Privacy Policy

Revised 8/29/2017

Altum, Inc. (“Altum”) recognizes the importance of protecting the privacy of information we may receive from visitors to our web site. You may visit the Altum site without telling us anything about yourself. If you contact us and choose to provide personally identifiable information, we will use it for the purpose for which you submitted it to us.

Altum takes reasonable and appropriate measures to protect [personal information] from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Any and all uses of personally identifiable information comply with applicable United States laws.

By submitting personally identifiable information to the Altum web site, to the extent permitted by law, you waive any rights you may have under any law of any other country or region.

Types of Personally Identifiable Information Collected and Purposes of Collection and Use

Altum only collects personally identifiable information of the following types and for the following purposes:

  • Altum collects contact information from website visitors when those visitors request information about or a demonstration of Altum products and services.
  • Altum collects contact information, employment experience and other relevant information from individuals seeking employment with Altum or responding to specific Altum job postings. If you send a resume in response to a job opening posted on this web site, we will retain your personal information only for the purpose of filling the job opening and will not use it for any other purpose.
  • Altum collects contact information from users of our products and services in order to provide technical support and updates about those products and services.
  • Altum collects contact information and other personally identifiable information from users on behalf of customers of Altum’s grants management products (proposalCENTRAL, Easygrants, and PhilanTrack). Users providing personally identifiable information include applicants, grantees, reviewers and grants administrators. This personally identifiable information is collected and used in process of applying for and managing grants.

Altum does not collect or maintain personally identifiable information for resale purposes.

Third Parties to Whom Altum Discloses Personally Identifiable Information

For users of Altum products and services and visitors to our website, Altum discloses that personal information for the purposes listed above to Altum employees and the Company’s subcontractors who provide and support the Company’s products and services.

When Altum collects personally identifiable information from users of Altum’s grants management products (proposalCENTRAL, Easygrants, and PhilanTrack), that personal information is disclosed to the grant funding organizations and their designated users to enable them to manage their grant-making processes. Applicant and grantee personal information may also be disclosed to co-applicants and applicant organizations in support of the application, review, approval and grantee reporting process.

Where customers of Altum’s grants management products and services integrate those products with the customer’s websites, software and/or other third party products used by the customer, Altum provides customers of our products and services with the ability to transfer information, including personally identifiable information, to the customer’s other products. Altum’s customers who use these facilities are typically grant funding organizations who utilize multiple systems to manage the process of receiving applications from and distributing grant funding to applicants and grantees respectively.

Other than as listed above or in connection with a proposed financing, merger or other corporate transaction, Altum does not share your information with any other third parties.

Other Information Routinely Collected by Our Site Technology

IP Address. From time to time the Altum web site may be configured to collect domain information – your Internet Protocol (IP) address – as part of our analysis of the use of the web site. This data enables Altum to become more familiar with which users visit our site, how often they visit and what parts of the site they visit most often. Altum uses this information to improve our web site. The IP address does not identify you personally and is collected automatically.

Cookies. Periodically, some pages on this web site may use “cookies,” which are small files that the site places on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit the web site. You should note that cookies cannot be read off your hard drive. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser. By not accepting cookies, some pages may not fully function and you may not be able to access certain information on this web site. We do not allow other sites or third parties to access our cookies for their own purposes or to place their own cookies on you as you access the Altum web site.

Third Party Links. As a convenience, the Altum web site currently contains links to a number of sites that we believe may offer useful information. The policies and procedures posted on those sites, not the policies and procedures as described here, apply to those sites. Altum suggests checking the privacy policy on each linked site directly for information on their privacy, security, data collection and distribution policies.

Changes in this Privacy Policy

Altum will only use personally identifying information in the manner described in the version of this Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to the web site.

Altum Privacy Shield Policy

This policy was last updated on 24th October, 2016.

Privacy Shield Policy.  ALTUM is committed to protecting your privacy. ALTUM has put in place internal procedures to ensure that your personal information is processed responsibly and in accordance with applicable data protection/privacy laws. This Privacy Shield policy (the “PS Policy”) sets out the privacy principles that ALTUM follows with respect to data about an identified or identifiable individual that are within the scope of Directive 95/46/EC received by ALTUM in the United States from the European Union (EU), and recorded in any form. For all such data, this PS Policy supplements ALTUM’s general Privacy Policy, above. Where this PS Policy is inconsistent with ALTUM’s general Privacy Policy with regard to the processing of such data, this PS Policy will prevail.

ALTUM complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the United States. ALTUM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this PS Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Definitions.  For the purposes of the PS Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, ALTUM or to which ALTUM discloses personal information for use on ALTUM’s behalf.
“ALTUM” means ALTUM, Incorporated, its subsidiaries, divisions, groups and affiliates in the United States.
“Personal information” and “personal data” are data about an identified or identifiable individual that are within the scope of Directive 95/46/EC, received by ALTUM in the United States from the EU, and recorded in any form.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns health or sex life. In addition, ALTUM will treat as sensitive, any information received from a third party where that third party treats and identifies the information as sensitive.

Scope.  This PS Policy applies to all personal information, either in electronic or paper format, received by ALTUM in the United States from the EU in any format, including electronic, paper, or verbal.

Privacy Principles.

The following privacy principles are based on the Privacy Shield Principles and the definitions applied therein.

Notice:

For information about the types of personal data that ALTUM collects and the purposes of such collection, see the “Types of Personally Identifiable Information Collected and Purposes of Collection and Use” section of ALTUM’s general Privacy Policy above. For information about the types of third parties to which Altum may disclose personal data, see the “Third Parties to Whom Altum Discloses Personally Identifiable Information” section of ALTUM’s general Privacy Policy above.

Where ALTUM collects personal information directly from individuals in the EU, ALTUM will adhere to the Notice Principle, including informing them about: the purposes for which it collects and uses personal information about them, the types of third parties to which ALTUM discloses that information, and the choices and means, if any, that ALTUM offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to ALTUM, or as soon as practical thereafter, and in any event before ALTUM uses the information for a purpose other than that for which it was originally collected or discloses it for the first time to a third party.

Where ALTUM receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

Choice:

ALTUM will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, ALTUM will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of such information to a third party or the use of such information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, as required by the Privacy Shield Principles. ALTUM will provide individuals with reasonable means to exercise their choices.

Accountability For Onward Transfer:

ALTUM does not transfer data to third parties outside of its agents. ALTUM transfers personal data to its agents only for limited and specified purposes, and will obtain assurances from its agents that they will process personal information consistently with this PS Policy and with ALTUM’s obligations under the Privacy Shield Principles. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). If the agent is no longer able to meet its obligation to provide the same level of protection as provided under the Principles, ALTUM requires the agent to notify ALTUM. Where ALTUM has knowledge that an agent is using or disclosing personal information in a manner contrary to this PS Policy, ALTUM will take reasonable steps to prevent or stop the use or disclosure.

In the context of an onward transfer, ALTUM has responsibility for the processing of personal information it received under the Privacy Shield and subsequently transfers to a third party acting on an agent on its behalf. ALTUM remains liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless ALTUM proves that it is not responsible for the event giving rise to the damage.

Please be aware that ALTUM may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Security:

ALTUM will take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data.

Data Integrity and Purpose Limitation:

ALTUM will process personal information only in ways that are compatible with the Privacy Shield Principles and with the purposes for which it was collected or subsequently authorized by the individual and only as relevant for the purposes of processing. ALTUM will take reasonable steps to ensure that personal information is relevant to and reliable for its intended use, accurate, complete, and current. ALTUM will adhere to the Principles for as long as it retains such information.

Access:

Upon request, ALTUM will grant individuals whose personal information is subject to this PS Policy reasonable access to the personal information about them that ALTUM holds. In addition, ALTUM will take reasonable steps to permit individuals to correct, amend, or delete personal information about them that ALTUM holds that is demonstrated to be inaccurate or incomplete, or has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, where the rights of persons other than the individual would be violated, or where access is otherwise not required or may be restricted under the Privacy Shield Principles. In cases where ALTUM is acting as a processor, ALTUM will obtain authorization from its client prior to providing access, or refer the requesting individual to the appropriate client contact.

Recourse, Enforcement and Liability:

ALTUM will conduct compliance audits of its relevant privacy practices to verify adherence to this PS Policy and the Privacy Shield Principles. ALTUM will take all necessary measures against any employee that ALTUM determines is in violation of this PS Policy, including disciplinary action. ALTUM is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Dispute Resolution:

Any questions, concerns, or complaints regarding ALTUM’s processing or disclosure of personal information should be directed to the ALTUM Global Data Protection Officer at the address given below. ALTUM will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information, in accordance with the principles contained in this PS Policy free of charge to the individual. Additionally, ALTUM has committed to cooperate with the panel established by the European Union data protection authorities (“DPAs”) to address unresolved Privacy Shield disputes and provide appropriate recourse free of charge to individuals whose personal information is subject to this PS Policy, pursuant to the EU-US Privacy Shield Principles.

Contact Information:

Questions or comments related to this PS policy should be submitted to the ALTUM Global Data Protection Officer by mail as follows:

Global Data Protection Officer
ALTUM, Inc.
1801 Robert Fulton Dr., Suite 450
Reston, VA 20191
+1-703-657-8299
1-877-GO-ALTUM

or by e-mail:

privacy@altum.com

Changes to This EU-US Privacy Shield Privacy Policy

This PS Policy may be amended from time to time, consistent with the requirements of the EU-US Privacy Shield Principles.  Appropriate notice will be given concerning such amendments.