Last Modified: 5/29/18
IntraEdge, Inc. (“IntraEdge,” “we”, “us”, or “our”) is responsible for this website and is the controller of data collected from it in most cases. We respect your privacy and aim to protect it along with your personal data. This privacy notice will inform you how we collect, process, and control your personal data when you visit our website and when we send you communications that you request from us . It will also inform you of your privacy rights. This Notice does not apply to information that we collect through other channels, such as information that we collect offline, from other websites or from emails you send us. For purposes of this Notice, personal data means any information relating to an identified or identifiable natural person.
1. Who We Are
IntraEdge has its principal place of business at 5660 W. Chandler Blvd., Suite 1, Chandler, AZ 85226. IntraEdge offers the GDPR Edge—a custom-built solution to meet the specific GDPR data processing record requirements for business and other organizations. In the future, we will provide you with a data subject rights portal so that you can easily access all of the personal information we have collected about you. However, in the meantime, this Notice will inform you of our data collection practices and your rights.
Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The Data We Collect About You
We collect personal data about you to provide our services. In most cases, this information is limited to the kinds of information that can be found on a business card: first name, last name, email address, phone number, job title, and company name (“Contact Data”). We use this information to provide our website services to you and help communicate effectively with you. The data collected is necessary for fulfilling the relationship we have with you or for a legitimate interest of ours.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. Also, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Also, we do not knowingly direct or website to or collect personal data from children under 13.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How We Collect Your Personal Data.
Personal Data You Give to Us.
We collect information when you voluntarily provide it to us. This includes information you provide by filling out forms on the website and any information that we may request in our communications with you. By default, we’ll only use your personal data to administer your account and to provide the products and services you requested from us. Because we may change our website and the services we offer from time to time, the means and methods to provide us with personal data may also change. Depending on how you interact with us and use the website, the personal data we collect may vary.
Information We Collect Automatically.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Technical Data by using cookies and other similar technologies. Technical Data may include you IP Address; device identifier data, the type of device you use, your operating system and version, the URL’s of our web pages that you visit, the URL’s of referring and exiting pages, the pages you view, the time spent on a page, the number of clicks made, the platform type, and generalized, non-specific location data.
4. How We Use Your Personal Data.
We will only use your personal data when allowed by law. Generally, we will use your personal data: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and (c) where we need to comply with a legal or regulatory obligation. Generally, uses include the following actions:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
Below is a chart of some of the common ways in which we process your personal data. We have identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||Contact||In furtherance of performance of a contract with you|
|Notifying you about changes to our terms or privacy notice||Contact||Performance of a contract with you |
Necessary to comply with a legal obligation
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)To provide you with information and marketing communications about our products and services.||Contact Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)|
|To provide you with information and marketing communications about our products and services.||Contact||Consent |
5. Disclosures Of Your Personal Data
From time to time, we may need to share your personal data with others.
Third Party Service Providers. We may share your information, including Contact Data and Technical Data, with third party service providers who perform various functions to enable us to provide our Services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the personal data we provide to them, only act on our behalf and under our instructions, and not use personal data for purposes other than the product or service they're providing to us or on our behalf.
Protection of IntraEdge and Others. We may share personal data when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of IntraEdge, our products and services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal data of our customers for commercial purposes in violation of the commitments set forth in this Notice.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we're required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your personal data may be shared with other third parties.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. International Data Transfers
IntraEdge has its headquarters in the United States. Information we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Notice.
Where we transfer your personal data to third party service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US, or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
9. EU Data Subjects Privacy Terms
EU data subjects have certain rights with respect to your personal data that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal data. You can often go directly into the Service under Account Settings to take these actions.
Please note that even if you request for your personal data to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in Section 7 “Data Retention”, above.
- Objection. You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restriction. You have the right to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability. You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent. If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal data.
To file a request or take action on one of your rights, please contact us at the contact details provided under Section 11, “How to Contact Us”. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Updates to Our Privacy Notice
By using this website, you agree to the terms and conditions contained in this Privacy Notice and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website. You agree that any dispute over privacy or the terms contained in this Privacy Notice will be governed by the laws of the State of Arizona. You also agree to arbitrate such disputes in Arizona, and to abide by any limitation on damages contained in any agreement we may have with you.
This Notice is expected to change from time to time. We reserve the right to amend this Notice at any time and provide notice to you by posting of the amended Privacy Notice on the website. We may also email you to give you notice of material changes to this Notice. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of this website.
11. How to Contact Us
If you have any questions or wish to register a complaint in relation to this Privacy Notice or the manner in which your personal data is used by us, please contact us by any of the following means:
By Email: email@example.com
5660 W. Chandler Blvd., Suite 1
Chandler, AZ 85226