Privacy Notice

Last updated: September 2025

This privacy notice for Alguna Inc. (“Alguna,” “we,” “us,” or “our”) describes how and why we collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at https://alguna.io or any other website that links to this notice
• Engage with us in sales, marketing, customer support, or events

If you have questions or concerns after reading this notice, please contact us at [email protected].

If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

• Personal information we collect: Names, emails, job titles, login details, and technical device data depending on how you interact with us.
• Sensitive information: We do not process sensitive personal information.
• Third-party sources: We do not obtain personal information from third parties.
• How we use information: To provide, improve, and secure our Services; to communicate with you; to comply with law; and, with consent, to send marketing communications.
• Sharing: We may share information with affiliates or during business transfers, but only as necessary.
• Security: We use organizational and technical safeguards. However, no system is 100% secure.
• Your rights: Depending on where you live, you may have rights to access, correct, delete, or restrict your data, and to object or withdraw consent.
• Who we process data for: Alguna’s customers are businesses; users are their employees; end-customers are those businesses’ customers. For users, we are a data controller. For end-customers, we act as a data processor under our customer’s instructions.

1. INFORMATION WE COLLECT

Personal information you provide

• Users of our Services (controller role): email address, name, job title, login details, and business-related information.
• End-customers of our customers (processor role): information determined by our customers based on their interaction with you. In these cases, our customer is the data controller, and we process information only on their behalf under a Data Processing Agreement (DPA). Please refer to their privacy notice.

Information collected automatically

We collect technical and usage data such as:

• IP address, browser, operating system, device configuration
• Log data (pages viewed, searches, time stamps, crash reports)
• Device identifiers and geolocation (IP-based)

2. HOW WE PROCESS YOUR INFORMATION

We process information to:

• Deliver and manage Services
• Provide support and respond to inquiries
• Send administrative updates (terms, policies, product updates)
• Manage payments, orders, and returns
• Request feedback and participation in surveys
• Send marketing communications (with opt-out available)
• Maintain security, prevent fraud, and comply with obligations
• Protect vital interests (e.g., prevent harm)

We do not use your personal data for automated decision-making that produces legal or similarly significant effects.

3. LEGAL BASES FOR PROCESSING (GDPR / UK GDPR)

We may rely on:

• Consent (withdrawable anytime)
• Contract (to deliver Services you requested)
• Legitimate interests (e.g., improve Services, prevent fraud, send product updates)
• Legal obligations (e.g., accounting, compliance, litigation)
• Vital interests (e.g., safety)

Roles:

• We are the data controller for users of Alguna’s Services.
• We are the data processor for end-customer data handled on behalf of our customers.

4. SHARING PERSONAL INFORMATION

We may share information:

• Business transfers: merger, acquisition, financing
• Affiliates: parent/subsidiary companies under common control

5. COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar tools (e.g., pixels, beacons) to:

• Enable essential site functions
• Track usage for debugging and security purposes only

We do not use cookies for marketing or profiling. You can manage cookies through your browser settings, but disabling them may affect functionality.

6. INTERNATIONAL TRANSFERS

Our servers are located in Ireland (EU). We may also process data in the UK, US, and other countries where we or our affiliates operate.

Safeguards include:

• European Commission’s Standard Contractual Clauses (SCCs)
• Other lawful GDPR/UK GDPR transfer mechanisms

7. DATA RETENTION

We retain personal data only as long as necessary for the purposes described in this notice, including legal, accounting, and compliance requirements.

• User data: Retained for the duration of the account and up to 60 days after closure, unless longer required by law.
• End-customer data: Retained according to our customer’s instructions.

8. SECURITY

We implement appropriate organizational and technical safeguards to protect personal data. However, no system can be guaranteed 100% secure. Transmission of data to and from our Services is at your own risk.

In the event of a personal data breach, we will notify affected individuals and regulators as required by applicable law.

9. MINORS

We do not knowingly collect data from children under 16 (or under 13 in the US under COPPA). If we discover such data, we will delete it.

10. YOUR RIGHTS

Depending on your location, you may have the right to:

• Access and receive a copy of your personal data
• Request correction, deletion, or restriction of processing
• Withdraw consent at any time
• Object to processing (including marketing)
• Data portability (where applicable)
• File a complaint with your Data Protection Authority

We respond to all data subject requests within the timeframes required by applicable law (generally within 30 days). Requests can be submitted to [email protected].

11. DO-NOT-TRACK & GLOBAL PRIVACY CONTROL

We do not currently respond to “Do Not Track” (DNT) signals. Where required (e.g., California), we honor Global Privacy Control (GPC) as an opt-out of sale/sharing.

12. UNITED STATES PRIVACY RIGHTS

Categories collected in the past 12 months:

• Identifiers (A): name, email, IP address ✅
• Geolocation (F): IP-based location ✅
• Others (B–E, G–K): ❌ not collected

We do not sell or share personal information.

13. UPDATES TO THIS NOTICE

We may update this notice. Updates will be effective when posted, with the revised date shown at the top. For material changes, we may notify you by email or banner.

14. CONTACT US

• Email: [email protected]
• United States (main office):
  Alguna Inc.
  1111B S Governors Ave #6268
  Dover, DE 19904
  United States
• United Kingdom (HQ & Data Protection Representative):
  Alguna HQ
  5 Epstein Square
  London, E14 6FX
  Registered with the UK Information Commissioner’s Office (ICO)
  Registration number: ZB664701

If you are based in the UK or EU, you may contact our UK HQ for all privacy-related matters.

15. REVIEW, UPDATE, OR DELETE DATA

To request access, correction, or deletion of your data, please contact [email protected]. We will respond in accordance with applicable law.