Effective Date: June 2026

Altrata (“we,” “our,” “Altrata”) is committed to protecting the privacy and security of the information we collect in connection with the use of our websites and this is governed by this online Privacy Notice. (“Online Privacy Notice”). 

This Online Privacy Notice sets forth our policies and practices for handling the information we collect from you when you use the websites and other online services (“Online Platforms”). The Online Privacy Notice is designed to ensure that visitors to the Online Platforms understand our privacy practices when they visit or use the Online Platforms. 

Our products include people intelligence and research services that contain information about individuals (collectively “Products”). Please see our separate Product Privacy Notice to understand our privacy practices in connection with these Products. 

Altrata is part of Delinian, a business registered in England and Wales with registration number 00954730 and address of: 4 Bouverie Street, London, EC4Y 8AX. More information on Delinian can be found here.  

1.    COLLECTION OF INFORMATION

We collect information about you when you use our Online Platforms, such as when you visit or use our websites or other Online Platforms, including: 

Information you provide directly to us.

• Contact and Sign-In Information, including username and password, name, email address, telephone or mobile phone number, address and other contact information you provide to us such as when you register with one of our websites or sign up for a free trial of our Online Platforms. 
• Employment Information, including job title, such as when you register for an event or conference, or information about your social or business connections if you choose to upload that information to one of our websites. We may also collect information, consistent with your permissions, if you sync your electronic address book to your account on one of our websites or use various third-party tools, such as software widgets, to otherwise synchronize your calendar or contacts with our Online Platforms. 
• Geolocation data, including geolocation information derived from your GPS, WiFi and Bluetooth signals, IP address, and other device information. 
• Correspondence you send to us, including correspondence related to our communications with you through email, messages sent to you through the Online Platforms, and surveys or polls which request your feedback on our products and services. 
• We may record and analyse certain business communications, including calls and video meetings involving our employees, clients and prospective clients. These recordings may include audio, transcripts and related metadata and are used for purposes such as maintaining records, improving customer engagement, training and quality assurance, and supporting our sales activities. We may use automated tools, including artificial intelligence, to assist with analysis, but these are used to support human decision-making. We use trusted service providers to process this data on our behalf. Where required by law, we will provide notice and/or obtain consent before recording, and individuals may request that a recording is not made.

Information we collect automatically. 

• We collect internet, electronic activity, and other information automatically from the devices, browsers, and apps that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers, and other unique personal or online identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Online Platforms, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Online Platforms and other information about how you use the Online Platforms; the technology on the devices you use to access the Online Platforms; standard server log information; and app usage data and files downloaded to your apps. Some of this information is collected through cookies and other tracking technologies, as described further below. 
• If you engage with our content on social media, we may receive information about people with whom you are friends or otherwise connected. 
• We may also automatically collect information from the emails we send you in order to determine if our emails are opened among other information. 
  • If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred. 

Information from other sources

We also receive some of the information described above from other sources, including from other users of our products and services, marketing partners, entities that sell data, and third-party services and organizations. For example, if you access any social media or similar services through the Online Platforms to login or to share information about your experience with others, we may collect information from these third-party services. We may associate some of the personal information we automatically collect about you with information that we collect in other ways or receive from third parties. Such third parties can be categorized as follows: 

Advertising companies

Affiliates of Delinian

Internet Service Providers

Operating systems and platforms

Aggregated and de-identified data

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Online Privacy Notice.

2.    USE OF INFORMATION AND PURPOSE OF DATA PROCESSING

We use and otherwise process each of the categories of information identified above for the following business purposes:

Purpose/Activity	EEA/UK lawful basis for processing, including basis of legitimate interest
To provide our Online Platforms; to allow for participation in interactive features of our Online Platforms.	(a) Necessity for our legitimate interests (for instance, to keep our records updated and to grow our business)
To notify you about changes to our terms or Online Privacy Notice.	Necessity to comply with a legal obligation
To make suggestions and recommendations about things that are similar to those that you have enquired about or may otherwise be of interest to you, or, where permitted by law, to send promotional materials from us or by our affiliates and trusted business partners.	Necessity for our legitimate interests (namely, to grow our business)
To improve our products and services, and to ensure that content is presented in the most relevant and effective manner; to administer our products and services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our products and services, business and users safe and secure;	Necessity for our legitimate interests (for running, protecting and growing our business; for provision of administration and IT services; for network security and to prevent fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our products and services, to develop the products and services, to keep our products and services updated and relevant, to grow our business and to inform our communications strategy)
To comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.	Necessary to comply with a legal obligation

Where legally required and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information in accordance with applicable law), which may subsequently be withdrawn at any time by you by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn. 

Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

We may use automated tools to assist with responding to general enquiries and directing individuals to relevant resources, such as arranging demonstrations or providing contact information. These tools operate based on predefined prompts and may use information you provide or that we already hold about you to tailor responses. These tools are used to support communications and do not make decisions that have legal or similarly significant effects on you.

3.       DISCLOSURE OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Authorized third-party vendors and service providers. We may share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as email deployment, security and performance monitoring, maintaining or servicing accounts, research, data hosting, and data processing. Such third parties can be categorized as follows: 

Advertising companies

Affiliates of Delinian

Internet Service Providers

Operating systems and platforms

• Corporate affiliates.  We may share your information with our corporate affiliates, including Delinian Limited and its subsidiaries.
• Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
• Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of our corporate affiliates (including Delinian its subsidiaries), users, or the public.
• With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.  

If you access third-party services such as social media services through the Online Platforms, these third-party services may be able to collect information about you, including information about your activity on the Online Platforms, and they may notify your connections on the third-party services about your use of our Online Platforms, in accordance with their own privacy policies. 

If you choose to engage in public activities on the Online Platforms, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas. 

4.       YOUR RIGHTS AND CHOICES

You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, correction, deletion, and portability of your information or to request more information about our information practices. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. 

You can also update your email preferences at any time by clicking the “unsubscribe” link included in the emails we send you. 

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Online Platforms may change or no longer be available to you. Any​​ difference in our products and services is  related to the value provided. 

Depending on where you live, you may be able to lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful. 

5.       INTERNATIONAL TRANSFERS

When you use the Online Platforms and provide us with information, we may transfer and store your information on servers located outside your resident jurisdiction. Some of the entities (such as third-party vendors) to which we disclose information may be located outside of the EEA, including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that such personnel and third-party vendors are bound to duties of confidentiality, and we implement measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below. 

6.       CHILDREN

We do not knowingly collect or sell​ ​​or share​ any information from children, as defined by applicable law. If you are a parent or guardian and believe we may have sold or collected information about your child, please contact us as described below.

7.       DATA RETENTION, SECURITY, AND INTEGRITY

Information will be retained only for so long as reasonably necessary for the purposes set out above and consistent with our retention policies, in accordance with applicable laws. Because we are in the business of providing information and people intelligence services to our customers, we will retain data in our secure database until we find that it is no longer useful to our customers whilst having full regard for the principles of data minimization and our obligations under law. 

We maintain reasonable security measures to safeguard information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. 

We endeavor to keep your personal data secure and takes appropriate technical and organizational measures to protect your personal data from loss, unauthorized use, disclosure or destruction. 

Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. 

All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested. 

8.       CHANGES TO THE ONLINE PRIVACY NOTICE

We may modify this Online Privacy Notice from time to time. When we update the Online Privacy Notice, we will revise the “Effective Date” date above and post the new Online Privacy Notice. We recommend that you review the Online Privacy Notice each time you visit the Online Platforms to stay informed of our privacy practices. 

9.  CONTACT INFORMATION

If you have any questions about this Online Privacy Notice or our practices, please contact us via [email protected]. 

To exercise your rights as described in this Online Privacy Notice, please contact us by post or email at the following addresses: 

Data Protection Officer Altrata 

4 Bouverie Street, London, EC4Y 8A London, EC4Y 8AX 

United Kingdom 

Email:[email protected] 

Toll free number for California residents: +1 877 314 5147 

 10.  ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

We have explained our privacy practices in the other sections of this Online Privacy Notice.

In this Section, we provide a list of the categories of personal information set forth in the California Consumer Privacy Act (“CCPA”) that have been collected, the purposes for which those categories of information are collected or used, and the business purposes (as defined in the CCPA) for which those categories are disclosed, in the twelve months preceding the date this Online Privacy Notice took effect. 

We have not sold personal information processed as detailed in the Online Privacy Notice in the twelve months preceding the effective date of this Online Privacy Policy, although we do use standard Internet advertising and analytics tools provided by third parties that rely on cookies and other tracking technologies (see our Cookie Policy for more information), and we may disclose your information for the business purposes described below. 

Categories of Personal Information Collected

·       Internet or other electronic network activity information, e.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer’s interaction with a website, application, or advertisement. ·       Demographic and statistical information, including information regarding personal characteristics of protected classifications under California law like race and gender. ·       Device information and other personal identifiers, e.g., name; alias; postal address; online identifiers; IP address; email address; account name. ·       Professional, education, or employment-related information, e.g., business name or job title. ·       Geolocation information ·       Commercial or transactions information, e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ·       Inferences, e.g., inferences drawn from the information identified in this Online Privacy Notice to create a profile about a consumer reflecting the consumer’s preferences, predispositions, behavior, etc.

Purposes for Which the Categories of Personal Information Are Collected or Used

·       To provide the Online Platforms. ·       To communicate with you. ·       To improve and develop the Online Platforms. ·       As otherwise outlined above.

In addition to the interest-based advertising choices and browser settings described above in the Your Rights and Choices section, California residents may also opt-out of the sale ​​​or sharing ​of their information by clicking the “Do Not Sell​​​ or Share​” ​​link or by contacting us as at [email protected] or by calling our Toll free number on +1 877 314 5147. 

The following table sets out, for the preceding calendar year (January–December 2025), the number of consumer rights requests received by us under the California Consumer Privacy Act, together with how we responded to those requests.

Request to Delete
Complied in Part	115
Individual	54
Third Party	61
Complied in Whole	13
Individual	6
Third Party	7
Total	128

Request to Know PI is Sold /Shared
Complied in Part	1
Individual	1
Total	1

Request to Opt-Out
Complied in Part	455
Individual	12
Third Party	443
Complied in Whole	17
Individual	1
Third Party	16
Total	472

Right to access
Complied in Part	8
Individual	8
Rights to correction/verification	1
Complied in Part	1
Individual	1
Total	8

Request to Limit/ Discloure of sensitive  PI
Complied in Part	1
Individual	1
Total	1

Request to Know PI is Collected
Complied in Whole	1
Individual	1
Total	1

Status	Count of Status
Open	612
Closed	0
Grand Total	612
Closed
Complied in Part	581
Complied in Whole	31
Denied	0

Where a request cannot be fully fulfilled, this is typically due to an inability to verify the identity or authority of the requestor, or because we could not locate a matching record in our systems.

11.  ADDITIONAL INFORMATION FOR UK AND EEA RESIDENTS

Under data protection law, you have rights including:

·                Your right of access

You have the right to ask us for copies of your personal information.

·                Your right to rectification

You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

·                Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances.

·                Your right to restriction of processing 

You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

·                Your right to object to processing

You have the right to object to the processing of your personal information in certain circumstances. 

·                Your right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. 

How to exercise your rights

To exercise any of these rights, please contact us by post or email at the following addresses:

Data Protection Officer
Altrata
4 Bouverie Street
London,
EC4Y 8AX
United Kingdom
Email: [email protected]
We may need to check your identity prior to processing a request. We will do our best to respond to any questions and address any of your concerns. 

Complaints

If you have any concerns about how we handle your personal data, you may submit a complaint to us by contacting our Data Protection Officer using the details set out below or by completing this complaints form.

We will consider your complaint in accordance with applicable data protection laws and will respond to you within a reasonable timeframe.

You also have the right to complain directly to the Regulator regarding the processing of your personal data – the Information Commissioner in the UK or the regulatory body of the country where you live. You can contact the UK Information Commissioner at the link provided or in writing to: 

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

For other regulatory bodies, this information is readily available. You can also contact us at [email protected] should you require assistance.

 

12.  ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE PEOPLE’S REPUBLIC OF CHINA

We also comply with specific requirements stipulated by PIPL (“Personal Information Protection Law of the People’s Republic of China”) and other relevant Chinese rules and regulations. This section of the Online Privacy Notice applies only if you use our Online Platforms covered by the Online Privacy Notice in China, and supplements the information in this Online Privacy Notice. 

Our Legal Basis for Processing the Personal Information

We will process your personal information in accordance with the principles of legality, legitimacy, necessity, and good faith. We will obtain your consent before processing your personal information. Especially, when we want to process your sensitive personal information, we will obtain your separate consent or your written consent according to laws and administrative regulations. 

If we process your personal information beyond the content in this Online Privacy Notice, we will separately explain the purpose, method, and scope of such processing to you through page tips, interactive processes, website announcements, etc., and obtain your consent again. 

When it comes to the following purposes of using your personal information, we will request your consent. You will always be free not to respond. You could easily withdraw the consent at any time. 

Advertising & Marketing

You’re fully aware that we may process your personal information outside the need to obtain the authority and consent from you, under any of the following circumstances: 

• where it is necessary for the conclusion or performance of a contract to which you are a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law;
• where it is necessary for the performance of statutory duties or statutory obligations;
• where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person;
• where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of personal information is within a reasonable scope;
• where it is necessary to process the personal information disclosed by you or other personal information that has been legally disclosed within a reasonable scope in accordance with the provisions of this Law; and
• other circumstances prescribed by laws and administrative regulations.

How We Share Your Information

We will not share your personal information with a third party unless we obtain your separate consent or in circumstances where your consent is not required according to laws and regulations. 

We may share your name, job title, company, address, telephone number and email with event sponsors. Due to the event sponsors will differ from time to time, we will inform you of the name and contact information of the sponsors, purpose and method of processing and obtain your separate consent before sharing your personal information. 

Where we need to transfer your personal information due to merger, division, dissolution or declaration of bankruptcy, etc., we will notify you of the name and contact information of the recipient, as well as urge the recipient to continue to process your personal information based on this Online Privacy Notice. Otherwise, we will request the recipient to obtain your consent again before processing.

Storage Location and International Transfers

Your personal information will be stored in the UK. Therefore, Delinian Limited (https://www.delinian.com/), who is running the information system , will receive your personal information (name, job title, company, address, telephone number and email). 

We may also share your personal information with our corporate affiliates, for them to send you marketing materials. 

We will take necessary measures required by laws including obtaining your separate consent, concluding standard contractual clauses with the overseas recipient to stipulate the rights and obligations between us, and will ensure that the foreign receiving party provides adequate protection for your personal information under applicable laws. 

You could contact us or the overseas recipient to exercise personal information rights through the contact information listed in this Online Privacy Notice.

Your Additional Privacy Rights

Under the stipulations of PIPL, you have the following rights:

• Right to be informed: You have the right to know the processing of your personal information. In addition, you have the right to ask us to explain this Online Privacy Notice and the rules governing our processing of personal information.
• Right to access and copy: You can request access to your personal information or obtain a copy of your personal information.
• Right to correct and supplement: You can request that we to make corrections or supplements where you find that your personal information is inaccurate or incomplete.
• Right to delete: You can request the deletion of your personal information in certain circumstances (for example while you withdraw your consent, or the purpose of personal information processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose;)
• Right to transfer: You can transfer your personal information to a personal information processor designated by you when it meets the conditions stipulated by the authorities.
• Right to make decisions, restrict and refuse: You can make decisions on the processing of your personal information and restrict or refuse that we process your personal information.
• Right to withdraw your consent: You can withdraw your consent. Please understand that each service needs some basic personal information to be completed. After you withdraw your consent, we will not process the relevant personal information, and cannot provide you with the corresponding services as a result. However, withdrawal of consent by you will not affect the previous personal information processing based on your authorization.

For security, we may verify your identity before handling your request. After verifying your identity, we will respond to your request in time, and give a reply and reasonable explanation within 15 days after verifying your identity, or inform you of the external ways to solve the dispute. 

We will not be able to respond to your request under the following circumstances:

• Related to our compliance with the obligations under the laws and regulations;
• Directly related to national security or defense security;
• Directly related to public security, public health or major public interests;
• Directly related to criminal investigations, prosecutions, trials and enforcement of court decisions, etc.;
• We have sufficient proof that you have subjective malice or abuse of rights;
• For the purpose of safeguarding your life, property and other important legal rights and interests or those of other individuals but it is difficult to obtain consent;
• Responding to your request will cause serious harm to your legitimate rights and interests, or those of other individuals or organizations.
• Involving trade secrets.

How to Contact Us

If you have any questions or concerns regarding this Online Privacy Notice and the processing of your personal information, you can send your questions to [email protected] or to the following address: Altrata, 12/F, V-Point, 18 Tang Lung Street, Causeway Bay, Hong Kong.