This Policy describes:
- The types of information we collect from you or that you may provide when you visit our website available at: http://www.try-alta.com/ as well as any websites and blogs directly owned by the Company (collectively, our “Website”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.
Information You Provide to Us
Personal Information is any information that can be used to individually identify you from a larger group. As a borrower you will necessarily provide us with Personal Information.
In order to register as a borrower on the Website and to use the Service, the Personal Information you will provide us, includes, but is not limited to, your:
- First and last name
- Email address
- Phone numbers
- Mailing or billing address
- Social media information (i.e., LinkedIn);
- Information required for statutory Know Your Customer (“KYC”) verification purposes, including your Social Security Number
- Comments or messages provided in free text boxes.
You may also provide us payment information for paying various fees associated with your use of the Website and/or the Service. Such payment information may include:
- Credit card numbers
- Bank account numbers
- Wire transfer information
- Apple Pay account information
- PayPal account information
We do not store or process credit card information on our Company systems. Instead, all credit card information is stored and processed by a trusted third-party PCI-DSS compliant processor.
In addition to the Personal Information you may provide to us as a borrower, you will also likely be required to provide information about your company or organizations, including, but not limited to:
- The company’s name and logo
- The URL for the company’s website
- The company’s corporate form and the jurisdiction in which it was formed
- The company’s employer identification (EIN) or tax identification number (TIN)
- References for the company including but not limited to correspondence from its attorney, accountant, and/or its landlord(s)
- Information related to the company’s financial history including whether the company or any of its owners has filed for bankruptcy and information regarding past legal proceedings
- Information related to the criminal history for all owners of the company
- Other corporate information (year established, headquarters state, executive positions, etc.)
- Information related to any and all licenses and permits issued to the company by any governmental authority that authorize it to operate, including copies of the company’s marijuana licenses and a list of what operations the company is licensed to perform
- The number of people the company employs
- The company’s social media information (i.e. company’s LinkedIn, Facebook, Instagram, Twitter, Weedmaps Profile, etc.)
- Company financial information (gross revenue information, assets and equipment, debt, name of banks with an account, balance sheet, etc.)
You may provide us Personal Information when you:
- share documents or other information with a lender;
- register with the Website (including monthly subscriptions);
- create a profile on the Website;
- create a new project;
- use the Website to message a lender or borrower; and
subscribe to our emails.
Any identifiers we may process shall only be used for identity and account validation and will be processed by a third-party service provider. The Company will not collect or retain biometric identifiers for any purpose. The information that you provide in each case will vary. Please use discretion in providing any Personal Information to the Company, including through any text boxes or messaging. In some cases, we may ask you to create a username and password that should only be known to you.
Automated Information Collection
In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. Such information includes:
- Online Identifiers, such as IP address, domain name;
- Device Information, such as hardware, operating system, browser, device name, language preferences;
- Usage Data, such as system activity, internal and external information related to pages on our Website that you visit, clickstream information; and
- Geolocation Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
We collect such information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website.
Some of the tools we use to automatically collect information about you may include:
- Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use both of them:
- (1) session cookies, which do not stay on your device after you close your browser, and
- (2) persistent cookies, which remain on your device until you delete them or they expire.
- We use the following categories of cookies on our Website.
- Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.
- Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our site, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
- Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. For example, these cookies can help us tailor listings to your preferences based on your past browsing history. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
- Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. These cookies are used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.
- Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
- Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
- Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.
Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage or contact us directly for assistance.
Information of Minors
We do not intentionally seek to gather information from individuals under the age of eighteen. We do not target the Website to minors and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.
How We Use Your Information
We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:
- Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
- Detect and prevent fraud. We process your Personal Information to detect and prevent fraud, which is especially important given the irreversible nature of cryptocurrency transactions.
- Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on the Website to maintain the security of your account and the Website.
- Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
- Market our products. We may contact you with information about our Services.
- Other business purposes. We may use your Personal Information for additional purposes including but not limited to:
- Automating matchmaking between borrowers and lenders by identifying leads that the lenders may review.
- Creating a database of marijuana businesses that utilize the Website (the “Alta Database”).
- Responding to general information requests regarding the Service.
- Preventing unwanted messages or content.
- Measuring the performance of our marketing programs.
How We Share Your Information
We will not share Personal Information with any third parties except as described in this Policy, including the following:
- Institutions. We may license your Personal Information or our Alta Database, in which your Personal Information may be stored, to institutional investors so that they can offer borrowers the best terms possible based on industry trends. Examples of such institutions include the Alta Real Estate Fund, which is owned and operated independently by some of the Company’s owners.
- Vendors. We may share your Personal Information with third-party vendors, contractors, and other service providers working on behalf of the Company and require access to your Personal Information to carry out the Services. Such vendors are under contract to only collect, use, store and share your Personal Information in accordance with our instructions. Examples of such vendors include companies that assist us in completing KYC checks, including processing any biometric information.
- Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
- Compliance with Laws. We may disclose your Personal Information to a third party if:
(1) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
(2) to respond to duly authorized information requests from law enforcement or other governmental authorities;
(4) to investigate and help prevent security threats, fraud, or other malicious activity; or
(5) to respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
There also may be circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.
California Privacy Rights
Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent. Such third parties do not include lenders with which you may be seeking a business relationship as part of the Service.
For Website Visitors in the European Union (“EU”)
Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU may be afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, the Company operates as a data controller and can be contacted as provided below. Any personal data we collect from you is processed in the United States and under the terms of this Policy.
Any limited personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.
You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:
- Access. You may email us at email@example.com to request a copy of the personal data our Website databases currently contain.
- Automated Processing and Decision-Making. You may email us at firstname.lastname@example.org to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
- Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at email@example.com to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
- Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to firstname.lastname@example.org. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to email@example.com. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to firstname.lastname@example.org. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
- Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at email@example.com. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
- Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at firstname.lastname@example.org. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
- Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.
Important Notice & Disclaimers
Your Personal Information will always be processed by the Company in accordance with this Policy unless otherwise agreed to in writing. Nonetheless, it is important to advise you that certain privacy laws do not apply to the Website or our Services.
- Gramm Leach Bliley Act (GLBA). Although we facilitate the matching of borrowers with qualified lenders, we are not a financial institution and therefore not subject to the requirements of GLBA in the operating of this Website.
- Fair Credit Report Act (FCRA). The Company is not a “consumer reporting agency” or “reseller” as those terms are defined under the FCRA. The Company does not process, assemble, or merge any Personal Information to create or modify any consumer report. Accordingly, the FCRA does not apply to the Company’s processing of Personal Information as described in this Policy. While lenders may use information you provide through the Website to make determinations about your eligibility for a loan, the Company plays no role in determining such eligibility. All such determinations are the sole responsibility of the lender subject to the lender’s own compliance programs.
Changes to this Policy
Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise (or guarantee) 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any suspected unauthorized use.