Last Revised Date: Oct 8, 2018
We will strive to process your personal data lawfully, fairly, and in a transparent manner that complies with the General Data Protection Regulation (“GDPR”) as specified by the European Union. Your personal data will be collected for specified, explicit and legitimate purposes that align with the services you have requested and not further processed in a manner that is incompatible with the requested services. Our processing of your data shall be limited to that which is adequate, relevant and limited to what is necessary to provide you the requested services. Once we have processed or stored your data we will use reasonable efforts to assure your personal data is accurate, up to date, and eliminate inaccuracies we find or you notify us exist. We do not, however, assert, claim, or ensure the personal data you provide or is provided by others to us is accurate. We will use industry standard practices to for no longer than is necessary to provide you with requested services, or personal data may be stored for longer periods insofar as the personal data will be required for financial or legal reasons, or remains part of our normal archiving process when such data shall remain offline and not available to the public, or processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with GDPR Article 89(1). We implement industry standard practices to provide security and protect the confidentiality of your personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. We periodically update our standard practices which can be obtained upon request.
We will process your personal data when you provide consent in compliance with all State and Federal laws, when the processing is necessary to provide you the service you requested, to protect your vital interests or that of someone else, when necessary to accomplish a task in the public interest, and when necessary for us to perform standard business and technical processes where such processes do not override your rights or that of a minor. If we must process or store your personal information for any other reason we will notify you and request your consent if such consent is required.
3. INFORMATION THAT ALOSANT COLLECTS
During our normal course of business we do not collect, process, or store personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, health data, or data concerning a natural person’s sex life or sexual orientation. Should such personal data come into our possession or be processed by us from other sources, including you providing such data, we will erase this type of data upon your request or maintain such data upon your request with explicit consent by you. Only with your consent or for compelling reasons enumerated in GDPR Chapter 2 Article 2(2) or as compelled by law will we collect, store, or process such data.
You understand and acknowledge that providing personal data may be a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as obliged to provide personal data to access the site, services, or software and may be denied as the result of a failure to provide such data.
Alosant collects two (2) types of information by and through the Websites and the Applications: Personal Information and Non-Personal Information.
Personal Information. Personal Information is information that tells Alosant specifics about you. The types of Personal Information that Alosant may collect include, without limitation: your name and contact information (such as your postal address, zip code, phone number and e-mail address); your password; your gender; the number and/or ages of members of your household; information about relating to product preferences; personal interests; household income; and areas of interest on the Websites.
Alosant may collect Personal Information from (and about) you in a variety of different ways. For example, when you register on a Website or Application, you submit Personal Information to Alosant. Similarly, when you use the Websites or the Applications to create or update a profile, register for events, or communicate or interact with Alosant and/or its representatives, you are providing Alosant with Personal Information. Alosant may also acquire Personal Information about you from publicly available sources, social media platforms (e.g., Facebook) and other third parties that may share information as permitted in their privacy policies.
Also note that Alosant may combine Personal Information about you with information available from other sources (e.g., social media platforms, analytics services [see Section 5.B, below], offline records or publicly available information). If the combined information is maintained, used or shared by Alosant in a manner that associates it with your name or contact information, Alosant will treat such information as Personal Information.
Non-Personal Information. Non-Personal Information refers to data and information that does not personally identify you as the individual to whom the data or information relates. Non-Personal Information may include, without limitation:
The IP address assigned to your computer (or other device);
Your media access control (MAC) address;
Information derived through Collection Technology (see Section 5.A, below);
The type of computer (or other device) you use, and the operating system you use (e.g., Microsoft Windows or Mac OS);
The type of Internet browser you use (e.g., Internet Explorer, Google Chrome or Safari);
The domain name of your Internet Service Provider;
Your activities while visiting or using the Websites or the Applications (including the content you access or view, the time of your visit to or use of the Websites or the Applications, and the pages you visit and the time spent on such pages);
Your general geographic location (such as the city from which your computer or device is connecting to the Internet); and
Information regarding the websites you visit prior to and after visiting the Websites or using the Applications.
Alosant may choose to receive and record Non-Personal Information on its server logs from your browser, as well as through other analytics in relation to the Websites and the Applications. Alosant may also obtain Non-Personal Information about you ‑ either directly or through inference ‑ from social media platforms, third parties and other lawful sources.
Information Obtained from Another Source. Alosant will notify you within one month after obtaining information about you from another source, which may be a source offering publicly available information or a private source which you have given us permission to access. If we communicate with you using information we obtained from a third-party we will notify you at the time of communication that we have obtained such information.
Right to Erasure of Data. You have the right to obtain from us the erasure of personal data concerning you without undue delay and we will have the obligation to erase personal data without undue delay when: (i) your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw your consent on which the processing is based providing there is no other legal ground for the processing or retaining of your personal data; (iii) you object to the processing and there are no overriding legal or legitimate grounds for the processing; (iv) we have inadvertently or unlawfully captured or processed your personal data; (v) your personal data must be erased in order to comply with a legal order issued by a court of proper jurisdiction or to comply with a statute to which we are subject; (vi) your personal data has been collected in relation to the offer of information society services referred to in GDPR Article 8(1). Where we have made your personal data public and are obligated to erase the personal data, we will, after taking account of available technology and the cost of implementation, take reasonable steps, including technical measures at our disposal, inform others which are processing or storing your personal data that you have requested the erasure by such others of any links to, or copy or replication of, your personal data. You acknowledge that such public information may never be completely erased despite our efforts. We may not be able to erase your information, specifically when continued processing or storage is necessary for: (i) exercising the right of freedom of expression and information; (ii) compliance with a legal obligation which requires processing or storage where such legal obligation stems from a legal order issued by a court of proper jurisdiction or compliance with a statute to which we are subject; (iii) reasons of public interest in the area of public health as specified in the GDPR; (iv) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with those specified in the GDPR; (v) or to assert, exercise, or defend legal claims.
4. USE AND DISCLOSURE OF INFORMATION
We will process and store your personal data while you continue to use the requested services and, upon termination of your use of the requested services, we will erase your personal data from active repositories and, through the normal course of business and technical processes, erase your personal information from archives and backup storage. We will employ industry standard practices as to removal from archive and backup storage which may impact the length of time the data is kept or the criteria used to determine the length of time. However, where such data is required for financial or legal compliance we may not be able to erase your data.
The information Alosant collects will vary depending upon how you use the Websites and the Applications. Data may be captured based on your user profile and your interaction in the site and such data may be utilized by algorithms to enhance your user experience or supplement personal data. Alosant’s use and disclosure of the collected information will vary depending on the type of information Alosant receives – i.e., Personal Information vs. Non-Personal Information.
If we intend to further process the personal data for any purpose other than that for which the personal data was obtained, we will provide you with information on that other purpose and with any relevant further information prior to the further processing. You will have the right to obtain from us information as to whether your personal data is being processed, and if so, (i) be informed of the purpose of the processing; (ii) be informed of the categories of personal data processed; (iii) be informed of the recipients or categories of recipient to whom the personal data have been or will be disclosed, if any; (iv) be aware, if possible, of the time period for which the personal data will be stored, or, if not possible, the criteria used to determine that time period; (v) be afforded the existence of the right to request from us, or a third-party, rectification or erasure of personal data or restriction of processing of your personal inform, or object to such processing; (vi) have the right to submit a complaint to us or the appropriate third-party; (vii) have the right to request the source of any information not collected directly from you; (viii) be notified if your personal data is utilized by algorithms to enhance your user experience or supplement personal data; and (ix) the right to obtain a copy of the personal data undergoing such processing and you agree to pay a reasonable fee if requested for a copy of your personal data being so processed providing obtaining such a copy does not adversely affect the rights and freedoms of others.
However, we may not provide notice as to third-party obtained information if providing such information would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in GDPR Article 89(1) or in so far as the obligation referred to in GDPR Article 14(1) is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases we will take appropriate measures to protect your rights, freedoms and legitimate interests, including making the general information publicly available but not identifying you specifically.
We may use Personal Information and Non-Personal Information as follows:
Personal Information. Alosant may use your Personal Information to:
Carry out the purposes for which you provided the information to Alosant;
Keep you apprised of events, news and information that you may find of interest;
Customize the content or functionality of the Websites and/or the Applications to your preferences;
Attend to tasks relating to your interactions or transactions with Alosant;
Inquire as to whether you would like to receive any additional information regarding Alosant’s activities, program offerings, etc.;
Forward or otherwise provide updates, announcements and newsletters; and
Respond to your communications, and communicate with you about the Websites, the Applications and activities related thereto.
By using the Websites and/or the Applications, you authorize Alosant to transmit email and direct mail to you, call you, send push notifications to your device, send you text messages, and otherwise contact you concerning these matters. You may, at any time, cancel such notifications. However, these notifications form part of the core serve we provide and cancelation may reduce the usefulness of our software and services.
If we disclose information to a third-party we will notify you before or at the time of disclosure. Alosant may intentionally disclose your Personal Information only in the following instances:
Disclosures You Have Requested. Alosant will provide your Personal Information to those entities and individuals that you have specifically designated (using the Websites, the Applications or otherwise) to receive your information so that said entities and individuals can perform in accordance with your directives/wishes, contact you to address your questions and requests, etc. However, the Company is not responsible for the collection or maintenance of such information once it is in the hands of the designated entit(y/ies) or individual(s).
Disclosures to Which You Have Consented. Alosant may disclose your Personal Information if you have consented (whether expressly or implicitly) to said disclosure. By way of example only, if (i) you elect to participate in a sweepstakes sponsored by Alosant and (ii) the official rules of the sweepstakes declare that Alosant may publish the names of (and other information regarding) the sweepstakes entrants and/or winners, then, by virtue of your decision to participate in the sweepstakes, you are deemed to have consented to the official rules and the disclosure of your Personal Information in accordance with the rules.
Disclosures to Trusted Third Parties. Alosant may provide your Personal Information to third-parties who work on behalf of or with Alosant, provided that (i) the disclosure is necessary or otherwise convenient in connection with assisting Alosant in its operations and (ii) said operators work under confidentiality or similar agreements. We may share your personal data with third-parties, such as social media, payment processing, and software support service providers which will provide you with their privacy policies and terms and conditions for use.
Non-Personal Information. Alosant may use your Non-Personal Information in several ways including, but not limited to:
Administration of the Websites;
Improvement of the Websites and the Applications (including navigation thereof);
Improvement of the programs and services offered by Alosant;
Analysis and development of advertisements and advertising campaigns;
Providing you with special offers and promotions (and determinations regarding their effectiveness);
Customization of the content or functionality of the Websites and the Applications to suit your preferences; and
Analysis of trends and usage.
Alosant may use, share or disclose your Non-Personal Information only with your permission or to provide critical services which you have requested. For example, Alosant may disclose your Non-Personal Information to employees, consultants and other professionals who Alosant reasonably believes need such information in order to perform the tasks described in this Section 4.B. Additionally, Alosant may combine your Non-Personal Information with other non-personal information collected by Alosant and will only share the aggregated data with service companies and product providers for marketing and research purposes when you have given us explicit permission to do so.
5. USE OF COLLECTION TECHNOLOGY AND ANALYTICS SERVICES
Non-Personal Information may be collected by Alosant using a
“Collection Technology” refers to cookies, web beacons, pixels,
gifs, tags and other tools that collect information in similar ways.
Collection Technology may store a piece of data on your browser or
device, while other forms of Collection Technology may identify your
browser or device and collect information through other means. When
you visit the Websites or use the Applications, your browser or
device may be exposed to Collection Technology, and Collection
Technology may be stored on your browser or device. Alosant may
access, retrieve and use the Non-Personal Information generated and
stored by the Collection Technology on your browser or device. You
may delete and/or refuse the use of certain Collection Technology by
selecting the appropriate settings on your browser. And, you are
not barred or precluded from using the Websites or the Applications
if you choose to delete and/or refuse such Collection Technology.
However, please note that some parts of the Websites and/or the
Applications may not work properly if you elect to delete and/or
refuse Collection Technology.
Alosant may use third-party analytics services to facilitate the
compilation, tracking and analysis of information that is
accumulated using Collection Technology. For example, Alosant may
use Google Analytics to measure, analyze and report on data gathered
through Collection Technology to assist Alosant in understanding and
optimizing use of the Websites. Information and data collected
through Alosant’s use of analytics services shall be used and
However, please be advised that third-party analytics services are
governed by their own privacy policies, and Alosant has no control
over the scope, limitations or requirements of these policies.
Should you have any questions regarding Alosant’s use of analytics
services, please contact the Privacy Administrator at the address
We may use automated processing, including artificial intelligence,
machine learning, and other techniques to process your data. We
will not use any type of automated processing if such processing
produces legal effects concerning you or similarly significantly
affects you unless such processing is: (i) necessary for entering
into, or performance of, a contract between the you and us; or (ii)
authorized by the State of Montana or US law to which we are subject
and which also establishes measures to safeguard the your rights,
freedoms, and legitimate interests; or results from your explicit
consent. In the case of (i) or (iii), we will implement reasonable
measures to safeguard your rights, freedoms, and legitimate
interests, and, where and when possible, involve human intervention
on our part to express your point of view and to contest the
decision. In the case of the most sensitive data, such as race,
ethnicity, gender, and the like, we will provide industry standard
measures to safeguard your rights, freedoms, and legitimate
6. PROTECTION OF INFORMATION
Artificial Intelligence. We may use automated processing, including artificial intelligence, machine learning, and other techniques to process your data. We will not use any type of automated processing if such processing produces legal effects concerning you or similarly significantly affects you unless such processing is: (i) necessary for entering into, or performance of, a contract between the you and us; or (ii) authorized by the State of Montana or US law to which we are subject and which also establishes measures to safeguard the your rights, freedoms, and legitimate interests; or results from your explicit consent. In the case of (i) or (iii), we will implement reasonable measures to safeguard your rights, freedoms, and legitimate interests, and, where and when possible, involve human intervention on our part to express your point of view and to contest the decision. In the case of the most sensitive data, such as race, ethnicity, gender, and the like, we will provide industry standard measures to safeguard your rights, freedoms, and legitimate interests.
Alosant is committed to protecting your Personal Information. Accordingly, Alosant has adopted commercially reasonable technical, administrative and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access and alteration. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure (e.g., third party “hackers” may unlawfully intercept or access information or confidential transmissions). Alosant wants you to feel confident using the Websites and the Applications; but, as indicated in Section 1, above, Alosant cannot ensure or warrant the security of any information you transmit to Alosant and any such transmission is done at your own risk.
7. LINKS TO THIRD-PARTY WEBSITES
8. CORRECTION OF PERSONAL INFORMATION
Alosant endeavors to keep your Personal Information current and accurate. You have the right to obtain from us without undue delay rectification of inaccurate personal data concerning you. Taking into account the purposes of our processing of your information and our regular business and technical processes, you have the right to supply incomplete personal data, including by means of providing a supplementary statement. Accordingly, Alosant appreciates your courtesy in providing Alosant with notice of any changes to your Personal Information via e-mail, telephone or postal mail at the addresses shown in Section 14, below. However, you have the right to request access to and rectification or erasure of personal data, or restriction of processing concerning your data, or to object to processing as well as the right to data portability.
You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format of our choice and have the right to provide such information to any party of your choosing without restriction or hindrance from us. If practicable, and at our sole discretion, we may provide your personal data to a third-party you have explicitly designated in writing. Receiving your data has no impact or relationship to decisions you may make regarding erasure of your personal data nor adversely affect the rights of others.
You may at any time opt-in to have your Personal Information used by Alosant for mailings, calls, etc. by notifying Alosant via e-mail, telephone or postal mail at the addresses shown in Section 14, below. If, subsequent to opting in, you elect not to receive any future contacts from Alosant, we will endeavor to remove your name from all of contact lists within ten (10) business days. However, information is sometimes difficult ‑ if not impossible ‑ to remove from all data sources and, accordingly, Alosant can only promise to remove you from any lists that Alosant controls using industry standard techniques.
The safety of children is very important to Alosant, and Alosant is committed to protecting the privacy of children. In this regard, (i) the Websites and the Applications are directed to persons 18 years of age or older and (ii) Alosant does not knowingly collect information from children under the age of 18.
If you provide Personal Information to Alosant through the Websites or the Applications, you represent and warrant to Alosant that you are 18 years of age or older, or of the legal age as legally specified in your jurisdiction. If you are under the age of 18 and not of the legal age within your jurisdiction to provide Personal Information, you may visit, browse and use the information on the Websites or the Applications, but you may not submit any Personal Information to/through the Websites or the Applications and you represent and warrant to Alosant that you have the permission of your parent or legally designated guardian to use the Websites and the Applications. If Alosant becomes aware that you, or any user of the Websites and/or the Applications, is under the age of 18 and has provided Personal Information, Alosant will remove said information from its files and repositories within thirty (30) days unless complexity and number of requests is excessive, in which case the time period may be extended up to two additional months. In such case, you, or the subject, will be notified of the timetable for removal of Personal Information. No fee shall be charged for removal of this type of information.
10. NOTICE TO RESIDENTS OF SPECIFIC JURISDICTIONS
Residents of specific jurisdictions which may have specific rights outside or beyond those of the GDPR are entitled to request information about Alosant’s compliance with specific jurisdictional standards. You may make such a request by sending an e-mail or letter to Alosant at the following address:
5 W MENDENHALL ST STE 202
BOZEMAN, MT 59715
13. GOVERNING LAW
14. QUESTIONS OR CONCERNS
Rancho Mission Viejo Community Services Organization (“Alosant”)
Todd Beebe, General Manager
Gateway Place, Ste. E-3
Rancho Mission Viejo, CA 92694