Last updated: July 12, 2017
Part I. General Information
Our stance regarding privacy
ACROSS MERIDIAN, LDA (Alfa Protection, We or Us) helps digital companies (Customers) identify and handle fraud and malicious conduct with regards to their online assets. As part of this agenda, we gather data about how Internet users (Users) work with our Customers' online properties, for example, their websites and mobile apps (Customer Sites). We strive to prioritize privacy when creating, planning and implementing our web-based machine-learning system that helps to model user intent and deal with fraudulent activities as they occur (the Alfa Protection Service).
Introducing the Alfa Protection
The Alfa Protection Service is triggered into action when Customers submit data about Users and how they use the Customer’s Site (Service Data) to us. Customers submit this information via the REST Application Programming Interfaces and admin dashboard. ACROSS MERIDIAN utilizes the Service Data and applies its analytical algorithms to build a comprehensive and relative grade (the Risk Assessment) taking the predefined action on the Customer Site into account (for example, orders, profile activity, etc.). Overall, this helps to recognize and handle fraudulent actions on the Customer Sites.
Having received their Risk Assessment, our Customers can choose how to respond to the possible threat. For instance, they may decide to suspend a transaction if it appears to carry a high risk of being a malicious activity. Additionally, customers are constantly giving us their feedback detailing whether the Risk Assessment has been concise by monitoring their transactions for any malicious actions.
Part II. Raw Data and Its Usage
Service Data that our Customers submit to us
Our Customers choose the types / configuration of the Service Data they submit to be analyzed by the Alfa Protection. We urge our Customers to cooperate with the Alfa Protection support team closely in order to evaluate the usefulness of any particular Service Data they submit. We strive to help our Customers evaluate whether any specific action has a malicious intent, for instance, figuring out the probability of the payment details being stolen or a User's identity information being false.
In particular, Customers may submit the personal data of their Users (e.g., their email addresses, shipping and charging addresses, phone numbers and login details) to the Alfa Protection. Customers can give us data about Users’ behavior on the Customer Sites, including the IP address of the gadget, the page views, time of login/logout, viewed products, products added to the cart or purchased. Customers may send us information about the payment details, for example, order size, payment method, some of the credit card digits and the status of the order.
Furthermore, Customers may give us data about the feedback that Users submit via their Customer Sites (for example, private messages, discussion threads or reviews). This data provides valuable insights to the Alfa Protection team so that we can enhance the quality of our services.
At the same time, Customers may deploy Alfa Protection SDKs to detect fraudulent activities that may happen through their mobile applications. The SDKs may empower Alfa Protection to capture more concise data about the client's location, for example GPS (if the location settings are enabled) and IP address. Also, the SDK may gather cell phone metadata (for example, battery level, gadget properties, carrier name, proximity, etc.) as well as gadget identifiers.
The security of the Service Data we get is safeguarded by Alfa Protection according to the procedures outlined below.
Part III. Other Data and Its Usage
Data we gather from Customers (the Customer Information)
We will gather data about every Customer in case they sign up for the Alfa Protection Service. This information typically includes the name and size of an organization, URL and fraud-related data. Additionally, we gather personal data about individuals that act on behalf of the Customer regarding the implementation of the Alfa Protection Service. This information includes full name, email address and phone number. We will utilize that data for further communications regarding Customer's implementation of the Alfa Protection Service.
In case the Customer pays with a credit card, our payment system will capture that data (Alfa Protection does not store full information on credit cards). Likewise, we will gather billing data. Such data is utilized for billing processes.
We may utilize the data you submit to us to fulfill our advertising projects, if this meets your marketing expectations. Depending on whether such outreach is to your liking or not, you will always have the opportunity to unsubscribe (see the "Unsubscribe from Our Mailing List" paragraph below).
How we utilize Customer Information we gather
We may utilize Customer Information to:
provide and charge for the Alfa Protection Service;
analyze Customers' implementation of the Alfa Protection Service in order to enhance the Alfa Protection Service;
send Customers updates, alerts, security notices and admin messages;
send Customers marketing info as per their marketing expectations;
for other purposes which we will inform our Customers about.
Part IV. Data Sharing and Disclosure Policy
Merchants, consultants and other companies: We may give access to the Customer and User data to the third-party merchants, consultants and other service providers who directly take part in our business processes and the sharing of such data with whom is vital to keep the work going, as is the case with customer support or billing.
Enhancing information: We may share basic Service Data (for example, email addresses) with third parties for the purpose of enhancing information. Enriching information enables us to build a more comprehensive subset of data that would open ample opportunities to make educated and well-informed risk assessments. For instance, we may share select client email addresses with another company in order to get URLs to the openly accessible social profiles. Before sharing information with a third party, Alfa Protection studies the seller's security standards to make sure that the information is sufficiently safeguarded.
Compliance with laws: We may reveal Customer Information and Service Data to another party in case we are legally required to provide this information to comply with any law, legal investigation or government request.
Essential interests and legal rights: We may reveal the data about you in case we think such action is required in order to secure the key interests or legitimate privileges of Alfa Protection, our Customers or the rights or assets of others.
Part V. International Transfer
Processing of data in the U.S.; International Data Transfer Compliance
Alfa Protection will interact with Customers from all over the world to build the legally binding insurances in order to help Customers comply with the laws of their countries. As for the information concerning EU residents, we provide model provisions to our EU Customers via email@example.com
Part V. Security
We implement proper administrative and technical procedures to safeguard personal data against illegal use, disclosure, modification and deletion.
For the most recent data about the procedures we have set up to shield client data, see our Security and Privacy Overview.
Part VI. Individual Privacy Rights
We enable all Customers and Users to view, audit, correct and delete any personal data incorporated into the Customer Information or Service Data, as required by the relevant law. You can send your message to firstname.lastname@example.org to learn more. In case you demand to get access to your personal data, we might charge you a fee that will not exceed the maximum fee defined by the law that applies.
Unsubscribe from our mailing list
Customers can request to opt out from any mailing list which they voluntarily joined earlier at any time by clicking "Unsubscribe" in any emails we have sent to them. Customers can ask their questions regarding our unsubscribe policy using the contacts we provided.
Part VII. Other Essential Information