Transfers to the United States
The Services are hosted and operated in the United States (“U.S.”) through Intello and its service providers. By using the Services, you acknowledge that Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Intello in the U.S. and will be hosted on U.S. servers, and you authorize Intello to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data. Intello processes Personal Data of our customers’ end users and employees in connection with our provision of services to these customers, making us the processor of Personal Data and those customers the controllers of the Personal Data. For more information about your potential rights under the GDPR, and to exercise such rights where applicable, please contact the controller party in the first instance.
EU-U.S. Privacy Shield
Intello is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Intello’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.
Notice of What Information We Collect and How We Use It
What Information Do We Collect?
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Data. We collect the following types of information from our users.
When you create an Account, you will provide information that could be Personal Data, such as your username, password and email address. Additionally, if you register for or access the Services using a Third Party Service (such as your Google Apps account login credentials), we may receive Personal Data that you have made available to share through such Third Party Service, which may include, without limitation, your user ID, email, name, and image. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Data to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services, but only when we feel such information is important. You may unsubscribe from some of these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.
The Services collects data about your computer usage (“Usage Data”) and also integrates with Third Party Services, including your browser and other software applications, that collect Usage Data. For example, browser plug-ins may record your IP address and browsing history, and APIs may record information about how you use our Services and various Third Party Services. This information may be Personal Data or may be linked to your Account or other Personal Data like your name. We use Usage Data for reasons such as to provide the Services to your employer, to generate Aggregate Information (as defined below), and to improve our Services.
IP Address Information and Other Information Collected Automatically:
- We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
- Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may also use this data in aggregate form. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
- We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.
- Essential Cookies. Essential cookies are required for providing you features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Site. Disabling these cookies may make certain features and services unavailable.
- Functionality Cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies.Performance/analytical cookies allow us to understand how visitors use our Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site, and how long visitors are viewing pages on the Site. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
- Retargeting/Advertising Cookies.Retargeting/advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
- Most browsers automatically accept cookies but have an option for blocking or deleting cookies, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can usually access these options through the “Settings” or similar menu in your browser. For more information about cookies, including how to see what cookies have been set and how to manage and delete cookies, visit http://www.aboutcookies.org/ or http://www.allaboutcookies.org/. Please note that if you block or delete cookies, some portions of the Services may not work properly. In some cases, cookies may enable us to aggregate certain information with other Personal Data we collect and hold about you.
More About Cookies
We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
We collect statistical information about how both unregistered and registered users, collectively, use the Services and their computers (“Aggregate Information”). Some of this information is derived from Personal Data and Usage Data, but as part of Aggregate Information it is not Personal Data and cannot be tied back to you, your Account or your web browser.
How, and With Whom, Is My Information Shared?
The Services are designed to share your Usage Data with your employer. As a result, some of the information generated through the Services is shared with third parties.
Your Usage Data may be connected with your Personal Data and shared with your employer.
IP Address Information:
Information You Elect to Share:
We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Data about you that they have independently developed or acquired.
Email Communications with Us:
As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account.
User Profile Information:
User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. Your account information may also be shared with your employer.
Information Shared with Our Service Providers:
We employ and contract with people and other entities that perform certain tasks on our behalf (our “Service Providers”). We may need to share Personal Data with our Service Providers in order to provide products or services to you. Unless we tell you differently, our Service Providers do not have any right to use Personal Data or other information we share except in connection with their services to us. You hereby consent to our sharing of Personal Data with our Service Providers.
Information Disclosed Pursuant to Business Transfer:
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
Information Disclosed for Our Protection and the Protection of Others:
Information We Share With Your Consent:
Except as set forth above, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information.
Is Information About Me Secure?
Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.
What Information of Mine Can I Access?
You can access certain information associated with your Account by logging into the Services or contacting us at [email protected]. You can also access and delete cookies through your web browser settings.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 137 Varick Street, 2nd Floor, New York, NY 10013.
How Can I Delete My Account?
Should you ever wish to delete your Account, please contact your employer.
What Choices Do I Have Regarding My Information?
- You can request that your employer deletes your Account. If your employer deletes your Account, it would limit the use and disclosure of your Personal Data, and. any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any activity on your Account prior to deletion will remain stored on our servers and will remain accessible.
- You can opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our features.
- You may manage the sharing of certain Personal Data when you register with us through a Third Party Service, such as by using your Google Apps account login credentials. Please refer to the privacy settings of the Third Party Service to determine how you may adjust our permissions and manage the interactivity between the Services and the Third Party Service.
- You can opt-out of certain cookies and tracking technologies by following the steps set forth in the section titled “IP Address Information and Other Information Collected Automatically” above.
- Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. The Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Services and after you leave our properties. This is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties react when you set this signal on your browser.
- You can contact us at [email protected] if you have any other questions about access to, or correction or deletion of, your Personal Data.
What If I Have Questions, Concerns or Complaints?
If you have any questions or concerns regarding privacy using the Services or about the Privacy Shield, please send us a detailed message to [email protected], and we will make every effort to resolve your concerns.
If you are located in the EU, you can also contact us through our Data Protection Officer:
Data Protection Officer
shlomo at intello.io
137 Varick Street, 2nd Floor
New York, NY 10013
Effective Date: July 29th, 2018