Privacy Policy

Important Information and Who We Are

This privacy policy gives you information about how Aligned collects and uses your personal data through your use of this Website (https://alignedlayer.com), including any data you may provide when you use our services, sign up to our newsletter, or contact us.

This Website is not intended for children (anyone under 18 years of age) and we do not knowingly collect data relating to children.

Defined terms used but not otherwise defined in this privacy policy have the meaning set forth in the Terms and Conditions.

Controller

Aligned Foundation, a company registered in the Cayman Islands with number 416187, is responsible for the operation of this Website and Aligned. It will be the controller of any personal data collected and processed on or via the Website.

When we mention "Aligned", "we", "us" or "our" in this privacy policy, we are referring to Aligned Foundation.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at [email protected].

The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name.
• Contact Data includes email address.
• Profile Data includes username or similar identifier, including for social platforms.
• Business Data includes your employer, professional role or title, and work email address (for example, if you are a business contact at one of our partners or collaborators).
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Website.
• Usage Data includes information about how you interact with and use our Website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us, your communication preferences, and details about your engagement with our communications.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends and improve the Website.

Aligned will not process nor require you to provide any sensitive personal data, such as genetic data, health information, or religious information.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:

• request a demo or schedule a call;
• sign up to our newsletter;
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using server logs, cookies, and similar technologies.

Cookies. We use Google Tag Manager and Google Analytics to understand how visitors use the Website. These set analytics cookies on your device. We only load them after you accept them in the cookie banner shown on your first visit, and you can decline without affecting how the Website works. You can change or withdraw your choice at any time using the Cookie preferences link in the footer of every page; withdrawing is as easy as accepting, and we delete the analytics cookies when you do.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, including:

• Technical Data from Cloudflare (hosting, security, and analytics).
• Technical Data and Usage Data from Google (Google Tag Manager and Google Analytics), where you have accepted analytics cookies.
• Identity Data, Contact Data, and Business Data from publicly available sources such as public records.
• Identity Data, Contact Data, and Business Data from your interactions with our social platforms, such as X and GitHub.

If you fail to provide personal information

It is voluntary to do business with us. However, please note that if you fail to provide certain information when requested, we may not be able to give you access to our Website or services, or otherwise perform a contract we have entered into with you.

How We Use Your Personal Data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We will typically rely on one or more of the following:

• Performance of a contract with you. Where we are taking steps to enter into a contract with you or where we need to perform the contract we have entered into with you.
• Legal obligation. Where it is necessary for compliance with a legal obligation that we are subject to.
• Consent. Where we have obtained your active agreement to use your personal data for a specified purpose (for example, if you subscribe to our newsletter).
• Legitimate Interest. Where it is necessary for the purposes of our legitimate interests, provided this does not prejudice your rights and freedoms (for example, to conduct analytics or improve our services).

Purposes for which we will use your personal data

To operate our Website. We will use your personal data to:

• provide, operate, maintain, and secure our Website;
• provide support assistance and troubleshooting;
• manage our relationship with you, including notifying you about changes to our terms or privacy policy; and
• administer and protect this Website (including data analysis, testing, system maintenance, security, support, reporting, and hosting of data).

To comply with legal obligations and to defend Aligned against legal claims or disputes, including to comply with applicable laws and respond to requests from government or regulatory authorities.

Direct marketing. On our Website, you may sign up to receive direct marketing communications from Aligned by signing up to our newsletter. We will process your personal data to provide this newsletter to you.

Third-party marketing. We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at [email protected]. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Disclosures of Your Personal Data

We do not sell, rent, license, or lease your personal data to third parties.

In certain circumstances, however, we may share your personal data where necessary with the following categories of third parties:

• Group entities as part of regular reporting activities, business reorganisation, system maintenance support, and hosting of data.
• Third-party service providers including Cloudflare (hosting, CDN, security, and analytics) and Google (Google Tag Manager and Google Analytics).
• Third-party linked services. If you link to or otherwise provide details of an external service, we may share your personal data with that service.
• With your consent. We may share your personal data with third parties where you have instructed us or provided your consent to do so.
• Business transfers. We may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
• Professional advisers such as lawyers, accountants, auditors, bankers and insurers, where necessary in the course of the services they render to us.
• Regulators or law enforcement where we need to comply with the law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

Your personal data may be processed in the Cayman Islands (given the establishment of Aligned Foundation). We may also transfer the personal data we collect about you to Uruguay and Argentina in order to perform our services, as these are where our team and offices are located.

We will only transfer your personal data to countries where there are adequate data protection safeguards, or we have your consent.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see "Your Legal Rights" below for further information.

Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data. Under certain circumstances, by law you have the right to:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information corrected.
• Object to processing of your personal data where we are processing your personal data for direct marketing purposes.
• Request erasure of your personal data where there is no good reason for us continuing to process it.

If you want to review, verify, or correct your personal data, or object to the processing of your personal data, please contact us at [email protected].

Right to withdraw consent

Where you may have provided your consent to the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us at [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose you originally agreed to, unless we have another legitimate basis for doing so in law.

Contact Details

If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your privacy rights, please contact us at [email protected].

Complaints

You have the right to make a complaint at any time to the Cayman Islands Ombudsman (by email to [email protected] or telephone on +1 345 946 6283) in respect of the handling of your personal data by Aligned Foundation. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.

Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated on the date set out at the start of this privacy policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.