Privacy Policy

Name and Address of the Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), or any other law related to data protection is ALOHA MOBILE LTD, a limited liability company, registered in the Republic of Cyprus under registration number HE 352095, having its registered office at: Spyrou Kyprianou 84, 4004, Limassol, Cyprus.

Data we collect from you

We are extremely committed to keeping your information safe. We make sure that we do not collect your personal information, unless you provide it to us on your own initiative and/or it’s necessary for us to provide our services, as described in Aloha Browser Policy and in this Policy. To use Aloha Profile, the only personal information we collect is your email. Also, our servers will keep a unique identifier for you, which will then be automatically provided on your synchronized devices under your Aloha Profile.

Two-Factor Authentication (2FA)

To enhance the protection of your data, we offer the option to enable Two-Factor Authentication (2FA) for your account. This feature is designed to add an extra layer of security to your account and ensure that only authorized users can access it. At Aloha, 2FA involves the use of a secondary method, such as a one-time code sent to your email address.

Collection and Use of 2FA Information

To enable 2FA for your account, we may collect, and store information related to the 2FA method, such as your email address. This information will only be used for the purpose of sending verification codes and will not be shared with any third parties for marketing or other purposes.

When you choose to enable 2FA for your account, we may collect and process the following information:

• Contact Information: We may collect and associate your email address with your 2FA settings to send verification codes or notifications.
• Authentication Data: We may collect, and store data related to your 2FA activities, such as the IP address, the location from where authentication requests were sent, the date and time of authentication requests, and the device or method used.

Purpose of Collecting 2FA Data

We collect 2FA data for the following purposes:

• Security: The primary purpose of collecting 2FA data is to enhance the security of your account by ensuring that only authorized individuals can access it.
• Account Recovery: In cases where you need to recover your account, this data may be used to help verify your identity.
• Account Monitoring: We may use this data to monitor and prevent unauthorized access to your account.

Opting Out of 2FA

You have the option to enable or disable 2FA for your account at any time. If you choose to disable 2FA, please be aware that your account may be more vulnerable to unauthorized access. We strongly recommend keeping 2FA enabled for enhanced security.

Sharing information with other companies and Disclosure of Personal Data

Your personal data (name, contact information, email address) may be shared with third parties - service providers who participate, directly or indirectly, in the development of Aloha Profile's commercial activities, such as providing support, analyzing data, provision and support of the website's functionalities and resources. Under the terms of your engagement, these service providers are not permitted to share or use your data for any purpose other than providing services to us. We clarify that the personal information collected is accessible only to those who need to know it to carry out relevant activities, respecting the purpose for which it was provided.

Some of the service providers mentioned above may be located abroad and, in this case, Aloha Profile adopts additional safeguards to guarantee an adequate level of protection of personal data, in accordance with the provisions of the relevant legislation.

Other situations in which disclosure may occur:

• Upon court decision or request by government oversight bodies;
• Data transferred to public bodies to comply with current legislation;
• When we consider disclosure to be the appropriate course of action in connection with efforts to investigate or prevent illegal activities, suspected fraud, or other wrongdoing, as well as to protect and defend the rights, property or safety of our organization, our users, our employees or others and to comply with applicable law or cooperate with law enforcement agencies, or to enforce our terms and conditions or other agreements or policy.
• In the event of a substantial business transaction, such as the sale of our business or portion thereof, a divestiture, merger, consolidation, reorganization or sale of assets, or in the unlikely event of bankruptcy, including to potential or actual purchasers in connection with any of these transactions, except for consumers subject the California Consumer Privacy Act of 2018 ("CCPA") as reported below, in specific topic targeted to this document.
• We may publicly share collected but non-personally identifiable data (anonymized data) in order to show trends about the general use of our services.

How long will we keep your information

We will keep your personal information for the entire period you use Aloha Profile adding a year from the date of your last login. After this period, the personal data we hold about you will be securely deleted. However, you can choose to delete data at any time in accordance with "Your Rights" listed below.

Minors' data

Aloha Profile is not directed at anyone under the age of 18. We also do not voluntarily collect information from minors. If we discover that we have collected personal information from a child in violation of the applicable personal data privacy legislation, we will do our best to delete this information as quickly as possible.

Security

To protect your personal information, we take reasonable precautions and follow industry best practices. For example, we use TLS protocols to encrypt data in transit so that it cannot be intercepted. We encrypt your stored data with the AES256 algorithm.

Your rights

Aloha Profile's personal data holders have certain rights with regard to their personal data and can exercise them via email: dpo@alohabrowser.com. The rights of holders are:

• Confirmation of the existence of personal data processing;
• Access to personal data, in accordance with applicable legislation;
• Correction of incomplete, inaccurate or outdated personal data;
• Portability of personal data;
• Deletion of personal data, when they are processed based on the holder's consent or when the data is unnecessary, excessive or processed in non-compliance with applicable legislation;
• Request for information about the shared use of personal data;
• Revocation of consent, when applicable.

Aloha Profile will always evaluate the best way to comply with the request to exercise any of your rights. However, Aloha Profile may fail to comply with your request, in whole or in part, in specific situations protected by law, such as, for example, to comply with a legal obligation or a contract it maintains with you. For security reasons, for requests made via email dpo@alohabrowser.com, the request will be fulfilled when we are certain of the user's identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the holder. This data and information will be protected during the storage period and deleted after the legal period for possible regular exercise of rights has passed.

We emphasize the importance of keeping your personal data accurate and up to date. You can consult your personal data and change it at any time as necessary. When doing so, we may ask you to first verify your identity.

Technical reasons may make it difficult and/or impossible for us to check whether you have stopped using our software and/or services. For mobile apps - currently - it will be practically impossible to check whether or not you have deleted an app. In such cases, we reserve the right to remove your account and delete the data you have provided to us if you do not use our software and/or services for an extended period of time.

California Consumer Privacy Act Notice

As of January 1, 2020, the California Consumer Privacy Act of 2018 ("CCPA") provides California residents ("Consumer(s)") certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:

• Opt-out of the sale of their personal information, should we sell their personal information;
• Be informed of certain information concerning our collection and use of their personal information;
• Request that we delete certain personal information we collected from them;
• Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
• Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.

Since its launch, Aloha Profile has neither sold, nor shared and is not now selling or sharing personal information to third parties for monetary or other valuable considerations. Also, Aloha Profile will not disclose certain personal information with entities within our corporate group in order to enable them to perform certain services on our behalf. Regardless, we respect the California residents' right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at dpo@alohabrowser.com

Changes to our Privacy Policy

We will be revising, updating and changing our privacy policy from time to time. Any time we do so, the revised and/or updated and/or changed privacy policy will be posted on our site. By agreeing to use and by continually agreeing to use our software and/or services you hereby agree to review our privacy policy from time to time and make yourself aware of any modifications. If at any point you do not agree to the terms of our privacy policy, then you should not be using our software and/or our services.

Any questions or exercise of rights?

For any questions, requests or complaints regarding the processing of personal data, please contact us at: dpo@alohabrowser.com

Enjoy the experience!