Privacy Policy

Effective Date: August 1, 2024

California Notice at Collection: See the California privacy rights section below for important information about your rights under applicable state privacy laws.

This Privacy Policy describes the privacy practices of Aluum, LLC and our subsidiaries and affiliates (collectively, “Aluum,” “we,” “us” or “our”) in connection with the www.myaluum.com and other Aluum owned, school-specific alumni websites, our mobile applications and any other digital property that we own or control and which posts or links to this Privacy Policy (collectively, the “Services”), as well as through social media, our marketing activities, our live events and other activities described in this privacy policy.

Aluum may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

TABLE OF CONTENTS

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Choices
• Other Sites and Services
• Security Practices
• International Data Transfers
• Children
• Changes to this Privacy Policy
• How to Contact Us
• Your California Privacy Rights

---

PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us through the Services or otherwise includes:

• Profile Information, such as your first and last name, email and mailing address, city of residents, date of birth, gender, class year, mobile number, university alma mater, profile picture, LinkedIn URL, Facebook URL, occupation, employer, graduation year, company name, company website, industry and company address.
• Account Information, such as a photo of your school identification card, other proof of graduation, or username and password.
• Content you choose to upload to the Services, such as text, images, audio, and video, comments, along with the metadata associated with the files you upload.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us.
• Financial Information, such as payment card information. However, all information is processed and stored by our payment processor(s) as described below.
• Transaction Information, such as information about payments to and from you and other details of services you have purchased from us.
• Usage Information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.
• Marketing Information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Form information, including the information you provide when completing forms relating to employment, investment, fundraising, mentorship, and other opportunities posted on the Services. The information users may choose to include in these forms includes: professional credentials and skills, educational and work history, and other information related to your resume or curriculum vitae; industries and geographic preferences; details about your business for promotional, funding or investment opportunities; areas of interests and expertise for establishing mentor relationships.
• Marketplace Information, such as the type of offering, associated company name and contact information, and any other information you may upload with a marketing post.
• Other Information, not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms.
We may maintain pages for or otherwise integrate our Services with social media or other third-party platforms, such as Facebook, Google, Apple, or LinkedIn. When you visit or interact with those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to login to the Services via a third-party platform or social media network (such as Facebook, Google, Apple, or LinkedIn) or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network, including your cover photo and e-mail address. For example, this information may include your username, user ID, profile picture, cover photo, and networks to which you belong (e.g. school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.

Information we obtain from other third parties.
We may receive personal information about you from third-party sources, such as marketing partners and publicly available sources. For example, a business partner may share your contact information with us if you have expressed interest in learning about our services.

Automatic data collection.
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services, such as:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.
• Geolocation data when you authorize our Services to access your device’s location.

Cookies and similar technologies. Like many online services, we use cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies.

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage or LSOs are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

We may also use Flash LSO on our website to collect and store information about your use of our website. Unlike cookies, Flash LSOs cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our website.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted Advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Data about others. Users of the Services may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

Service Delivery. We use your personal information to:

• provide, operate and improve the Services;
• provide information about our Services;
• establish and maintain your account on the Services;
• facilitate your ability to login to the Services via third-party identity and access management providers, such as LinkedIn;
• communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events;
• understand your needs and interests, and personalize your experience with the Services and our communications;
• provide support and maintenance for the Services; and
• to respond to your requests, questions and feedback.

Research and development. We analyze use of the Services to analyze and improve the Services and to develop new products and services, including by studying user demographics and use of the Services. As part of these activities, we may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Marketing. We may send you Aluum-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the opt out of marketing section below.

Advertising. We work with advertising partners to display advertisements on the Services. These advertisements are posted by and on behalf of our advertising partners and may be targeted based on your use of the Services or profile. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted Advertising.”

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, e-mail delivery, marketing, and database management services).

Payment processors.Any payment card you use to make a purchase on the Services is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Third-party platforms and social media networks.  If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by linking your account with the Services to a social media network’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Marketplace partners. Our Services allow advertisers and users to post items within our “Marketplace”. We share your Profile Information and/or other information that you provide in response to posts on the Services with those Marketplace partners when you view or engage with listings in the Marketplace.

Other Users of the Services and the Public.  We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Services (such as Opportunity Postings), and we will display Profile Information along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or during negotiations and diligence for a potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

We make commercially reasonable efforts to verify that the parties with whom our Services shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

YOUR CHOICES

In this section, we describe the rights and choices available to all users.

Opt-out of marketing communications. You may opt out of marketing-related e-mails by following the opt-out or unsubscribe instructions at the bottom of the e-mail, or by contacting us at hello@myaluum.com. You may continue to receive service-related and other non-marketing e-mails.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms. If you choose to connect to the Services via your social media account or other third-party platform, you may have the ability to limit the information. If you withdraw our ability to access certain information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please send us an email at hello@myaluum.com.

OTHER SITES AND SERVICES

The Services may contain links to other websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

SECURITY PRACTICES

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

CHILDREN

The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

HOW TO CONTACT US

Please direct any questions or comments about this Policy or privacy practices to hello@myaluum.com. You may also write to us via postal mail at:

Aluum, LLC
15051 N. Kierland Blvd, Suite 300
Scottsdale, Arizona 85258

INFORMATION FOR CALIFORNIA RESIDENTS

Scope. This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. You can opt-out any “sale” of your Personal Information.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
• Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.

How to exercise your rights. You may exercise your California privacy rights described above as follows:

• Right to information, access, correction and deletion. You may submit requests to exercise your right to information, access or deletion by visiting your profile and then clicking on the edit icon on the right of your profile image, or via email to hello@myaluum.com.
• Notice of Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information in the conventional sense (i.e., for money). However, as outlined above, our Services allow advertisers and users to post items within our “Marketplace” and we share your Profile Information and/or other information that you provide in response to posts on the Services with those advertising Marketplace partners when you view or engage with listings in the Marketplace. You can request to opt-out out of this “sale” of your personal information by signing into your account and clicking on the Do Not Sell My Personal Information link. Please note, however, that if you click on the SEND Button in the Show interest section within a Marketplace listing after you have opted-out, we will treat as a direction from you to disclose your information to the Marketplace partner.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140)	PI we collect in this category (See Personal information we collect above for description)	Source of PI	Business/commercial purpose for collection	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” PI
Identifiers	Profile Information Account Information Content you choose to upload to the Services Feedback or correspondence Transaction Information Financial Information Marketing Information Information provided by applicants when responding to posts on the Services Data about others	You Third-party sources Third-party platforms and social media platforms Automatic collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Payment processors Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	Marketplace partners (in conjunction with Marketplace listings)
California Customer Records (as defined in California Civil Code section 1798.80)	Profile Information Account Information Content you choose to upload to the Services Feedback or correspondence Financial information Transactional information Usage Information Marketing Information Information provided by applicants when responding to posts on the Services Device & Online activity data Data about others	You Third-party sources Third-party platforms and social Media Platforms Automatic Collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Payment processors Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	Marketplace partners (in conjunction with Marketplace listings)
Commercial Information	Transactional Information Usage Information Marketing Information Online activity data	You Third-party sources Automatic collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Payment processors Marketplace partners Professional advisors Authorities and others Business transferees	Marketplace partners (in conjunction with Marketplace listings)
Financial Information	Financial Information Transactional Information	You Third-party sources	Service delivery Research & development Compliance & protection	Affiliates Service Providers Payment processors Professional advisors Authorities and others Business transferees	None
Online Identifiers	Profile Information Account Information Device data Online activity data	You Third-party sources Automatic collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Payment processors Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	Marketplace partners (in conjunction with Marketplace listings)
Internet or Network Information	Marketing data Usage Information Device data Online activity data	You Third-party sources Automatic collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Payment processors Professional advisors Authorities and others Business transferees	None
Geolocation Data	Precise geolocation/Location data	Automatic collection	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Confirm Professional advisors Authorities and others Business transferees	None
Inferences	May be derived from your: Profile Information Account Information Content you choose to upload to the Service Feedback or correspondence Transactional data Usage Information Marketing Information Form information Device data Online activity data Data about others	N/A	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Professional advisors Authorities and others Business transferees	None
Professional or Employment Information	Profile information (resume or CV information , if users choose to include in user profile) Form information (resume or CV information, if users choose to provide in response to posts)	You	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	Marketplace partners (in conjunction with Marketplace listings)
Protected Classification Characteristics	Profile information (gender, if users choose to include in user profile) We do not otherwise intentionally collect this information but it may be revealed in identity data or other information we collect	You	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	None
Sensory Information	Profile information Content you choose to upload to the Services	You Third-party platforms and social Media Platforms	Service delivery Research & development Marketing Advertising Compliance & protection	Affiliates Service providers Marketplace partners Other users and the public Professional advisors Authorities and others Business transferees	None

SHINE THE LIGHT LAW

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at hello@myaluum.com or at Aluum, 15051 N. Kierland Blvd, Suite 300, Scottsdale, AZ 85258. You must put the statement “Shine the Light Request” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.