VERTICE TECHNOLOGIES LLC. SERVICE PRIVACY STATEMENT

Updated: July 1, 2018

In this Privacy Statement (“Statement”), Vertice Technologies LLC. ( “Vertice Technologies LLC.” or “Vertice”) explains how Customer Data is collected, used, maintained, disclosed and transferred. Vertice operates as a data processor, and as such, will process all Customer Data according to the contractual agreements with our customers and as required by law.

References in this Statement to “Vertice,” “us” or “our” are references to Vertice Technologies LLC.  Statements referring to “you” or “your” or “customer” are references to the Customer as defined in your Financial Products License Agreement with Vertice and for whom Vertice processes Customer Data.

Our use of the term Solutions in this Statement has the same definition as in Customer’s Vertice Financial Products License Agreement (“Solution(s) or Subscribed Solution(s)”).

Customer Data is defined as information relating to an identified or identifiable living individual that our customers and their end-users input or upload into Vertice financial products, also known as Solutions, for processing or reporting. It does not include data Vertice collects from visitors to our Websites, nor data Vertice collects about our customers or prospective customers, vendors, service providers, professional advisors, consultants, and other third parties otherwise in the course of doing business, for example, to manage our customer’s accounts or communicate with them, or to engage our vendors.

If you have any questions regarding this Statement, please email us at Compliance@altareturn.com or contact us as described in the “How to Contact Us” section below.

SCOPE

This Statement applies to Customer Data only as defined above for which Vertice is a data processor.
The Federal Trade Commission has jurisdiction over Vertice’s compliance with the Privacy Shield.

OUT OF SCOPE

For purposes of clarity, this Statement does not apply to Business Data as defined in Vertice’s Business Privacy Statement.

COLLECTION PURPOSES, USE OF CUSTOMER DATA

Vertice processes Customer Data submitted by customers according to the parameters made available by the Solutions. Customers, or their end-users, input or upload information into the Solutions. Vertice only processes Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Financial Products License Agreement, including the Schedules, SOWs, Product Riders and Exhibits, with us. Vertice acts as a data processor or sub-processor with respect to this Customer Data. Vertice limits the interaction with Customer Data to the following purposes:

  • To provide and deliver the contracted services;
  • To provide customer service or support;
  • To respond to a customer’s requests to address technical issues;
  • To respond to lawful requests.

Our customers are responsible as data controllers for ensuring (i) their end-users receive proper notice of customer’s privacy practices, (ii) Customer Data is obtained in accordance with all applicable laws, and (iii) their end-users are given a choice regarding our processing activities of Customer Data. If a customer’s end-user has any questions or concerns related to the handling of Customer Data, the end-user may contact us as described in the How to Contact Us section and Vertice will work with the Customer to address the end-user concerns.

DATA TRANSFERS TO THIRD PARTIES

Vertice does not sell, distribute or loan Customer Data to any third-parties; however, Vertice may share Customer Data with third-parties as follows:

  • Within Vertice Technologies LLC consistent with this Statement.
  • With trusted sub-contractors to perform business related functions such as to help support the Solutions on behalf of or at the direction of Vertice.

OTHER DISCLOSURES

Under certain circumstances, Vertice may be required to disclose Customer Data in response to valid requests by governmental authorities, including to meet national security or law enforcement requirements.

Vertice will attempt to refer any request for disclosure of Customer Data by governmental authorities, including those received for national security or law enforcement reasons, to the customer. Vertice may, where legally obligated to do so, disclose Customer Data to law enforcement or other government authorities, in which case Vertice will notify our customer of such a request (unless prohibited by law to do so) and will furnish only that portion of the Confidential Information that is legally required. Vertice is liable for appropriate onward transfers of personal data to third parties.

DATA ACCESS

Vertice maintains physical and process security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
While Vertice employs security measures to protect Customer Data in our Solutions, our customers, and their end-users, should only access the Solutions within a secure environment and take appropriate steps to always ensure that login credentials and passwords are kept safe at all times. Customers should notify us as soon as possible if they become aware of any misuse of their user IDs, passwords, or accounts, and immediately change their passwords within the Solutions in accordance with the “How to Contact Us” section, below.

SECURITY

Vertice takes reasonable steps to determine who gains access to Customer Data. Vertice’s User Access Management guidelines are based on the “Principle of Least Privilege,” and access to Customer Data shall be limited by that principle, which requires that privileged access must be provisioned with the minimum level of access to non-public data which is required to satisfy a user’s job responsibilities.

CROSS BORDER TRANSFERS

Customer Data will not be transferred across any political or geographic boundary except the US, in which case the EU- US Privacy Shield Framework applies.

Vertice complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

Vertice has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Vertice is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission and commits to cooperate with EU data protection authorities.

DISPUTE RESOLUTION

Vertice commits to resolve complaints regarding use and disclosure of Customer Data in accordance with this Statement.  EU individuals with inquiries or complaints regarding our compliance with this Statement should first contact Vertice at: Compliance@altareturn.com. Vertice will investigate and attempt to resolve complaints and disputes.

Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Vertice Technologies, LLC’s internal processes, Vertice Technologies, LLC has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here:  https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

In certain conditions you may have the ability to invoke binding arbitration to address any complaint that Vertice has violated its obligations under this Statement to you and that has not been resolved by other means.

RETENTION

Vertice retains Customer Data and any other data collected through the Solutions in accordance with the timeframes set out in the relevant Financial Products License Agreement with our customers. Our retention periods may change:

  • If there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them)
  • If retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

GENERAL DATA REQUESTS

If any data subjects have questions or concerns about the processing of Customer Data, they should contact our customer (the data Controller) directly or read their privacy policy.

Similarly, an individual who seeks to access Customer Data, or to correct, amend, or delete Customer Data should direct their query to the customer. If the customer asks us to retrieve, amend or remove the Customer Data, Vertice will do so in accordance with our Financial Products License Agreement with them and our Privacy Shield commitments.

Vertice customers who want to find out more about the data security settings on their account can refer to their Financial Products License Agreement or other applicable contractual documents with us; or contact us directly for further information.

HOW TO CONTACT US

If you have any questions regarding this Statement or if you need to request access to or update, change or remove personal information that Vertice processes on your behalf, you can do so by contacting:

Vertice’s Compliance Team at:

9350 South Dixie Highway | Suite 1420 | Miami | FL 33156
Main: +1.305.925.0500 | Fax: +1.203-489-9047 |
Email: compliance@altareturn.com

If you wish to change your name, company name, email address, or any other part as your business contact information as listed in your contacts profile, you must contact our Support Team at support@altareturn.com or https://support.altareturn.com.

You also may decline to receive mail or email from us that does not relate directly to your access to or use of the Service. If you wish to receive “support-only” communication at any time, please email us at support@altareturn.com.

You can also unsubscribe from our marketing communications by following the unsubscribe mechanism in the e-mail message. Please note that if you do opt-out of receiving marketing- related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving account-related or other administrative messages.

AMENDMENTS

Vertice reserves the right to change, modify, add or remove portions of this Statement from time to time and in our sole discretion, but will alert you that changes have been made by indicating on this Statement the date it was last updated listed at the top.
When you visit this site, you are accepting the current version of this Statement as posted on the site at that time. Vertice recommends that customers revisit this Statement on occasion to learn of any changes.