Privacy Policy

1. Introduction

Welcome to the Alto.Money Privacy Policy! Use of the words “Alto,” “Pearl Labs,” “we,” “us,” or “our” refer to any or all Pearl Labs entities and their affiliates.

This Privacy Policy (the “Policy”) explains what information we collect, why we collect it, how we use and disclose it, your choices, any rights you may have, and how you can contact us about our privacy practices. By continuing to use Alto.Money or any of our services, you agree to the Policy. The Policy does not apply to third-party websites, products, or services, even if we provide links to them or they link to us.

Please take time to get to know and familiarize yourself with our policies and practices. You should be aware that we reserve the right to change the Policy with no notice to you. The most recent version will always be posted here on this page.

You further agree to our Terms of Use (the “Terms”) and understand that the Terms represent a binding agreement between you and us. By using any of our services, you also agree to our collection, use, and disclosure practices, as well as any other activities described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should immediately discontinue the access and use of any of our services.

NOTICE TO CALIFORNIA RESIDENTS: For users who are California residents and subject to the CCPA, please review this Privacy Policy and see the below Section “California Residents Rights Under the CCPA”, for a description of your rights with regard to your personal information (as defined by the CCPA), notice of collection, and additional disclosures.

NOTICE TO EUROPEAN ECONOMIC AREA RESIDENTS: For users who are located in the European Economic Area (“EEA”) and/or the UK and subject to the EU GDPR and/or the UK GDPR (together, the “GDPR”), please review this Privacy Policy and see the below Section, “EU/UK Based Users and the GDPR” for a description of your rights and other information related to the GDPR.

2. Personal Information We Collect

Personal information generally means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with or could reasonably be linked to an identified or reasonably identifiable individual.

For the avoidance of doubt, if we combine Personal Information with non-personal information, the combined information will be treated as Personal Information as long as it remains combined.

Information You Provide. We may collect the following information about you when you use any of our services:

Voluntarily Provided Information. We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email, or share additional information about yourself through your use Alto or any of our services We may also collect the feedback, suggestions, complaints, and reports that you send to us. Please note that we may also collect complaints about you from other users, which may include your Personal Information.

Content. Within any messages you send to us (such as feedback and questions to information support). You may choose to voluntarily provide other information to us that we have not solicited from you, and, in such instances, you are solely responsible for such information.

Information Collected Automatically. We do not automatically collect information from you when you access any of our services. If this changes, we would utilize this information to operate and ensure the security, reliability, and robust performance of any of our services. We may also use tracking technologies to automatically collect information including the following:

• Log Files, which are tools that track actions occurring on the site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We will only use strictly necessary cookies in connection with any of our services For the avoidance of doubt, the cookies that we include are essential for you to browse any of our services and use its features, including accessing secure areas of any of our services.

3. Use of Information

We reserve the right to collect and use, information for business purposes in accordance with the practices described below:

• Operating and managing any of our services performing services requested by you, such as responding to your comments, questions, and requests, and providing information support; sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; detecting, preventing, and addressing fraud, breach of Terms, and threats, or harm; and compliance with legal and regulatory requirements.

• Protecting the security and integrity of any of our services; improving any of our services and other websites, products and services; conducting promotions, such as hackathons, including to verify your eligibility and deliver prizes in connection with your entries; and fulfilling any other business purpose, with notice to you and your consent.\

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

4. Sharing and Disclosure of Information

If we share or disclose information that we collect, we do so in accordance with the practices described in this Privacy Policy. The categories of parties with whom we may share information include:

• Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.

• Service Providers. We share information with third-party service providers for business purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, information technology, storage, and transaction monitoring. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers that we engage with are restricted to only utilizing the information on our behalf and in accordance with our instructions.

• Professional Advisors. We share information with our professional advisors for purposes of audits and compliance with our legal obligations.

• Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

• Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

• Facilitating Requests. We may share information about you at your request or direction.

• Consent. We may share information about you with your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law.

5. Other Parties

We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with other parties, including when you leave the Site, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics

We do not use analytics services for this Site.

7. Your Rights & Choices

• Cookies. We will only use strictly necessary cookies. These cookies are essential for you to browse the Site and use its features, including accessing secure areas of the Site

• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to the online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the

Alto.Money and other of our services may not function correctly.

8. How We Protect Your Information

We take care in implementing and maintaining the security of the services and your information. We will take reasonable steps and use technical, administrative and physical security measures appropriate to the nature of the information and that comply with applicable laws to protect Personal Information against unauthorized access and exfiltration, acquisition, theft, or disclosure. Although we take enhanced steps to safeguard information, given the nature of information security, there is no guarantee that such measures will always be successful. We cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that such access will be prevented. If you feel that your privacy was not treated in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at [e-mail].

9. International Transfer.

Please note that some data recipients may be located outside the EEA and/or the UK. In such cases we will seek to ensure a similar degree of protection is afforded to it by ensuring that, where possible, Personal Information is generally transferred only to persons in countries outside the EU or the UK in one of the following circumstances:

• transfers only to such countries as approved by the European Commission or the equivalent entity in the UK as providing adequate level of data protection;

• to persons and undertakings to whom the transfer of such Personal Information is made pursuant to a contract that is compliant with the model contracts for the transfer of Personal Information to third countries from time to time approved by the European Commission (as supplemented where and if required) or the equivalent body in the UK;

• to persons and undertakings outside of the EU or the UK pursuant to other appropriate safeguards for the transfer of Personal Information; and

• only on one of the conditions allowed under the GDPR in the absence of (i) a decision by the European Commission or the equivalent entity in the UK that has deemed a country to provide an adequate level of protection for Personal Information (i.e. an adequacy decision) or (ii) appropriate safeguards such as a contract that is compliant with the model contracts for the transfer of Personal Information to third countries approved by the European Commission or the equivalent entity in the UK.

10. Children.

Alto.Money is not intended for children under the age of 18 and we do not knowingly collect Personal Information of children under the age of 18. If we learn that we have collected any Personal Information from a child under the age of 18, we will promptly delete it from our systems.

11. EU/UK Based Users and the GDPR

If you are an EU or UK data subject and the processing of your Personal Information is subject to the GDPR, please review this section in addition to the entire Policy.

Grounds for Processing. We will only process your Personal Information in circumstances where we have established a lawful basis to do so. Our lawful bases for processing that Personal Information include:

• Legitimate Interests. We process Personal Information for our legitimate business interest in managing and promoting our business, provided that our interest is not overridden by your interest. In identifying and relying on this basis for certain processing, we have weighed our legitimate interest as a business against your rights and freedoms and have determined that such processing will not unfairly impact your rights. If you would like further information on how we balanced these interests, you can contact us using the details below. Please note that you have a right to object to the processing of your Personal Information where that processing is carried on for our legitimate interest.

• Legal Requirements. We may need to process your Personal Information in order to comply with certain legal and regulatory requirements, including to establish, exercise or defend legal claims, respond to a judicial process, law enforcement or governmental agency.

• Contract. Depending on the circumstances, we may need to process your Personal Information for the performance of a contract to which you are a party, or related pre-contractual steps.

• Consent. We may process your Personal Information with your consent, as required by the GDPR. You have the right to withdraw this consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Your Rights under the GDPR. We respect your privacy rights and therefore you may contact us at any time and request:

• Access. You have the right to know we collect certain Personal Information about you and to ask us for copies of your Personal Information. Please use the contact details provided at the end of this Policy.

• Rectification. You have the right to request that we correct your Personal Information you think is inaccurate or incomplete.

• Objection to processing. You have the right to object to processing in some circumstances, including where we are using your Personal Information for our legitimate interests and for direct marketing purposes, including by opting-out of marketing communications by contacting us using the contact details provided at the end of this Policy.

• Erasure. You have the right to request that we erase the Personal Information we have collected about you in certain circumstances. The right to erasure is not absolute, and only applies if we no longer need your Personal Information to carry out the purpose that we collected it for, whilst in compliance with laws applicable to us; you have withdrawn your consent to our use of your Personal Information; you have objected to our use of your Personal Information and your interests outweigh our interests in using it; you believe we have processed your Personal Information unlawfully; or we have a legal obligation to erase your data.

• Restrict processing. You have the right to ask us to restrict the processing of your Personal Information in certain circumstances, including if you have concerns regarding the accuracy of your Personal Information, where you have made an objection to our use of your personal data; or if you believe we processed your Personal Information unlawfully, but you do not want us to delete it.

• Data portability. You have the right to receive a copy of the Personal Information that we collect about you in a way that is accessible and in a machine-readable format where the processing is based on your consent, the performance of a contract with you, or carried out by automated means. You have the right to request that such Personal Information be transmitted directly from us to another data controller, where technically feasible.

• Withdrawal of consent. You can withdraw your consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

We will store your Personal Information only for as long as necessary for the purposes for which it was collected, including to provide the Services and to comply with our legal obligations, resolve disputes and enforce our policies and agreements. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. If you wish to make a complaint regarding our handling of your Personal Information, you can contact us at [e-mail]. You may also make a complaint to the relevant supervisory authority for data protection issues. In the UK this is the Information Commissioner’s Office (“ICO”). Contact details for the ICO may be found at www.ico.org.uk.

12. California Residents Rights Under the CCPA

If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:

• Notice at Collection. Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.

• Request to Delete. Request that we delete any personal information about you that we have collected or maintained, subject to certain exceptions. For example, we may be required to retain the personal information for certain retention periods in order to comply with legal and regulatory requirements under applicable laws and regulations to which we are subject. If you wish to exercise this right, please contact us at: [e-mail]

• Request to Know. Request that we provide you with: (i) the categories of personal information we have collected about you; (ii) the categories of sources from which we collected the personal information; (iii) the business or commercial purpose for collecting or selling the personal information; (iv) the categories of third parties with whom we share personal information; (v) the specific pieces of personal information we have collected about you; and (vi) the categories of personal information about you we have disclosed for a business purpose.

• Not to Be Discriminated Against. Not be discriminated against because you exercised any of your rights under the CCPA.

• Opt-Out of Sale. Request that we not sell your personal information if a business sells your personal information (we do not).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted or required by the CCPA or another law or regulation.

How to Submit a CCPA Rights Request. You can submit a Request to Know or Request to Delete via email to [e-mail]. When you submit a Request to Know, Request to Delete, or Request to Opt-Out, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name, email address and a copy of government issued identification. Any information gathered as part of the verification for a Request to Know, Request to Delete, or Request to Opt-Out will be used for verification or opt-out purposes only.

If you would like to use an authorized agent to submit a Request to Know or a Request to Delete, we may request proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request. We will deliver responses to verifiable consumer requests, free of charge by mail or electronically, at your election. We will try to respond to your Requests to Know or to Delete within forty-five (45) days of receipt of the request. If we require more time, we will try to inform you of our need for an extension. Even with an extension, we will try to provide a response within ninety (90) days of initial receipt of the request.

Notice at Collection and Use of Personal Information.

• What Type of Information We Collect. Depending on how you interact with us, we may collect the categories of personal information listed above in this Policy.

• How We Use Collected Information. We may use your personal information for the business or commercial purpose listed above in this Policy.

• What Information We Have Collected and the Sources from Which We Collected It. In the preceding 12 months, and depending on how you interact with us, we may have

• Our Disclosure, Sharing of Personal Information. We do not sell your personal information. We do not knowingly sell the personal information of California residents under 16 years old. We may disclose your personal information to certain third parties for a business purpose.

• We may share your personal information with our service providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within collected all or some of the personal information listed above in this Policy.

• Purposes for Collecting Personal Information. We may collect the personal information for one or more of the following business or commercial purposes described in the other exemptions or exceptions in or as otherwise permitted by the CCPA.

13. Contact Us

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email: [e-mail]

By mail: Pearl Labs LTD.

Quijana Chambers,

P.O. Box 3159, Road Town, Tortola, British Virgin Islands

If you experience any difficulties accessing the information here, please contact us at [e-mail].