PRIVACY POLICY

1. Who we are

This Privacy Policy explains how ALO3 LIMITED (“ALO3”, “we”, “us” or “our”) collects, uses, discloses, stores and protects personal information. ALO3 is based at Suite 200, 1001 1 St SE, Calgary, Alberta T2G 5G3, Canada. Contact: alo3compliance@gmail.com.

This Policy applies to personal information processed in connection with our website, contact form, business enquiries, prospective and existing business relationships, compliance checks and related communications. Our services are intended for business customers, not consumers.

2. Personal information we collect

Depending on your relationship with us, we may collect:

• identity and contact details, such as name, business email, telephone number, job title and business address;
• business and organisation information, including legal name, registration details, ownership, directors, beneficial owners, authorised representatives, business activities and website;
• due diligence and compliance information, including identity documents, corporate records, source-of-funds or source-of-wealth information, sanctions/adverse-media screening results and transaction-related information;
• communications and enquiry details submitted through our contact form or sent to us by email;
• technical and usage data, such as IP address, device/browser information, approximate location derived from IP, pages visited, timestamps, referral information and cookie identifiers;
• information received from Payment Providers, public registers, verification vendors, professional advisers and other lawful sources.

Please do not submit sensitive personal information through the website contact form unless we specifically request it through an appropriate secure channel.

3. How we use personal information

We may use personal information to:

• respond to enquiries and communicate with business contacts;
• assess prospective business relationships and provide requested services;
• verify identity, business legitimacy, ownership and authority, and perform AML/CTF, sanctions, fraud-prevention and risk-management checks;
• coordinate with banks, Payment Providers and other counterparties where needed to provide a requested business service;
• monitor, investigate and document transactions and potential suspicious or prohibited activity;
• operate, secure, troubleshoot and improve our website and services;
• manage contracts, billing, records, disputes and legal claims;
• comply with legal, regulatory, reporting, audit and law-enforcement obligations;
• send service-related notices and, where permitted, relevant business communications.

4. Legal bases for processing under the GDPR

Where the EU/UK General Data Protection Regulation applies, we process personal data on one or more of these bases: performance of a contract or steps requested before entering a contract; compliance with a legal obligation; our legitimate interests in operating and protecting our B2B services, preventing fraud and managing business relationships, where those interests are not overridden by your rights; and consent, where consent is required (for example, for certain non-essential cookies or marketing communications). You may withdraw consent at any time, without affecting processing already carried out.

5. Cookies and analytics

Our website uses cookies and similar technologies. These may include strictly necessary cookies required for website operation and security, and analytics cookies used to understand website traffic and improve performance. Where required by applicable law, we will obtain consent before placing non-essential cookies. You can manage cookies through the consent mechanism presented on the website and through your browser settings. Blocking certain cookies may affect website functionality.

Analytics providers may receive technical and usage information in order to provide aggregated reports and measurement services. The specific providers and cookie lifetimes should be described in the cookie banner or a separate cookie list maintained on the website.

6. How we disclose information

We may disclose personal information, where appropriate and lawful, to:

• banks, payment service providers, financial institutions, correspondent/intermediary institutions and transaction counterparties;
• identity verification, AML screening, fraud prevention, analytics, hosting, IT, security and other service providers;
• our professional advisers, auditors, insurers and legal counsel;
• regulators, government bodies, courts, law enforcement and competent authorities where required or permitted by law;
• a successor, purchaser or investor in connection with a corporate transaction, subject to appropriate safeguards.

We do not sell personal information for money. We do not disclose personal information to third parties for their own direct marketing purposes.

7. International transfers

ALO3 is based in Canada and may work with Payment Providers and service providers in Canada, the European Economic Area and other countries. Personal information may therefore be transferred to or accessed from countries whose data protection laws may differ from those in your country. Where the GDPR applies and a transfer requires safeguards, we will use an applicable transfer mechanism, such as an adequacy decision, standard contractual clauses or another lawful safeguard, together with supplementary measures where required.

8. Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide services, complete due diligence, maintain business and compliance records, resolve disputes and meet legal or regulatory retention requirements. Retention periods vary according to the type of information, the relationship and applicable law. When information is no longer required, we will delete it, anonymise it or securely dispose of it, subject to lawful retention obligations.

9. Security

We use reasonable administrative, technical and organisational safeguards designed to protect personal information against loss, unauthorised access, use, alteration or disclosure. No website, email transmission or storage system can be guaranteed to be completely secure. Please use appropriate care when sending information and contact us promptly if you believe information sent to us has been compromised.

10. Your privacy rights

Depending on the law that applies to you, you may have the right to request access to personal information, correction of inaccurate information, deletion, restriction of processing, data portability, objection to certain processing, or withdrawal of consent. You may also have the right to complain to a competent data protection authority. These rights are subject to legal exceptions, including obligations to retain information for AML/CTF, regulatory, fraud-prevention or legal-claims purposes.

To make a request, contact us at alo3compliance@gmail.com. We may need to verify your identity and authority before responding. We aim to respond within the time required by applicable law.

11. Canadian privacy laws

ALO3 handles personal information in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) where applicable and any applicable provincial privacy laws. Individuals may contact us with questions or complaints about our privacy practices using the contact details below.

12. Children

Our website and services are intended for businesses and are not directed to children. We do not knowingly collect personal information directly from children.

13. Third-party websites

Our website may contain links to third-party websites or services. Those third parties operate under their own privacy notices and practices. ALO3 is not responsible for their content, security or privacy practices.

14. Changes to this Policy

We may update this Policy from time to time. The current version will be published on our website with its effective date. Material changes will be handled in accordance with applicable law.

15. Contact and complaints

For privacy questions, requests or complaints, contact ALO3 LIMITED at alo3compliance@gmail.com or by post at Suite 200, 1001 1 St SE, Calgary, Alberta T2G 5G3, Canada. If you are in the EEA and believe the GDPR applies, you may also lodge a complaint with your local supervisory authority. If ALO3 is required to appoint an EU representative under GDPR Article 27, the representative’s contact details will be published here.