Terms of Service

Privacy Policy

Last updated July 13, 2021

At First Mile Group, Inc. d/b/a Alloy ("First Mile Group", “Alloy”, "we", "us", or "our" which include our group and affiliated companies), our most important asset is our relationship with our user community. We are committed to maintaining the confidentiality, integrity and security of information about our users, their organizations and their customers and prospective customers. This Privacy Policy describes how we treat personal and company information when you visit the First Mile Group Website www.alloy.com ("the Site") or use the Alloy Service.

In this privacy policy, "you" and "your" refers to individual users of the First Mile Group's Site or Alloy Service, and "Alloy Service", "Member", "Corporate Member", "Application" and other capitalized terms not defined in this Privacy Policy are defined in the First Mile Group Terms of Service [www.alloy.com/tos]. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at [email protected].


Information that our European users submit through the Alloy Service or the Site is sent to and stored on secure servers located in the United States of America and may be transferred by us to our other offices and/or to the third parties (such as our Partner Companies), who may be situated in the United States or elsewhere outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The United States and other non-EEA countries may not have similar data protection laws to the European Union and EEA countries, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from in the EEA countries. When we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected consistent with our obligations under local law. By submitting information via the Alloy Service or Site, you agree to this storing, processing and/or transfer.

This Privacy Policy is incorporated into, and considered a part of, the First Mile Group Terms of Service, currently located at [www.alloy.com/tos]. Any terms not defined herein have the meanings ascribed to them in the Terms of Service.


By submitting or making available Personal Data (as defined below) through the Alloy Service or Site, you agree to the terms of this Privacy Policy and you expressly consent to the processing of Personal Data in accordance with this Privacy Policy.


Our Site, as well the Alloy Services, are not intended for children under 16 years of age. We do not intentionally gather or process Personal Data about individuals who are under the age of 16. If we inadvertently hold or have access to Personal Data about anyone under 16, please let us know so we can delete it.


First Mile Group collects Personal Data and Anonymous Data from you when you visit our Site and/or when you send us information or communications in connection with your use of the Alloy Service. "Personal Data" means data that allows someone to identify you or your customers or prospective customers, including, for example, name, address, geographic location of computer or mobile device, telephone number, social security number, credit card number, email address and bank account information, as well as any other non-public information that is associated with or linked to any of the foregoing data. "Anonymous Data" means data about you or your customers or prospective customers that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.


We collect Personal Data from you, such as first and last name, email and mailing addresses, telephone number, professional title, company name, payment information and password, when you register for the Alloy Service. We also retain information on your behalf, such as the Personal Data described above and any correspondence. If you provide us feedback or contact us via email, we will collect your name and email address, IP address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us. We may also collect Personal Data at other instances in the Alloy Service user experience where we state that Personal Data is being collected. In addition to Personal Information that we collect on you, we also collect the Personal Data of your customers and prospective customers that you submit to us for processing through the Alloy Service.


We may receive Personal Data about you from other sources like companies that provide services (such as payment processing services) in connection with the Alloy Service (collectively, "Partner Companies"). Our Partner Companies may supply us with Personal Data, such as your name and email and mailing address information or your login credentials for such Partner Company's website or service, in order to help us provide the Alloy Service. We may add this information to the information we have already collected from you via the Alloy Service or Site in order to perform and improve the Alloy Service. In addition, in the process of processing the Personal Data of your customers or prospective customers through the Alloy Service, we may receive further Personal Data regarding your customers or prospective customers from various information service providers utilized by the Alloy Service.

This Privacy Policy applies only to the use and disclosure of Personal Data that we collect while you use the Alloy Service or the Site. Our provision of a link to any other third-party website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave the Alloy Service or Site and go to another site. During this process, a third party may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on a link to a third-party website. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any third-party website you visit.


The Alloy Service (which may be hosted by a third-party service provider) may collect Personal Data from you, such as browser type, geographic location of your mobile device or computer, operating system and version, Internet Protocol (IP) address, domain name, information about your application, operating environment and hardware profiles and/or a date/time stamp for your visit. We may also use Identifiers (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and/or access to the Alloy Service and your activity on the Alloy Service. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit the Site, use the Application or access your account on our network.

When you interact with the Site or the Application, we try to make that experience simple and useful. We use industry standard identifiers, such as cookies and mobile device identifiers which perform a similar role. Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site or Application (as the case may be). A number of cookies we use last only for the duration of your web or Application session and expire when you close your browser or exit the Application. Other cookies are used to remember you when you return to the Site or Application and will last for longer. We refer to cookies and the mobile device equivalents as "Identifiers."

We use Identifiers to:

Our affiliates may use Identifiers to monitor performance and usage on the Site and the Application for internal analytics. The use of Identifiers by our affiliates is covered by this Privacy Policy. We do have access or control over these cookies. Some of the Identifiers used by the Site are set or accessed (as appropriate) by us, and some by third parties who are delivering services on our behalf.

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site or Application, you may not be able to take full advantage of the Site or Application (as the case may be).

In addition to cookies, tracking Gifs may be set by us or third parties in respect of your use of the Site or Application. Tracking Gifs are small image files within the content of the Site or Application so we or third parties can understand parts of the Site are visited and which functions of the Application are used and whether particular content is of interest.

Do Not Track: Your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, First Mile Group does not respond to “Do Not Track” signals or other mechanisms from a visitor’s browser. If, in the future, we create a program or protocol to respond to such web browser “Do Not Track” signals, we will inform you of the details of that protocol in this Privacy Policy. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.


We collect, process your Personal Data, provided by or collected as described above, for the purposes and on the legal bases identified in the following:

We may create Anonymous Data records from Personal Data by excluding information that render the data personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content and functionality of the Alloy Service. First Mile Group reserves the right to use for other purposes and to disclose Anonymous Data to third parties in its discretion.

If you provide feedback on the Alloy Service or Site, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Data. First Mile Group will collect and store any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.

First Mile Group receives specific contractual authorization from all customers which it receives data from for processing in line with one or more purposes as outlined above, and for processing the data within the United States.


We may share your Personal Data with Partner Companies to provide technical support or to provide specific services, such as maintenance services, database management or payment processing for purchases. Partner Companies will have access to your Personal Data only to perform these services on our behalf and are obligated not to disclose or use it for any other purpose. They may be located, or their data processing activities may take place, in the United States or elsewhere outside the EEA. The United States and other non-EEA countries may not have similar data protection laws to the European Union and EEA countries, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from in the EEA countries. Personal Data of your customers or prospective customers that you provide through the Alloy Service will be disclosed to the various third party information database providers used in the provision of identity verification services through the Alloy Service. We may also disclose your Personal Data with your consent for any other purpose disclosed by us when you provide the data.

Any subsidiaries, joint ventures, or other companies under common control with us (collectively, "Related Entities"), may share some or all of your Personal Data, in which case we will require our Related Entities to honor this Privacy Policy, and our Related Entities will use your Personal Data only for the purposes set out in this Privacy Policy.

First Mile Group may sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Personal Data may be among the items sold or otherwise transferred in these types of transactions, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Regardless of any choices you make regarding your Personal Data (if applicable), First Mile Group may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants or lawful requests from government authorities served on Alloy; or (b) protect or defend the rights, reputation or property of First Mile Group or users of the Alloy Service.

Except as otherwise stated in this Privacy Policy, we do not sell, trade, share, or rent the Personal Data collected from our services to third parties. You expressly consent to the sharing of Personal Data as described in this Privacy Policy.


First Mile Group offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your account.


Changes to the Personal Data of you or your customers or prospective customers should be sent to us immediately. You may change aspects of any of your Personal Data in your account by editing your profile within the registration portion of the Site or by sending an email to us at [email protected]. You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Where a Member accesses the Application or the Alloy Service because their employer is a Corporate Member, First Mile Group has no direct relationship with that Member. In that situation, a Member who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Alloy’s Corporate Member (the data controller). If the Corporate Member requests First Mile Group to remove the data, we will respond to their request within 30 business days.


First Mile Group will retain data we process on behalf of our Corporate Members for as long as needed to provide services to our Corporate Member or otherwise in accordance with applicable law. First Mile Group will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Our Site may offer blogs or community forums, which may be publicly available or which may require login credentials. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Data from any of our blogs or community forums, contact us at [email protected]. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so and why.


California residents may request certain information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to [email protected].


First Mile Group is committed to protecting the security of Personal Data. We use a variety of industry-standard security technologies and procedures to help protect Personal Data from unauthorized access, use, or disclosure. When you enter sensitive information on the Alloy Service, we encrypt the transmission of that information using secure socket layer technology (SSL). We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. Despite these measures, you should know that First Mile Group cannot fully eliminate security risks associated with Personal Data, and any transmission of Personal Data is at your own risk. Should you have any questions regarding our security procedures, or wish to report any potential system failures or breaches, please contact us at [email protected].


Under applicable law, you may have, among others, the rights (under the conditions set out in applicable law): (i) to check whether and what kind of Personal Data we hold about you and to request copies of such data, (ii) to request correction, supplementation or deletion of your Personal Data that is inaccurate or processed in non-compliance with applicable requirements, and (iii) to request us to restrict the processing of your Personal Data, (iv) in certain circumstances, to object for legitimate reasons to the processing of your Personal Data or to revoke consent previously granted where such revocation has no effect on the lawfulness of the processing prior to the revocation, (v) to request data portability, (vi) to know the identities of third parties to which your Personal Data are transferred, and (vii) to lodge a complaint with the competent authority.

If you want to learn more about the Personal Data that First Mile Group has about you, or you would like to update or change that information, please contact us by email at [email protected].

First Mile Group makes good faith efforts to provide individuals with access to their Personal Data, although there may be circumstances in which First Mile Group is unable to comply with your request, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If First Mile Group is unable to comply with your request we will provide you with an explanation of why that conclusion has been made, and provide a point of contact for further inquiries.


As part of the Alloy Service, Alloy, acting as a service provider to the company that owns or operates a website or app that you are using or is providing services you wish to access (“Client”), may with your written consent collect your Personal Data, including images of you or your identity documents and/or facial geometry scans and other biometric information or identifiers.

This data may be processed and stored by Alloy, our Client and/or our or our Client’s vendors for the purpose of verifying your identity or otherwise in a manner consistent with this Privacy Policy, or, in the case of Client and/or its vendors, as set forth in their applicable privacy policies or agreements with you. Alloy collects, processes, transmits and stores this information in accordance with our Client’s instructions (as separately authorized by you or your legal representative), this Privacy Policy and applicable law. Alloy will process, store, transmit and protect from unauthorized disclosure any facial geometry scans or other biometric information or biometric identifiers we collect from you using a reasonable standard of care, and in any case in a matter that is the same or more protective than the manner in which we process, store, transmit and protect other confidential and sensitive information.

Alloy will retain this data for as long as directed by our Client or otherwise in accordance with our legal, contractual and policy obligations, except where applicable law provides for a shorter period.

Alloy’s third-party vendors may have access to this data to store the data, to maintain backup copies and/or to service the systems on which such data is stored. Alloy may transmit the data to other third-party vendors used by our Client in accordance with our Client’s instructions. Other than as described in this Privacy Policy, Alloy will not disclose, redisclose, or otherwise disseminate facial geometry scans or other biometric information or biometric identifiers we collect unless doing so: (a) completes a transaction that our Client instructs us is requested and authorized by you or your legally authorized representative; (b) is required by law; (c) is required pursuant to a warrant or subpoena issued by a court of competent jurisdiction; or (d) is expressly consented to by you.


First Mile Group welcomes your comments or questions regarding this Privacy Policy. Feel free to email comments or questions to us at [email protected] or 41 Elizabeth Street, Suite 501 New York, NY 10013.


If First Mile Group makes changes to this Privacy Policy, these changes will be posted on the Site in a timely manner. First Mile Group reserves the right to modify this Privacy Policy at any time, so please review it frequently. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Privacy Policy will become effective upon our posting of the revised Privacy Policy on the Site or Application. If we make any material changes we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Use of the Alloy Service or Site following such changes constitutes your acceptance of the revised Privacy Policy then in effect.