Privacy Policy
alphaTUB Service Privacy Policy
alphaTUB (hereafter called “alphaTUB” “us” or “we”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy describes our collection and use of personal information collected from you through the alphaTUB Platform, alphaTUB, online and/or mobile services, websites, and software provided on or in connection with www.alphaTUB.com (collectively, the “Service”), which are offered through (i) www.alphaTUB.com, (ii) mobile applications associated with www.alphaTUB.com, and (iii) any other alphaTUB website, app, or online service which links to this Privacy Policy. “You” or “your” means a visitor or a user (whether signed in or not) of our Service. Your use of the Service is conditioned on your acceptance of this Policy. Please read this privacy policy (“Policy”) carefully before using the Application, Website, its services and products, along with the Terms of Service (“TOS”) provided on the Application and on the alphaTUB Website.
A note about Student Data: This Service may be purchased by providers of educational services, such as schools, school districts, or teachers (collectively referred to as “Schools”) that use our services for educational purposes. When alphaTUB contracts with a School to provide the Service, we may collect or have access to Student Data (defined below), which may be provided by the School or by the student. We consider such Student Data to be strictly confidential and in general do not use such data for any purpose other than improving and providing our Services to the School or on the school’s behalf. However, ff you reside outside India your information will be transferred, processed and stored in accordance with the applicable data protection laws of India. However, it will be our endeavor to maintain that our collection, use and sharing of Student Data is governed by our contracts with the School and any applicable laws and regulations including, in the U.S., provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and applicable state laws. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your School directly. See Section 11 to understand the principles which guide our collection, use and disclosure of Student Data.
Use these links to navigate to the following topics of interest:
- What information does alphaTUB collect about you?
- How alphaTUB uses the information we collect
- How does alphaTUB share your information?
- Third-party tracking and online advertising
- How to control e-mail communications
- How to access, update or delete your personal information
- How long does alphaTUB retain your information?
- How does alphaTUB protect your information?
- Region-specific disclosures
- How does alphaTUB protect children’s privacy?
- How does alphaTUB protect Student Data and comply with laws?
- Links to other websites and services
- Public Forums
- Your Consent
- Updates to this Policy
- Contact Us
- What information does alphaTUB collect about you?
alphaTUB collects information in several ways from different parts of the Service. The circumstances in which “users” (which could be teacher or parent or guardian referred as “Parent or User interchangeably”) may provide information include, without limitation, when they register for the Services, to access various content or features including sharing on social media or similar platforms, sign up to receive emails or other communications, or by enabling sharing of content among users or through the use of community features such as including our parent community blogs and discussion forums, participate in promotions, use a send-to-a-friend feature, or directly contact us with questions or feedback. The information that parents or teachers may provide includes might also include various types of User Generated Content, see Content Uploaded by You, such as content in the TUB Gallery, TUB Sheets, TUB Cards, TUB Math, TUB Science, TUB Signs, TAGS or any other user Generated content which is created or shared by the App users. Other than as provided for in this Policy, we won’t share or disclose this kind of information unless we get your permission. Other information that we collect may not identify you personally. This kind of information may be shared or disclosed in an aggregate form, used to personalize your experience, and so on.
Information you provide to us. The type of personal information we collect may vary depending on your account type.
- School Information. When a teacher, school administrator, or other authorized person associated with a School registers for an account on our Service or corresponds with us, we may collect personal information such as a name, e-mail address, payment information, username and password, and information about the School.
- Student Information. Once registered, a School may provide information about its students, such as student names or other identifiers, passwords, e-mail address for the student or the student’s parent or legal guardian, and educational level and topic of study. Personal information collected from or about students, along with other information associated with that personal information is “Student Data.” The School may elect to provide usernames or identifiers which are not readily identifiable to anyone outside of the School community in lieu of a full student name, at its discretion. Additionally, some Schools may elect to use a single-sign on (SSO) service like G Suite for Education rather than usernames and passwords to authenticate student access.
- Parent and Child Information. When a parent or guardian (“Parent”) registers for an account on our Service or corresponds with us, we may collect personal information such as a name, e-mail address, payment information, username and password. We may also collect information about the child(ren) authorized by the Parent to use the Service through the Parent’s account, including a profile name for the child user and selection of a profile avatar. Each child user profile must be associated with a Parent account, and children cannot access the Service without the Parent first signing in to the Parent account with the Parent’s sign in credentials.
- Learning and Activity Information. During the course of providing the Service, we collect information about your use of the Service, as well as any information that you submit to the Service, such as answers to questions or content or messages posted or shared through the Service. In addition, we may ask you for personal information at other times, such as when you contact our technical support team, send us an e-mail, complete a user survey or otherwise communicate with alphaTUB.
Information we receive automatically from your use of our Service. Like most websites and online services, alphaTUB and our vendors automatically collect certain types of usage information when you visit www.alphaTUB.com, read our e-mails, use our Service or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, Locally Stored Objects (LSOs such as Flash or HTML5), log files, and similar technology (collectively, “tracking technologies”), and we may use third party providers to collect this information on our behalf. These tracking technologies collect information about how you access and use the Service (e.g., referring / exit pages and URLs, how frequently you access the Service, the pages you view, the links you click, and other actions you take on the Service); information about your browser and information about the device(s) you use to access the Service (e.g., Internet Protocol (IP address), browser type, browser language, Internet service provider, device type, model and manufacturer, a unique ID that allows us to uniquely identify your browser, device or account, operating system brand and model, and whether you access the Service from multiple devices). We may also collect information about your geographical location data at the city level. We may collect analytics data, or use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics and behaviors of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to secure the Service, improve the Service, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, tracking technologies help us to:
- Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.
- Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit.
- Customize the function and appearance of the pages you visit based on information relating to your account; for example, to default you to a particular grade level, or to remember customized settings for a report.
- Track website usage for various purposes including website optimization, website improvement, sales, marketing, and billing.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign in) may not function properly if your cookies are disabled. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects — including how to manage privacy and storage settings for Flash cookies — on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third-party tracking and online advertising” below.
Content Uploaded by You
- you have the right to publish such Content (whether by virtue of ownership of the intellectual property rights in such Content or as a result of the grant to you of a license to use and publish such Content);
- the publication of such Content on the Website is not likely to bring our reputation into disrepute.
- such Content:
- is purely for your personal and educational use
- is not illegal in the India or in any jurisdiction in which such Content
- does not promote terrorism or assist any person in committing or
- such Content does not encourage or promote any political cause or
- such Content is not of a pornographic, sexually explicit, violent,
- such Content does not promote racism, bigotry, hatred or physical
- such Content does not contain libelous or otherwise untrue
- such Content does not depict any person less than 18 years of age
- such Content is not likely to cause offence to any viewer of such
- such Content is true and not misleading in all material respects might reasonably be expected to be viewed and does not promote any illegal activity; procuring the commitment of any act of terrorism; affiliation or any religious views; offensive or obscene nature; harm of any kind against any person or group of persons; statements about any person (whether living or dead) and does not harass or advocate the harassment of any person; (whether or not decent or indecent); Content; (including without limitation any information and images posted by you relating to your personal statistics, age, occupation and relationship status);
- does not promote or relate to any pyramid scheme, contest, lottery, sweepstake, or barter activity; and
- is not likely to lead a viewer to assume that you are related to, authorized by or otherwise represent us.
- You acknowledge and agree that we may review and approve some or all Content (at our sole and absolute discretion) uploaded to alphaTUB Platform and/or transmitted by you to any other user via alphaTUB Platform. We shall be entitled to remove any Content without notice and without giving any reason.
- Further you acknowledge and agree that we may be required to provide information about the origin of any unlawful Content published and/or the occurrence of any unlawful activity occurring on the Website to any police or judicial authority in any country in which such Content has been viewed and is illegal and you hereby irrevocably authorize us to provide such information to such persons (on request or in our discretion) without consulting or informing you.
- If you view any Content on the alphaTUB Platform that you believe breaches any of the above restrictions, you undertake and agree to report such content to us as soon as is reasonably possible.
- You acknowledge and agree that we shall at all times be permitted to distribute, display, or use for promotional purposes and in advertising or any third-party website (including without limitation any social network) any Content uploaded by you to the alphaTUB Platform. Further we may without your consent and/or notifying you post user Content on our profiles on social media websites.
- On submitting or uploading any Content to the Resource section of the Website, you grant us a non-exclusive license to use, reproduce, distribute, prepare derivative works of, display and transmit such Content as we reasonably see fit.
- You hereby acknowledge that we have no control over how other users of the alphaTUB Platformuse your Content. By submitting Content, you acknowledge and agree that We shall not be liable for any discrimination or unlawful activity by any user in relation to their use of your Content.
- You hereby acknowledge and agree that you cannot delete any Content You upload to the alphaTUB Platform without our consent. We may retain any deleted Content in our archives as required by our back-up systems purely at our discretion.
- Currently, alphaTUB retains user data while an account is active and for a period of at least ninety-nine years afterwards thereon. alphaTUB may alter this practice according to legal and business requirements. For example, it may lengthen the retention period for some data if needed to comply with law or voluntary codes of conduct. Unless otherwise prohibited, it may shorten the retention period for some types of data if needed to free up storage space.
- How does alphaTUB share your information?
- Third-party tracking and online advertising
- How to control e-mail communications
- How to access, update or delete your personal information
- How long does alphaTUB retain your information?
- How does alphaTUB protect your information?
- Region-specific disclosures
- Right to Know. The right to request to know more about the specific pieces or categories of personal information we have collected, the categories of data sources, and the categories of third parties with whom we have shared the personal information for a business or commercial purpose in the last 12 months.
- Right to Request Deletion. The right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- Right to Opt Out of Personal Information Sales. The right to direct us not to sell (as such term is defined by the CCPA) personal information we have collected about you to third parties.
- The processing is necessary to perform our contractual obligations in our Terms of Service or other contracts with you (such as to provide you the Service as described in our Terms of Service);
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Service, marketing the Service, such as new features or products that may be of interest, and promoting safety and security as described above.
- Right of access and portability. The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
- Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
- Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
- Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
- How does alphaTUB protect children’s privacy?
- How does alphaTUB protect Student Data and comply with laws?
- alphaTUB does not collect, maintain, use or share Student Data beyond that needed for an authorized educational or school purpose, or as authorized by our agreement with a School.
- alphaTUB does not use or disclose Student Data for targeted advertising purposes.
- alphaTUB does not build a personal profile of a Student other than in furtherance of a K-12 School purpose, or as authorized by a parent.
- alphaTUB will maintain a comprehensive data security program designed to protect the types of Student Data maintained by alphaTUB.
- alphaTUB will not knowingly retain Student Data beyond the time period required to support the School’s purpose, unless authorized by the parent.
- alphaTUB will clearly and transparently disclose our data policies and practices.
- alphaTUB will never sell Student Data unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets, in which case we will use our best efforts to ensure the successor entity honors the privacy commitments made in this policy and/or we will notify the School of such a sale and provide the School an opportunity to opt-out by terminating its account before the data transfer occurs.
- We will not make any material changes to our Privacy Policy or Terms of Service that relate to the collection or use of Student Data without first giving notice to the School and providing a choice before the Student Data is used in a materially different manner than was disclosed when the information was collected.
- Links to other websites and services
- Public Forums
- Your Consent
- Updates to this Policy
- Contact Us
alphaTUB Service Children’s Privacy Policy
alphaTUB does not permit children under the age of 13 (“Child”) to create an account and does not knowingly collect personally identifying information from children under the age of 13 without the consent and at the direction of a parent.
alphaTUB permits Parents to set up child profiles associated with the Parent account so that children may access the Service under the Parent’s supervision. We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service and to ensure that Parents have access to and control of their child’s use of the Service.
This Children’s Privacy Policy applies to all users of child profiles associated with a Parent account, regardless of the age of the child.
By creating a child profile associated with a Parent account and permitting your child to use the alphaTUB Service, you expressly agree to the practices described in this Children’s Privacy Policy and you consent to the collection, use, and disclosure of your child’s personal information as described herein.
- How to create a child profile associated with a Parent account.
A parent must either create a free user account or obtain a paid user account by making payment or by using a credit card to register an account with alphaTUB and agree to the terms of our Terms of Service, Privacy Policy and this Children’s Privacy Policy. Once the account creation & registration process is complete, the Parent may create individual profiles for each child(ren) authorized by the Parent to use the Service through the Parent’s account. Each child user profile must be associated with a Parent account, and children cannot access the Service without the Parent first signing into the Parent account with the Parent’s login credentials. After the Parent logs into a Parent account, the child user selects the child profile to use the Service.
- What information does alphaTUB collect from or about a child and how does alphaTUB use this information?
Information you provide us. Through the Parent’s account set-up, the Parent provides information about the child(ren) authorized by the Parent to use the Service through the Parent’s account, including a profile name and selection of a profile avatar. We recommend that the Parent selects a profile name that does not include the real name or identifying characteristics of the child. The Parent may also create a “secret word,” which functions similar to a password to access the child profile, though it cannot be used to sign in to the Service without the Parent first signing in to the Parent’s account using the Parent’s login credentials. alphaTUB does not request a birthdate or any additional personal information from the user of the child profile, though the child may change his/her profile avatar, secret word and profile name (of course, the Parent will see these changes through the Parent’s account dashboard).
alphaTUB uses this information to provide the Service to the user of the child profile. alphaTUB uses the e-mail address provided by users of Parent accounts to communicate messages about the account, such as subscription notices and password resets, and the child user reports and awards.
Information collected from the Child’s use of the Service. During the course of providing the Service, we collect information about the user of the child profile’s use of the Service and information submitted to the Service, such as answers to questions, for the purpose of providing feedback to the user and for compiling reports and awards.
When your Child accesses the Service through the Parent’s account, we automatically collect and store usage information as well as information about the device used by the Parent and Child to access the Service. For example, we collect an IP address, location (at the city level), browser type, language preferences, and other information about the device used to access the Service, such as the device type, model and manufacturer and a unique identifier which allows us to uniquely identify your browser, device, or account, as well as account usage information such as the day/time stamp, referring/exit pages and URLs, pages viewed, and similar information. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, log files, and similar technology (collectively, “tracking technologies”), and we may use third party providers to collect this information on our behalf. This data collection is explained in greater detail in Section 1 of our Privacy Policy under the sub-heading “Information we receive when you use the Service.”
We use this information to secure and improve the Service, to provide personalized content and information, to remember you when you return to the Service at a later time or using a different device, to improve the Service, to save you time, to provide better technical support, to track website usage and other similar purposes.
- How we disclose information
alphaTUB may share or disclose a child’s personal information as needed to provide our Service or with your consent or permission. For example, we share information with our trusted vendors, third party service providers and individuals to provide services for us on our behalf, which may include analytics providers and hosting services. We may also share personal information if we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of alphaTUB, its users, or the public; or (e) as required or permitted by law.
If alphaTUB becomes involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets, personal information may be transferred or disclosed in connection with the business transaction, subject to any applicable laws.
We may also share aggregate or de-identified information in a manner that cannot be reasonably used to identify an individual user.
- Third party tracking and online advertising on the Service
alphaTUB does not display any targeted advertising on the Service.
We work with third-party online advertising networks which use tracking technologies (such as cookies, web beacons and similar technologies) to collect information about visitors to direct targeted advertising on other websites or services. You can learn more by referring to Section 4 of the alphaTUB Privacy Policy called “Third party tracking and online advertising,”.
We take certain steps designed to avoid these third-party tracking technologies from collecting information from users of Child profiles for targeted advertising purposes, by taking steps to disable such tracking technologies once a subscriber to our Service (e.g., the Parent) logs into our Service, maintaining the preferences for as long as the subscriber is signed in, and by remembering these preferences the next time you return to our Service using the same browser or device. Please note that we rely on cookies to identify whether you are a Subscriber and if you delete or block cookies you may also delete the alphaTUB cookie which allows us to recognize returning users and prevent subscribers from receiving targeted alphaTUB advertisements on other websites or services. These preferences are unique to the browser or device you used to sign in to the Service. Therefore, third-party tracking technologies may be present if you navigate to certain pages of our website using a new browser or device until you sign in to your account on that browser or device.
If you do not want to receive targeted advertising from alphaTUB based on your visit to our website, you can use the below link to request that alphaTUB take steps to prevent third-party advertising networks from using information about your visit to our website to display targeted alphaTUB advertisements to you on other websites or services on behalf of alphaTUB. alphaTUB cannot, however, guarantee that such steps will eliminate all collection and/or display of targeted advertising, and it may take some time for your request to take effect. Such requests will not prevent you from receiving contextual advertising or other types of advertisements that are displayed without taking into consideration whether you have previously visited www.alphaTUB.com (for example, advertisements shown on the basis of a search term keyword). Such requests will not stop the collection of information for purposes other than advertising (e.g., for website analytics). This opt-out requires the setting of a cookie in your browser to record your request (and thus will no longer be effective if the required cookie is deleted), will be effective only in the browser from which you make the request, and will be effective for a maximum of one year from the request. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to make the request again. You may make additional requests at any time.
Write to us at compliance@alphaTUB.com to request not to have information about your visit to https://www.alphatub.com/ tracked for the purpose of displaying targeted alphaTUB advertisements on other sites or services.
- How to access and delete your child’s personal information
The Parent may review the information collected from the user of the child profile at any time by signing in to the Parent account. The Parent may refuse to permit the further collection of the child user’s information by no longer providing the child user access to the Service through the Parent’s account.
alphaTUB will retain the personal information collected from and about the user of the child profile for as long as necessary to provide the Service and will de-identify or soft-delete user uploaded content and the personal information after the termination of the Parent’s subscription account in accordance with our standard data retention policy or until we receive a deletion request. To request deletion of personal information of a user of a child profile at any time, please contact us at compliance@alphaTUB.com
- Our practices involving Schools
When alphaTUB is used by a School in an educational setting, the School may authorize alphaTUB to collect information from a child under 13. If you are a Parent whose child accesses the alphaTUB Service through a School, please contact the child’s School to request to access, review and/or delete your child’s information. alphaTUB will process such requests promptly as directed by the School.
Please refer to Section 11 of the alphaTUB Privacy Policy to learn more about how alphaTUB protects Student Data, including Students who may be under the age of 13, when the Service is used by a School.
- Region-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer to the Region-Specific Disclosures section of our Privacy Policy to learn more.
- Contact us
If you have questions or concerns about this policy or about our use of information provided by a user of a child profile, please contact us: compliance@alphaTUB.com
alphaTUB Privacy Shield Statement
alphaTUB complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, Switzerland, and the United Kingdom transferred to the United States pursuant to Privacy Shield. alphaTUB has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Purpose
The purpose of this alphaTUB Privacy Shield Statement (“Statement”) is to outline how we comply with the Principles with respect to the personal information we collect. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our Privacy Policy. If there is any conflict between this Statement and the Privacy Policy, this Statement shall prevail.
Scope
This Statement applies to any personal information received by alphaTUB from the European Union, Switzerland, or the United Kingdom in reliance on Privacy Shield.
alphaTUB Data Processing Activities
alphaTUB at times acts as a data processor or a data controller when processing personal data transferred from the EEA, Switzerland, or the United Kingdom. Though the types of data alphaTUB collects and processes may vary depending on the Account Terms and our customers’ preferences, data we collect typically includes personal information relating to students and schools, billing and payments information, web browsing behavior and other information relating to a user’s device used to access the services, and other information as described in our Privacy Policy. alphaTUB processes this data to provide our business and consumer services; billing and payments; customer service and product support; communications and marketing; online advertising; analytics to inform and improve our services; and for other internal purposes.
Principles
- Notice. We will provide individuals with notice of our data collection and processing practices in our Privacy Policy, describing what personal information we collect, the purpose and use of personal information, the categories of third parties with whom we may share such information (and the purposes for which we do so), the individual’s right to access such information, the choices and means through which the individual may limit the use and disclosure of personal information, and other disclosures consistent with the Notice Principle.
Where we process personal information on behalf of an educational or other institution (each a “School”) with which you have a direct relationship, we will assist them upon request to provide appropriate notice to you.
You can read about our data collection and processing practices in our main Privacy Policy.
- Choice. We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents and service providers, or before we use it for a purpose other than it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to compliance@alphaTUB.com
Where we process personal information on behalf of a School, we will work with that School to comply with any individual’s choices for limiting use or disclosure of personal information, if possible.
- Onward Transfers (Transfer to Third Parties). alphaTUB may transfer personal information to certain third parties (as described in our Privacy Policy). Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with alphaTUB’s Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, alphaTUB may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.
In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Security. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
- Data Integrity and Purpose Limitation. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. Where we receive personal information from a School, it shall be the School that determines those purposes. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
- Access. EU and Swiss individuals have the right to reasonable access to the personal information about you that we hold. On request, we will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated. Where we process personal information on behalf of a School, we will direct any individual requests for access or to limit use or disclosure to the School, and we will work with such School in complying with such requests in accordance with applicable law and our obligations under Privacy Shield.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to compliance@alphaTUB.com. If requested to remove data, we will respond within a reasonable timeframe.
- Jurisdiction and Enforcement. As part of our participation in Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission.
- Lawful Requests. alphaTUB may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Contact alphaTUB and Recourse.
In compliance with the Privacy Shield Principles, alphaTUB commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. If you have any questions about this Statement or the information that we collect from you in reliance on Privacy Shield, please contact us at compliance@alphaTUB.com or write to:
alphaTUB Innovations Private Limited,
In the event that you are concerned about how personal information you have provided to alphaTUB has been used, please address your inquiry or complaint first to us at the address listed above. alphaTUB takes all concerns about privacy and use of personal information very seriously and shall endeavor to reply to you within 45 days of receiving a complaint.
Last Updated: January 01, 2025