Pursuant to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), the E.U. General Data Protection Regulation (GDPR) and ePrivacy Directive, and other applicable laws and regulations, individuals may have privacy and data subject rights enabling them to request to access, delete, correct, limit the use, and/or receive a copy of their personal information in Inflect’s possession or for which Inflect is otherwise responsible.
- attendees of Inflect events, or of service provider- or industry-sponsored events in which Inflect participates;
- partners, prospective partners, customers, prospective customers, suppliers, and their respective representatives;
- subscribers to Inflect publications and newsletters; and
- Inflect employees, contractors, advisors and visitors.
3. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?
Inflect can process information about you collected directly from you both offline and online, including when you create an Inflect account to access Inflect products and services or attend an event participated in by Inflect. Information about you may also be collected indirectly, including when it is provided to Inflect by selected third party sources, such as data aggregators, who may not have a direct relationship with you, or obtained by or for Inflect from publicly available sources or through observation.
Specific pieces of information about you that Inflect may collect and process depending on your interaction with Inflect, include:
- name and physical address, email addresses, and telephone numbers;
- demographic attributes, when tied to personal information that identifies you;
- transactional data, including products and services ordered, financial details and payment methods;
- company data such as the name, size and location of the company you work for and your role within the company as well as publicly available company information and activity associated with company data;
- data from surveys conducted by Inflect or by third parties on behalf of Inflect and publicly available information, such as social media posts;
- call recording and chat transcript data from sales and customer support calls and live chat sessions or interviews;
- unique IDs such as your mobile device identifier or cookie ID on your browser;
- IP address and information that may be derived from an IP address, such as geographic location;
- information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
- certain location or geolocation information you provide directly or through automated means, if you choose to enable location-based services from your device or an Inflect app;
- photographs that identify you and testimonials; and
- behavioral data of the internet-connected computer or device you use when interacting with the Sites, such as advertisements clicked or viewed, site and content areas, date and time of activities or the web search used to locate and navigate to a Site.
Please note that Inflect does not control the content that you may post to our Sites, databases, or forums; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these sies, databases, or forums and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.
4. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use personal information for the following business purposes:
- to communicate and respond to your requests and inquiries to Inflect, and to create and administer an Inflect single sign-on (SSO) account for you (an “Inflect Account”);
- to deliver functionality on our Sites and perform technical and functional management of the Sites;
- to engage in transactions with service providers, partners, customers, suppliers and other parties, and to process orders for Inflect products and services;
- to analyze, develop, improve and optimize the use, function and performance of the Sites and our products and services;
- to manage the security and operation of our Sites, facilities, networks and systems; and
- to comply with applicable laws and regulations and to operate our business.
- to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests;
- to provide select business-to-business services to Inflect partners and customers using publicly available information about companies which may include personal information such as the name of a company’s CEO that is publicly available; and
- to administer subscriptions of Inflect publications, newsletters, and databases.
We may use personal information for the following commercial purposes:
5. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?
For personal information collected about you in the European Union (“EU”)/European Economic Area (“EEA”), the United Kingdom and other relevant jurisdictions, our basis for processing is the following:
- We rely on our legitimate interest in processing contact and related information about you in order to communicate adequately with you and to respond to your requests.
- In order to engage in transactions with partners, customers, and suppliers, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
- We process personal information for marketing and sales activities (including events) based on your consent where so indicated on our Sites at the time your personal information was collected, or further to our legitimate interest to keep you updated on developments around our products and services which may be of interest to you.
- We rely on our legitimate interest to analyze, develop, improve and optimize our Sites, facilities, products and services, and to maintain the security of our Sites, networks and systems.
- In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.
6. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION?
Inflect maintains personal information for the following retention periods:
- Information about you we collect to engage in transactions with our partners, customers and suppliers, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
- If you have registered for an Inflect Account to access our Sites or to sign up for Inflect marketing materials, your account information will be retained for as long as you maintain an active account. Your account and account information generally will be deleted if you do not log in for 18 consecutive months, although minimal account information will continue to be held for records retention purposes.
- If you have registered for our newsletters, blogs, or databases, your subscription data will be retained for as long as you are subscribed to our distribution lists.
- Contact information such as your email address or phone number collected online on our Sites or offline from our interactions with you at Inflect events, booths and conferences, and used for direct marketing and sales activities, will be retained for as long as we have an active business relationship with you.
- If you have reached out to us via chat, we will delete all chat transcripts not later than 90 days after the chat has concluded.
- If you have reached out to us via our support line and you have not opted out of call recording, we will delete call recordings not later than 60 days after the call has concluded unless otherwise specified during the call.
- If you have visited an Inflect facility, the personal information needed to allow you to enter the facility will be held for one year after your last visit for records retention purposes.
- Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).
7. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?
Sharing within Inflect
As a global organization, information about you may be shared globally throughout Inflect’s worldwide organization. In each case, Inflect employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions. If personal information is transferred to an Inflect recipient in a country that does not provide an adequate level of protection for personal information, Inflect will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to the terms of the EU Model Clauses or other adequate transfer mechanism as required under relevant data protection laws.
Sharing with third parties
We may share personal information with the following third parties for a business or commercial purpose:
- Service providers, partners, customers and suppliers in connection with business opportunities and transactions;
- Third-party credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, corporate record keeping, hiring, payroll, auditing, and other similar service providers, in order for those companies to perform business functions on behalf of Inflect;
- Event partners or conference sponsors for Inflect events such as when you scan your badge at a sponsored booth;
- Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
- As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
8. HOW IS YOUR PERSONAL INFORMATION SECURED?
Inflect is committed to protecting the security of any personal data that we collect. Inflect has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing. Despite these measures, no method of transmission over the Internet or method of electronic storage is 100% secure. Inflect cannot fully eliminate security risks associated with the collection and storage of personal data, including without limitation, any mistakes and security breaches that may happen. While we strive to use commercially acceptable means to protect all information about you, we cannot guarantee its absolute security.
9. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?
Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Inflect and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 4 above.
Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. We place cookies in your browser when you visit our Sites and non-Inflect sites that host our plugins or tags. Depending on your jurisdiction, you may be presented with different consent options, including without limitation the option to reject all non-essential cookies, prior to Inflect placing cookies on your browser. Visitors from all jurisdictions are provided with the right to opt out of non-required cookies.
If you are a visitor or our Sites, you can use our cookie preferences tool to opt out of cookies that are not required to enable core site functionality, such as advertising and functional cookies. If you do not want to receive cookies, you can also change your browser settings on your computer or other device you are using to access our services. Most browsers also provide functionality that lets you review and delete cookies, including Inflect cookies.
10. WHAT ARE YOUR PRIVACY RIGHTS?
You have multiple privacy rights, subject to applicable law, in respect of the information we process about you:
- Opt-out of our use or sharing of your personal information
You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Inflect.
- Delete personal information
You can ask us to erase or delete all or some of the information about you.
- Change or correct personal information
You can edit some of the information about you by [add appropriate action]. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.
- Object to, or limit or restrict use of personal information
You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).
- Right to access and/or have your information provided to you
You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine-readable form if you reside in the EU, California or other jurisdiction that provides you this right as a matter of law.
If you are authorized to make an access or deletion request on behalf of a data subject, please reach out to us in writing and indicate that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a data subject.
In the event you have previously created an account for a certain Inflect portal, you can access and manage your personal information stored in these portals (i) by clicking the links and following the corresponding instructions, and (ii) taking the actions within each portal with regards to your personal information, such as updating your contact details, deleting certain entries or records, or downloading a copy of your profile. Please note that these actions are available to the extent permitted by each portal’s functionality.
If your inquiry relates to your company’s service account or support of Inflect products or services, please note that Inflect cannot delete, correct, or access service account data or terminate your contracted Inflect product or service account. Please go to Section 12 for Inflect contact information to administer service account data.
11. WHAT ARE YOUR RIGHTS AS A CALIFORNIA RESIDENT?
Under the California Consumer Privacy Act (CCPA), as amended and expanded by the California Privacy Rights Act (CPRA), any natural person residing in California may request that Inflect:
- Disclose to you the following information: (a) the categories and specific pieces of personal information we collected about you and the categories of personal information we shared or sold (see Section 3); (b) the categories of sources from which we collected such personal information (see Section 3); (c) the business or commercial purpose for collecting, sharing or selling personal information about you (see Section 4); and (d) the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 7);
- Delete personal information we collected from you or correct inaccurate personal information about you (see Section 10);
- Opt-out of any future sale or sharing of personal information about you (see Section 10); or
- Limit the use and disclosure of “sensitive personal information”, which is a subset of personal information newly defined in the CPRA.
We will respond to your requests consistent with applicable law and without discrimination. If you are an authorized agent making an access or deletion request on behalf of a Californian resident, please reach out to us in writing and indicate that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a Californian resident.
Inflect receives data subject access requests (DSARs) from across the globe and works to ensure all valid requests where Inflect is the Controller are responded to within the appropriate timeframe. In accordance with the verification process set forth in the CCPA, as modified by the CPRA, Inflect will require a more stringent verification process for deletion requests, or for personal data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your personal data. If Inflect must request additional information from you outside of information that is already maintained by Inflect, Inflect will only use it to verify your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.
If you are a California resident, you may obtain information about exercising your rights, as described above, as well as obtain information on the CCPA requests Inflect received, complied with, or denied for the previous calendar year, in each case by contacting us at email@example.com.
12. QUESTIONS OR COMPLAINTS?
Inflect’s corporate headquarters are located at:
447 Sutter Street
Suite No. 405
San Francisco, California 94108
You can send email communications to Inflect at firstname.lastname@example.org