Privacy Notice

Last updated: September 2026

This privacy notice for Alguna Inc. ("Alguna," "we," "us," or "our") describes how and why we collect, store, use, and share ("process") your information in connection with the Alguna product and our business relationships, such as when you:

• Use the Alguna product as a customer or as a user at a customer
• Engage with us in sales, marketing, customer support, or events

This notice does not cover our marketing website. If you are browsing alguna.com, see our Website Privacy Notice, which describes the cookies, analytics and advertising used there. Those practices do not apply to the product.

If you have questions after reading this notice, contact us at [email protected]. If you do not agree with our policies and practices, please do not use our Services.

Summary of key points

• Personal information we collect. Names, emails, job titles, login details, and technical device data, depending on how you interact with us.
• Sensitive information. We do not process sensitive personal information.
• Third-party sources. We do not obtain personal information about product users from third parties.
• How we use information. To provide, improve and secure the product, to communicate with you, to comply with law, and with your consent to send marketing communications.
• Cookies. The product uses cookies that are necessary to run the service, and first-party product analytics. It uses no advertising cookies. Cookies on our website are covered by the Website Privacy Notice.
• Sharing. With service providers who process on our instructions, with affiliates, and during business transfers. We do not sell or share personal information in connection with the product.
• Security. We use organizational and technical safeguards. No system is completely secure.
• Your rights. Depending on where you live, you may have rights to access, correct, delete or restrict your data, and to object or withdraw consent.
• Who we process data for. Alguna's customers are businesses, users are their employees, and end-customers are those businesses' customers. For users we are a data controller. For end-customers we act as a data processor under our customer's instructions.

1. Information we collect

Personal information you provide

• Users of our Services (controller role): email address, name, job title, login details, and business-related information.
• End-customers of our customers (processor role): information determined by our customers based on their interaction with you. Our customer is the data controller and we process only on their behalf under a Data Processing Agreement. Please refer to their privacy notice.

Information collected automatically

We collect technical and usage data such as:

• IP address, browser, operating system, device configuration
• Log data: pages viewed, searches, time stamps, crash reports
• Device identifiers and approximate location derived from IP address

2. How we process your information

We process information to:

• Deliver and manage the Services
• Provide support and respond to enquiries
• Send administrative updates about terms, policies and product changes
• Manage payments, orders and returns
• Request feedback and participation in surveys
• Send marketing communications, with opt-out available
• Understand how the product is used, so we can improve it
• Maintain security, prevent fraud, and comply with our obligations
• Protect vital interests, for example to prevent harm

We do not use your personal data for automated decision-making that produces legal or similarly significant effects.

3. Legal bases for processing (GDPR / UK GDPR)

We may rely on:

• Consent, which you can withdraw at any time
• Contract, to deliver the Services you requested
• Legitimate interests, to improve the Services, understand product usage through our own first-party analytics, prevent fraud, and send product updates
• Legal obligations, such as accounting and compliance
• Vital interests, such as safety

Roles:

• We are the data controller for users of Alguna's Services.
• We are the data processor for end-customer data handled on behalf of our customers.

4. Sharing personal information

We may share information with:

• Service providers who process information on our instructions and may not use it for their own purposes. These include our hosting, infrastructure, communications, support and product analytics providers.
• Affiliates, meaning parent or subsidiary companies under common control.
• Business transfers, such as a merger, acquisition or financing.
• Authorities, where we are required to by law.

We do not sell personal information, and we do not disclose product data to advertising networks.

5. Cookies in the product

The Alguna product uses cookies that are strictly necessary to run the service, including keeping you signed in, remembering your preferences, and protecting against fraud and abuse.

We also use first-party product analytics to understand how the product is used and to improve it. That data stays with us and the providers who process it on our instructions.

We do not use advertising cookies in the product, and we do not disclose product data to advertising networks.

Cookies on our marketing website are different, and are described in our Website Privacy Notice.

6. International transfers

Our servers are located in Ireland (EU). We may also process data in the UK, the US, and other countries where we or our affiliates operate.

Safeguards include the European Commission's Standard Contractual Clauses and other lawful GDPR and UK GDPR transfer mechanisms.

7. Data retention

We retain personal data only as long as necessary for the purposes described in this notice, including legal, accounting and compliance requirements.

• User data: retained for the duration of the account and up to 60 days after closure, unless a longer period is required by law.
• End-customer data: retained according to our customer's instructions.

8. Security

We implement appropriate organizational and technical safeguards to protect personal data. However, no system can be guaranteed completely secure, and transmission of data to and from our Services is at your own risk.

In the event of a personal data breach, we will notify affected individuals and regulators as required by applicable law.

9. Minors

We do not knowingly collect data from children under 16, or under 13 in the US under COPPA. If we discover such data, we will delete it.

10. Your rights

Depending on your location, you may have the right to:

• Access and receive a copy of your personal data
• Request correction, deletion or restriction of processing
• Withdraw consent at any time
• Object to processing, including for marketing
• Data portability, where applicable
• Complain to your data protection authority

We respond to data subject requests within the timeframes required by applicable law, generally within 30 days. Send requests to [email protected].

11. Do Not Track and Global Privacy Control

We do not respond to Do Not Track signals, as no common standard for them has been adopted.

Global Privacy Control is an opt-out of the sale or sharing of personal information. We do not sell or share personal information in connection with the product, so there is nothing for the signal to act on here.

How we honor Global Privacy Control on alguna.com is described in our Website Privacy Notice.

12. United States privacy rights

Categories of personal information we have collected in connection with the product in the past 12 months:

• Identifiers — name, work email, IP address, login identifiers
• Customer records — job title and business contact details
• Internet or network activity — product usage and access logs
• Geolocation data — approximate location inferred from IP address

We do not collect the other categories defined under California law, including biometric information, precise geolocation, or information about race, religion, health or sexual orientation.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, in connection with the product. Advertising on our marketing website, and the opt-out available there, is described in our Website Privacy Notice.

Depending on your state you may have the right to know what we hold, to have it deleted or corrected, and not to be treated differently for exercising these rights. Send requests to [email protected].

Where we process personal information on behalf of a customer, that customer directs how the data is used and you should contact them first. We assist our customers in responding to these requests under our Data Processing Agreement.

13. Updates to this notice

We may update this notice. Updates are effective when posted, with the revised date shown at the top. For material changes we may notify you by email or by a banner in the product.

14. Contact us

Email: [email protected]

United States (main office) Alguna Inc. 1111B S Governors Ave #6268 Dover, DE 19904 United States

United Kingdom (HQ and Data Protection Representative) Alguna HQ, London, E14 6FX

Registered with the UK Information Commissioner's Office, registration number ZB664701.

If you are based in the UK or EU, you may contact our UK HQ for all privacy matters.

15. Review, update or delete your data

To request access, correction or deletion of your data, contact [email protected]. We will respond in accordance with applicable law.