(Last revised: 03 September 2020)

This Privacy Policy outlines Alphien’s policy and responsibility to you when you sign up and use our Site and Services. Your Privacy and the security of your Personal Data is important to us and we want to explain what Personal Data we collect from you, how we collect it, why we use it, how we store and process your Personal Data as well as your associated rights and choices in relation to your Personal Data in this Privacy Policy.

By clicking “I have read and agreed to the Terms Of Use and Privacy Policy”, you signify that you have read and understood this Privacy Policy and given your consent to the processing of your Personal Data in accordance with this Privacy Policy.

Capitalised terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use or as per the European Union General Data Protection Regulation 2016/679 (“EU GDPR”).
 

Updates to this Privacy Policy[edit]

In order to adopt the best practices to protect your Personal Data, this Privacy Policy may be amended to reflect our current privacy practices. If any such changes to this Privacy Policy is material, we will notify you of this update (date stamped) via Alphien’s home page, community forum, and/or by email to you prior to or simultaneously with the change becoming effective. It is your duty to check back frequently to see any updates or changes to this Privacy Policy.

How to contact us[edit]

If you have any enquiries or if you wish to exercise any of your rights as defined below, contact us at info@alphien.com referencing “Privacy Policy”.

What we collect and receive[edit]

We adopt the definition of “Personal Data” as defined in EU GDPR, section 4 (1), and we collect the following categories of Personal Data from you:

What you provide to us:

• Account Registration Data refers to your full name, email address, and LinkedIn account. These information are necessary for your account creation and for your use of the Site and Services. In certain limited cases, we may ask you to provide us with your country of residence to ensure that the national laws of your country allows for copyright enforcement and protection.
• Profile Data refers to any image that you voluntarily upload to your account. You give us your consent to process and collect such Personal Data, however you may withdraw your consent by removing any such uploaded image.
• Feedback and Survey Results Data refers to your feedback, comments and responses during the engagement surveys that we conduct.

What is collected automatically:

• Technical Data refers to your Internet Protocol (IP) address, login data, browser type and version, time zone setting and location (country), browser plugin types and versions, operating system and platform, and other technology on the devices that you use to access our Site and Services.
• Communications Data refers to your usage of the Site and Services, including traffic data, forum posts, logs, pages you visit, cookie information (see our Cookie Policy), and any other communication data arising from your access and use of the Site and Services.

What third parties provide to us:

• Professional Data refers to the information available on your LinkedIn account, such as details of your current employer as well as your professional and education background. In order to minimise the risks of any potential conflict of interest (when you create strategies or works that attract copyright protection on Alphien’s platform) with your current employment, we collect and process such information to conduct a more complete assessment.

How we collect[edit]

As mentioned above, we collect your Personal Data (1) that you supply us when you create your account or through the use of the Site and the Services, and (2) through cookies and web beacons when you use our Site and Services.

How we use[edit]

As it is in our obligation and legitimate interest to be responsive to you and to ensure the proper functioning of our Site and Services, we use your Personal Data:

International Data Transfers[edit]

As Alphien operates on a global basis, we will transfer your Personal Data (i) to Paris, where Alphien is located, (ii) to Singapore, where our parent company is located, and (iii) to Indonesia, where our subprocessor is located. Such transfers are necessary for the purposes of delivering the Site and Services to you. Alphien may also subcontract the processing to, or share your Personal data with, third parties located in other countries other than your home country. Your Personal data, therefore, may be subject to privacy laws that are different from those in your country of residence however we will take appropriate steps to ensure that the transmission of your Personal Data is in accordance with applicable law and limited to countries which are recognised as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights. For residents of the EU, this Privacy Policy will apply even if we transfer your Personal Data out of the EU region.

Who we may share with[edit]

We may share your Personal Data, to a varying extent, with the following entities:

• Users: Users can only view your username and profile picture, if any is uploaded.
• Employees of Alphien: Employees at Alphien who are responsible for maintaining and facilitating the Site and Services will have access to your Personal Data.
• Alphien’s Parent Company: When necessary, we may share some or all of your Personal Data with the employees of our parent company located in Singapore (Four Elements Capital Pte. Ltd.) (“Parent Company”) to help develop our Site and Services, and in such cases we will require our Parent Company to honour this Privacy Policy. In the event of any corporate restructuring, you will be notified of the transfer of your Personal Data to the new parties, and they will be subject to this Privacy Policy.
• Third Party Services: When necessary, we may share some or all of your Personal Data with our external service providers which we use for providing high-quality Services to you. In such cases, we will require these external service providers to honour this Privacy Policy and for them to undertake formal written confidentiality obligations. All your Personal Data will be transferred and stored in a secured manner during any such outsourcing process. Currently, we use a consulting company based in Indonesia that provides Alphien with business administrative and information technology support services.
• Lawyers or Law Enforcement Authorities: When necessary, we may disclose your Personal Data to the relevant law enforcement authorities or lawyers if we believe in good faith that such disclosure is necessary (i) to protect or defend the rights or property of Alphien or Users of the Site and Services; (ii) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use; or (iii) if required by law enforcement authorities.
• Changes to Business Ownership and Control: We may sell, transfer, or otherwise share some or all of our business or assets, including your Personal Data in connection with a merger, acquisition, reorganisation or sale of assets or in the event of bankruptcy. If Alphien is sold or otherwise changes its business status, we will notify you that we are transferring your information.

Data Security[edit]

Taking into account the state of art, the costs of implementation, the nature, scope, context and purposes of processing your Personal Data, we implement various measures including access and retention policies to guard against unauthorised access and unnecessary retention of Personal Data in our systems. We also ensure that those who have permanent or regular access to your Personal Data or who are involved in the processing of Personal Data, or in charge of developing the tools used to process Personal Data are trained and informed of their rights and responsibilities when processing such Personal Data. In the event that your data is lost or stolen, and if this data breach could harm you, we will inform you without undue delay. We also strongly encourage you to use a unique and strong password, limit access to your computer and browser, and log out after using our Site and Services to ensure the security of your account.

Retention of Data[edit]

To determine the appropriate retention period for Personal Data, we consider the nature and sensitivity of the Personal Data, the potential risk of harm that may be involved from any unauthorised use or disclosure of your Personal Data, the purposes for why we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Currently, we retain:

• your account registration data, profile data, and professional data for as long as your account is active;
• your cookies data for not more than 13 months;
• your technical data for a period of 24 months;
• your communications data for a period of 24 months; and
• your feedback and surveys data for a period of 24 months.

If your account remains inactive for 24 months from your last login date, your account (along with your Personal Data) will be deleted, unless you expressly request to maintain your account.

Your rights[edit]

We comply with the EU GDPR standard and you have the right to request access, correction, or deletion of the Personal Data we have about you. If you have any questions, please contact us at info@alphien.com and we will respond to your request within a reasonable timeframe. Here are your rights:

• Right of access: You have the right to obtain confirmation from Alphien as to whether or not personal information concerning you is being processed, and where that is the case, access to your Personal Data.
• Right to rectification: You have the right to request from Alphien to (i) rectify any inaccurate personal information concerning you and (ii) have incomplete personal information completed. You may also directly modify or complete any such personal information at any time via your User Account.
• Right to erasure: Subject to our storage legal obligations, you have the right to request from Alphien to erase any of your Personal Data, in particular where (i) the Personal Data is no longer necessary in relation to the purposes for which it was initially collected or processed; (ii) you have withdrawn your consent for certain processing of your Personal Data; (iii) you believe that the Personal Data have been unlawfully processed; or (iv) the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which Alphien is subject.
• Right to restrict processing: You have the right to obtain from Alphien restriction of processing where (i) you contest the accuracy of your retained Personal Data, (ii) you believe that our processing is unlawful and you request the restriction of our use instead of the erasure, or (iii) Alphien no longer needs the Personal Data for the purposes of the processing but Alphien needs such Personal Data for the establishment, exercise or defense of legal claims.
• Right to data portability: You have the right to receive or transmit to another data controller the collected Personal Data concerning you in a structured, commonly used and machine-readable format.
• Right to object: You have the right to object, on grounds relating to your particular position, at any time to the processing of Personal Data concerning you where the processing is necessary for the purposes of the legitimate interests pursued by us, unless Alphien demonstrates compelling legitimate grounds for the processing which overrides your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
• Reject automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you, unless this decision is necessary for entering into, or performance of a contract between you and Alphien or if the decision is authorized by Union or Member State law to which Alphien is subject, or if you have given your explicit consent.
• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority.