INASEC MIAMI, LLC
Effective Date: June ,2022
Personal information we collect
What personal information we collect depends on how you interact with our Services.
Information You Provide to Us
Account Information. When you create an Account, we will collect the personal information you provide to us, including but not limited to your name, email address, phone number, other social networking accounts, personal website, and picture.
Payment Information. We may sell services or through our software applications, website and other virtual mediums. When you make purchases through the Services, we may use a third-party application, such as the Apple App Store, Google Play App Store, Amazon App Store, and/or services such as third party’s to process your payments. These third-party applications may collect certain financial information from you to process a payment on behalf of INASEC, including your name, email address, mailing address, phone number, payment card information, and other billing information. INASEC does not store or receive your payment information, but it may store and receive information associated with your payment information (e.g., your billing details).
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us.
Use of the Services. We collect information you provide to INASEC related to the Services for the purpose of providing the Services to you, which may require personal information.
Customer Service, Training and Quality Assurance. If you call or otherwise interact with INASEC’s sales, customer service or support personnel, we may collect the information you provide to our representatives. In addition, we may record telephone calls or video conferences between you and our representatives for training or quality assurance purposes.
Sweepstakes, Contests, Surveys and Events. We may run sweepstakes or contests, ask you to complete surveys, and host or attend events. In each case, you may provide information to us, or we may receive information about you. In such situations, we shall use the information for the purposes for which it was collected.
Information collected automatically
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (inferred based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and information about how you interact with and use the Services.
We may use a visitor’s IP address to ﬁght spam, malware and identity theft. With your permission, we may also collect information about your operating system’s installed fonts in connection with providing the Services to you. Combined with other system information, this information could be used to give your computer a unique ﬁngerprint/signature and enable us to track your usage of our Services after you log out.
Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may also use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about how Google uses data, please visit www.google.com/policies/privacy. You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by going to http://tools.google.com.
How we use your information
We use your personal information for a variety of business purposes, including:
To Provide the Services or Information Requested, such as:
- Managing your information and account;
- Responding to questions, comments, and other requests;
- Processing payment card and/or other financial information to facilitate your use of the Services;
- Providing access to certain areas, functionalities, and features of our Services; and
- Answering requests for customer or technical support.
Administrative Purposes, such as:
Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities that allow you to share content. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, industry analysis, analytics, and any other legally permissible purposes.
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site and application behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed; Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.
Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and we may match the information of the browser and devices that appear to be used by the same person.
Disclosing your information
to third parties
We may share any personal information we collect with the following categories of third parties: Other Users of INASEC’s Services. When you use the Services, we will share certain information with other users.
For Collaboration. You can create content, create your own bracelets and accessories, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you comment, we display your profile picture, your accessory profile, and name next to your comments so that other users with access to the comment understand who made it. Similarly, when you join a community, your name, profile picture and contact information will be displayed in a list for other team members so they can find and interact with you. Please be aware that some content can be published or otherwise made publicly available, including information about you, can be publicly viewed and indexed by and returned in search results of search engines. You can check the settings at any time to confirm whether particular content is public or private. In addition, in connection with your posting of content, we will share your picture, name, user handle, and Twitter (or other social networking site) handle (to the extent you have provided us with this information). We are not responsible for privacy practices of the other users who may view and use the posted information.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Your Organization. If you access the Services on behalf of an organization, we may share your information with that organization at its request.
Third-Party Platforms and Services. We will share your personal information with third-party platforms and/or services if you have expressly consented or requested that we do so. Please note we do not endorse, screen or approve, and are not responsible for, the practices or conduct of such third-party services.
Affiliates. We may share personal information with our affiliated entities.
Advertising Partners. Through our Services, we may allow third-party advertising partners and ambassadors to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we have associated with you if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to enforce INASEC’s policies and contracts; (iv) to collect amounts owed to us; (v) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
International data transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
E.U. - U.S. Privacy Shield and Swiss - U.S. Privacy Shield
INASEC relies on Standard Contractual Clauses for the transfer of personal data. In addition, INASEC continues to comply with the E.U. – U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.
INASEC is responsible for onward transfers to our agents under the Privacy Shield Framework. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, INASEC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
If you have any questions or concerns related to our Privacy Shield certification or to resolve any complaints about our collection or use of your personal information, you should first contact us using the information set forth below.
INASEC has further committed to refer unresolved complaints related to personal information to JAMS Privacy Shield Dispute Resolution Program, an independent dispute resolution provider located in the United States made available free of charge. For more information or to submit a complaint visit: https://www.jamsadr.com/eu-us-privacy-shield.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution options do not satisfactorily resolve your concerns.
General. You may have the right to opt out of certain uses of your personal information.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Note: Please note you must separately opt out in each browser and on each device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to DNT signals or similar mechanisms transmitted by web browsers.
Your privacy rights
In accordance with applicable law, you may have the right to:
Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”); Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information; Request Deletion of your personal information; Request Restriction of or Object to our processing of your personal information; and
Withdraw your Consent to our processing of your personal information. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
Please note that if you use our Services on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the individual rights requests referenced above.
Security of your information
By using the Services 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 Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
Supplemental notice for California residents
INASEC collects the following Categories of Personal Information:
Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, address, telephone number or employment. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
Commercial information: Records of products or services purchased or obtained from INASEC.
Internet or other electronic network activity: Information on a consumer’s interaction with websites, applications, or advertisements related to the Services.
Geolocation data: Physical location.
Sensory data: Audio, electronic, visual, or similar information.
Inferences drawn from other personal information to create a profile about a consumer: Profile reflecting a consumer’s preferences or characteristics as they relate to the Services.
INASEC Discloses to the following Categories of Third Parties for a Business Purpose:
- Advertising networks
- Internet service providers
- Data analytics providers
- Operating systems and platforms
- Social networks
- Service providers
- Sales of Personal Information under the California Consumer Protection Act (“CCPA”)
As defined by the California Consumer Protection Act (“CCPA”) CCPA, INASEC does not sell personal information of California residents, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age.
ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the California Consumer Privacy Act (“CCPA”).
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth below.
Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to log in to your account or verify your email address.
If you are a California resident and would like to exercise any of your rights under the California Consumer Privacy Act (“CCPA”), please contact us as set forth below. We will process such requests in accordance with applicable laws.
Supplemental notice for Nevada residents
If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise your right by contacting us as described below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. As defined by Nevada Revised Statutes Chapter 603A, we do not currently sell Personal Information of Nevada residents.
The Services are not directed to children under 13, and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law, including but not limited to the GDPR.