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Effective Date: March 19th, 2018
When Inavero receives personal information under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on Inavero's behalf, Inavero has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) Inavero is responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Inavero commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Inavero at:
[email protected]522 SW 5th Ave Suite 600Portland, OR 97204
Inavero commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner, as applicable and comply with the advice given by the panel and Commissioner with regard to data transferred from the EU and Switzerland.
The Federal Trade Commission has jurisdiction over Inavero’s compliance with the Privacy Shield. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Surveying Company and Survey Respondent
When you use Inavero, we collect information relating to you and your use of our services from a variety of sources.
Account information. When you register for an Inavero account, we collect your personal contact information (name, company, phone number, title, email, and a password).
Billing information. If you make a payment to Inavero, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment.
Device data. We collect data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics. Emails sent by Inavero or by users through our services may include page tags that allow the sender to collect information about who opened those emails and clicked on links within them. We do this to allow the email sender to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.
Referral data. If you arrive at an Inavero website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
Survey Respondent information. In order for us to send email survey invitations to potential survey respondents we must collect from you basic contact information, including email address, for all of the individuals you would like to send a survey to. You have the option to provide additional custom data for each individual, along with segmentation information. We don’t use any of this information for our own purposes or email them except at your direction.
Survey data. We store your survey data (questions and responses) for you.
Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
Generally, we use the information we collect from you in connection with providing our services to you and, on your behalf, to your survey respondents.
Provide our services. This includes providing you with customer support, which requires us to access your information to assist you.
Manage our services. We internally use your information, including certain survey data, for the following limited purposes:
Contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications since they are required to provide our services to you.
Contact you for marketing purposes. We will only do this if you have consented to Inavero contacting you for this purpose. You may opt out of these communications at any time by clicking on the “unsubscribe” link in them.
Respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
The only times we will disclose or share your personal information or survey data with a third party is under one of the circumstances identified below, we have obtained your express consent, or aggregated the information so that individuals or other entities cannot reasonably be identified by it. Where required by law, we will obtain your express consent prior to disclosing or sharing any personal information.
We may disclose:
Your email address to your organization. If the email address under which you’ve registered your account belongs to or is controlled by an organization, we may disclose that email address to that organization in order to help it understand who associated with that organization uses Inavero.
Aggregated or de-identified information to third parties to improve or promote our services. No individuals can reasonably be identified or linked to any part of the information we share with third parties to improve or promote our services.
Your information if required or permitted by law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
Your information if there’s a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between Inavero entities, you expressly consent to Inavero transferring your information to the new owner or successor entity so that we can continue providing our services. If required, Inavero will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
Rights to Collected Information
Update your account details. You can update your account information on your My Account page. Information is updated immediately.
Access and correct your personal information. As an account holder, you may access and correct certain personal information that Inavero holds about you by visiting your My Account page. Some account holders and other individuals (including those whose information we receive under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework) have certain legal rights to obtain information of whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. For some information, these rights may be exercised through the My Account page mentioned above, and in all cases, requests to exercise these rights may be directed to our customer support team. These rights are subject to some exceptions, such as where giving you access would have an unreasonable impact on the privacy of other individuals. We will respond to your request to exercise these rights within a reasonable time and, where required by law or where we deem it otherwise appropriate and practicable to do so, we will honor your request.
Download/backup your survey data. Depending on what subscription plan you have, we provide you with the ability to export, share and publish your survey data in a variety of formats. This allows you to create your own backups or conduct offline data analysis.
Delete your survey data. As long as you maintain an account with us, we may retain your deleted data for a limited time in case you delete something by accident and need to restore it (which you can request by contacting customer support). To the extent permitted by law, we will permanently delete your data if you request to cancel your account.
Cancel your account. To cancel and delete your account, please contact customer support. Deleting your account will cause all the survey data in the account to be permanently deleted from our systems within a reasonable time period, as permitted by law, and will disable your access to any other services that require a Inavero account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
Other Important Information
Security. Details about Inavero’s security practices are available in our Security Statement.
Data locations. Our servers are based in the United States, so your personal information will be hosted and processed by us in the United States.
Online Tracking. We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services (unless otherwise stated in a service-specific privacy statement).
Safety of Children and COPPA. Our services are not intended for and may not permissibly be used by individuals under the age of 13. Inavero does not knowingly collect personal data from persons under the age of 13 or allow them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
Additional Information for European Union Users
“Personal data”. For users located in the EU, references to “personal information” in this policy are equivalent to what is commonly referred to as “personal data” in the EU.
Accessing and correcting your personal data. You have the right to access and correct the personal information that Inavero holds about you. This right may be exercised by visiting your account’s My Account page or by contacting customer support.
Your responsibilities. By using our services, you agree to comply with applicable data protection requirements when collecting and using your survey data, such as requirements to inform respondents about the specific uses and disclosures of their data.
Consents. By using any Inavero service you expressly consent to the following:
Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, as with most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
Device data. We collect data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address. Your IP address will be linked to your survey responses.
Referral data. We record information about the source that referred you to a survey.
Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics.
Your email address. We collect your email address and basic contact information when the surveying company requests that we survey you on their behalf. We don’t use this to send you email except at the direction of a surveying company. The emails we send on behalf of a surveying company appear to come from that surveying company’s email address. If you no longer want to be contacted by a surveying company, please contact the surveying company directly or follow the unsubscribe link in the footer of the survey invitation email you received to opt-out of future surveys from the surveying company.
Providing survey responses is voluntary. You can always choose not to provide an answer to any given survey question.
Your survey responses are owned and managed by the surveying company, and we treat that information as private to the surveying company. Please contact the surveying company directly to understand how they will use your survey responses. Inavero does not sell survey responses to third parties and we do not use any contact details collected in our customers’ surveys to contact survey respondents.
We disclose your survey responses to surveying companies. We host surveys for surveying companies, but they are the primary curator of survey data. Anything you expressly disclose in your survey responses will be provided to them. Please contact the surveying company directly to understand how they might share your survey responses.
Contact the surveying company to access and correct your responses and personal information. Because we collect survey responses on behalf of surveying companies, you will need to contact the surveying company if you have any questions about the survey, or if you want to access, update, or delete anything in your responses. You may request access to and correction of the personal information we hold about you by contacting customer support, but in most cases Inavero cannot provide you with this access since survey responses are the surveying company’s private information and giving you access may have an unreasonable impact on the privacy of other individuals. We will respond to your request for access or correction within a reasonable time and, where reasonable and practicable to do so, we will provide access to your personal information in the manner requested by you.
Opt out of receiving surveys. You may opt out of receiving email invitations to take surveys which are sent by surveying companies via Inavero.
Safety of Children and COPPA. Our services are not intended for and may not permissibly be used by individuals under the age of 13. Inavero does not knowingly collect personal data from persons under 13 or allow them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
Accessing and correcting your personal data. You have the right to access and correct the personal information that Inavero holds about you. This right may be exercised by contacting [email protected]
Consents. By responding to a survey delivered to you by Inavero on behalf of a surveying company:
When a user accesses secured areas of our Sites, Secure Sockets Layer (SSL) technology protects user information using both server authentication and data encryption, ensuring that user data is safe, secure, and available only to authorized persons.
Inavero computer systems are hosted in a secure data center environment that uses a firewall, intrusion detection systems, and other advanced technology to prevent interference or access from outside intruders. The data center is a highly protected environment with several levels of physical access security and 24-hour surveillance.
However, no method of transmission over the Internet, or method of electronic storage, is perfectly secure. Therefore, we cannot guarantee absolute security. If Inavero learns of a security systems breach that affects certain users, then we will attempt to notify those users electronically so that they can take appropriate protective steps.