Alecton respects your privacy and is committed to protecting your
after your personal data when you visit our website (regardless of
where you visit it from) and tell you about your privacy rights and
how the law protects you.
Important information and who we are
In this Privacy Statement, ALECTON LLC (“Alecton”) explains
which (personal) data Alecton collects and how Alecton uses and
protects your (personal) data. Alecton is responsible for
ensuring that it uses that Personal Data in compliance with data
At Alecton we respect the privacy of our clients and we are
committed to keeping all your Personal Data secure. This Privacy
Policy governs the handling of Personal Data by Alecton in the
course of carrying on commercial activities.
“Alecton”, “we” or “us” means ALECTON LLC is a personal data
“Personal Data” means any data which relates to a living
individual who can be identified from that data or from that
data and other information which is in the possession of, or
is likely to come into the possession of, Alecton (or its
representatives or service providers). In addition to
factual information, it includes any expression of opinion
about an individual and any indication of the intentions of
Alecton or any other person in respect of an individual.
This website is not intended for children and we do not
knowingly collect data relating to children.
provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware
supplements other notices and privacy policies and is not
regular review. It is important that the personal data we hold
about you is accurate and current. Please keep us informed if
your personal data changes during your relationship with us.
that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes
during your relationship with us.
This website may include links to third-party websites, plug-ins
and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are
not responsible for their privacy statements. When you leave our
website you visit.
The products and services we provide
information that we collect about you when providing the
following products and services:(A) Information we receive
through our website Alecton.com ("Website"); (B) Information we
receive through our support, mobile security solution or cloud
based services ("Alecton Services").
The types of personal data we collect and storage time
In order to receive our newsletter and project updates, you may
submit your e-mail address via “Get notifications” form.
Automatically Collected Information: Alecton may automatically
collect certain information about the computer or devices you
use to access the Website or using our Services, including
mobile devices, through commonly-used information-gathering
tools, such as cookies and web beacons. Such information
includes standard information from your browser or device (such
as browser/device type and language), your Internet Protocol
address, and the actions you take on our Website, such as the
pages viewed and the links clicked. We use this information to
ensure the proper functioning and security of our Website and
Services and to optimize our Website or Services. We use certain
first part and third party cookies and refer to our Cookie
Policy, which forms an integral part of this Privacy Statement,
Unless indicated otherwise in this Privacy and our Cookie
Policy, Cirlegain stores your personal data as long as it is
providing you the Services.
Personal data, or personal information, means any information
about an individual from which that person can be identified. It
does not include data where the identity has been removed
We may collect, use, store and transfer different kinds of
personal data about you which we have grouped together as
Identity Data includes first name, maiden name, last name,
username or similar identifier, marital status, title, date
of birth and gender.
Contact Data includes billing address, delivery address,
email address and telephone numbers.
Financial Data includes bank account and payment card
Transaction Data includes details about payments to and from
you and other details of products and services you have
purchased from us.
Technical Data includes internet protocol (IP) address, your
login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating
system and platform, and other technology on the devices you
use to access this website.
Profile Data includes your username and password, purchases
or orders made by you, your interests, preferences, feedback
and survey responses.
Usage Data includes information about how you use our
website, products and services.
Marketing and Communications Data includes your preferences
in receiving marketing from us and our third parties and
your communication preferences.
We also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data
could be derived from your personal data but is not considered
personal data in law as this data will not directly or
indirectly reveal your identity. For example, we may aggregate
your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy
We do not collect any Special Categories of Personal Data about
you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data).
Nor do we collect any information about criminal convictions and
If you fail to provide personal data where we need to collect
personal data by law, or under the terms of a contract we have
with you, and you fail to provide that data when requested, we
may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with services).
In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the
How do we collect your data?
We use different methods to collect data from and about you
Direct interactions. You may give us your Identity, Contact
and Financial Data by filling in forms or by corresponding
with us by post, phone, email or otherwise. This includes
personal data you provide when you:
— apply for our products or services;
— create an account on our website;
— subscribe to our service or publications;
— request marketing to be sent to you;
— enter a competition, promotion or survey; or
— give us feedback or contact us.
Automated technologies or interactions. As you interact with
our website, we will automatically collect Technical Data
about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs and
other similar technologies.
Third parties or publicly available sources. We will receive
personal data about you from various third parties and
public sources as set out below:
— Technical Data from the following parties;
— analytics providers;
— advertising networks; and
— search information providers;
— Contact, Financial and Transaction Data from providers of
technical, payment and delivery services;
— Identity and Contact Data from data brokers or
— Identity and Contact Data from publicly available sources.
How we use your information
Your Personal Data may be stored and processed by us in the
following ways and for the following purposes:
to communicate with you in order to provide you with
services or information about Alecton;
for ongoing review and improvement of the information
provided on Website to ensure they are user friendly and to
prevent any potential disruptions or cyber attacks;
to allow you to use and access the functionality provided by
for statistical monitoring and analysis of current attacks
on devices and systems;
- for in-depth threat analysis;
- to understand your needs and interests;
in order to comply with and in order to assess compliance
with applicable laws, rules and regulations, and internal
policies and procedures; or
for the administration and maintenance of databases storing
In case of explicit consent via Get notifications form, your
Personal Data will be used for marketing communication
regarding existing or new Alecton services.
However we use Personal Data we make sure that the usage
complies with the law and the law allows us and requires us to
use Personal Data for a variety of reasons. These include:
we need to do so in order to perform its contractual
obligations with its customers;
- we have obtained your consent;
we have legal and regulatory obligations that we have to
we may need to do so in order to establish, exercise or
defend our legal rights or for
- the purpose of legal proceedings;
the use of your Personal Data as described is necessary for
our legitimate business
interests, such as:
— allowing us to effectively and efficiently manage and
administer the operation of our business;
— maintaining compliance with internal policies and
— monitoring the use of our copyrighted materials; and
— enabling quick and easy access to information on Alecton.
We will take steps to ensure that the Personal Data is accessed
only by employees of Alecton that have a need to do so for the
Disclosure of your information to the third parties
We may share your Personal Data within Alecton and any of its
group companies for the purposes described above:
We may also share your Personal Data outside of the Alecton
group for the following purposes:
with third party agents and contractors for the purposes of
providing services to us. This
will include Alecton’s accountants, professional advisors,
IT and communications providers and debt collectors as well
as companies that provide CMS, hosting and backup services,
sales and support services to Alecton. In such a case,
Alecton ensures, by way of contracting with these companies,
that your (personal) data will not be used for other
purposes, while we also ensure that your (personal) data
will be removed once they are no longer needed.
to the extent required by law, for example if we are under a
duty to disclose your
Personal Data in order to comply with any legal obligation
(including, without limitation,
in order to comply with tax reporting requirements and
disclosures to regulators), or to
- establish, exercise or defend its legal rights;
if we sell our business or assets, in which case we may need
to disclose your Personal
Data to the prospective buyer for due diligence purposes;
if we are acquired by a third party, in which case the
Personal Data held by us about you
- will be disclosed to the third party buyer.
We will ensure that each third party we share Personal Data with
will be subject to appropriate data protection obligations.
International transfers of your personal data
Alecton is a global business. Our customers and our operations
are spread around the world. As a result we collect and transfer
Personal Data on a global basis. That means that we may transfer
your Personal Data to locations outside of your Country.
Where we transfer your Personal Data to another country outside
the EEA, we will ensure that it is protected and transferred in
a manner consistent with legal requirements. In relation to data
being transferred outside of Europe, for example, this may be
done in one of the following ways:
the country that we send the data to might be approved by
the European Commission as offering an adequate level of
protection for Personal Data;
the recipient might have signed up to a contract based on
“model contractual clauses” approved by the European
Commission, obliging them to protect your Personal Data;
where the recipient is located in the US, it might be a
certified member of the EU-US Privacy Shield scheme; or
In other circumstances the law may permit us to otherwise
transfer your Personal Data outside Europe.
You can obtain more details of the protection given to your
Personal Data when it is transferred outside Europe (including a
copy of the standard data protection clauses which we have
entered into with recipients of your Personal Data) by
contacting us as described in paragraph 11 below.
How we safeguard your information
We have extensive controls in place to maintain the security of
our information and information systems. Client files are
protected with safeguards according to the sensitivity of the
relevant information. Appropriate controls (such as restricted
access) are placed on our computer systems. Physical access to
areas where Personal Data is gathered, processed or stored is
limited to authorised employees.
As a condition of employment, Alecton employees are required to
follow all applicable laws and regulations, including in
relation to data protection law. Access to sensitive Personal
Data is limited to those employees who needs it to perform their
roles. Unauthorised use or disclosure of confidential client
information by Alecton employees is prohibited and may result in
How long we keep your personal information
How long we will hold your Personal Data for will vary and will
be determined by the following criteria:
the purpose for which we are using it – Alecton will need to
keep the data for as long as is necessary for that purpose;
legal obligations – laws or regulation may set a minimum
period for which we have to keep your Personal Data.
In all the above cases in which we collect, use or store your
Personal Data, you may have the following rights and, in most
cases, you can exercise them free of charge.
the right to obtain information regarding the processing of
your Personal Data and access to the Personal Data which we
hold about you;
the right to withdraw your consent to the processing of your
Personal Data at any time. Please note, however, that we may
still be entitled to process your Personal Data if we have
another legitimate reason for doing so. For example, we may
need to retain Personal Data to comply with a legal
obligation; in some circumstances, the right to receive some
Personal Data in a structured, commonly used and
machine-readable format and/or request that we transmit
those data to a third party where this is technically
feasible. Please note that this right only applies to
Personal Data which you have provided directly to Alecton;
the right to request that we rectify your Personal Data if
it is inaccurate or incomplete;
the right to request that we erase your Personal Data in
certain circumstances. Please note that there may be
circumstances where you ask us to erase your Personal Data
but we are legally entitled to retain it;
the right to object to, or request that we restrict, our
processing of your Personal Data in certain circumstances.
Again, there may be circumstances where you object to, or
ask us to restrict, our processing of your Personal Data but
we are legally entitled to refuse that request; and
the right to lodge a complaint with the relevant data
protection regulator if you think that any of your rights
have been infringed by us.
You can exercise your rights by contacting us using the
details listed in paragraph 11 below.
Alecton’s registered office may be contacted using the following
If you have any questions or concerns about Alecton’s handling
of your Personal Data, or about this Policy, please contact our
Privacy Officer using the following contact information:
We are usually able to resolve privacy questions or concerns
promptly and effectively. If you are not satisfied with the
response you receive from our Privacy Officer, you may escalate
concerns to the applicable privacy regulator in your
jurisdiction. Upon request, Alectons’ Privacy Officer will
provide you with the contact information for that regulator.