Definitions

• “Account” means the Intelitics account you may be required to register with Intelitics in order to use the Services.
• “App” means Intelitics’ mobile application.

•  “General Information” means general non-personal information we may collect from your use of the Services and/or which you provide to us, such as our approximate location which may be derived from your IP address and through your use of the App, your visit to the Site, such as pages viewed, links clicked and other similar navigation action in connection with the Site, certain information about your mobile device, for example, advertising identifiers, the hardware model, operating system, software and file names, preferred language, unique device identifier, serial number, device motion information, and mobile network information; and certain standard browser information, such as your browser type, IP address, access times, and App usage data.

• “Intelitics”, “we”, “us” and “our” means Intelitics, Inc.

•  “Personally Identifiable Information” means personally identifiable information you provide to us which can readily identify you, such as, your name, your company name, your e-mail address, and your Phone Number.

• “Services” means Intelitics’ tracking, reporting and analytics platform, including the Software, the App, all related data, content and related documentation, information and services provided by Intelitics.
• “Software” means Intelitics’ proprietary software, as updated or upgraded from time-to-time and including any third party software made available in conjunction with such software.
• “User Agreement” means that certain user agreement between you and Intelitics, which can be found at http://www.intelitics/userAgreement.html and incorporated herein by reference.
• “you”, “your”, and “yours” means a user of the Services.

What is Covered in this Policy? This Data Security and Policy (the “Policy”) covers our treatment of Personally Identifiable Information and General Information that we gather when you access and/or use any part of the Services.  This Policy also covers information we may share with our business partners, but does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Security of Your Personally Identifiable Information. Personally Identifiable Information is securely stored within our database, and we use standard, industry-wide practices such as firewalls, encryption, and (in certain areas) Secure Socket Layers (“SSL”) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to Intelitics over the Internet.  We recommend that you not disclose your password to anyone.

Information Security Practices.  We agree to take and maintain all appropriate technical, administrative and organizational measures required to ensure a level of confidentiality and security appropriate to the risks represented by the processing and the nature of such Personally Identifiable Information, and to prevent unauthorized or unlawful processing of Personally Identifiable Information.  In the event of a breach or suspected breach of security of any system, website, database, equipment or storage medium or facility that results or could reasonably result in unauthorized access to Personally Identifiable Information by any unauthorized third party, we will notify you as promptly as is reasonably possible under the circumstances and make commercially reasonable efforts to secure our systems promptly.  We will provide reasonable cooperation to you and any applicable government agency in investigating and resolving any such security incident.

Collection of Your Information.   When you register for an Account, you can do so by (1) providing certain Personally Identifiable Information, or (2) by allowing us to access your name and other profile information through existing accounts you may have on sites such as Google or LinkedIn (collectively, the “Account Websites”, and each of your profiles on such Account Websites, an “Account Profile”).    You agree to give us current, complete, truthful and accurate information, including Personally Identifiable Information, and to keep such information up to date.  We will not be responsible for any problems or liability related to inaccurate or incomplete Personally Identifiable Information, whether due to your failure to update such Personally Identifiable Information or otherwise.  If you register for an Account through the use of an Account Profile, you will not be required to directly provide us with any Personally Identifiable Information as we use the information you have already provided to the Account Website in registering for an account with such Account Website and which you have allowed the Account Website to share with us, including, but not limited to, your first name, your Account Website user profile picture, and the networks to which you belong.

In addition to Personally Identifiable Information, we may collect General Information and, if you use or access the Services, you expressly authorize us to collect and use your Personally Identifiable Information and General Information in connection with the Services. You further acknowledge and agree that we may, but are not obligated to, maintain copies of your Personally Identifiable Information and General Information indefinitely, or delete any or all such information, at our sole discretion. When you receive promotional e-mails or newsletters from us, if any, we may use customized links or similar technologies to determine whether such newsletters or e-mail has been opened and which links you click. This information is used to provide you more focused e-mail communications and/or other information.

Use of Your Information.

1. General.  We collect and use your Personally Identifiable Information and General Information to operate and improve the Services and better deliver the Services. These uses may include performing analysis aimed at improving the Service; making the Services more user friendly by reducing the need for you to repeatedly enter the same information; and displaying advertising and content that are tailored to your preferences and interests.   We are headquartered in the United States of America. Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By providing us with your information, you consent to this transfer. We will protect the privacy and security of Personally Identifiable Information and General Information according to our Policy, regardless of where it is processed or stored.
2. Account Profile.  If you registered for an Account through an Account Profile, we will not knowingly use, display, or share any of your information in a manner inconsistent with the privacy settings and policies of the Account Websites (collectively, the “Account Policies”) which you registered through.  However, we advise you to carefully read and understand the terms of use and Account Policies that you access the Services through as it is your responsibility to read and accept the respective Account Policies prior to accessing and using the Services.
3. Advertising and Notices.  We may support the Service by advertising, and accordingly, we may use some of the information collected in order to customize the advertisements to your interests and preferences. However, the process of selecting customized ads tailored to you will use data that does not personally identify you, such as using demographic data such as ZIP code.  We may also use your Personally Identifiable Information and General Information to communicate with you, such as providing you with mandatory notices or discretionary notices about the Service.  From time to time, we may also send you surveys or promotional mailings to inform you of other products or services available from us and our affiliates.
4. Aggregated Data.  You understand and agree that we may, from time to time, use and disclose any information, content or data you provide to us or that we collect from you during your use of the Services in an aggregated and anonymized form (i.e., the aggregated data will not personally identify you or any other user in any way).

Disclosing of Your Personally Identifiable Information to Third Parties

1. General.  Except as described in this Policy, we do not sell, rent, lease or disclose your Personally Identifiable Information without your consent, and your Personally Identifiable Information will be used only by us and our controlled subsidiaries and affiliates. By accessing your Account, you may choose to share your Personally Identifiable Information with our select partners so that they can contact you about their respective products, services or offers.
2. Third Party Services.  We may hire other companies to provide limited administrative and communication services on our behalf, such as hosting Sites, the processing and delivery of mailings, providing customer support, or providing credit card processing services (if applicable). We have the right to disclose your Personally Identifiable Information to these third party companies for the purpose of administering and maintaining the Services’ features, functions and operations. Those companies will be permitted to obtain only such Personally Identifiable Information as necessary for them to deliver the respective services, and we do not authorize these companies to use your Personally Identifiable Information except for the sole purpose of providing those services requested by Intelitics.
3. Disclosures.  You understand and agree that we may access and/or disclose Personally Identifiable Information and General Information about you or your Account without your prior consent if we have a good faith belief that such action is necessary to:
   • Comply with legal process or other legal requirements of any governmental authority;
   • Protect and defend the rights or property of Intelitics (including the enforcement of our agreements);
   • Enforce the User Agreement;
   • Operate or conduct maintenance and repair of the Site, the App or equipment as authorized by law;
   • Act in urgent circumstances to protect the personal safety of Users or members of the public; or
   • Comply with a bankruptcy, merger, acquisition, transfer of control, joint venture of other business combination.

We are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive. In some cases, we may choose to buy or sell assets. In these types of transactions, User information is typically one of the business assets that is transferred. Moreover, if we, or substantially all of our assets, weve acquired, 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 Intelitics may continue to use your Personally Identifiable Information and General Information as set forth in this Policy.

Information Collected Automatically. We may receive and store certain types of information whenever you interact with the Site, the App and/or Service. We may choose to automatically receive and record information on our server logs from your browser including your IP address, cookie information, and the page you requested. We use “cookies” to collect non-personal data and information. Cookies are small text files a website uses to recognize repeat users, and is typically placed on your hard disk by a web page server.  Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. The way cookies function is by assigning a number to the user that has no meaning outside of the assigning website. You should be aware that we cannot control the use of cookies (or the resulting information) by our third-party partners or advertisers. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Services that depend on cookies.

Third Party Analytics.  We may use third party analytics providers and products to obtain, compile and analyze General Information about how Users are using and interacting with Intelitics and/or the Services. We may provide General Information to these analytics providers for the purpose of obtaining statistics and other information about how Users are using and interacting with Intelitics. These analytics providers may use a variety of established or new tracking technologies or tools (including, without limitation, cookies, web beacons, HTTP cache, local shared objects and persistent identifiers) to recognize your computer or device and/or to collect or compile this information. We have no control over the technologies, tools or practices of the third parties that providing analytics products and services to Intelitics.

Collection and Use of Children’s Personally Identifiable Information. The Services are intended for general audiences, and we do not knowingly collect any Personally Identifiable Information from children.

E-mail Communications. Upon registration for an Account or using the Services provided, we may send you daily or weekly e-mails. If you do not want to receive e-mail or other mail from us, please notify us by e-mail at info@Intelitics.com and include sufficient information for us to identify your Account, including your name, email address and the specifics of your request. However, after you unsubscribe to cease receiving e-mails, we may still contact you via e-mail for administrative or informational purposes, including messages regarding the administration of your Account and/or any services or events to which you have registered.

Advertisements Displayed by Third Parties. We may allow third-party ad serving companies, including ad networks, to display advertisements on the Site. Ad serving companies may place a persistent cookie on your computer in order to recognize your computer each time they display an online advertisement to you, and as such, they may be able to compile information over time about whether you reviewed or clicked on advertisements they display. These companies may use this information to display targeted advertisements and may associate this information with your subsequent visits, purchases or other activities on participating advertisers’ Sites. We have no access to or control over cookies of these links to other Sites and organizations, nor do we have control over or access to cookies by our third-party partners or advertisers. This Policy does not cover any use of Personally Identifiable Information that a third-party advertiser or ad server may collect from you.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.  By law we have to keep basic information about our customers for six years after they cease being customers. In some circumstances you can ask us to delete your data; see your legal rights below for further information. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

DATA SECURITY

Security — All records containing personal or financial information are considered to be our property and are afforded confidential treatment at all times. We work hard to protect against the unauthorized access, use, alteration or destruction of personal or financial information. All such electronic information is stored on restricted database servers, and is generally kept until such time as you may ask us to edit or delete it, as described below. We only disclose such information to our employees, contractors or affiliates that a) need to know that information in order to process it for us or to provide other services, and b) have agreed not to disclose it to others. All interactions with our Services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. We use a third-party, industry-accepted Payment Gateway to securely process credit card transactions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Integrity — In addition to assuring you that we will protect your personal information, we also want to make sure that it is reliable, accurate, and up-to-date. In order to do that, we provide:

Access — Upon request, we will provide you with reasonable access to the personal information we collect about you. Because personal information—for example, your email address—is required to use the Services, we retain personal information as long as your account is active. You will have the opportunity to correct, update, modify or delete this information updating your information in the Services. Please note that some information may remain in our records even after you request deletion of your information, to the extent permitted by the Privacy Shield Principles. Additionally, there may be limits to the amount of information we can practically provide. For example, we may limit an individual’s access to personal information where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where doing so would violate others’ rights.

Enforcement — We will conduct internal audits of our compliance with this privacy policy, including an annual self-assessment. Our employees take your privacy as seriously as we do, and we will take all reasonable measures against any employee found to be in violation of this policy.

If you have any concerns or complaints about how you think we’ve handled your personal information, please contact info@Intelitics.com or our Data Protection Officer at 2942 Century Pl, Costa Mesa, CA 92626
.

We will work hard to investigate and resolve any complaints you might have.

NOTICE TO CALIFORNIA RESIDENTS

Residents of the State of California may request a list of all third parties to which we have disclosed certain personal information (as defined by California law) during the preceding year for those third parties’ direct marketing purposes.  If you are a California resident and want such a list, please contact us at info@Intelitics.com.  For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state and zip code.  In the body of your request, please provide enough information for us to determine if this applies to you.  You need to attest to the fact that you are a California resident and provide a current California address for our response.  Please not that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

How we respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Intelitics, Inc. responds to “Do Not Track” browser settings.  Intelitics, Inc. does not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed.  We continue to review new technologies and may adopt a standard once one is created.

INTERNATIONAL TRANSFERS

If you are a resident of the European Economic Area (EEA), your personal data may be transferred outside the EEA.  Our offices are in the United States are your data is stored there.  Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.  Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that your data is given the same protection it has in the EEA.

LEGAL RIGHTS FOR EEA RESIDENTS

EEA Residents have the following rights under data protection laws:

• Request access to your personal data (commonly known as “data subject access request”).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o   If you want us to establish the data’s accuracy.

o   Where our use of the data is unlawful but you do not want us to erase it.

o   Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

o   You have objective to our use of your data but we need to verify whether you have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact info@Intelitics.com.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you further information in relation to your request to speed up our response.  We try to respond to all legitimate requests within one month.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

GDPR Compliance

Intelitics, Inc. serves as a data processor under GDPR, and adheres to the principles and rules of GDPR. Specifically, Intelitics, Inc. implements privacy by design and default principles, ensures limited data retention protocols, adheres to incident response norms, allows for appropriate third party audits, ensures data is only transferred internationally with a lawful basis, only contracts with subprocessors with adequate written commitments to data processing, respects data subject rights, does not process sensitive personal data, and provides data processing agreements to all appropriate clients and partners.