Effective Date November 25th, 2017
Privacy Shield Compliance
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, ITM is subject to the regulatory enforcement powers of the IT ACT. In certain situations, ITM, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our support team.
How Do We Collect, Use and Share Your Personal Information and Other Information?
We may collect the following personal information from you within the Websites:
- Contact Information, such as name, email address, mailing address, or phone number;
- Information about your business, such as company name, company size, business type
We may collect the following personal information from you when you use our Service(s):
- Contact Information, such as name, email address, mailing address, IP address, geographic location, or phone number;
- Billing Information, such as credit card number and billing address;
- Unique Identifiers, such as username, account number or password;
- Name and e-mail address when you provide feedback from the Service(s)
For new sales, in addition to the above, the following personal information about your contacts is collected from you:
- We collect your e-mail address through the Website in order to refer our Service(s).
For new sales, in addition to the above, the following personal information about your contacts is collected from you:
- In order to manage customer relationships, our customers may collect name, e-mail address, phone number, physical address, billing information, designation, company name of your contacts through the “import contacts” feature within the Service.
We may use the personal information collected from within the Websites or when you use the Service(s) to:
- Provide you with the Service(s).
- Send you communication from the Service(s).
- Assess the needs of your business to determine or suggest suitable products
- Send you requested product or service information
- Respond to customer service requests
- Administer your account
- Send you promotional and marketing communications
- Respond to your questions and concerns
- Facilitate your transactions with other users when you use our Service(s).
When you provide us with personal information about your contacts we will only use this information for the specific reason for which it is provided.
Except as outlined in this Policy, your information will never be sold to or shared with other companies or organizations for commercial purposes or otherwise. We may transfer personal information to our Group Companies and sub-contractors that help us provide our Service(s). Transfers to subsequent third parties are covered by the service agreements with our sub-contractors. Such sub-contractors may include third-party payment processors who process your credit card and other payment information for ITM but are otherwise not permitted to store, retain or use such information.
Correction or Removal of Personal Information
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org
ITM acknowledges that you have the right to access your personal information. ITM collects information on behalf of our customers, and has no direct relationship with the individuals with whom our customers may interact using the Service(s). If you are a customer of one of our customers (“End-Customer”) and would no longer like to be contacted by that customer, please contact the customer that you interact with directly. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the ITM’s customer (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
Other information such as End-Customer device models, IP address, usage patterns are also captured by the Service(s). This information is not used by ITM except in allowing you to view and use this information for targeting future communication with the End-Customers. Content and messages in voice, text or other format created by you or your End-Customers to send or share with other users or End-Customers shall be hosted on ITM’s servers.
Retention of Personal Information
We retain Personal Data we process for as long as an Account is active or as needed to provide the Service(s). If you wish to terminate your Account or request that we no longer use Your Data, please contact us at email@example.com. We will retain Your Data as necessary to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements. We delete all Your Data on the expiry of 14 days after the termination of your Account, except as otherwise prohibited by applicable law.
Processing Personal Information
We are the data processors and not the data controllers of the information on our platform for purposes of the EU Directive on Data Protection (Directive) and the Swiss Federal Act on Data Protection. Our EEA or Switzerland based customers, who control their customer data and send it to ITM for processing, are the “controllers” of that data and are responsible for compliance with the Directive. In particular, ITM’s customers are responsible for complying with the Directive and relevant data protection legislation in the relevant EEA member state before sending personal information to ITM for processing. We work with our customers to help them provide notice to their customers concerning the purpose for which personal information is collected.
We store and process data, including personal information, in the United States and the European Economic Area (“EEA”) and possibly in other countries through third parties that we use to operate and manage the Service(s). When you access or use our Websites or the Service(s), or otherwise provide information to us, you are consenting, on behalf of you and your authorized agents or End-Customers, (and representing that you have the authority to provide such consent) to the processing and transfer of information in and to the United States and other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. We may enter agreements with our customers located in the EEA to provide them access to our Service(s), which includes the processing of information relating the End-Customers.
We do not own, control or direct the use of the information stored or processed on our platform, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by our customers or as required by law.
It shall be our customers’ responsibility to inform the End-Customers about and obtain necessary consent for any personal information that is collected through our customer’s use of the Service(s). As the processors of personal information on behalf of our customers, we follow their instructions with respect to the information they control to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information as more fully described under the section below entitled, “Protection of Information”.
When you download, install and use our Mobile Applications, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”).
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We collect your location based information for the purpose of locating a place that you may be searching for in your area. We will only share this information with our mapping provider for the sole purpose of providing you this service.
You may opt-out of location based services at any time by editing the setting at the device level.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Application on your mobile or handheld device. This Mobile Application may record information such as how often you use the Mobile Application, the events that occur within the Mobile Application, aggregated usage, performance data, and where the Mobile 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.
ITM uses third party software for analytics. All metrics information collected from your usage of the Service(s) shall be transmitted to analytics provider. This information is then used to evaluate how users use ITM, and to compile statistical reports on activity for us. We further use the same statistical analytics tool to track or to collect your Personally Identifiable Information (PII). We will use this information in order to maintain, enhance, or add to the functionality of the Service(s) and to personalize the experience for you. Aggregated information and analysis may be made public where desired by ITM. Third party analytics software will not share your PII or associate your PII with any other data held by them.
Essential Cookies: These cookies are essential for the basic functionalities offered by the Service(s). These class of cookies helps in keeping a user logged in to the Service(s) and remember relevant information when they return to the Service(s). These cookies are essential for the basic functionalities offered by the Service(s). These class of cookies helps in keeping a user logged in to the Service(s) and remember relevant information when they return to the Service(s).
Insight Cookies: These are used for tracking the user activities within the Service(s), which in turn helps us in improving your user experience.
Marketing Cookies: These are used for providing you with customized and interest-based ads based on your browsing behaviour and other similar activities on our Websites.
Clear Gifs and Log Files
We and our third-party advertising partners use technologies such as web beacons in analysing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you.
Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
We partner with a third party to either display advertising on our Websites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by sending email to firstname.lastname@example.org sub as “No ads”
Social Media Features
Links to Third Party Sites
Our Websites contain links to other websites that are not owned or controlled by ITM. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects personal information.
Our Websites offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.
You can log in to our Websites using sign-in services such as Google, Facebook Connect and LinkedIn. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address. Services like Google, Facebook Connect, Twitter, LinkedIn give you the option to post information about your activities on our Websites to your profile page and to share information with others within your network.
Communications from the Websites
We may use your email address to send our newsletters and/or marketing communications. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive or by contacting us at firstname.lastname@example.org .
We will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.
Protection of Information
The Websites and Service(s) have industry standard security measures in place to protect against the loss, misuse, and alteration of the information under our control. When you provide us with sensitive information (such as credit card information or login credentials), we will encrypt that information via Secure Socket Layer (SSL).
While there is no such thing as “perfect security” on the Internet, we take all reasonable steps to ensure the safety of your personal information. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites or via the Service(s) and any transmission is at your own risk. Once we receive your personal information, we will use strict procedures and security features to try to prevent unauthorised access.
Additionally, you retain all rights of ownership to your personal data we collect. Except as set forth herein under sections elaborating on use of your personal information above and legal disclosure below we will not sell or share your personal data with any third parties or use your personal data to compete with you. Your privacy and the privacy of your customers are of utmost importance to us. If you have questions about our security you can contact us at email@example.com.
We post customer testimonials/comments/reviews on our Websites which may contain personal information. Prior to posting the testimonial, we obtain the customer's consent to post their name along with their testimonial. If you want your testimonial removed, please contact us at firstname.lastname@example.org.
Corrections and Updates
Upon request ITM will provide you with information about whether we hold, any of your personal information. To request this information please contact us at email@example.com.
We allow users of the Service(s) or Website to access, update or modify their information by clicking on the My Account link in the ITM navigation menu or by contacting us at firstname.lastname@example.org. We seek to respond to requests for access or modification as soon as possible and within reasonable timeframe.
Children's Personal Information
ITM does not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Websites or Service(s), please contact us and we will endeavor to delete that information and terminate the child's account from our databases.
Amendments to this Policy will be posted to this URL and will be effective when posted. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. Provided we will not be notifying you if we amend the Policy to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate. You should frequently visit this Policy to check for amendments. Your continued use of this Websites or the Service(s) following the posting of any amendment, modification, or change to this Policy shall constitute your acceptance of the amendments to this Policy. You can choose to discontinue use of the Websites or Service(s), if you do not accept the terms of this Policy, or any modified version of this Policy.
We reserve the right to disclose your personal data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Your personal data will also be shared between our Group Companies for the activities permitted under this Policy.
In the event ITM goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred. You will be notified via email@example.com and via a prominent notice on our Websites of any such change in ownership or control. We may also disclose your personal information to any other third party with your prior consent.