InAuth, Inc. (InAuth) is committed to protecting your privacy. This Privacy Policy applies to activities directly related to your visit to the InAuth website. This statement does not describe InAuth’s treatment of consumer data provided by our clients that is described in the Client Data Privacy Statement. It does not apply to third parties’ websites linked through InAuth’s website. We strongly recommend that you read these third parties’ privacy policies prior to providing any information to such sites. InAuth has no responsibility or liability in connection with any third parties’ websites.

InAuth also has a registered branch office in England, which adheres to all aspects of this Privacy Statement, including the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

COLLECTION, USE AND TRANSFER OF YOUR INFORMATION

You can visit portions of the InAuth site without disclosing your personally identifiable information (personal data). However, you may choose to provide us with your personal data, for example when you contact us, register for seminars, activities and programs available on our website, seek employment or when you request information or services. You also may decide to provide us voluntarily with personal data of a third person, such as your colleague or coworker. In such case, we assume that you have the unrestricted permission of such person to provide his/her personal data to InAuth. InAuth may use third-party suppliers to collect, process, store, use, analyze and/or transfer the data on its behalf. In such cases, it is InAuth’s practice to require that these suppliers handle the personal data they process or transfer in a manner consistent with InAuth’s policies. By submitting the personal data to us, you acknowledge and agree with your data being processed and/or transferred on InAuth’s behalf by its suppliers. InAuth will handle the information we learn from you from your visit to our website in the following manner:

IF YOU VISIT OUR SITE TO READ OR DOWNLOAD INFORMATION, SUCH AS NEWS, PRODUCT INFORMATION, CASE STUDIES OR ARTICLES

We may collect, process or transfer the following information about you: the name of the domain from which you access the Internet; the date and time you access our site; and the Internet address of the website from which you linked directly to our site. We use the information we collect to measure the number of visitors to the different sections of our site, and to help us make our site more useful to visitors. We may transfer the information we collect to our corporate affiliates. We may use “cookies” and/or technologies to collect non-personally identifiable information from your visits to our website and your browser sessions to enhance your overall site experience and for statistical purposes. You can set your browser to turn off “cookies” or to warn you when a website attempts to place a “cookie” on your computer. However, if you turn off the “cookies,” our and other websites may not work as intended.

IF YOU SUBMIT PERSONAL DATA WHEN VISITING AN INAUTH WEBSITE

We may collect, process or transfer the specific information you voluntarily provide to us in accessing the client portal or in the contact form you choose to fill in on our website, including the personal data you provide. By submitting any personal data on InAuth’s site, you authorize InAuth to use, process and transfer (if necessary across national borders) such data, even in and to countries where the level of data protection may not be commensurate with the high standard of protection adopted by certain countries, such as the standard suggested by the EU General Data Protection Regulation (GDPR) or the Swiss Federal Data Protection Act.  InAuth will still handle your personal data in the manner described in this Privacy Policy. InAuth will not sell personal data to third parties; however your personal data may be automatically transferred to any successor to substantially all of the assets and business of InAuth, or we may transfer the information to our corporate affiliates.  Also, InAuth may transfer your personal data to third party business partners to help develop and market programs, products or services and present targeted content including, to conduct analysis and research about website and app users; or to place ads (including ads of our business partners) on various websites and apps, and to analyze the effectiveness of those ads.

IF YOU ARE A CLIENT, OR ARE PART OF A CLIENT ORGANIZATION, OR ARE A SUBCONTRACTOR

Personal data you provide to InAuth, including personal data of a third party, such as your spouse, colleague and friend may be collected, stored, used and transferred as necessary for InAuth and our corporate affiliates to carry out business or seek potential business in the future with your company. If you provide us with personal data, whether in the form of an e-mail, business card, verbally during business meeting or otherwise, we assume that you have granted us a permission to collect, store, use and transfer such information with no limitations even in and to countries where the level of data protection may not be commensurate with the high standard of protection adopted by certain countries, such as the standard suggested by the EU General Data Protection Regulation (GDPR) or the Swiss Federal Data Protection Act. We also assume that you have unrestricted permission from the third party for the transfer of his or her personal data.

DISCLOSURES TO THIRD PARTIES

InAuth may share your personal data with third parties in the following limited circumstances: (1) personal information may be accessible to third-parties and service providers to develop and market programs and to process data on behalf of InAuth; however, any such third parties or service providers are required by contract to implement privacy and security safeguards consistent with this policy, including the EU-U.S. and Swiss-U.S. Privacy Shield; (2) We may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements; and (3) your personal information may be provided to a third party to the extent InAuth enters into a transaction for the acquisition of all or substantially all of InAuth’s assets. InAuth faces potential liability when we onward transfer to third parties.  InAuth’s accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles set forth by the U.S. Department of Commerce.  InAuth remains responsible and liable under the Privacy Shield Principles if third-parties that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless InAuth proves that we are not responsible for the event giving rise to the damage.

SENSITIVE PERSONAL INFORMATION

InAuth will not generally collect, process or transfer sensitive personal data through its site, unless you expressly consent with such collection, processing or transfer. “Sensitive personal data” for the purposes of this InAuth Privacy Policy shall mean data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life.

ACCESS, CHOICE, CORRECTION AND DELETION OF PERSONAL DATA

InAuth acknowledges your right to request that the personal data you provided to us is accurate and up to date by contacting InAuth directly at the contact information noted below. We will honor your choice and refrain from sending you such announcements. You may change your choice at any time. To update or delete your data or correct an inaccuracy, we may ask you to verify your identity and cooperate with us in our effort.

E-mail:

legal@inauth.com (put “Privacy Compliance” in subject line)

Mailing address:

Legal/Privacy Compliance

InAuth, Inc.

376 Boylston Street, Suite 501

Boston, MA, 02116 USA

Telephone:

+1 (855) 801-0774 (ask for Legal/Privacy Compliance)

CHOICE, OPT OUT OF PERSONAL DATA

Data subjects who have provided data to InAuth for marketing purposes have the right under the Privacy Shield Framework to opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

They may limit the use and disclosure of their personal information by selecting the opt-out option within marketing communications or by contacting InAuth’s marketing department directly at the contact information noted below:

Mailing address:

Marketing

InAuth, Inc.

376 Boylston Street, Suite 501

Boston, MA 02116 USA

Telephone:

+1 (855) 801-0774 (ask for Marketing)

EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS

InAuth complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield.  InAuth has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

PRIVACY COMPLAINTS BY EUROPEAN UNION (EU) OR SWISS INDIVIDUALS

EU & Swiss Individuals:

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, InAuth commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield.  European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact InAuth at the contact information noted below:

E-mail:

legal@inauth.com (put “Privacy Compliance” in subject line)

Mailing address:

Legal/Privacy Compliance

InAuth, Inc.

376 Boylston Street, Suite 501

Boston, MA, 02116 USA

Telephone:

+1 (855) 801-0774 (ask for Legal/Privacy Compliance)

InAuth has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

ENFORCEMENT

InAuth has implemented internal mechanisms to verify ongoing adherence to this policy. We periodically verify that this policy remains accurate, comprehensive for its intended purpose, and is accessible in accordance with applicable law. InAuth is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

AMENDMENTS

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. InAuth will post any revised policy on this website.

CONTACT FOR QUESTIONS

Any questions about the accuracy, use, processing or storage of data received by InAuth should be directed to legal@inauth.com.

SECURITY OF YOUR PERSONAL INFORMATION

InAuth uses various organizational and technical measures to protect your privacy and avoid unauthorized use or disclosure of your personal data. However, you should note that no transfer of data over the Internet is completely secure. While we use reasonable efforts to protect your data on our systems, when the data is transferred over the Internet, it may be accessed and used by unauthorized third parties. InAuth has no control over the performance, reliability, availability or security of the Internet and does not warrant that any information transfer via the Internet or any communication through the Internet is secure. InAuth shall not be liable for any disclosure, unauthorized use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception, corruption, intervention, misuse or alteration of any personal information due to any action beyond InAuth’s reasonable control.

CHILDREN’S PERSONAL INFORMATION

www.inauth.com is a site not targeted to children and is not intended to collect personal data from children under age of 13. If you have questions regarding privacy of your personal information you submit to us through our website, please send an e-mail to legal@inauth.com.

EFFECTIVE DATE:  May1, 2018

NORTH AMERICA

Headquarters

376 Boylston Street, Suite 501
Boston, MA 02116
+1.855.801.0774

West Coast Office

227 Broadway, Suite 200
Santa Monica, CA 904011

EMEA

Belgrave House
76 Buckingham Palace Road
London, SW1W 9AX

LATIN AMERICA

Eje 5 Norte 990, Building C, 1st Floor
Santa Barbara, Mexico City 02230
+52 (55) 52097037

ASIA PACIFIC

Australia

Level 9, 12 Shelley Street
Sydney, NSW, Australia, 2000
+61 2 9152 2851

Level 14, 360 Collins Street
Melbourne, VIC, Australia 3000
+61 3 9152 2851

Singapore

Level 15, Marina Bay Financial Centre
Tower 1, Singapore 018940
+65 6317 6414