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 the people who visit our web sites and/or people who use INDATA as well as the information collected and/or registered by them in INDATA and services or systems directly associated by whom contracted the INDATA service. In accordance with the Law and its regulatory decrees, INFINITY TECH ADVISORY, LLC (hereinafter “INDATA”) adopts this policy of protection of personal data and privacy, which regulates the collection, storage, processing, protection and management of data that “INDATA” obtains from its customers (Subscribers) and interested parties, and other persons with whom INDATA has or comes to have any relationship of any nature.
INTERESTED
People who of their own free will contact us through our web sites, e-mail, telephone calls or other means, in order to request information about our products or services, evaluate possibilities of commercial alliances, provide INDATA. its products and services and, in short, evaluate the possibility of developing some kind of relationship with the company and/or service. In these cases the information requested is of a basic nature, such as information related to the identification of the person and company to which he/she belongs, position, e-mail, telephone, city, country and subject. Occasionally, 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 IP address.
SUBSCRIBERS
When a definitive commercial relationship is established, INDATA collects the necessary information to properly manage the relationship, in accordance with the parameters established in this policy and complying with all legal requirements.
DEMO SUBSCRIBERS
When a transitory commercial link is established for a short and defined period (usually 15 calendar days) in order for the potential Subscriber to test the operation of INDATA prior to its definitive commercial link (Subscription).
Hereinafter, when referring to Subscribers, it will refer indistinctly 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 to adapt it to industry practices. In that event, INDATA will announce on its website, or by other appropriate means, the introduction of such changes with due notice.
In this Policy, personal information means information relating to an identified or identifiable person. 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 purpose of providing the service that Subscribers have contracted for.
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 analytics service providers.
USER DATA
If you purchase licenses with inData, for each account/license created on our website we store your chosen user name, your email address and any additional personal information added to your user profile. You may view, edit or delete your personal information at any time. Administrators of the administrative website can also view and edit this information. Photos, videos and access to the device 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 logging into our App, they are sharing with us access to location data in format (longitude and latitude), travel speed, battery status, type of travel. This is sent every time you move or change position, as long as you have an open session from the app. Our app suggests the use of location sharing for some activities within the app, however it is not mandatory to do so.
DATA LOCATION DATA BACKGROUND
If the mobile user chooses to share their location in the background from the permissions when logging in from the mobile app, we would be collecting location information when traveling even if the app is closed or not using the indata app (this depends on the configuration of each device), all of the above as long as it is an open session. As for the location permission, you can withdraw your permission at any time by logging into the settings of your operating device and disabling 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, application version.
2. Usage analytics within the mobile app, i.e. the behavior that the user has within our app, we collect information from the modules used to improve the customization of the same.
3. USE OF PERSONAL DATA
INDATA treats personal data in an appropriate and secure manner, complying with all legal requirements. The information collected on Subscribers and interested parties is used, under their authorization, for the following purposes:
1. Verification / identification of the subscriber during the use of the website and mobile.
2. Send updates to our admin users with important information for upgrades and releases.
3. Ensure that overall performance and administrative functions run smoothly.
4. Tracking of location positioning of mobile users by administrators in order to assist remotely.
5. Facial verification of collaborators of the accounts created within the INDATA system.
6. To take the necessary steps to comply with the obligations inherent to the contracted services.
7. To carry out marketing, promotion, advertising, purchasing, invoicing, billing, collection, payment, service and product improvements, 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 enabled for this purpose.
The data will never be public, it is only used by INDATA team members and subscriber type administrators of your account, we use your data to operate and maintain our optimal services, to understand user usage behavior to customize services, offer new features or services of our platform.
We also use mobile application analytics software in order to better understand the functionality of our mobile application 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 you submit within the mobile application.
CHILDREN’S PERSONAL INFORMATION
INDATA expects the information provided to be truthful. INDATA does not accept or process information and data from children 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 may be accessed by:
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 the information about customers’ accounts and access.
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 discloses your personal information such as email address, 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 registered 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. Administrators on the website can also view and edit that information.
Upon request, we will provide you with information about whether we hold or process on behalf of a third party any personal information. To request this information, please contact us at [email protected]. Subscribers to our Services may update or change their account information by editing their profile or organization registration or by contacting [email protected]for more detailed instructions. To make a request to have personal information maintained by us returned or deleted, please send an email to [email protected].Requests to access, change or delete your information will be responded to within 30 days.
An individual seeking access to or seeking to correct, amend or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct his or her inquiry to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers to remove data, we will respond to your 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 upon 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 provide us with personal information in connection with your use of our Websites or services, we will delete this information upon your request, provided, however, that 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. MODIFICATIONS TO THIS POLICY***.
If you have questions or concerns about this policy, please send an email to [email protected].
