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Privacy Notice
This Privacy Notice (or “Notice”) describes the information that Ingenious Dataworks, Inc. (“Ingenious”, “our”, “we”, or “us”) may collect, use, and disclose about you when you visit our website www.PutDataFirst.com (“Website”); sign up or attend our events, webinars, and newsletters; register for a demonstration or trial of our product; use our on premise solution or one of our cloud hosted product offerings either as a Customer or as a limited user; and any other use of our product, platform, or applications (collectively, the “Services”).
Ingenious is committed to the responsible collection and use of Personal Information. This notice governs the collection, use, and disclosure of any Personal Information that is provided to us by Customers or users (“You”) as part of our Services.
If you have questions about anything in this notice, please contact us at privacy@PutDataFirst.com.
This notice covers our privacy practices on:
- Collection
- Use
- Disclosure
- Safeguarding Information
- Our Use of Information Technologies
- Managing Your Preferences
- Use of Services By Minors
- International Transfers
- Residents in the EEA, UK, and Switzerland
- US Data Privacy Laws
- Updates to this Notice
- Contact Us Information
Collection
Customers & Customer Data: Ingenious is a service provider/data processor for the companies that use our platform. We refer to such companies as “Ingenious Customers”, and to the content and information submitted by those companies as “Customer Data” in this Notice.
Where Ingenious collects or processes Customer Data, it generally does so on behalf of an Ingenious Customer. If you are using the Services by invitation or on behalf of a Customer (for example, your employer) that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Customer Data that may apply to your use of the Services. Please check with the Customer about the policies and settings it has in place.
Website, Demo Registration, & Events:
Ingenious may collect information from you when you join one of our virtual or in person events, or sign up for promotional newsletters. More details are below:
Use
We use your information for the following purposes, or as otherwise described to you at the time of collection. Customer Data: Ingenious may access and use Customer Data as reasonably necessary in accordance with the Customer’s instructions to:
Website, Demo Registration, & Events:
We may use the information we collect from our Website, Demo Registration, and Events in the following ways:
Disclosure
Ingenious does not rent or sell Personal Information. We only share information as described in this Notice under the following limited circumstances.
Customer Data: Ingenious may share Customer Data in accordance with our agreement with the Customer and the Customer’s instructions, including:
Website, Demo Registration, & Events:
Safeguarding Information
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. As a matter of policy, we do not disclose details regarding our security measures.
Be advised, no security safeguards or standards are guaranteed to provide 100% security. You should always use appropriate self-protection measures and practice safe browsing on all websites. For more information, the National Cybersecurity Alliance provides comprehensive information on how to Stay Safe Online.
Our Use of Information Technologies
The following section describes various types of technologies we use when you interact with us online and through our Services:
Facebook
Google
Preference Management
You may opt out of certain marketing communications, withdraw previously provided consent for posted testimonials, or choose not to share your information where required in the Services by using the following provided mechanisms:
Use of Our Services by Minors
International Transfers
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the services, you consent to the transfer of information to countries outside of your country of residence, including the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
EU-US Data Privacy Framework Principles & Privacy Notice
On July 10, 2023, the European Commission adopted its Implementing Decision of 10.7.2023 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate level of protection of personal data under the EU-US Data Privacy Framework (‘the Adequacy Decision’), which contains in its annex the EU-US Data Privacy Framework (‘DPF’). While discussions regarding possible replacement mechanisms are ongoing for the United Kingdom (including Gibraltar), and Switzerland, Ingenious will continue to protect European data according to the Principles of the EU-US DPF Framework and applicable EU, UK, and Swiss law.
Ingenious Dataworks, Inc. (“Ingenious” or “we”, “us”, or “our”) complies with the EU-U.S. Data Privacy Framework (EU-US DPF) and, as applicable, the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the U.S. Department of Commerce. Ingenious has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. Ingenious has certified to the U.S. Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF.
If there is any conflict between the terms in this Privacy Notice and the EU-US DPF Principles, the UK Extension to the EU-US DPF Principles, and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the Personal Information that we hold about you. You may also correct, amend, or delete the Personal Information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@PutDataFirst.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your 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. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@PutDataFirst.com.
Scope & Commitment. Our certification of adherence to the EU-US DPF and its Principles applies to the personal data that (a) we collect from our EU, UK, and Swiss customers and other visitors to our website for account management, billing, or marketing purposes (Ingenious user data”); and (b) we process on behalf of our EU, UK, and Swiss customers in providing online services to them under a service agreement (“Services Agreement”).
Data Collection & Use. The Ingenious user data that we collect, use, and share is described in our Privacy Notice. While our customers decide what services data to submit, it typically includes information about their own users and how they use the customer’s sites, applications, services, and third-party applications. We process services data as instructed by our customers and do not own or control Services Data.
Data Processing Purposes. We collect, use, and share Ingenious services data for the purposes described in our Privacy Notice. We process Services Data for the purpose of providing our online services to our customers, which may include accessing and processing the data to provide the services, to correct and address technical or service problems, to follow instructions of the customer who submitted the data, and/or to comply with contractual requirements.
Inquiries & Complaints. In compliance with the EU-US DPF Principles (and, as applicable, the UK Extension to the EU-US DPF and the Swiss-US DPF), Ingenious commits to resolve DPF Principles-related complaints about our collection and use of your personal information. Individuals from the EU, UK, and Switzerland with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF (and, as applicable, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF) should first contact Ingenious by email at privacy@PutDataFirst.com.
Ingenious Dataworks, Inc.
530 Technology Dr, Suite 100
Irvine, CA 92618
Attention: Chief Privacy Officer
Independent Recourse Mechanism. In compliance with the Data Privacy Framework Principles, Ingenious commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Ingenious by email at privacy@PutDataFirst.com.
Ingenious has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
Arbitration. If your DPF Principles-related complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for residual claims not resolved by any of the other DPF redress mechanisms. For additional information, please see ANNEX 1.
U.S. Federal Trade Commission Enforcement. The Federal Trade Commission has jurisdiction over Ingenious’ compliance with the EU-US DPF, and, as applicable, the UK Extension to the EU-US DPF, and the Swiss-US DPF.
Data Disclosures & Recipients. We share Ingenious services data with third parties as described in our Privacy Notice. We may share services data with third parties under the following circumstances and only in accordance with the applicable customer agreements:
- Service Providers. We may employ third party Service Providers and vendors to administer and provide the Services on our behalf (such as customer support, hosting, website analytics, email delivery, database management services). Ingenious’ accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Ingenious remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Ingenious proves that it is not responsible for the event giving rise to the damage.
- Affiliates. We may disclose services data to our subsidiaries and corporate affiliates for use consistent with this Privacy Notice. To view our current list of affiliates please visit: https://PutDataFirst.com/sub-processors/.
- Legal Requirements. We may disclose services data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency, or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the services, (d) to act in urgent circumstances to protect the personal safety of customers, their users or the public, or (e) to protect against legal liability.
- Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Services Data may be part of the transferred assets.
In addition, we may be required to disclose any personal data that we process in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Your Rights to Access, Limit Use, & Limit Disclosures. Individuals in the EU, UK, and Switzerland have rights to access personal data about them, and to limit use and disclosure of their personal data. With our EU-US DPF certification and, as applicable, the UK Extension to the EU-US DPF, and the Swiss-US DPF self-certification, we have committed to respect those rights.
If your personal data includes Ingenious personal data, you can request access to that data and request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF Principles by emailing your request to privacy@PutDataFirst.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
As stated above, if there is any conflict between the terms in this Privacy Notice and the EU-US DPF Principles, the UK Extension to the EU-US DPF Principles, and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Residents in the EEA, UK, & Switzerland
Personal Information: References to “Personal Information” in this Privacy Notice are equivalent to “Personal Data” governed by European data protection legislation.
EU Representative: For purposes of European data protection legislation, and except when acting as a processor on behalf of our Customers, Ingenious is the controller of your personal information covered by this Notice. You can contact us and our Data Protection Officer using the email listed below.
Email: privacy@PutDataFirst.com
UK Representative: For purposes of United Kingdom data protection legislation, and except when acting as a processor on behalf of our customers, Ingenious is the controller of your personal information covered by this Notice. You can contact us and our Data Protection Officer using the email listed below.
Email: privacy@PutDataFirst.com
Swiss Representative: For purposes of Swiss data protection legislation, and except when acting as a processor on behalf of our Customers, Ingenious is the controller of your personal information covered by this Notice. You can contact us and our Data Protection Officer using the email listed below.
Email: privacy@PutDataFirst.com
Legal bases for processing: We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@PutDataFirst.com.
Use for New Purposes: We may use your Personal Information for reasons not described in this Notice where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention: We will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the volume, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights: European data protection laws give you certain rights regarding your PersonalIinformation. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests to our postal address below:
Ingenious Dataworks, Inc.
530 Technology Dr, Suite 100
Irvine, CA 92618
Attention: Chief Privacy Officer
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
US Data Privacy Laws
Consumers who are also residents of either California, Colorado, Connecticut, Montana, Oregon, Texas, Virginia, or Utah may exercise certain rights over their Personal Data by email privacy@PutDataFirst.com.
California Residents
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the newly enacted California Privacy Rights Act of 2020 (“CPRA”), and the California Consumer Privacy Act Regulations (“CCPA Regulations”), requires us to provide California residents additional information, which we address in this section.
For information on the categories of Personal Information we have collected from California residents in the last 12 months, please refer to our above sections on Collection, Use, and Disclosure.
For information on the types of information we collect, the sources of that collected information, the purposes for collecting information, and the categories of third parties with whom we share that information, please refer to our above sections on Collection, Use, and Disclosure.
California residents are granted additional rights under the CCPA, as amended by the CPRA, and the CCPA Regulations, which include the right to opt out of any sales or sharing of your personal information, to request access to and information on our data practices, and to request deletion or correction of your Personal Information, as well as the right not to be discriminated against for exercising your privacy rights. Please note that Ingenious does not use or disclose Sensitive Personal Information except to provide you the Services or as otherwise permitted by the CCPA/CPRA.
You or your authorized agent can submit a request by emailing privacy@PutDataFirst.com. Should you submit a request, Ingenious will verify your identity/authorized agent identity by internally reviewing the requested identity if you are the consumer or the signed paperwork if you are an authorized agent. If you have questions or concerns about this Notice, please contact us at: privacy@PutDataFirst.com.
California Employee Applicant and Employee Data. Whether you are applying for a position at Ingenious or are a current or former employee, you are entitled to request access to and information on our data practices, and to request deletion or correction of your Personal Information by following the steps listed in the paragraph above. For up to date information on the types of data we process about you and how we protect it, please see our California Employee Privacy Notice.
Colorado, Connecticut, Montana, Oregon, Texas, & Virginia Residents
Pursuant to the Colorado Privacy Act (“CPA”) and the Colorado Privacy Act Rules (“CPAR”), the Connecticut Data Privacy and Online Monitoring Act (“CTDPA”), the Montana Consumer Data Privacy Act (“MCDPA”) beginning on October 1, 2024, the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), and the Virginia Consumer Data Protection Act (“VCDPA”), Ingenious is required to provide residents of Connecticut, Colorado, Montana, Oregon, Texas, or Virginia further information, which we address in this section. For details about the categories of information we collect and process, and the purposes for processing those categories of information, please refer to our above sections on Collection, Use, and Disclosure.
Residents of Colorado, Connecticut, Montana, Oregon, Texas, and Virginia are granted additional rights under their respective state privacy laws, which include the right to request confirmation of and provide access to processed Personal Data, to request deletion or correction of Personal Data obtained about or provided by you, to request and obtain a portable copy of your Personal Data, and to opt out of the processing of your Personal Data for the purposes of targeted advertising, sales, or profiling in furtherance of decisions (or solely automated decisions under the MCDPA) that may produce legal or similarly significant effects. Residents from those states also have a right not to be discriminated against for exercising any of these privacy rights. You can submit a request by emailing privacy@PutDataFirst.com.
Residents of Oregon have expanded rights, which in addition to above, include the right to request the deletion of derived data and the right to obtain a list of specific third parties other than natural persons whom an Oregon resident’s Personal Data or any Personal Data has been disclosed at Ingenious’ discretion.
Please note that Ingenious does not “sell” Personal Information as the term is defined under the CPA, CTDPA, MCDPA, OCPA, TDPSA, and VCDPA. Ingenious also does not use or disclose sensitive personal information except to provide you the Services or as otherwise permitted by those laws.
You may appeal an unprocessed or denied request by emailing us at privacy@PutDataFirst.com. We will have 60 days (or 45 days, as prescribed by the CPA and OCPA, with an option to extend for an additional 60 days under the CPA) after receiving your request to explain why we have or have not processed your request. If you are not satisfied with our decision, then you may consult the following information, based on your state of residence, to contact the appropriate state Attorney General’s Office:
For Colorado Residents:
Colorado residents may contact the Colorado Attorney General’s Office by calling (720) 508-6000, or by filing a complaint on their website.
For Connecticut Residents:
Connecticut residents may contact the Connecticut Attorney General’s Office by calling the Consumer Assistance Unit at (860) 808-5440, or by filing a complaint on their website.
For Montana Residents:
Montana residents may contact the Montana Attorney General’s Office by calling the Consumer Protection Hotline at 1-800-481-6896, or by filing a complaint on their website.
For Oregon Residents:
Oregon residents may contact the Oregon Attorney General’s Office by calling the Consumer Protection Hotline at 1-877-877-9392, or by filing a complaint on their website..
For Texas Residents:
Texas residents may contact the Texas Attorney General’s Office by calling the Consumer Protection Hotline at 1-800-621-0508, or by filing a complaint on their website.
For Virginia Residents:
Virginia residents may contact the Virginia Attorney General’s Office by calling the Consumer Protection Hotline at 1-800-552-9963 if calling from Virginia, or (804) 786-2042 if calling from the Richmond area or from outside Virginia, or by filing a complaint on their website.
For Utah Residents:
The Utah Consumer Privacy Act (“UCPA”) requires us to provide Utah residents additional information, which we address in this section. For information on the categories of information we collect and process, and the purposes for processing those categories of information, please refer to our above sections on Collection, Use, and Disclosure.
Utah residents are granted additional rights under the UCPA, which include the right to request confirmation of and provide access to processed personal data, to request deletion of personal data provided by you, to request and obtain a portable copy of your personal data, and to opt out of the processing of your Personal Data for the purposes of selling or targeted advertising. Ingenious may also not discriminate against Utah residents for exercising any of these privacy rights by denying a good or service, charging a different price or rate for a good or service, or providing the consumer a different quality level of a good or service. You can submit a request by emailing privacy@PutDataFirst.com.
Please note that Ingenious does not “sell” Personal Information as the term is defined under the UCPA. Ingenious also does not use or disclose sensitive Personal Information except to provide you the services or as otherwise permitted by the UCPA.
Updates to This Notice
We may periodically review and update this Notice to ensure it complies with applicable laws and covers any changes to our policies or business. Any changes or updates we make will become effective once we post the revised Notice on the website. The date at the top of the page indicates when this notice was last revised.
We encourage you to please review this page regularly for the latest information on our privacy practices. Your use of the Services following these changes means that you accept the revised notice.
Contact Us
If you have any questions or concerns about this notice, please contact us at:
Ingenious Dataworks, Inc.
530 Technology Drive
Suite 100
Irvine, CA 92618
Attention: Chief Privacy Officer