Privacy Policy

1. Who We Are

Alutra ("we," "us," or "our") is a private strategy practice providing advisory services through the website alutrahouse.com (the "Site"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our Site, submit an inquiry, or engage our services. This policy applies to all visitors, users, and clients regardless of location, and is designed to comply with applicable privacy laws in the United States (including the California Consumer Privacy Act as amended by the CPRA) and Canada (including the Personal Information Protection and Electronic Documents Act, PIPEDA).

2. Categories of Personal Information We Collect

When you submit a private inquiry or engage our services, we may collect the following categories of personal information:

Identifiers: First name, last name, and email address.

Professional information: Information about your professional situation, career history, or decision context that you voluntarily provide in your inquiry.

Internet activity: Anonymized, aggregate data about Site performance and usage collected through Vercel Analytics. This does not include cookies or individual tracking.

Referral source: How you heard about us (e.g., search engine, referral, social media).

We do not collect sensitive personal information such as Social Security numbers, financial account details, biometric data, precise geolocation, race, ethnicity, religious beliefs, or health information through the Site.

3. Sources of Personal Information

We collect personal information directly from you when you submit an inquiry form on our Site, communicate with us via email or other channels, or engage our advisory services. We do not purchase personal information from third-party data brokers or collect information through automated tracking technologies beyond anonymized analytics.

4. How We Use Your Information

We use the personal information we collect for the following business purposes: to respond to your inquiry and assess whether our services are a fit for your situation; to communicate with you about potential or active engagements; to deliver advisory services you have engaged; to improve our Site, services, and client experience; and to comply with legal obligations.

We do not use your personal information for automated decision-making or profiling. We do not use personal information for purposes materially different from those described here without providing you with notice.

5. Disclosure of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. We do not rent, trade, or otherwise make your personal information available to third parties for their own marketing purposes.

We may disclose your personal information to the following categories of service providers who process data on our behalf and are contractually obligated to protect it:

Encharge: Customer relationship management and email communication platform. Processes inquiry data including name, email, inquiry type, and situation description.

Vercel: Website hosting and anonymized analytics. Processes aggregate, non-identifying usage data.

We may also disclose personal information if required to do so by law, regulation, legal process, or enforceable governmental request, or to protect the rights, property, or safety of Alutra, our clients, or the public.

6. Cookies and Tracking Technologies

This Site does not use cookies for tracking, advertising, or analytics purposes. We use Vercel Analytics, which operates without cookies and does not track individual users. Essential cookies may be set by our hosting infrastructure for security and performance purposes only. We do not use third-party advertising cookies, social media tracking pixels, or remarketing technologies.

7. Data Retention

We retain your personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, maintain our business records, comply with legal obligations, resolve disputes, and enforce our agreements. Inquiry data is retained for up to 24 months after your last interaction with us unless you request earlier deletion. Client engagement records may be retained longer as required for legal and professional obligations.

8. Your Privacy Rights

For California Residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we have collected about you over the past 12 months, including the categories of information, sources, business purposes, and any third parties with whom it was shared. You have the right to delete personal information we have collected from you, subject to certain exceptions. You have the right to correct inaccurate personal information. You have the right to opt out of the sale or sharing of your personal information (we do not sell or share personal information, so there is no action required). You have the right to non-discrimination for exercising any of these rights.

For Canadian Residents (PIPEDA)

If you are a Canadian resident, you have the right to access the personal information we hold about you. You have the right to request correction of inaccurate or incomplete information. You have the right to withdraw consent for any processing activities for which you have previously provided consent. You have the right to file a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

For All Users

Regardless of your location, you may request access to, correction of, or deletion of your personal information at any time. You may also request a copy of the data we hold about you in a portable format. We will respond to all verifiable requests within 30 days (or 45 days if an extension is necessary, with notice to you).

9. How to Exercise Your Rights

To exercise any of the rights described above, submit a request through our inquiry page at alutrahouse.com/inquiry or email us directly at the address provided below. We may need to verify your identity before processing your request. We will not charge a fee for processing your request unless it is manifestly unfounded or excessive.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encrypted data transmission (TLS/SSL), access controls, and secure hosting infrastructure. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

11. International Data Transfers

Our service providers may process your data in jurisdictions outside your country of residence, including the United States. Where personal information is transferred across borders, we ensure appropriate safeguards are in place through contractual agreements with our service providers that require them to protect your data in accordance with applicable privacy laws.

12. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete it promptly. If you believe we have collected information from a minor, please contact us immediately.

13. Third-Party Links

Our Site may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

14. Do Not Track Signals

Our Site does not respond to Do Not Track (DNT) browser signals. However, as described in Section 6, we do not use tracking cookies or behavioral advertising technologies, so your browsing activity on our Site is not tracked for advertising purposes regardless of your DNT settings.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically. This policy is reviewed and updated at least once every 12 months.

16. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your personal information is handled, please contact us through our private inquiry page at alutrahouse.com/inquiry.

If you are a California resident and are not satisfied with our response, you may contact the California Privacy Protection Agency at cppa.ca.gov. If you are a Canadian resident, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca.