alilo (“alilo”) alilo helps companies around the world empower human talent development through its learning content, digital tools, and technology services. We design and build our solutions around core principles of innovation, user experience, and customer satisfaction, ensuring they work seamlessly across multiple platforms, formats, and mobile devices across all tiers to deliver and manage highly engaging, impactful digital content.

This Privacy Policy (hereinafter "Policy") describes how alilo manages its website, collects, uses, and discloses information, and outlines the choices users have regarding the information they share. alilo may collect and process personal information to provide efficient service on our platform. User personal information will only be used to deliver the service, and any payment method details will never be used under any circumstances without user consent. Only authorized personnel from alilo will have access to personal information, and they may only access it to resolve issues related to the use of the website and its applications.

Alilo's primary policy is to respect the privacy of its clients and users regarding any information collected from them while using our software applications and/or websites ("Services"). By using our Services, users accept this Privacy Policy.

This policy applies to:

• Visitors to our website
• Clients
• Users of our products and services

The purpose of this Privacy Policy is to inform you about how we collect, use, store, share, retain, transfer, and process your Personal Information. In addition, this policy outlines your choices and rights regarding your Personal Information and how to exercise those rights. "Personal Information" means any information relating to an identified or identifiable individual.

Data You Provide

As a user, you provide us with personal data for processing as part of using Alilo. This includes:

• Account creation or contact: We collect your first name, last name, email address, and phone number when you create an account or request that one of our agents contact you.
• User and public profile: We collect any personal information you include in your user profile and public profile, as well as content generated while using our services.

Other Data We Collect

We collect and store additional information to improve and monitor the effectiveness of our services, including:

• Usage data: Information related to the use of our products and services, such as featured interactions, bookmarks, page views, and other data useful for improving product quality.
• Technical information: Information regarding the status of products on your devices, including uptime, available memory, and errors encountered.
• Interactions with our services: We use tools like Flash and JavaScript to collect data on how you interact with our products, including clicks, drags, scrolls, error response times, and length of visits to specific pages.

Website Visitor Data

When you use our applications and websites, we also collect:

• Log data: Our servers automatically collect information such as your IP address and other data recorded in log files.
• Product interactions: When you request product demos or subscribe to our newsletters, we collect personal data necessary to fulfill these requests.
• Contact data: When you inquire about our products and services, we store this information to communicate with you and respond to your inquiries.

Personal Information from Partner Companies

As an LXP, we receive personal information from the companies we work with, including name, date of birth, national ID, employment start date, personal email, and other relevant details. We handle this information under strict privacy standards to ensure its protection and compliance with our legal obligations.

We collect personal information in several ways, depending on how you interact with our website and use our products and services. The specific methods of information collection are outlined below:

Information provided directly by users:

• When visiting our website: When you visit our website, you may provide us with information by filling out forms, such as subscribing to a newsletter or requesting information about our products and services.
• When using our products and services: When registering and using our products, we collect information you provide directly to us, including, but not limited to, your name, email address, physical address, and payment details.

Automatic data collection:

• Interaction with our website and products: We automatically collect information about how you interact with our website and products. This includes data such as IP addresses, browser information, visit times, and accessed pages through technologies such as cookies and server logs.
• Product usage analytics: We use analytics tools to understand how you use our services, which helps us improve the functionality and efficiency of our products.

External sources:

• Public databases and commercial sources: We may obtain information from public databases, commercial affiliates, and other external sources to supplement the data we already have. This helps us update, expand, and analyze our records, identify new customers, and provide products and services that may be of interest.
• Partners and third parties: We receive information from third parties we work with, such as marketing partners and data providers. This may include demographic, behavioral, or personal information that helps improve our services and customize our interactions.

Information from clients or corporate clients:

• Authorized users: When we work with companies, we may receive information about their employees or customers acting as authorized users of our services. This information is managed in compliance with privacy agreements established with those companies and is used exclusively to provide our services.

Cookies are small files stored on your web browser when you visit our website. Some cookies last only while you remain on the site; others, known as "persistent cookies," can be stored for longer periods. These cookies make browsing easier by saving your password or your preferences for how you use the website. Cookies collect information such as your computer's IP address, your browser settings, and details about how you use the website. Your general location may be estimated from your IP address. Some cookies track user activity across our website, applications, and services to deliver tailored advertising on this and other websites.

If you wish to opt out of cookie use, you can adjust your web browser settings to reject or delete cookies. You can also find more information about cookies, including how to opt out of interest-based advertising, at www.cookiesandyou.com.

You can find more information about how we use cookies here: [insert link to cookie policy].

Use of Google Analytics

We currently use Google Analytics to collect information anonymously and report on website trends without individually identifying visitors. We use Google Analytics to conduct analysis and measurement to understand how our services are used. For example, we analyze data about your visits to our sites to optimize product design.

We may use the information we collect to:

• Provide, activate, maintain, manage, and improve our Services—such as facilitating payments, sending receipts or invoices, delivering services you request (and sending related information or commercial communications), developing new features, providing customer support, developing security options, authenticating users, and sending product updates and administrative messages.
• Perform internal operations, such as keeping the website secure, preventing fraud and abuse of our Services, troubleshooting software bugs and operational issues, conducting data analysis, testing, and research, monitoring and analyzing usage and activity trends, and verifying compliance with the terms and conditions governing the use of our Services.
• Send communications requested by the User or that may be of interest to them, including information about alilo products, services, promotions, news, and events, where permitted and in compliance with applicable laws; and process contests, sweepstakes, or other promotional entries and deliver related prizes.
• Personalize and improve services and products, including providing or recommending features, content, social connections, referrals, and advertisements.
• Other uses permitted under applicable law.

When you connect your Google account to alilo, we only access your name and email address, and create Google Meet spaces on your behalf solely to schedule training sessions. We do not use this data for advertising or sell it, and we do not share it with third parties except as necessary to provide or improve features visible to you, for security reasons, or to comply with the law. The foregoing supersedes any general provision in the "Information Sharing" section.

The use and transfer to any other application of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements. Google user data is not used to develop, improve, or train generalized AI or machine learning models.

You can revoke alilo's access at any time from myaccount.google.com/permissions or by writing to privacidad@alilo.app.

We may share the information we collect from our Users as described below:

• With our customer support team to respond to User questions and complaints regarding our products and services;
• With the general public if you submit content to a public forum, such as blog comments, social media posts, or other publicly accessible features of our Services, where we cannot prevent third parties from using or misusing the information;
• With third parties with whom alilo maintains commercial relationships (in a manner such that these third parties cannot identify any individual User from such information);
• With employees, officers, subsidiaries, affiliates, vendors, consultants, agents, marketing partners, and other providers or contractors who reasonably require access to such information for the purposes outlined in this policy;
• For any other use not expressly described in this policy, provided it is notified to and accepted by the User beforehand.

You can access your account information at any time, as well as request the update, modification, and deletion of information contained in it, free of charge. Please note that in some cases we may retain certain information about Users as required by law or for legitimate business purposes to the extent permitted by law.

At alilo, we maintain robust legal bases for processing your personal data, fully compliant with international data protection standards. The primary reasons we collect and process your personal data are:

Consent: We process your personal information when you give us explicit consent. This includes, for example, when you subscribe to our newsletter, request information, or sign up for our services. It also applies when you accept the use of cookies on our website.

Contractual relationship: We collect and process the personal information necessary to perform contracts to which you are a party, or to take steps at your request prior to entering into a contract. This is essential to provide our services efficiently.

Legal obligations: In certain cases, we have a legal obligation to collect and process your personal information. We fulfill these obligations to comply with applicable laws.

Legitimate interests: We process your information when we have a legitimate interest to do so, such as in direct marketing activities. In these cases, we ensure that our interests do not override your fundamental rights and freedoms.

Vital interests: In exceptional circumstances, we may process personal information if necessary to protect your vital interests or those of another individual.

At alilo, we comply with regulations in the country where the legal entity backing operations is based, as well as the EU General Data Protection Regulation (GDPR) and the EU-U.S. Privacy Shield framework. We strive to adhere to all relevant laws to safeguard and respect your personal data. If you decide that you do not want Alilo to use your personal data for certain services, as a data subject you have the right to opt out, request data deletion, or request amendments at any time. Furthermore, if you provided consent for specific processing of your data, you have the right to withdraw that consent at any time by reaching out to our data quality team at: privacidad@alilo.app.

The length of time we retain collected personal information depends on the type of data and the purpose for which it was gathered. We retain your personal information based on the following criteria:

Business Needs: We retain personal information for as long as we have an ongoing legitimate business purpose. For example, to resolve disputes, meet ongoing legal obligations, or maintain commercial relationships.

Contract Duration: We maintain personal information for the term of any contract you hold with us and, depending on the contract's nature, may retain information for a reasonable period following termination to satisfy post-contract obligations such as legal audits and dispute resolution.

Legal Obligations: We retain personal information in compliance with the legal requirements of each jurisdiction where we operate. This includes storing data for specific statutory periods established under local laws and regulations.

Anonymization or Erasure: Once personal information is no longer needed for its initial collection purposes or after a reasonable period, we proceed to erase or anonymize it, ensuring it cannot be reconstructed or read.

If you reside in the EU/EEA, you have the following rights regarding your personal information:

Right of access and information: You have the right to access the personal information we hold about you and to receive a copy of it.

Right to rectification: You have the right to correct or update inaccurate or outdated personal information.

Right to erasure: You can request that your personal information be permanently deleted.

Right to restriction of processing: You have the right to restrict the processing of your personal information.

Right to object to processing: You have the right to object to specific types of processing of your personal information.

Right to data portability: You can request to receive a portable copy of your personal information in a format that can be transferred to another organization.

Right not to be subject to automated decision-making: You have the right not to be subject to decisions based solely on automated processing.

Right to lodge a complaint with a data protection authority: You can file a complaint with a supervisory authority in the country where you reside, details of which can be provided upon request, or with alilo's lead supervisory authority:

EU Representative
Osano International Compliance Services Limited
ATTN: 3BQ4
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative

Right to withdraw consent: If you gave us consent to collect or process your personal information, you can withdraw that consent at any time.

Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

If you wish to exercise any of these rights, please submit a request to privacidad@alilo.app.

We may charge a reasonable fee if your request is unfounded under applicable law, repetitive, or excessive. We may also request additional information to verify your identity before processing your request.

These rights may only be available to EEA residents

Information for California Residents

The California Consumer Privacy Act (CCPA) applies to information collected from California residents. California residents have the following rights regarding their personal information:

• Right to know and access information: The categories of personal information we collect are described above in the "Information We Receive" section. California residents may submit a verifiable request regarding the information collected, the categories of sources from which personal information is collected, the purposes for collecting the information, and the specific pieces of personal information collected about them.
• Right to have personal information deleted
• Right to data portability: California residents may request a copy of their personal information in a format that can be transferred to another person or entity.
• Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

You may be asked for further information to verify your identity when submitting a request. You can exercise your rights via the website contact form or by email at privacidad@alilo.app

We do not sell personal information to third parties (pursuant to California Civil Code Sections 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).

We may transfer personal data from our European Union users to our servers, partners, or vendors located in the United States and other countries outside the EU where an adequacy decision may not exist for those jurisdictions. We have implemented appropriate safeguards to ensure that personal information remains protected, regardless of where it is processed. When we transfer personal information of individuals located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK) to the United States, we rely on Standard Contractual Clauses together with the UK Addendum, as well as additional safeguards where appropriate. To obtain a copy of our Standard Contractual Clauses, please contact legal@alilo.app. We are also certified under the EU-U.S. and Swiss-U.S. Privacy Shield principles to help safeguard transfers of data collected from the EEA, Switzerland, and the UK.

We implement advanced security controls to protect against breaches and unauthorized access to your data. We maintain appropriate and reasonable physical, technical, and administrative safeguards to protect user data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, it is important to recognize that no security measure is fail-safe; a potential risk of data breach always exists.

Security measures we implement include:

• Physical access controls across our facilities.
• Data encryption during transmission and at rest within our data centers.
• Use of secure protocols such as HTTPS to protect data in transit.
• Restricted data access based on a need-to-know basis to perform job duties.
• Continuous monitoring of threats and vulnerabilities.
• Security certifications conforming to internationally recognized standards.

In addition, we implement specific policies for staff handling personal data:

• Only employees who need access to personal data for their job functions receive authorization.
• All employees undergo regular information security training.
• We conduct background checks on all employees granted access to personal information.
• All employees with access to personal information are required to sign a binding confidentiality agreement.

Before sharing any personal information with our vendors, we verify they maintain effective security procedures to protect your data. Our vendors and partners are strictly prohibited from using or sharing your data for any purpose other than providing the services for which they have been retained.

We do not knowingly collect or solicit personal information from children under 13 without parental consent, unless permitted by law. If we discover that we have collected personal information from children under 13 without parental consent (or where permitted by law), we will take steps to delete that information. If you believe a child has provided us with personal information without parental consent, please contact us.

California Consumers: We will not sell information from California consumers under the age of 16 without prior parental authorization. If the California consumer is under 13, a parent or guardian must consent to the sale of the minor's personal information. If the California consumer is between 13 and 16 years old, the minor may opt in directly to the sale of their personal information. Any sites directed at children will verify age and require appropriate consent.

EU Residents: We do not collect or process personal information from data subjects in the EU under the age of 16 without explicit consent from a parent or legal guardian. Any sites directed at children will verify age and require appropriate consent.

The laws of the State of Florida, United States, will govern any dispute related to these Terms, our policies, the Site, or the Services. Any claims directly arising from the Terms or the Services will be litigated exclusively in the competent courts of Florida. Both you and alilo hereby consent to the personal jurisdiction of such courts. Any cause of action or claim you may have related to the services must be filed within one (1) year after the claim or cause of action arises; otherwise, it shall be permanently barred.

If any provision of these terms is held invalid, this will not affect the validity of the remaining provisions, which will remain in full force and effect. To the extent permitted by law, you hereby release alilo and its officers, directors, employees, agents, affiliates, successors, and assigns from any damages or claims, known or unknown, suspected or unsuspected, disclosed or undisclosed, arising out of any dispute related to any transaction or attempted transaction with another user of the services. You understand and agree that this release and waiver of liability extends to you, your heirs, executors, administrators, and assigns.

Sensitive Information

Unless explicitly requested, we ask that you do not send or disclose sensitive personal information to us via our websites or by any other means. Sensitive personal information includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for uniquely identifying you, health data, sex life, or sexual orientation.

Contact Information

You can contact us regarding this privacy policy or the use of our services. If you have questions or complaints regarding this Policy, you can reach us by email at privacidad@alilo.app or at our postal address listed below.
exo eseplus sl

Calle Nuñez de Balboa 120, Madrid, 28006, Spain

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66 West Flagler Street, Miami, FL, 33130, United States

Privacy Policy Changes

alilo may update this Privacy Policy from time to time, at our sole discretion. alilo encourages visitors and customers to frequently check this page for any changes to the Privacy Policy. When you register for the Services, we will notify you of material changes in advance via email or in-app notice. You confirm that your continued use of our services after any changes to this Policy constitutes your acceptance of such changes and your agreement to be bound by the revised Policy.

We often introduce new features that may require collecting new information. If we collect materially different personal data or materially change how we use your data, we will notify you and update our Privacy Policy accordingly.

GDPR Representatives

EU Representative: Osano International Compliance Services Limited ATTN: 3BQ4 3 Dublin Landings North Wall Quay Dublin 1 D01C4E0, Ireland

UK Representative: Osano UK Compliance LTD ATTN: 3BQ4 42-46 Fountain Street Belfast Antrim, BT1 5EE