Privacy Policy

Last update: September 20, 2023

We at ALPSANTO GLOBAL MOMENTUM LLC (“Company,” “we,” “our,” or “us”) take your privacy and the protection of your personal data very seriously. We strive to comply with all applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), other U.S. state laws, and all relevant requirements for the Apple App Store and Google Play Store. This Privacy Policy applies to our mobile application (“App”), related online services, and any other interactions you have with us.

By using our App or services, you agree to the collection, use, processing, and transfer of your personal information as described in this Privacy Policy. If you do not agree, please refrain from using our App or services.

If you have any questions or concerns, please contact us at:

Controller / Responsible Entity under GDPR:

ALPSANTO GLOBAL MOMENTUM LLC

7901 4th St N, STE 300

St. Petersburg, FL 33702, USA

Email: support@alpsanto.com



1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data we collect when you:


  • Install and use our App on Android, iOS, or other supported operating systems.

  • Visit our website or interact with our online services.

  • Contact us via email, contact forms, or support channels.

  • Engage with our App’s features, including AI-based functionalities, data storage, and notifications.

It also addresses data processing by third-party providers that we integrate into our App. We ensure that any data sharing is covered by appropriate legal frameworks and security measures.



2. LEGAL BASES FOR PROCESSING

We process your personal data based on:


  • Your consent (Art. 6(1)(a) GDPR): For certain services like push notifications, personalized offers, or where required by Apple App Tracking Transparency (ATT).

  • Performance of a contract (Art. 6(1)(b) GDPR): To provide you with the App’s core functionalities, user account maintenance, and service delivery.

  • Legal obligations (Art. 6(1)(c) GDPR): To comply with applicable laws, regulations, and lawful requests from authorities.

  • Legitimate interests (Art. 6(1)(f) GDPR): For app improvement, analytics, preventing fraud, and maintaining security, provided these interests are not overridden by your rights and interests.

If you reside in California, our data practices may also be subject to the CCPA. Under the CCPA, we may process your data for “business purposes” and, if applicable, request your consent for “selling” or “sharing” personal information as defined under California law.



3. TYPES OF DATA WE COLLECT

3.1 Automatically Collected Data (Usage Data)


  • Device Information: IP address, operating system, device model, unique device identifiers (such as Android Advertising ID or Apple ID for Advertising), browser type, and version.

  • App Usage Data: Features you use, access times, pages viewed, crash logs, diagnostic data, and performance metrics.

3.2 User-Provided Data


  • Account Registration Data: Email address, username, password, or other credentials to create and maintain your user account.

  • Content and Interactions: Data you input into the App, including text entries, uploaded files, images, or documents.

  • Support and Communication: Any information you provide when contacting our support team or communicating via email, in-app chat, or feedback forms.

3.3 Cookies and Similar Technologies

Our website and certain App features may use cookies, local storage, or similar tracking technologies to remember your preferences and understand usage patterns. You may disable cookies through your device or browser settings, but this may affect some functionalities.



4. HOW WE USE YOUR DATA

We may use your data for:


  • Core Functionality: Ensuring the App’s features work properly, including login, file uploads, AI queries, and personalization.

  • Push Notifications: If you grant permission, we use Firebase (Google LLC) and Apple Push Notification Service (APNS) to send you updates, alerts, and relevant information. You can disable notifications at any time in your device or App settings.

  • AI Features: We may process your inputs through AI models (DeepInfraFal.ai, OpenAI, Google AI) to provide intelligent responses, generate content, or offer smart suggestions. Data is typically processed in pseudonymized form.

  • Analytics and Improvement: We use aggregated, anonymized, or pseudonymized data to understand usage trends, fix bugs, improve performance, develop new features, and enhance user experience.

  • Compliance and Legal Obligations: We may process data as required by law, enforce our Terms of Service, or prevent fraud, abuse, and security threats.



5. THIRD-PARTY SERVICES AND INTERNATIONAL DATA TRANSFERS

We rely on trusted third-party services to operate our App efficiently:



  • Hosting and Infrastructure:



    • Amazon Web Services (AWS): Our App and data are hosted on servers provided by AWS, which may be located outside the EU/EEA. We rely on Standard Contractual Clauses (SCCs) or other approved transfer mechanisms to ensure an adequate level of data protection.
      https://aws.amazon.com/privacy/
  • Framework and Cloud Functions (Laravel Vapor)
https://vapor.laravel.com/privacy

We encourage you to review the privacy policies of these third-party services to understand their data handling practices.



6. DATA SHARING AND DISCLOSURE

We only share personal data with third parties:


  • To fulfill contractual obligations or provide services you have requested.

  • If you have given explicit consent.

  • To comply with legal requirements, respond to lawful requests by authorities, or protect our rights and property.

  • In connection with a merger, acquisition, financing, or sale of assets, provided that the receiving party agrees to respect your personal data in a manner consistent with this Privacy Policy.

We never “sell” personal information to third parties, as commonly defined by privacy laws such as the CCPA, without first obtaining your consent where required.



7. DATA RETENTION

We retain your data only as long as necessary to provide the App’s functionalities, comply with legal obligations, or fulfill the purposes for which the data was collected. The retention period may vary depending on the data type, legal requirements, and contractual obligations. For instance:


  • Account Data: Retained until you delete your account or for a defined period after account inactivity.

  • Usage Data: Anonymized or aggregated usage data may be retained for longer periods for analytical purposes.

You may request deletion of your data at any time (see Section 9), and we will make reasonable efforts to accommodate such requests unless we are legally required or have a compelling legitimate interest to retain such data.



8. SECURITY MEASURES

We implement appropriate technical and organizational security measures to protect your data from unauthorized access, loss, misuse, or alteration. These measures include encryption, access controls, and secure data storage. However, no method of transmission over the internet or electronic storage is entirely secure. While we strive to protect your personal data, we cannot guarantee absolute security.



9. YOUR RIGHTS AND CHOICES

Under GDPR (EU/EEA Users):


  • Access (Art. 15 GDPR): Request information about the personal data we hold about you.

  • Rectification (Art. 16 GDPR): Request correction of inaccurate or incomplete data.

  • Erasure (Art. 17 GDPR): Request deletion of your data, subject to certain exceptions.

  • Restriction (Art. 18 GDPR): Request restricted processing of your data under certain circumstances.

  • Data Portability (Art. 20 GDPR): Receive your personal data in a structured, commonly used, and machine-readable format.

  • Objection (Art. 21 GDPR): Object to processing of your data for certain purposes.

  • Withdraw Consent (Art. 7(3) GDPR): If processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

Under CCPA (California Residents):


  • Access and Deletion: You have the right to know what personal data we collect about you and to request its deletion.

  • Non-Discrimination: We will not discriminate against you for exercising your rights.

  • Opt-Out of Selling/Sharing: If applicable, you can opt-out of any “sale” or “sharing” of your personal information.

For other jurisdictions, similar rights may apply. Please check your local laws.

To exercise your rights, contact us at [Insert Contact Email]. We may require additional information to verify your identity.

Opt-Out of Push Notifications and Tracking:


  • Push Notifications: Disable them in your device’s notification settings or within the App settings.

  • AppTrackingTransparency (iOS): If we utilize tracking for advertising or analytics, we will ask for your permission via the iOS ATT prompt. You can change these permissions anytime under your iOS device’s Privacy > Tracking settings.

  • Android Data Settings (Google Play): You can adjust your Google Play Services and device-level privacy settings to limit personalized advertising or tracking.



10. COMPLIANCE WITH APP STORE AND PLAY STORE REQUIREMENTS

We strive to adhere to all Apple App Store and Google Play Store policies and guidelines:


  • We clearly disclose what data we collect, how it’s used, and with whom it’s shared.

  • We comply with Apple’s AppTrackingTransparency framework by seeking your consent where required.

  • We align our disclosures with the Google Play Data Safety Section and provide consistent information in the App Store Connect’s Privacy Nutrition Labels.

  • We provide links to third-party privacy policies and explain how to opt-out of data collection and usage where possible.



11. LINKS TO OTHER WEBSITES AND SERVICES

Our App may contain links to external websites, services, or content that are not operated by us. We are not responsible for the privacy practices of these third-party sites or services. We encourage you to review their respective privacy policies before providing personal information.



12. INTERNATIONAL USERS

If you access our services from outside the United States or European Union, your information may be transferred to, stored, and processed in countries where data protection laws may differ from those in your jurisdiction. We ensure that such transfers comply with applicable legal requirements and that adequate protections are in place to safeguard your personal data.



13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advances. The current version will always be available within the App and/or on our website. If we make significant changes, we will provide notice (e.g., via in-app alert or email) before they become effective. Your continued use of the App after changes are posted constitutes your acceptance of the updated Privacy Policy.



14. CONTACT US

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:

ALPSANTO GLOBAL MOMENTUM LLC

7901 4th St N, STE 300

St. Petersburg, FL 33702, USA

Email: support@alpsanto.com














































































Our intention is with this Privacy Policy to be as inclusive, transparent, and compliant as possible with multiple regulatory and platform requirements.