Alto Labs, LLC and its affiliates (collectively, “Alto Labs,” “we,” “us,” or “our”) maintain this Privacy Policy to explain how we collect, use, disclose, and safeguard personal information when you visit our websites (including altolabs.app and any subdomains), use our applications, or otherwise interact with us (collectively, the “Services”). This Privacy Policy also applies to our affiliates, such as Auralife Management, Inc., and any other legal entity controlled by Alto Labs.

Please read this Privacy Policy carefully. By accessing or using our Services, you agree to the terms herein. If you do not agree with our policies and practices, do not use the Services.

1.1 Information You Provide Directly

• Account Information. When you register for an account, subscribe to newsletters, or otherwise create a profile, you may provide:

  • Name, email address, phone number, mailing address, and username.

  • Company name, job title, and other professional contact details.

• Communications. If you correspond with us (e.g., via email, support tickets, or social media), you may share additional personal or business information to address your inquiry.

• Payment & Billing Information. If you purchase products or services directly from us, we may collect billing address, payment card information (processed by third-party payment processors), and billing history.

1.2 Information Collected Automatically

• Usage Data. We automatically collect certain technical information when you interact with our Services, including:

  • IP address; browser type and version; operating system; device type and unique device identifiers; pages you visit; links you click; and date/time stamps.

• Cookies & Tracking Technologies. We use cookies, web beacons, analytics tools (e.g., Google Analytics), and similar tracking technologies to collect and store information about your activities over time.

  • For more details, see Section 4 (“Cookies & Tracking Technologies”) below.

1.3 Information from Third Parties

• Affiliates & Partners. When you interact with our affiliates or partners—such as Oralife Management, Inc.—those entities may share information about you with Alto Labs, subject to their own privacy notices and your consent where required.

• Social Media & Public Sources. If you link, log in, or interact via third-party social media platforms (e.g., LinkedIn, Facebook), we may collect basic profile information (publicly available name, email, profile picture).

• Marketing & Advertising Providers. We may obtain demographic or interest-based information from third parties to help us tailor communications or display interest-based advertising.

2. How We Use Your Information

We use personal information for the following legitimate business purposes:

1. To Provide & Improve Services.

   • Operate, maintain, and enhance our Services.

   • Personalize your experience (e.g., remembering preferences, language settings).

2. To Communicate.

   • Respond to your inquiries, requests, or customer-support needs.

   • Send administrative notifications (e.g., account updates, policy changes).

   • Deliver marketing communications (e.g., newsletters, promotional offers), subject to your opt-in preferences.

3. For Billing & Fraud Prevention.

   • Process payments, verify billing information, detect and prevent fraudulent transactions, comply with accounting and tax obligations.

4. To Comply with Legal Obligations.

   • Comply with applicable laws, regulations, legal processes, or government requests.

   • Enforce our Terms of Service, Privacy Policy, and other agreements.

5. For Security & Protection.

   • Protect our Services and users against unauthorized access, abuse, or malicious activity.

   • Monitor, detect, and respond to security incidents.

6. For Analytics & Business Insights.

   • Analyze trends, usage, and activities to understand how our Services are used and identify areas for improvement.

   • Generate aggregated, de-identified reports for internal and external purposes (e.g., marketing, investor updates).

3. Cookies & Tracking Technologies

3.1 Cookies

We use cookies—small text files stored on your device—to distinguish you from other users and improve your experience. Cookies enable us to:

• Remember your preferences (e.g., language, region).

• Understand how you interact with our Services (e.g., pages visited, links clicked).

We use both session cookies (deleted when you close your browser) and persistent cookies (stored until expiration or deletion).

3.2 Web Beacons & Similar Technologies

We may embed web beacons, pixel tags, or other tracking technologies in our emails or web pages to track actions (e.g., email opens, link clicks). This information helps us measure the effectiveness of our communications.

3.3 Third-Party Analytics & Advertising

We, along with our third-party partners (e.g., Google Analytics, LinkedIn Insight Tag), may use cookies and similar technologies to track usage across websites, serve targeted ads, and compile statistical reports on user activity.

• To learn about Google Analytics’ practices and opt-out, visit https://tools.google.com/dlpage/gaoptout.

• To opt out of interest-based advertising from LinkedIn, visit https://www.linkedin.com/psettings/advertising.

3.4 Managing Cookies

Most browsers allow you to manage or disable cookies (e.g., via browser settings). However, disabling cookies may result in loss of certain features or personalized experiences on our Services.

4. How We Share Your Information

We do not sell your personal data. We may share your information as described below:

1. Affiliates & Subsidiaries.

   Alto Labs shares information internally among our legal entities (e.g., Oralife Management, Inc.) for consistent operation, support, and enforcement of policies, subject to confidentiality safeguards.

2. Service Providers & Contractors.

   We engage third-party vendors to perform business functions on our behalf, including:

   • Payment processing

   • Hosting & infrastructure

   • Customer support & CRM tools

   • Email delivery services

   • Analytics & advertising

     These providers may have access to personal data only to perform services for us and are contractually bound to keep your information confidential and secure.

3. Business Transfers.

   In the event of a merger, acquisition, sale of assets, financing, or similar transaction involving Alto Labs (including, but not limited to, a potential acquisition of StackMod Innovations Private Limited), your personal data may be transferred to the successor or acquiring entity, subject to this Privacy Policy, unless you are notified otherwise.

4. Legal & Safety Requirements.

   We may disclose personal data if we reasonably believe that disclosure is necessary to:

   • Comply with applicable laws, regulations, legal processes, or governmental requests.

   • Enforce our Terms of Service or investigate potential violations.

   • Protect the rights, property, or safety of Alto Labs, our users, or the public.

5. With Your Consent.

   We may share or disclose any personal data with your explicit consent or at your direction.

5. Third-Party Links & Embedded Content

Our Services may contain links to third-party websites, services, or embedded content (e.g., videos, social media feeds). Those third parties have their own privacy practices, and this Privacy Policy does not apply to them. We are not responsible for the content or privacy practices of third-party sites. We encourage you to read the privacy policies of any external site you visit.

6. Data Security

We implement reasonable technical, administrative, and physical security measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit (e.g., TLS/SSL)

• Access controls (role-based permissions, multi-factor authentication)

• Regular security assessments, vulnerability scans, and penetration tests

• Employee training on data protection and confidentiality

However, no security protocol is impenetrable. We cannot guarantee absolute security of your data. If you believe your data has been compromised, please contact us immediately (see Section 10).

7. International Data Transfers

Alto Labs is headquartered in the United States but has affiliates and service providers worldwide. By using our Services, you acknowledge that your personal data may be transferred to, processed, and stored in the United States or other countries whose data protection laws may differ from your jurisdiction. We will take commercially reasonable steps to ensure that such data transfers comply with applicable legal requirements and that your data remains protected in accordance with this Privacy Policy.

8. Children’s Privacy

Our Services are not directed to children under the age of 16 (or higher age threshold if required by local law). We do not knowingly collect personal data from minors. If you become aware that a child has provided us with personal data without parental consent, please contact us at privacy@altolabs.com. If we learn that we have collected personal data from a child without proper verification of parental consent, we will take reasonable steps to delete such information.

9. Your Choices & Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data. These may include:

• Access & Portability: Request a copy of the personal data we hold about you.

• Correction: Request that we update or correct inaccurate or incomplete personal data.

• Deletion: Request the deletion of personal data, subject to legal obligations to retain certain information.

• Opt-out of Marketing: You may unsubscribe from our marketing communications by following the “unsubscribe” link in any email or contacting us directly.

• Object or Restrict Processing: Depending on local law, you may have the right to object to or restrict certain processing of your personal data (e.g., direct marketing, profiling).

To exercise any of these rights, please email privacy@altolabs.com with “Privacy Rights Request” in the subject line. We will verify your identity before processing your request. We may need to retain certain information to comply with legal obligations or to resolve disputes.

10. Retention of Personal Data

We retain personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need personal data for those purposes, we will delete or anonymize it in a secure manner.

11. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by posting a prominent notice on our website or by sending an email to the address you provided. We encourage you to review this Privacy Policy periodically to stay informed about our information practices. Your continued use of our Services following any update indicates your acceptance of the revised policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy or Alto Labs’ data practices, please contact us at:

Email: privacy@altolabs.app

Mailing Address:

Alto Labs, LLC

1111b South Governors Ave, STE 34064

Dover, DE, US

Effective Date: June 1, 2024.