Privacy Policy

1. Information We Collect

We collect information you provide directly to us, such as:

• Contact information (name, email, phone number)
• Case details and documentation
• Payment and billing information
• Communication preferences

2. How We Use Your Information

We use the information we collect to:

• Provide and improve our services
• Communicate with you about your case
• Process payments and billing
• Comply with legal obligations
• Protect against fraud and abuse

3. Information Sharing

We do not sell, trade, or rent your personal information. We may share information only in these circumstances:

• With your explicit consent
• To comply with legal requirements
• To protect our rights and safety
• With trusted service providers under strict confidentiality agreements

4. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

5. Data Retention

We retain your information only as long as necessary to provide services and comply with legal obligations. Case files are securely archived according to industry standards.

6. Your Rights

You have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your information
• Object to processing of your information
• Data portability
• Manage your communication preferences
• Opt-out from marketing communications

7. Cookies and Tracking

Our website uses cookies to improve user experience and analyze website traffic. You can control cookie settings through your browser preferences.

8. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices of these external sites.

9. Changes to This Policy

We may update this privacy policy periodically. We will notify you of any material changes by posting the new policy on our website.

10. Contact Us

If you have questions about this privacy policy or our data practices, please contact us through our official channels.

11. Voice and Call Recording

We record phone calls between you and our intake team for the following purposes:

• Service quality assurance and training
• Legal compliance and dispute resolution
• Cooperation with law enforcement under valid legal process

You are notified of recording at the start of each call. By continuing the call after this notification, you provide implied consent to recording. For customers located in two-party consent jurisdictions — including New Hampshire, California, Florida, Illinois, Maryland, Massachusetts, Michigan, Montana, Pennsylvania, and Washington — recording requires consent of all parties, which is obtained through the pre-call notification and your continued participation.

Voice recordings may contain personal data and, in some cases, special category data (see Section 13). Retention is described in Section 14. You may request a non-recorded follow-up by writing to hello@altahonos.com (subject to operational availability).

12. Legal Basis for Processing (GDPR)

For customers covered by the EU or UK General Data Protection Regulation, we process your personal data on the following legal bases:

• Article 6(1)(a) – Consent: marketing communications and certain voluntary submissions.
• Article 6(1)(b) – Contract: service delivery, payment processing, customer support.
• Article 6(1)(c) – Legal obligation: tax records, anti-fraud, and law enforcement cooperation.
• Article 6(1)(d) – Vital interests: extortion crisis intervention where wellbeing is at risk.
• Article 6(1)(f) – Legitimate interests: fraud prevention, network security, service improvement.

For Turkish customers, processing complies with KVKK Madde 5 grounds (see Section 19).

13. Special Category Data (GDPR Article 9)

Some of our services — particularly those addressing extortion and intimate-image takedowns — may involve processing of special category data under GDPR Article 9, specifically data revealing sex life or sexual orientation, and in some cases health-related information.

Our legal bases for processing this data:

• Article 9(2)(a): Explicit consent, where you voluntarily share such information.
• Article 9(2)(c): Vital interests, where acute distress prevents consent and processing is necessary to protect your wellbeing.
• Article 9(2)(f): Establishment, exercise or defence of legal claims, when supporting prosecution of extortionists or content removal proceedings.

We do not process special category data for marketing, profiling, or any purpose unrelated to your case.

14. Specific Data Retention Periods

We retain personal data only as long as necessary for the purposes for which it was collected:

After retention, data is permanently deleted or fully anonymized (irreversible aggregation).

15. International Data Transfers

Altahonos operates through multiple entities: Altahonos LLC (Delaware, USA), Altahonos Ltd (United Kingdom), and Altahonos A.Ş. (Türkiye). Your data may be transferred between these entities and to third-party processors in various jurisdictions.

For data transferred from the European Economic Area or the United Kingdom to the United States or other non-adequate countries, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• UK International Data Transfer Agreement (IDTA) for UK-origin transfers
• European Commission adequacy decisions where applicable

You may request information about the safeguards in place by contacting hello@altahonos.com.

16. Service Providers (Data Processors)

We share data with the following service providers, all bound by data protection agreements:

We do not share your data with third parties for advertising or unrelated commercial purposes.

17. Children's Data

Our services are intended for adults aged 18 and over. We do not knowingly collect data from minors.

Where a customer self-reports as under 18 during intake — including via automatic age detection in our intake systems — we:

• Decline service immediately and without charge
• Anonymize identifying data within 30 days
• Refer the matter to appropriate child safety resources where applicable

Parents or legal guardians who believe their child's data may have been collected can request immediate deletion at hello@altahonos.com. This policy is consistent with the U.S. Children's Online Privacy Protection Act (COPPA), UK Children's Code, GDPR Article 8, and KVKK provisions regarding minors.

18. Cookies — Categories and Consent

In addition to the general statement in Section 7, the following categories apply:

• Strictly necessary (no consent required): session management, login state, security tokens.
• Functional: user preferences such as language and accessibility settings.
• Analytics: anonymized visitor counts to improve the site (no personal identifiers stored).
• Marketing: currently none deployed; this section will be updated and explicit consent obtained before any marketing or tracking cookies are introduced.

You may manage or revoke cookie consent through your browser settings or any cookie preference link provided in our website footer.

19. KVKK Aydınlatma Metni (Türkiye)

For data subjects in Türkiye, processing is conducted by Altahonos A.Ş. as veri sorumlusu under Law No. 6698 on the Protection of Personal Data (KVKK). You have the following rights under KVKK Madde 11:

• To learn whether your personal data is processed
• To request information if it is processed
• To learn the purposes of processing and whether they are used in accordance therewith
• To learn third-party recipients of transfers, domestically or abroad
• To request correction of incomplete or inaccurate data
• To request deletion or destruction under conditions in KVKK Madde 7
• To request notification of correction or deletion to third-party recipients
• To object to outcomes resulting from automated processing
• To claim compensation for damages from unlawful processing

Applications under KVKK should be sent in writing to merhaba@altahonos.com. We respond within 30 days as required by law. You may also file a complaint with the Turkish Data Protection Authority (KVKB) at kvkk.gov.tr.

20. Right to Withdraw Consent and to Lodge a Complaint

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

You may also lodge a complaint with a supervisory authority:

• European Union: your national Data Protection Authority (directory at edpb.europa.eu)
• United Kingdom: Information Commissioner's Office (ico.org.uk)
• Türkiye: Kişisel Verileri Koruma Kurulu / KVKB (kvkk.gov.tr)
• United States: Federal Trade Commission (ftc.gov); your state Attorney General for state-specific privacy violations

21. Data Protection Contact

For privacy-related inquiries:

• General privacy (English): hello@altahonos.com
• KVKK ve Türkçe başvurular: merhaba@altahonos.com
• Postal: Altahonos LLC, 2604 Whittier Place, Wilmington, Delaware 19808, USA

Where required by GDPR Article 27 or KVKK, we will publish details of our EU/UK Representative and any appointed Data Protection Officer on this page.