Privacy Policy

Effective date: August 4th, 2020

Thank you for visiting the Privacy Policy for Aloha Profile. Our highest priority at ALOHA MOBILE LTD is to provide a safe environment for your personal data. This Privacy Notice is governed by the provisions of EU Regulation 2016/679 also known as General Data Protection Regulation (GDPR). This privacy notice aims to provide you with all mandatory information regarding the transparency of personal data processing.

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: 132 Arch. Makariou III, Sagro Building, 3021 Limassol, CYPRUS

Definitions

Here is a short dictionary of the most commonly used terms you will come across in this Privacy Notice:

Personal data: in general any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as for example an e-mail, name, location data, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Consent: any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

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. In order 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.

Purpose and Use of Personal Data

Our processing of your personal data will be justified if one of the following conditions is satisfied:

Whenever we obtain your consent;
Whenever you need to use Aloha Profile service;
Whenever we need to identify and prevent unauthorized access to your account;
Whenever the processing of your personal data is necessary for the performance of a contract,
Where the processing is necessary for us to comply with a legal obligation,
Where the processing is necessary for the purposes of our legitimate interests.

Your information will not be used for any other than the purposes specified below:

To deliver our Aloha Profile service;

Sharing information with other companies and Disclosure of Personal Data

Your information will never be exchanged or sold. We make sure that your personal data is looked after as if we were handling it directly.

We will also disclose your personal information if we are required by law to do so, for law enforcement purposes.

For how long we will keep your information

We will retain your personal information for the whole period that you use Aloha Profile + 1 year from the date of your last login. After that period, personal data we hold about you will be erased securely. However, you can opt at any time to data erasure, as per “Your Rights” listed below.

Children’s data

Aloha Profile is not directed to children under the age of 18 years old. Nor do we knowingly collect information from them. In case we find out that we have collected personal information from a child without appropriate and verified parental consent, we will try our best to delete that information as soon 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 whilst in transit so that it cannot be intercepted. We encrypt your stored data with AES256 algorithm.

Your rights

You, as a data subject, have the following rights under the GDPR.:

The right to be informed. Anyone who processes your personal data, must inform you what data is processed, for what purpose and to whom else the data might pass.

The right of access You have the right to see what data is held of you by the data controller.

The right to rectification. You can ask to correct or amend any false or incomplete personal data that is held of you.

The right to erasure or also known as "the right to be forgotten". Under certain circumstances you can ask the controller to erase personal data concerning you without delay and the controller has the obligation to erase it without any delay.

The right to restriction of processing. Under certain circumstances you have the right to ask the controller for a temporary halt of processing of personal data.

The right to data portability. You have the right to receive the personal data concerning you and to transmit those data to another controller.

The right to object. You have the right to object to further processing of your data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.

Rights in relation to automated decision making and profiling. You have the right not to be subject to a decision based solely on automated processing.

You may contact us any time in order to:

Confirm whether any of your personal information is held,
Have access to any of your personal information and verify its accuracy,
Correct and update your record with personal data, in case it is inaccurate,
Erase data or cease processing provided that there are no legitimate grounds for retaining it.

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 support@alohabrowser.com

Changes to this Privacy Notice

This Privacy Notice may be modified at any time. Please review this page for the latest information on our privacy practices. This policy is effective since August 4^th, 2020.

Contact Details

Feel free to contact us for any issue relating to the processing of your personal data, or to submit a complaint or manage your information. Email us at: support@alohabrowser.com