REVISED: January 23, 2019
“Personal Information” means any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
“Anonymous Information” means data that is not associated with or linked to Personal Information and that does not permit the identification of individual persons. We collect Personal Information and Anonymous Information, as described below.
With respect to Direct User data, business contact information, usage information we collect on our websites and in our platform and apps, Ingage is a controller. With respect to End User data added to the platform and apps by the Direct User, Ingage is a processor, handling the data on behalf our Direct Users
HOW WE COLLECT YOUR INFORMATION
Information You Provide.
We collect Personal Information from Direct Users when they register to use the Service, post content on the Service (such as in an Ingage App), or communicate with us (e.g., through the “Contact” page on our site, or when requesting customer service) or provide us with feedback about the Service. We may also collect Personal Information at other points in the Service when clearly identified.
We do not collect Personal Information directly from End Users unless they contact us (i.e., through the “Contact” page on our site or to provide feedback about the Service). Each individual operator of an Ingage App determines what End User information is required to operate their Ingage App, is required to comply with all applicable laws respecting the treatment of such information and is responsible for all use of such information. However, because Ingage Apps run on our infrastructure, the “Information Collected via Technology” section below applies equally to End Users and Direct Users with respect to Ingage.
Registration. To create an account, Direct Users need to provide a password and email address. Direct Users may provide other optional information and, if signing up for a paid account, will have to provide payment information to our third-party payment provider, subject to the terms below. Direct Users may always go to the “My account” section of the Service to update, change, or remove their information.
Ingage Apps. We do not collect or use End User Personal Information except to provide customer support, respond to direct requests, or as automatically collected through technical means as set forth below. As noted above, the operators of Ingage Apps may collect and use the information of End Users of their sites, including Personal Information and content posted to Ingage Apps. Ingage does not control or monitor such collection and usage.
Information Collected via Technology
Information Collected by Our Servers. To make the Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, data typed into the site, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, gather demographic information about our user base as a whole, and better tailor the Service to our users’ needs. For example, certain information may be collected so that when you visit the Service again, it will recognize you and remember preferences (such as progress in building Ingage content). Except as noted in this Policy, we do not link this automatically-collected data to Personal Information.
You can erase or block Cookies from your device if you wish to do so (your internet browser help screen or manual will thoroughly explain this process), but certain parts of the Service will not work correctly or at all if your browser is set not to accept Cookies. How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable you to opt out of tracking on our site.
Mobile Services. We may also collect non-personal information from your mobile device if you access the Service from your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location and information about the type of device you use. In addition, if Ingage crashes on your mobile device, we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of the service. This information is sent to us as aggregated information and cannot be used to identify an individual.
HOW INGAGE USES YOUR INFORMATION
Personal Information. In general, Personal Information you submit to us is used either to deliver the Service or respond to requests that you make. We use your Personal Information in the following ways:
facilitate the creation of and secure your account (Direct Users only);
identify you as a user of the Service;
provide improved administration of the Service;
improve the quality of experience when you interact with the Service;
send you administrative e-mail notifications, such as security or support and maintenance advisories (Direct Users only);
respond to your inquiries related to employment opportunities or other requests; and
send newsletters, surveys, offers, and other promotional materials related to the Service and for other marketing purposes of Ingage to users.
Anonymous Information. We may create Anonymous Information about both Direct Users and End Users by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Information to analyze request and usage patterns so that we may enhance the content of the Service. We may use Anonymous Information and aggregated and other de-identified information for any purpose and disclose Anonymous Information to third parties in our sole discretion.
HOW INGAGE MAY SHARE YOUR INFORMATION
Posting on the Service. You may be able to post content on the Service, including in public portions thereof. Any information included in public portions of the Service will be visible to others, and Ingage is not responsible for how others use such information. If you post Personal Information, even if you later remove it, other individuals who saw that Personal Information may retain copies of it through other means than the Service. We urge you to exercise discretion when posting content.
As Required By Law. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required by law or if those actions are reasonably necessary to:
comply with legal process, such as a court order or subpoena;
respond to claims that any content violates the rights of third parties;
respond to law enforcement or national security-related requests;
investigate and prevent unauthorized transactions or other illegal activities; or
protect our or others’ rights, property, or personal safety.
In the event of such disclosure or transfer of your Personal Information to public authorities, Ingage may not be able to require such public authorities to implement and maintain reasonable security controls to protect the confidentiality, integrity, and availability of your Personal Information.
Corporate Events. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction. We cannot control how such entities may use or disclose such information.
We may also disclose your Personal Information with your permission.
SECURITY OF YOUR INFORMATION
We have implemented and will maintain reasonable security controls to protect the confidentiality, integrity, and availability of the Personal Information that we process. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a breach of Personal Information, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at email@example.com.
INFORMATION ABOUT CHILDREN
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age. If you learn that a child has provided us with Personal Information, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information about children under 13, we will promptly take steps to delete such information.
If you are a non-U.S. user of the Service or visitor to an Ingage App, by providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
For any such transfers, we will require that any third parties who receive the data maintain at least the same level of confidentiality that we maintain for such Personal Information. Such third parties will also be required to maintain the confidentiality of all Personal Information that they process on our behalf and to implement and maintain reasonable security controls to protect the confidentiality, integrity and availability of such Personal Information. Ingage remains legally accountable for the protection of your Personal Information that we transfer to our third-party service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
ACCESS AND REVIEW
If you are a data subject about whom we store Personal Information, you may have a right to request access to, and the opportunity to update, correct, port, or delete such Personal Information. Under certain circumstances, you may have a right to restrict or object to the processing of your personal information. Requests should be sent to Ingage’s customer who provided your Personal Information to us, or to us directly by using the “My Account” tab of the Service or by sending an email to email@example.com.
We have limited rights to access Personal Information our customers provide to us. Therefore, if you contact us with a request outlined in the above paragraph, please provide the name of our customer who provided your Personal Information to us. We will forward your request to that customer and provide assistance, as needed, as they respond to your request.
Following the termination of your access to or use of the Service, Ingage will, subject to the requirements of applicable law or any governmental authority, promptly delete any of your Personal Information that it has in its possession.
CHANGES TO THIS POLICY
Any changes to this Policy will always be posted to this section of the website, along with the effective date of the updated Policy. You should check this page periodically to stay abreast of any such changes. Ingage will never make changes to the Policy that violate any applicable privacy laws. For any material changes to the Policy, we will notify Direct Users via email or by placing a prominent notice on the homepage of our website.
If you have any questions or suggestions regarding this Policy or any complaints or inquiries about our processing of your Personal Information, please write to Dean Curtis, Ingage’s Data Protection Officer, by email at firstname.lastname@example.org.
Ingage will respond promptly to any such complaints or inquiries, within a maximum of four weeks from the date on which we receive such complaint or inquiry.
VeraSafe has been appointed as Ingage’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Dean Curtis, Data Protection Officer for Ingage by emailing email@example.com, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative
Alternatively, VeraSafe can be contacted at:
VeraSafe Czech Republic s.r.o
Prague 1, 11002
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road