Portal Privacy Policy      

Last updated: June 2022 

Vebra Solutions Limited t/a Alto (“Alto“) respects your right to privacy.  This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  This Privacy Policy only applies to personal information that we collect and process through our website (“Website”).  

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

What does Alto do?

We offer our property professionals a cloud based, one-stop shop for property software to cover all their needs from sales and lettings, property management or client accounting. This Website allows our clients to update to our software platform Alto. 

What personal information does Alto collect and why?

The personal information that we may collect about you broadly falls into the following categories:

• Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily: for example, we will ask you to provide your email address and  phone number to enable multi-factor authentication and login as well as details of your trading  bank details for accounting and billing purposes. This personal information is needed to migrate and upgrade your account to our property software, Alto. 

• Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device.  In some countries, including countries in the UK and European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically from your device may include data related to your activity on the Website, as well as information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location).

Collecting this information enables us to better understand how the Website is being used and to help track your progress through the Website.  We also use this information for our internal analytics purposes and to help us improve the Website.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” link below.

• Information that we obtain from third party sources

In order to assist your progress through the Website, we pre-populate a number of fields with information we already hold about you from third party sources including your user data information such as full name, email, branch, role and accounts user identity which you provided to Jupix previously and is pre-populated and validated by our systems.. 

This information is needed to assist with your progress through the Website and migrate and upgrade your account  to Alto. 

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your personal information.  However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.     

Who does Alto share my personal information with?

We may disclose your personal information to the following categories of recipients:

• to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information. Our service providers and partners include data storage and hosting providers, such as AWS; marketing software providers, such as Pardot; relationship management software providers, such as Salesforce; business management and accounting software providers, such as Netsuite and analytics providers such as Google Analytics, as may be updated from time to time. A list of our current group companies is available on request. 
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy;
• to any other person with your consent to the disclosure.

Legal basis for processing personal information 

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.  

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may have obtained your consent to process personal information about you, or have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).  

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Cookies and similar tracking technology 

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you for analytics purposes. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.

How does Alto keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. More information on our security measures is available on request.  

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident.  These countries may have data protection laws that are different to the laws of your country.

Specifically, our group companies and third party service providers and partners operate around the world.  This means that when we collect your personal information we may process it in or access it from any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. These include implementing appropriate contractual clauses with our third party service providers, in accordance with UK data protection law. Further details can be provided on request. 

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).  

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

Your data protection rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.  
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to the UK data protection authority about our collection and use of your personal information.  For more information, please contact the UK Information Commissioner’s Office. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with UK data protection laws.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.  We will obtain your consent to any material Privacy Policy changes if and where this is required by UK data protection laws. 

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.  

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our data protection officer using the following details: dpo@zpg.co.uk 

The data controller of your personal information is Vebra Solutions Limited which is registered with the ICO with registration number Z7426718.