Effective: March 27th, 2020
Thank you for choosing to be part of our community at InfoSense, Inc. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
- WHAT DATA DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WHO WILL YOUR INFORMATION BE SHARED WITH?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DATA BREACH
- CONTROLS FOR DO-NOT-TRACK FEATURES
1- WHAT DATA DO WE COLLECT?
Personal Information you disclose to us.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Publicly Available Personal Information. We collect phone numbers; email addresses; business email; business phone number; first name; last name, and nickname; and other similar data.
Personal Information Provided by You. We collect app usage; data collected from surveys; and other similar data.
All personal information that you provide to us must be true, complete and accurate and you must notify us of any changes to such personal information.
Information automatically collected.
In short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services or Apps.
We automatically collect certain information when you visit, use or navigate the Services or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect devices; applications; tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or other such as the ones used for analytics and marketing; and other similar data.
Information collected through our Apps.
In Short: We may collect information when you use our apps.
We may collect information regarding you when you use our apps such as device characteristics, device name, country, location, operating system, username, or other such as the ones used for analytics and marketing and other similar data.
Information collected from other sources.
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: marketing lead and search results and links, including paid listings (such as sponsored links). We will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data.
2- HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests and the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We do not sell your personal information.
We use personal information collected via our Services or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests in order to enter into a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process.
- To send you marketing and promotional communication. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “What are your Privacy Rights” below).
- To send administrative information to you. We may use your personal information to send you product service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services or Apps.
- Request Feedback. We may use your information to request feedback and contact you about your use of our Services or Apps.
- To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal requests, we may need to inspect the data we hold to determine how to respond.
- To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- To deliver services to the user. We may use your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- For other Business Purposes. We may use your information for other Business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Services or Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organizations apart from us. They will hold it securely and retain it for the period we instruct.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
4- WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third parties.
We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Advertising, Direct Marketing and Lead Generation (Constant Contact)
- Content Optimization (DNN; WordPress)
- Data Backup and Security (Dropbox Backup)
- Functionality and Infrastructure Optimization (Copper CRM)
- Invoice and Billing (Quickbooks)
- Web and Mobile Analytics (Google Analytics and DNN)
- Website Hosting (DNN)
- Website Performance Monitoring (Pingdom)
What are cookies: Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For more information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
There are several different types of cookies, however, our website uses:
- Functionality – We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in.
- Advertising – Our company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device and your IP address.
How to manage cookies
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
6- HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7- HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.
8- DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or market to children under 18 years of age.
9- WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws, These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
Pursuant to the Privacy Shield Frameworks, EU and UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
InfoSense’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, InfoSense remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless InfoSense proves that it is not responsible for the event giving rise to the damage.
If you are located in the European Economic Area or United Kingdom and you believe we are unlawfully processing your personal information, you also have the right to submit a complaint related to the way that we have handled your personal data. In compliance with the Privacy Shield Principles, InfoSense, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and United Kingdom individuals with Privacy Shield inquiries or complaints should first contact InfoSense at:
email@example.com or 877-747-3245 ext 8
InfoSense, Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
If you have any questions or comments about your privacy rights, you may email us at firstname.lastname@example.org.
If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.
Cookies and similar technologies: Most Web browser are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services or Apps. To opt out of interest-based advertising by our advertisers on our Services or Apps visit http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.
10- DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when InfoSense, Inc. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that InfoSense, Inc. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information InfoSense, Inc. will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
11- CONTROLS FOR DO-NOT-TRACK FEATURES
12- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing proposes and the names and addresses of all third parties with which we shared personal 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 us using the contact information provided below.
13- DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
14- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have any questions or comments about this policy, you may contact our Data Protection Officer (DPO), Diane Ryu, by email at email@example.com, by phone at 877-747-3245, or by post to:
2102 Cambridge Beltway Dr. STE D1
Charlotte, NC 28273
How can you Review, Update, or Delete the Data we Collect from you?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by submitting request at https://infosense.com/contact-us/.