Privacy Policy

Last Updated: 13 January, 2025

Privacy Notice

Introduction

Alectrona LLC, (“Alectrona”) is committed to protecting the privacy of your personal information. As such, this Privacy Policy covers how we collect, use, disclose, transfer, and store your information.  Alectrona follows the EU’s General Data Protection Regulations (“GDPR”) when handling the data of all of our customers. We process data both as a Processor and Controller as defined by the GDPR.

What personal data does Alectrona collect?

We collect certain personal information about visitors and users of our platforms. The most common types of information we collect include things like: first and last name, email addresses, professional contact details, IP addresses, online form responses, and web analytics and cookie data.


What information is included in web analytics and cookie data?

When you visit our platforms, generally anonymous information is recorded that does not reveal your identity. If you complete an online form on our site, some of this information could be associated with your account. The following kinds of details are what tend to be collected:
● your IP address or proxy server IP address
● the domain name you requested
● the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection

● the date and time of your visit to the website
● the length of your session
● the pages which you have accessed
● the number of times you access our site within any month
● the file URL you look at and information relating to it
● the website which referred you to our platform
● the operating system which your computer uses

Occasionally, we will use third party advertising companies to serve ads based on prior visits to our various platforms (i.e. our website, Facebook,
etc.).  For example, if you visit our platforms, you may later see an ad for our products and services when you visit a different site or use the Google Search Engine.


Why does Alectrona need to collect and store personal data?

Alectrona needs to collect personal data for managing Apple devices, providing support services, and direct marketing activities. We are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
Our website does not require any form of registration, allowing you to visit our site without telling us who you are. However, some of the services we provide require you to provide us with personal data. If you choose to withhold that personal data, we may not be able to provide services or respond to your inquiry.


How will Alectrona use the personal data it collects about me?

Alectrona will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR) in order to fulfill contractual obligations with you, or to take necessary steps to fulfill contractual obligations with you. We may also use the data we collect from you to help manage our relationship with you, verify your identity when you use our services, inform you of operational news about our services (such as system outages or holiday schedules), manage our legal and operational affairs, and comply with financial, operational, and security audits.

With your consent, we also will provide you with promotional information about our services, including new offerings and training and events offered by us and our partners.
Alectrona is also required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

Does Alectrona collect sensitive personal data about me?

If personal data covered by this Privacy Policy is to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized, or if it is to be disclosed to a non-agent third party in a manner not outlined in this Policy, Alectrona will provide you with the opportunity to opt out of such use or disclosure. Requests to opt out should be directed to us as described in the "How do I contact Alectrona" section below.
Alectrona does not collect sensitive personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs. Alectrona will not collect, use or disclose this kind of information for any purpose unless we obtain your explicit affirmative consent through an “opt-in” system.

Will Alectrona share my personal data with anyone else?

Alectrona may pass your personal data on to third-party service providers contracted to Alectrona in the course of providing service to you. Any third parties that we may share your data with are required to store your data in accordance with applicable GDPR protections, and to use that data only to provide you with the services which we agreed to provide to you.
We may also share some of your data with our professional advisers (e.g. lawyers, accountants, financial advisers, etc.) and regulators and government authorities in connection with our compliance procedures and obligations. If you’re accessing our services from outside the United States, please be aware that you are sending information (including personal data) to the United States. That information may then be transferred within the United States or back out of the United States to other countries outside your country of residence, depending on the type of information and how we store it. These countries (including the United States) may not have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal data will at all times continue to be governed by this Privacy Policy.
In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Such disclosures will be made only as permitted by applicable laws and in line with our commitment to transparency and privacy protection under the DPF Principles.

Onward Transfer: EU-U.S. Data Privacy Framework (DPF) & UK Extension

We ensure that any onward transfer complies with the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the
EU-U.S. DPF by requiring third parties to implement stringent data protection measures. Furthermore, Alectrona remains fully liable for any misuse or mishandling of your data by these third parties if they fail to uphold the required standards. You can read more about DPF principles on onward transfers here.

How long will Alectrona keep my data?

We retain your personal information for as long as is necessary to provide services to you and others, and to comply with our legal and contractual obligations. If you no longer want us to use your personal information, you can request that we erase your personal information. Please note that if you request we erase your personal information, we will retain information from deleted accounts as necessary for our legitimate interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

What rights do I have regarding my data?

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
● Right of access – you have the right to request a copy of the information that we hold about you.
● Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

● Right to be forgotten – in certain circumstances, you can ask the data we hold about you be erased from our records.
● Right to the restriction of processing – you have the right to restrict the processing of your data in certain circumstances, such as when you
contest the data’s accuracy.
● Right of portability – you have the right to have the data we hold about you transferred to another organization.
● Right to object – you have the right to object to certain types of processing such as direct marketing.
● Right to object to automated processing, including profiling – you also have the right to not be subject to the legal effects of automated
processing or profiling.
● Right to review: in the event that Alectrona refuses your request under rights of access, we will provide you with a reason as to why.

How Can I Access My Personal Information?

You can can contact Alectrona to:
● make a request to access the personal information we hold about you and to request corrections of any errors in that data.
● close the account you have with us, subject to the terms of your agreement with us.
● ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or
restrict its processing.
● object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.
To make an access or correction request, contact us at letstalk@alectrona.com.

What forms of ID will I need to provide in order to access my data?

In order to protect your personal data, Alectrona may require one of the following forms of ID when information on your personal data is requested:
● Passport
● Driver’s Licence
● Birth Certificate
● Utility Bill (from last 3 months)

Our Pledge: EU-U.S. Data Privacy Framework (DPF) & UK Extension

Alectrona complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Alectrona has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit here for more information.

How do I contact Alectrona?

If you wish to contact Alectrona about anything in this Privacy Policy, please contact us via the below:
● Name – Alectrona LLC
● Address – 2776 S Arlington Mill Drive #175, Arlington, VA 22206
● Email – letstalk at alectrona dot com
● Phone (US) – (+1) 571-210-0012
● Phone (UK) - (+44) 20 3900 1800
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Alectrona commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Alectrona at the information above for assistance.

Unresolved Complaints: EU-U.S. Data Privacy Framework (DPF) & UK Ext.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Alectrona commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Alectrona is subject to investigation and enforcement by the Federal Trade Commission (FTC).


Binding Arbitration: EU-U.S. Data Privacy Framework (DPF) & UK Ext.

If you have a privacy-related dispute that remains unresolved after exhausting all other available remedies under the Data Privacy Framework (DPF), you may invoke binding arbitration as outlined in Annex I of the DPF Principles.

Our organization is committed to arbitrating such claims in accordance with the procedures and conditions set forth in Annex I. To initiate this process, you must provide us with formal notice and comply with the requirements specified in the framework here. Binding arbitration is available as a final recourse to ensure your privacy rights are protected and disputes are resolved fairly.


When will you update this Privacy Policy?

We will need to change this policy from time to time to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do change the policy, we will make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

Alectrona Privacy Policy, effective date 25 May 2018, last updated 13 January, 2025