Important Note! This policy is not intended to replace or contradict local legislation, such as labor laws and the data protection privacy legislations, including any policies and procedures of Alphanumerics clients. If there is any contradiction between policies and procedures, or similar internal regulations of Alphanumeric and a client, the rules of the latter will prevail.
This Policy establishes for the Alphanumeric Group, and its affiliates or subsidiaries, hereafter referred to in this document as “Alphanumeric” or the “Company”, the rules regarding the privacy of personal data of website users. This document is a policy exclusively directed to the external public.
The External Privacy Policy on the Alphanumeric website describes the company policies and procedures on the collection, use, and disclosure of user’s information when using our services, as well as informing them about their data privacy rights and legal protections.
The website version can be accessed via: Privacy Policy (hs-sites.com)
The intention of the External Privacy Policy is to protect the security and integrity of Alphanumeric’s user’s website. This Policy describes how Alphanumeric collects and processes users’ personal when accessing the Company’s website, in accordance with the relevant data protection legislation.
This Policy refers only to the data collected and processed by Alphanumeric’s website and applies to the entire company including all subsidiaries and affiliates.
According to the data privacy legislation, especially the GDPR, if any personal data is processed, the organization/website owner must provide the user with a Privacy Policy upon accessing the website. This Privacy Policy provided must be concise, transparent, intelligible, easily accessible, and written in a clear format.
A specific privacy policy statement needs to contain the following information about the use of personal data:
(i) what information is collected;
(ii) for what purpose it is collected;
(iii) the technical means by which it is collected;
(iv) who sees the data subject’s information;
(v) how the data subject can access, verify its accuracy, and correct their information;
(vi) how long the data subject’s information is kept;
(vii) what security measures are taken to safeguard the data subject’s information, and;
(viii) who to contact if the data subject has questions or complaints (the privacy department or the DPO contact’s).
All the elements required by the data privacy legislation can be accessed on the External Data Privacy on the Alphanumeric website.
Alphanumeric – Alphanumeric is the term used to describe the Alphanumeric Group that consists of Alphanumeric System, Inc. (a US based company) and its affiliates, subsidiaries, and associates worldwide (hereafter referred to as the “company” or “Alphanumeric”).
Please consult the definitions described in the Privacy Policy available at Privacy Policy (hs-sites.com) and in the POL-DP-ASI 3.0 Data Privacy Accountability & Governance Policy.
This document follows the requirements for review and approval as defined in POL-ASI 001 Governance of Internal Policies, Standard Operating Procedures, and Instructions.
Whenever the information contained on the website need to be changed, it is necessary to modify this Policy (POL-DP-ASI 02.0) simultaneously.
The owner has identified the following areas to consult for review of changed to this document, when applicable:
This Policy impacts all those who have a direct, or indirect, relationship with Alphanumeric System, Inc. (a US based company) and its affiliates, subsidiaries, and associates worldwide and have access to the website.
Thank you so much for visiting the Alphanumeric website.
Alphanumeric Systems is committed to user privacy. This Privacy Policy describes how we collect and process your personal data during your visit/registration to our website in accordance with the European General Data Protection Regulation – GDPR – EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu).
(i) Introduction
According to this European Regulation, Alphanumeric may be considered as a controller of your personal data, which means that we can determine the purposes and means of the processing of your personal information. However, we will require your consent to collect your information during user registration and/or newsletter subscription.
Alphanumeric has a high priority to protect the data of our website visitors/users so that we can establish a loyal, secure, and transparent connection in compliance with your rights as the data subject.
The objective of this Privacy Policy (or “Policy”) is to explain exactly what is entailed in this process in further detail below.
(ii) Department/person responsible for personal data protection
Alphanumeric has a Data Protection Compliance Department that can be contacted at the following email address.
privacy-department@alphanumeric.com
We also have a Data Protection Officer based in Europe who can be contacted at the following email address:
dpo@alphanumeric.com
If you have any questions or concerns regarding this Policy, please don’t hesitate to contact our specialized department, as we will be pleased to assist you.
When you visit our website and/or use our online services your visit will be logged, and the following data may be collected:
IP address currently used by your device;
date and time;
browser type and operating system of your device, and;
pages accessed.
The purpose of collecting this data is optimizing and improving our website as well as our online services. The processing is legally based on legitimate interest, i.e. it is in our legitimate interest to protect our website and to improve the quality of our services.
Your personal data is only recorded if you provide it to us on your own account, e.g. as part of a registration, a survey, or an online application.
Alphanumeric has taken appropriate measures to ensure that the data provided to us during the registration is adequately protected in accordance with data protection laws.
a) Newsletter registration
If you are interested, you can subscribe to our newsletter to receive news and updates about Alphanumeric by clicking on this link: (put the link to the registration form here).
For this purpose, your email will be collected in the registration form with your express consent and will only be used to send the newsletter.
We inform you that your personal data will be processed until you unsubscribe from the newsletter by clicking on the “unsubscribe” link that is provided in each newsletter you receive from us. Please be advised that you will not receive any more newsletters from us after you unsubscribe.
This subscription will have a duration of 2 years, after which period we will send you an email requesting the renewal of this subscription.
b) User account registration
If you are interested, you can create a customer account on our website by clicking on the following link and filling in your personal information: (put the link to the contact form here).
The personal data you have provided in the registration form will only be processed to respond to your request and further support you in using our services. Filling out and submitting the contact form indicates an affirmative action by which you have given your consent for the data processing.
The following personal data will be collected:
First and last name;
Email;
IP address.
You can also let us know your areas of interest and you can leave a message with suggestions or questions.
The information that you provide in the registration form will only be processed for creating and maintaining your customer account.
Your personal data will only be recorded until you cancel your subscription. If you proceed with the cancelation, your personal data will be deleted without undue delay except where we are legally obliged by law to further store your data. Please note that you will no longer be able to use your customer account after it has been deleted. If you change your mind later, please proceed with a new registration.
You can cancel your registration any time by clicking on: (put the link to the cancelation here).
d) Cookies
When you visit our website, we use “cookies” to make your visit more enjoyable, in addition to allowing you to use certain functions, in accordance with GDPR and the ePrivacy Directive (Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002).
For more information about your rights under the ePrivacy Directive click on the following link: EUR-Lex – 32002L0058 – EN – EUR-Lex (europa.eu)
Cookies are small text files that websites place on your device as you are browsing. They are processed and stored by your web browser. Cookies are harmless and serve crucial functions for websites, and they can generally be easily viewed and deleted.
Some of the cookies we use are deleted after your browser session ends. However, other cookies can remain on your device and enable us or our partner companies to recognize your browser on your next visit.
It is possible to configure your browser so that you can be informed about all kinds of cookies that are in use. In this way, you can individually allow access to certain cookies while excluding the other ones. If you do not accept certain types of cookies, it is possible that certain functionality on our website will be limited.
To find out more, see the help function of your internet browser.
For more information about how we use cookies you can access our “Cookie Policy”.
e) Data transfer / data location
Third party service providers who process your personal data may be located in countries within and outside the European Union (EU) and the European Economic Area (EEA). Whenever possible, we aspire to ensure that these providers have an adequate level of data protection, even if personal data is transferred to a country outside the EEA for which there is no EU Commission adequacy decision.
Please note that transfers of personal data to other recipients are not carried out, except when we are required to do so by law. If you need more information about appropriate safeguards for the international data transfer or a copy of them, please contact our Data Privacy Department or our DPO, that can be contacted through the channels provided above on item 2.
We use email marketing service providers to manage and send emails to you:
Provider Name: HubSpot. Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy
We use third-party service provider to monitor and analyze the use of our Service.
Provider Name: Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Your data is located at our partner providers. For more information please visit:
Link to HubSpot data privacy: https://legal.hubspot.com/privacy-policy
Link to Zoom Info data privacy https://www.zoominfo.com/about-zoominfo/privacy-center
Link to ConnectWise data privacy: https://www.connectwise.com/company/privacy-policy
f) Data retention
Your personal data provided to us via our website will only be stored until the purpose for which it was processed has been fulfilled. Retention periods under commercial and tax law must be observed in accordance with the customs and laws of your locality.
In general, your data will be recorded in our system for subscription and/or registration for two years, after which period we will send you an email requesting the renewal of this subscription and/or registration. However, storage periods may also be amended due to our legitimate interest (e.g., to guarantee data security, to prevent misuse or to prosecute criminal offenders). This period will in any case be limited and we will contact you to have your registration/subscription renewed.
As a data subject, you have rights that Alphanumeric highly respects, according to the following descriptive list:
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a statutory or contractual requirement for us to process your personal data, it would interfere with our legal obligations if we were to stop. Further information on your rights is available from the links below: European Commission | Choose your language | Choisir une langue | Wählen Sie eine Sprache (europa.eu) or; EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu)
This Privacy Policy refers only to the data collected and processed by our website, and applies to the entire company, including all subsidiaries.
IF YOU ARE ONE OF OUR WORKERS, EMPLOYEES, OR CONTRACTORS, OR OTHERWISE MAINTAIN A CONTRACTUAL RELATIONSHIP WITH ALPHANUMERIC, PLEASE CONTACT YOUR LOCAL MANAGER OR THE RESPONSIBLE PARTIES, AS PER OUR CONTRACTUAL RELATIONSHIP AND/OR CONSULT OUR INTERNAL (AND/OR LOCAL) PRIVACY POLICIES RELATED TO YOUR AREA OF EXPERTISE OR PARTNERSHIP, WHICH CAN BE FOUND THROUGH THE CHANNELS YOU HAVE ACCESS TO.
However, we will require your consent to collect your information during user registration and/or newsletter subscription.
Alphanumeric has a high priority to protect the data of our website visitors/users so that we can establish a loyal, secure, and transparent connection in compliance with your rights as the data subject.
The objective of this Privacy Policy (or “Policy”) is to explain exactly what is entailed in this process in further detail below.
(ii) Department/person responsible for personal data protection
Alphanumeric has a Data Protection Compliance Department that can be contacted at the following email address.
privacy-department@alphanumeric.com
We also have a Data Protection Officer based in Europe who can be contacted at the following email address:
dpo@alphanumeric.com
If you have any questions or concerns regarding this Policy, please don’t hesitate to contact our specialized department, as we will be pleased to assist you.
| ASI | Alphanumeric Systems, Inc | INS | Instructions |
|---|---|---|---|
| CEO | Chief Executive Officer | IP | Internet Protocol |
| CIO | Chief Information Officer | IPsec | Internet Protocol Security |
| DP | Data Privacy | IT | Information Technology |
| DPO | Data Protection Officer | MS | Microsoft |
| FTP | File Transfer Protocol | SSL | Secure Socket Layer |
| GDPR | General Data Protection Regulation | TSL | Transport Layer Security |
| HTTP | Hypertext Transfer Protocol | VP | Vice President |
| HTTPS | Secure Hypertext Transfer Protocol | VPN | Virtual Private Network |
| HR | Human Resources |
POL-ASI 001 Governance of Internal Policies, Standard Operating Procedures, and Instructions Policy
POL-DP-ASI 3.0 Data Privacy Accountability & Governance Policy
| Version No. | Date of Change | Revised By | Approved By | Description of Change |
|---|---|---|---|---|
| 1.0 | 15Mar2022 | Patrícia Pereira, DPO | J Baucom, CIO | Initial Release |
| 2.0 |