PERSONAL DATA PROTECTION AND PRIVACY POLICY
Effective as of Tuesday, March 15, 2020
1. INTRODUCTION
This policy details our commitment to protect the privacy of people who visit our websites and/or people who use INDATA, as well as the information collected and/or recorded by them in INDATA and services or systems directly associated with those who contracted the INDATA service. In accordance with the Law and its regulatory decrees, INFINITY TECH ADVISORY, LLC (hereinafter “INDATA”) adopts this personal data protection and privacy policy, which regulates the collection, storage, treatment, protection and administration of the data that “INDATA” obtains from its clients (Subscribers) and interested parties, and other people with whom INDATA has or may have a relationship of any nature.
INTERESTED
People who, of their own volition, contact us through our websites, email, telephone calls or other means, in order to request information about our products or services, evaluate possibilities of commercial alliances, and provide INDATA. its products and services and finally, evaluate the possibility of developing some type of relationship with the company and/or service. In these cases, the information requested is of a basic nature, such as that related to the identification of the person and company to which it belongs, position, email, telephone, city, country and subject. Sometimes, when contacted through our website, our servers obtain, for statistical purposes, data regarding the operating system used by the person contacting us, the version and type of browser and the IP address.
SUBSCRIBERS
When a definitive commercial link is established, INDATA. collects the necessary information to adequately manage the relationship, in accordance with the parameters established in this policy and complying with all legal requirements.
DEMO SUBSCRIBERS
When a temporary commercial link is established and for a short and defined period (Generally 15 calendar days) in order for the potential Subscriber to test the operation of INDATA before its definitive commercial link (Subscription). From now on, when referring to Subscribers, it will refer interchangeably to Subscribers or Demo Subscribers.
2. DATA COLLECTED
DATA STORAGE
INDATA may modify this policy in order to adapt it to changes in current legislation and jurisprudence and adapt it to industry practices. In that event, it will announce on its website, or by other appropriate means, the introduction of such changes with due advance notice.
In this Policy, personal information means information relating to an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, in a particular way by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity. The use of information collected through our Service will be limited to the purposes of providing the service for which Subscribers contracted.
We collect analytical information when you use the Websites to help us improve them. We may also share anonymous data about your actions on our Websites with third-party analyst service providers.
USER DATA
If you purchase licenses with inData, for each account/license created on our website we store your chosen username, your email address and any additional personal information added to your user profile. You can view, edit or delete your personal information at any time. Administrative website administrators can also view and edit this information. Photos, videos and access to the device’s gallery is also a permission requested from our app. By accepting them, the application will have access to these device resources.
LOCATION DATA
If the mobile user chooses to share their location from the permissions requested when entering our App, they are sharing with us access to location data in format (longitude and latitude), movement speed, battery status, type of movement. This is sent every time you move or change position, as long as you have a session open from the app. Our app suggests the use of position sharing for some activities within the app, however it is not mandatory to do so.
BACKGROUND LOCATION DATA
If the mobile user chooses to share their location in the background from the permissions when they log in from the mobile app, we would be collecting information about their location when they move even if the app is closed or they are not using the indata app (this depends on the configuration of each device), all of the above as long as there is an open session. Regarding location permission, you can withdraw your permission at any time by going into the settings of your operating device and turning off background sharing.
DEVICE DATA
We also collect additional data when the mobile user uses our app.
1. Device information, device model and name, operating system, operating system version, wireless network, signal strength, device name, app version.
2. Usage analytics within the mobile app, that is, the behavior that the user has within our app, we collect information from the modules used to improve their customization.
3. USE OF PERSONAL DATA
INDATA processes personal data appropriately and securely, complying with all legal requirements. The information collected about Subscribers and interested parties is used, under their authorization, for the following purposes:
1. Subscriber verification/identification during website and mobile usage.
2. Send updates to our admin users with important information for updates and releases.
3. Ensure overall performance and administrative functions run smoothly.
4. Location positioning tracking of mobile users by administrators in order to assist remotely.
5. Facial verification of collaborators of accounts created within the INDATA system.
6. Carry out the necessary steps to comply with the obligations inherent to the contracted services.
7. Carry out marketing activities, promotion, advertising, purchases, billing, collection, collection, payments, improvements in the service and product, consultations, controls, verifications, alliances, agreements, as well as any other activity related to our current and future services.
8. Evaluate the quality of our services and the level of satisfaction of our Subscribers, demo subscribers and interested parties, through satisfaction surveys and other mechanisms that are enabled for the purpose.
The data will never be public, they are only used by members of the INDATA team and subscriber administrators of their account. We use your data to operate and maintain our optimal services, to understand the usage behavior of users and thus personalize the services, offer new features or services of our platform.
We also use mobile app analytics software to better understand the functionality of our mobile app on your device. This software may record information such as how often you use the mobile application, events that occur within the mobile application, average usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
PERSONAL INFORMATION OF CHILDREN
INDATA expects that the information provided to it is true. It does not accept or process information and data from minors under 14 years of age that have not been collected with the consent of parents or legal representatives.
4. WHO HAS ACCESS TO YOUR DATA
If you are not a registered or licensed customer on our site, there is no personal information that we may retain. If you are a customer with a purchased account or license, your personal information can be accessed through:
1. Our administrators and system development team, through audit logs of web and mobile system behaviors.
2.Our collaborators when (to provide support) they need to obtain information about customer accounts and access.
3. System account administrator type subscribers. We will never share your location with others except with your consent or as permitted by this Privacy Policy.
5. THIRD PARTY ACCESS TO YOUR DATA
We do not share your data with third parties in a way that reveals your personal information such as email, name, etc. The only exceptions to that rule with whom we have to share limited data are system administrators or external providers who help us with different issues related to the service and quality of the platform.
6. HOW LONG WE KEEP YOUR DATA
Once you register on our platform, we also store the personal information you provide in your user profile. You can view, edit or delete your personal information at any time. Web administrators can also view and edit that information.
Upon request, we will provide you with information about whether we hold or process any personal information on behalf of a third party. To request this information, contact us at [email protected].co. Subscribers to our Services may update or change their account information by editing their profile or organization record or by contacting [email protected].co for more detailed instructions. To make a request for the personal information we hold to be returned or deleted, please send an email to [email protected].co. Requests to access, change or delete your information will be responded to within 30 days.
A person seeking access to, or attempting to correct, amend or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct their query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove data, we will respond to their request within thirty 30 days. We will retain personal information that we store and process on behalf of our Subscribers for as long as necessary to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information you submit to us during transmission and after receipt. If you have any questions about the security of your personal information, please contact us at [email protected]. If you are a Subscriber or you provide us with personal information in connection with your use of our Websites or services, we will delete this information upon request, however this information may be retained for as long as you maintain an account for our Services or as necessary to provide you with our Services, comply with our legal obligations, resolve disputes, and enforce our agreements.
COMMERCIAL TRANSACTIONS
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets or with whom we merge.
7. MODIFICACIONES DE ESTA POLITICA***
If you have questions or concerns about this policy, please send an email to[email protected]