
In addition, you can exercise this right at any time by sending an email to: privacy@alpi.it.
How We Manage Your Privacy Requests
Upon receipt of your communication, our representative will contact you within a reasonable time to respond to your questions or concerns. In some cases, we may request further information to verify your identity, complete you request, ask for the service your request refers to, clarify the nature of your request, remedy any deficiencies with your request, or let you know if we need more time, as permitted in applicable law. Please refrain from sending us sensitive personal data.
Timing
We will acknowledge receipt of your request within 10 business days after we receive your request. You will receive our response to your request within 45 days of your request, unless we provide you with notice that it will take more than 45 days to respond (in that case, we won't take more than 90 days to respond).
Supplementary Privacy Notice for California Residents
California “Shine the Light” Privacy Rights
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with some additional transparency information.
This State Consumer Privacy Notice supplements the transparency information in our Privacy Statement and applies solely to California residents. The Privacy Statement includes what personal data is collected, the source of the personal data, and the business and commercial purposes (as that term is defined by California law) of use, as well as whether ALPI discloses, sells, or shares that personal data and if so, the categories of third parties to whom it is disclosed, sold and shared (as that term is defined by California law). This Notice does not apply to personal data we collect from our employees or job applicants.
ALPI does not discriminate in response to privacy rights requests. ALPI also does not use or disclose sensitive personal data for any purposes that would require a user to exercise a right to limit according to California law.
What Data We Collect About You
ALPI collects personal data to provide our services and protect and improve the customer experience. To learn more about the categories of personal data we collect please see the “What Data We Collect” section.
How We Use Your Data
ALPI appreciates that our services are used for purposes of managing the relationship with ALPI and to better serve California residents by personalizing their experience and interaction with us for which the categories of personal data, including categories of sensitive personal data, are collected, and used. For information on how ALPI collects, and uses personal data, please visit the “How We Use Data” section.
How We Protect Your Data
We will retain the personal data consistent with our internal record-retention policies and for as long as is necessary to provide products and services to California residents or as required by law. Please see “How We Retain and Keep Your Data Secure” for more information on retention of personal data.
Your California Rights
California residents have a right to know, access, correct, limit, and delete their personal data under the California law by exercising their rights directly or through an authorized agent visiting the above “Exercising Your Rights & Contacting Us” section of the Privacy Statement.
Our ALPI US Privacy Statement
We regularly review and update our ALPI US Privacy Statement to ensure that it reflects our personal data handling and privacy practices and facilitates monitoring of compliance by our California consumers.
Additional Rights for Certain US States Residents
California, Colorado, Connecticut, and Virginia privacy laws permit their respective residents to request us to stop sharing their personal data with third parties. If you are a resident of such states, this section applies to any personal data that we collect about you in accordance with your respective state's privacy laws.
Obtaining Information about the Sale or Sharing of your Personal Data
You can request and obtain from us further information regarding those categories of third parties to whom your personal data was disclosed, or shared (if any, and as defined under applicable law), the purposes for collecting or sharing your personal data, and the categories of personal data disclosed or shared, as provided for in the local law.
Your Right to Opt-Out
As a Consumer, you have the right to Opt-out, this means you the right to direct ALPI to not share personal data about you to third parties, as defined by local law, or to stop doing so for the following purposes:
• Targeted advertising, cross-context behavioral advertising, or personalized advertising as defined by law in your jurisdiction;
• The sale or sharing of personal data as defined by law in your jurisdiction, or
• If applicable, profiling in furtherance of automated decisions that produce legal or similarly significant effects concerning you.
As a California, Colorado, Connecticut or Virginia resident, you can also exercise your Opt-out right of the sale or sharing of personal data in offline scenarios. In addition, you can exercise this right at any time by sending an email to: privacy@alpi.it. Similarly, exercising your right to Opt-out of sale or sharing that occurs during your browsing activity can be accomplished in either of the ways listed below:
• Opt-out in Cookie Preference Center: As a California, Colorado, Connecticut, and Virginia resident, in addition to being able to select your preference on which cookies are allowed, you can Opt-out browsing based personal data by clicking on the “Privacy Preference Center” and changing the setting to “inactive”.
• Universal Opt-out Mechanism (e.g., Global Privacy Control): If you use a Universal Opt-out Mechanism or Opt-out Preference Signal (as defined in applicable law), including a web browser or extension, we will interpret as Opting-out of the sale or sharing of your personal data with third parties that are in scope of Do Not Sell or Share. Please note that the use of Universal Opt-out mechanism only applies to your browsing activity and not to offline sale or sharing of personal data.
We are committed to processing your Opt-out preferences (and as a result, Opt-out of personalized advertising) for the device and web browser from which the Opt-out signal is being made, as it will be tied a specific device ID or browser ID. If you use another device or browser, you will need to Opt-out on each device and browser. If you wish to Opt-out, we recommend that you clear your cookies from your browser first and then select your cookie preferences above. Even when Opted-out, you may still see contextual ads online such as those based on the topic and content of a webpage you visit.
Most browsers automatically accept cookies (including some of our third-party analytics providers), but this is typically something you can adjust. Please reference your browser’s settings to adjust your privacy preferences.
Your Right to Appeal
We aim to ensure that your concerns are resolved in a timely and appropriate manner. If we fail to take any action regarding your request to exercise rights or decline to respond, you have, or by entrusting an authorized agent, the right to appeal by using contacting us to privacy@alpi.it. The appeal must describe your request with a detailed summary that allows us to properly understand, evaluate, and respond to it. Similarly, in case an appeal is denied, you have the right to contact your local Attorney General or dedicated Agency if you have concerns about the result of the appeal, as prescribed by applicable law.
Changes to Our ALPI US Privacy Statement
If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. If we make significant changes to our Privacy Statement that materially alter our privacy practices, or as otherwise required by local law, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.
Date Posted: November 2023.
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