This Application collects some Personal Data from its Users.

This document contains a section dedicated to Users in the United States and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Alternative Innovations Financial Services GmbH

Absberggasse 27/9/27

1100 Vienna

Austria

Owner contact email: rklemm@ai-fs.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Trackers; Usage

Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by

specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it

impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not

mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the

Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this

Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the

present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized

destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes

strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of

persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration)

or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies,

communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be

requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are

located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To

find out more about the place of processing of such transferred Data, Users can check the section containing details about the

processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose

they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to

enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent

activity, as well as the following: Analytics.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information

on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User

behavior.

Google Analytics (Universal Analytics) (Google Ireland Limited)

Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes

the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other

Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

Further information about the processing of Personal Data

The Service is directed to children under the age of 13

This Application is directed to children under the age of 13. It doesn't require the child to disclose any more information than is

reasonably necessary to participate in its activity. Parents may review the personal information about their child collected by this

Application - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted

by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow

disclosure to third parties, unless disclosure is integral to the Service.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes.

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations

thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the

Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether

the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose

they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be

retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill

such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the

relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing,

as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period

whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to

rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their

consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is

carried out on a legal basis other than consent.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding

certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or

corrected.

Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner

will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the

Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a

structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another

controller without any hindrance.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed

by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the

Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for

the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground

related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to

that processing at any time, free of charge and without providing any justification. Where the User objects to processing

for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the

Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this

document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such

requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users

with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be

communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves

impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is

provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes

of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”),

who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or

disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone

who is not a California resident to get a general idea of what types of Personal Information are collected.

Identifiers

Personal Information collected or disclosed: Various types of data as specified in the privacy policy of the service

Purposes:

Further information about Personal Data

Retention period: for the time necessary to fulfill the purpose

Sold or Shared

ℹ

: No

Targeted Advertising:

ℹ

: No

Service providers or contractors: this Application

Internet or other electronic network activity information

Personal Information collected or disclosed: Trackers, Usage data

Purposes:

Analytics

Retention period: for the time necessary to fulfill the purpose

Sold or Shared

ℹ

: No

Targeted Advertising:

ℹ

: No

Third-parties: Google Ireland Limited

ℹ

You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights you can refer to the “Your privacy rights under US state laws” section of our privacy

policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of

Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible

with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this

Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You

also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is

automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the

functioning of this Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you

have:

the right to access Personal Information: the right to know. You have the right to request that we confirm whether or

not we are processing your Personal Information. You also have the right to access such Personal Information;

the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate

Personal Information we maintain about you;

the right to request the deletion of your Personal Information. You have the right to request that we delete any of your

Personal Information;

the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and

usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;

the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising

your privacy rights.

the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;

The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is

necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that

certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal

Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado,

Connecticut, Texas and Oregon, you have

The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance

of decisions that produce legal or similarly significant effects concerning you;

The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information.

Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and

processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by

the consumer.

Additional rights for users residing in Utah

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have

The right to opt out of the processing of your Personal Information for Targeted Advertising;

The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions

outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal

Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in

this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your

identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account

with us to submit your request. We will use any Personal Information collected from you in connection with the verification of

your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for

purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use

the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy

control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a

frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we

need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may

then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all

other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the

request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action

arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and

contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction

with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see

the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly

within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information

available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at

the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent

from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information that directly, indirectly, or in connection with other information — including a personal identification number —

allows for the identification or identifiability of a natural person.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered

sensitive according to the applicable privacy law.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can

include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses

(Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file

received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country

of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time

spent on each page within the Application) and the details about the path followed within the Application with special reference

to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as

described in this privacy policy.

Data Controller (or Owner)

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, including the security measures concerning the operation and use of this

Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable

consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a

service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of

your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise

communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third

party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions

between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is

exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service

provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing

of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal

Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict

such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to

the European Union and the European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -

that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: May 31, 2024