PRIVACY POLICY

Your privacy is important to Alpine Tremont LLC, a US-based company, headquartered in Massachusetts. We make it a high priority to ensure the security and confidentiality of the personal information you provide to us. 

Alpine Tremont LLC’s core business is advising banks, government agencies, and financial institutions on the development of strategies for non-core and non-performing asset valuation, acquisition, and/or disposal. Alpine Tremont LLC’s customers do not include individuals.

This privacy policy statement (“Privacy Policy”) is meant to provide you with notice of Alpine Tremont LLC’s privacy policy, specifically to help you understand how we process your personal data, why we process it, and how we use your personal data. Please take a few moments to read this policy.

Categories of Personal Data That We Process

This Privacy Policy applies to all personal data that is processed by Alpine Tremont LLC. We are processing the following categories of personal data:

· Name

· Address

· E-mail address

· Phone number

· Fax number

· Company

· Birthdate

· Credit details

· Credit assessments

· Payment histories

· Correspondence related to credits 

· Loan details including interest rate, maturity, etc.

How We Collect Information

For Clients Considering Our Services and Potential Buyers of Non-Core and Non-Performing Assets

· Online Registration and/or Directly From You: We collect your information, including personal information (information that individually identifies you) directly through registration forms made available directly or on www.alpinetremont.com, which may also include your execution of an online confidentiality agreement on our website or by other means. We may maintain your digital signature in our files relating to your execution of confidentiality agreements. We may request additional information from you via e-mail or phone. In some cases, the professional organization you are affiliated with may provide pertinent contact information to us. To inform us of changes to your personal information, please contact us via e-mail at contactus@alpinetremont.com.

· IP Addresses: An IP address is a number that is automatically assigned to your computer whenever you browse the internet. Alpine Tremont LLC logs IP addresses of visitors for system administration, security and troubleshooting purposes as well as tracking relative statistical information for a specific sale. Web servers automatically identify your computer by its IP address. When you request pages from any Alpine Tremont LLC related website, our servers log your IP address. Alpine Tremont LLC collects these IP addresses for the purpose of identifying our users' service providers so we can better develop our products.

· Cookies: A cookie is a piece of data stored on the user’s hard drive containing information about the user session that tracks online system behavior and history. Cookies can also enable us to track and target the interests of our users to enhance the experience on our website. This statistical information may also be shared with sellers associated with a sale registered by the user and for Alpine Tremont’s own internal informational purposes. By visiting www.alpinetremont.com with your browser settings adjusted to accept cookies, you consent to Alpine Tremont’s use of your cookies.

· E-mail Address: When a visitor submits an inquiry via e-mail, Alpine Tremont LLC may log or retain the email address for Alpine Tremont’s records.

For Individuals Whose Loans We May Be Assessing For Alpine Tremont LLC’s customers

· Information Provided by Our Customers: When a customer requests us to analyze their non-core and non-performing assets, we may have access to data related to credit relationships, including names, contact details, birthdates, credit assessments, payment history, correspondence history with the bank, and other loan details. We process this information in order to create a summary of the non-core and non-performing assets, estimate the secondary value of such assets, and allow our customers to decide which assets they choose to sell or buy. 

The Way We Process Personal Data

When you register with Alpine Tremont LLC as a potential buyer or seller and/or submit an inquiry or a comment, we may contact you regarding your registration, inquiry, or comment. We may also use your e-mail address and/or phone number to provide you with information regarding a specific sale you have registered for or about related sales, industry information that might be of interest, and/or Alpine Tremont’s services, as well as email alerts. We use the information you provide about yourself when bidding in order to complete the bid and to maintain Alpine Tremont LLC’s sale records, which are internal to Alpine Tremont LLC. The legal ground for processing personal data for this purpose is our legitimate interest to provide you with accurate information for your enquiries and to foster a collaboration with you or the company you represent.

We may also use aggregate information for business purposes to enhance Alpine Tremont LLC’s services and offerings, website, data analysis, and marketing analysis. The legal ground for processing personal data for this purpose is our legitimate interest to improve our business offerings.

When we are analyzing non-core and non-performing assets under the instruction of our bank, government, and financial institutions clients, our clients will give us access to information that may include your personal data. For this processing we are acting as Personal Data Processors, and we process your personal data based on the instructions given by our customers (banks, governments, and financial institutions) who act as Personal Data Controllers.

Data Security

To prevent unauthorized access, maintain data accuracy, ensure the appropriate use of information, and protect against the loss, misuse, or alteration of information under our control, we have put in place appropriate physical, electronic and managerial procedures to safeguard and protect the information we collect online.

While we follow generally accepted standards to protect personal data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of the website after your session.

With Whom We Share Your Information And Why

We are sharing your personal data with Google, Inc, a US-based company that acts as personal data processor for us, providing online cloud based file storage services. The compliance of the ongoing transfer of personal data is ensured by the adequacy decision issued by the European Commission for the companies that are members of the Data Privacy Framework, including Google Inc.

We are sharing your personal data with Microsoft, Inc, a US-based company that acts as personal data processor for us, providing online cloud based file storage services and email services. The compliance of the ongoing transfer of personal data is ensured by the adequacy decision issued by the European Commission for the companies that are members of the Data Privacy Framework, including Microsoft, Inc.

We are sharing your personal data with Hubspot, Inc, a US-based company that acts as personal data processor for us, providing online customer relationship management services. The compliance of the ongoing transfer of personal data is ensured by the adequacy decision issued by the European Commission for the companies that are members of the Data Privacy Framework, including Hubspot, Inc.

We are sharing your personal data with GoDaddy Operating Company, Inc, a US-based company that acts as personal data processor for us, providing email and website hosting. The compliance of the ongoing transfer of personal data is ensured by the adequacy decision issued by the European Commission for the companies that are members of the Data Privacy Framework, including GoDaddy Operating Company, Inc.

In the process of advising our clients on the sales of non-core and non-performing loans, we may also share your personal data with different banks and financial institutions, as instructed by our clients, who act as Personal Data Controllers, while we act as Personal Data Processors on their behalf. 

We may share your information with appropriate entities if we believe it is reasonably necessary to comply with a law, rule or regulation, reporting requirement, protect the safety of any person, address fraud, security or technical issues, or to protect Alpine Tremont LLC’s legal rights or property. We may share your information in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

When we transfer your information to third parties, we comply with the requirements of the legal protections that cover your information. For example, when we perform an onward transfer of your information protected under the GDPR, we remain responsible for the processing of your personal information. For information subject to an onward transfer by us under the Data Privacy Framework, we will remain liable under the Data Privacy Framework Principles if a recipient of your protected personal information processes such personal information in a manner inconsistent with the Principles, unless we are able to prove that we are not responsible for the event giving rise to the damage.

Retention of Information

We keep your personal information for no longer than necessary for the purposes for which it is processed.

Thus, we will keep personal data from invoices, purchase orders and sales records for five years, based on our legitimate interest to demonstrate that we are compliant with the fiscal laws of the United States of America.

We will keep personal data from accounts payable ledgers and accounts receivable ledgers for seven years, based on our legitimate interest to demonstrate that we are compliant with the fiscal laws of the United States of America.

We will keep personal data from sales leads for a maximum of three years from the last contact, based on our legitimate interest to capitalize on the business opportunities. 

Your Rights with Respect to the Collection and Use of Your Information

Where we are acting as a Personal Data Controller, you may have certain rights relating to your personal data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, the United Kingdom, and/or Switzerland these rights may include:

· To access your personal data (right to access);

· To rectify inaccurate personal data (right to rectification);

· To erase/delete your personal data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);

· To transfer your personal data to another controller, to the extent possible (right to portability);

· To object to any processing of your personal data carried out on the basis of our legitimate interests (right to object). Where we process your personal data for direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide a specific reason for such objection;

· To not be subject to a decision based solely on automated processing, including profiling, which produces legal affects (automated decision-making).

· To withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise your rights, please contact Alpine Tremont’s Data Protection Officer by sending an email to contactus@alpinetremont.com.  

You may, subject to its terms, invoke binding arbitration in accordance with Annex I of the DPF Principles: https://www.dataprivacyframework.gov/program-articles/Participation-Requirements-Data-Privacy-Framework-(DPF)-Principles 

This provides that you may invoke binding arbitration by delivering notice to Alpine Tremont LLC, and following the procedures and subject to conditions set forth in Annex I of the Principles.

Please note that we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

What is our contact data?

Please contact us, should you have any queries::

Data Protection Officer

Alpine Tremont LLC, Inc.
e: contactus@alpinetremont.com

p: +1 (617) 939-9705

Children’s Privacy

Our Services are not designed for and are not marketed to people under the age of 18 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our services. If you are a minor, please do not use our services or send us your information. Please email us at contactus@alpinetremont.com if you believe we might have information from or about a minor.

Links to Other Websites

You should be aware that when you are on any Alpine Tremont LLC site, you could be directed to other sites that are beyond  Alpine Tremont LLC’s control and not governed by this Privacy Policy.

Data Privacy Framework

Alpine Tremont LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Alpine Tremont LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Alpine Tremont LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov.  Alpine Tremont LLC’s privacy policy can be found at https://alpinetremont.com/privacy-policy.

Compliance and Enforcement

We have designated a Data Protection Officer (DPO) to monitor our adherence to the Data Privacy Framework and to address questions and concerns regarding our adherence.

Individuals may file a complaint with Data Protection Officer in connection with AT’s processing of their personal data under the Data Privacy Framework.

With respect to any dispute relating to this policy that cannot be resolved through our internal processes:

· Individuals may file a claim with Judicial Arbitration and Mediation Services (JAMS). To contact JAMS and learn more about submitting a complaint, please visit:  https://www.jamsadr.com/DPF-Dispute-Resolution . JAMS will provide independent dispute resolution and, should it determine it appropriate, can also assess sanctions, including damages, for violation of the Principles outlined in the Data Privacy Framework.

· An individual may under certain conditions invoke binding arbitration. Please see the Data Privacy Framework website for more information on conditions giving rise to binding arbitration.

Changes to this Privacy Policy

This Privacy Policy is subject to change from time to time. We will post any applicable Privacy Policy changes on this page. If the changes are significant, we will provide a prominent notice to you. So long as we adhere to the Data Privacy Framework, we will not amend our policy in a manner inconsistent with the Data Privacy Framework.

This policy was last modified on April 29, 2024.