Effective Date: September 14th, 2022
The personal information we collect depends on how you interact with our Services.
Account Information. When you create a IDIGITALIP or Mobile Insight or VIBA account, we collect the personal information you provide to us, such as your name, email address, personal website, and picture. If you enable phone based two-factor authentication, we collect a phone number.
Payment Information. Where we sell products and services through the Services, we use third-party applications, such as theApple App Store, Google Play App Store, Amazon App Store, and/or services such as Stripe to process your payments. These third-party applications will collect information from you to process a payment on behalf of IDIGITALIP, including your name, email address, mailing address, payment card information, and other billing information. IDIGITALIP does not receive or store your payment information, but it may receive, and store information associated with your payment information (e.g., the fact that you have paid, the last four digits or your credit card information, and your country of origin).
Communication Information. We collect personal information from you such as email address, phone number, mailing address, and marketing preferences when you request information about the Services, register for our newsletter, or otherwise communicate with us.
Candidate Information. We may post job openings and opportunities on the Services. If you reply to one of these postings or otherwise provide us with your candidacy information, we will collect and process the information you provide to us.
Service Use Information. We collect information you provide to the Services for the purpose of providing the Services to you, which may include personal information such as information about your interactions with other users.
Customer Service Information (including Training and Quality Assurance). If you call or otherwise interact with IDIGITALIP’s (orMobile Insight’s or VIBA’s) sales, customer service or support personnel, we collect the information you provide to our representatives. In addition, we may record telephone calls or video conferences between you and our representatives for training or quality assurance purposes.
Student Account Information. If you qualify for Educational Use, we may collect information relating to your school and curriculum, such as your school’s name, school mailing address, school website and proof of registration. Note that, as provided in our published Terms of Service, the Services are only for users 13 years old and over.
Sweepstakes, Contests, Surveys and Events Information. In connection with sweepstakes, contests, surveys, conferences, and other events hosted, run, or sponsored by us, you may provide information to us, or we may receive information about you, such as name, email address, mailing address, demographic data, and any information specific to the event.
Automatic Data Collection. We collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (inferred from your IP address), internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and information about how you interact with and use the Services.
With your permission, we may also collect information about your operating system’s installed fonts in connection with providing theServices to you.
Analytics. We use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about how Google uses data, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by going to http://tools.google.com/dlpage/gaoptout.
IDIGITALIP Customers. If you use our Services on behalf of, or in collaboration with, an organization (e.g., your employer), that organization may provide us with information about you so that we can provision your account.
Third Party Services and Organizations. We may obtain information about you from other sources, including from third party services and organizations. For example, if you access our Services through a third-party service, we may collect information about you from that third-party service that you have made available via your privacy settings.
In this section we describe all the ways we use your personal data, and the legal bases we rely on to do so.
In certain situations, we require your data to pursue our legitimate interests in a way which is reasonable for you to expect as part of running our business and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are.
We use your personal information for a variety of business purposes, including:
1. Providing and managing the Services or information requested, such as:
This includes: the processing of all categories of information except for Candidate Information.
Legal Basis: Performance of the contract with you.Necessary for our legitimate interests to recover debts due to us. Necessary for our legitimate interests to respond to and communicate with you (where we do not have a contractual relationship or legal obligation to do so). Necessary to comply with a legal obligation (including national data protection and consumer protection laws, for example to respond to requests in relation to personal data processed about the individual)
Legal Basis: Performance of the contract with you.Necessary to comply with a legal obligation (including national data protection and consumer protection laws).
3. Administering and protecting our business andServices (including troubleshooting, data analysis, testing, system maintenance, support, reporting, internal quality control and safety and hosting of data).
This includes: the processing of your Account Information,Communication Information, Technical Information, Service Use Information,Student Account Information and Customer Service Information
Legal Basis: Performance of the contract with you.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).Necessary to comply with a legal obligation (including national data protection and information security laws)
4. Using data analytics to improve our website, products/Services, marketing, customer relationships and experiences.
This includes: the processing of your TechnicalInformation, Service Use Information, and Customer Service Information.
Legal Basis: Necessary for our legitimate interests (to define types of customers for our products and Services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy).
5. Enabling you to partake in a prize draw, competition or complete a survey.
This includes: the processing of your Sweepstakes, Contests, Surveys and Events Information and Communications Information.
Legal Basis: Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, and to develop them and grow our business).
6. Carrying out surveys for user research and analyzing your feedback.
This includes: the processing of your Surveys and EventsInformation and Account Information, Student Account Information, Communications Information, and Use of Services Information.
Legal Basis: Necessary for our legitimate interests (to study how customers use our products/services, and to develop them and grow our business).
7. Make suggestions and recommendations to you about goods or services that may be of interest to you.
This includes: the processing of your Account Information,Student Account Information, Communications Information, Service UseInformation, and Technical Information.
Legal Basis: Necessary for our legitimate interests (to develop our products/services and grow our business) (where consent is not required by marketing laws – in which case consent shall be relied upon).
8. Contacting customers and prospective customers about products, services, developments, and events we think may be of interest to you.
This includes: the processing of your Account Information,Student Account Information, and Communication Information.
Legal Basis: In certain situations, we seek consent before sending marketing materials to individuals and in such cases, consent is our lawful basis for sending marketing to you.
Where we do not obtain consent, we rely on our legitimate interests (to develop our products/services and grow our business) as our lawful basis for sending marketing materials to you.
9. Delivering relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
This includes: the processing of your Account Information,Student Account Information, Communications Information, Service UseInformation, and Technical Information.
Legal Basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). If required by marketing laws, we seek consent before serving advertisements to individuals and in such cases, consent is our lawful basis for sending marketing to you.
10. Collecting information through the device-based settings which you have enabled, and cross device tracking.
This includes: the processing of User Content (if provided by a user), including media that you choose to share.
Legal Basis: Consent.
11. Enforcing our agreements and complying with our legal obligations including to share information with law enforcement, the courts and other authorities.
This could include any personal data we process about you.
Legal Basis: Necessary to comply with a legal obligation(including national data protection, cyber security, subpoena compliance and surveillance laws). Necessary for our legitimate interests (to enforce our agreements, to seek professional advice, or to establish, exercise or defend a legal claim).
12. Recruiting and hiring, including considering your candidacy for employment.
This includes: the processing of Candidate Information andCommunication Information.
Legal Basis: Necessary for our legitimate interests (to screen candidates and consider your suitability for a position). Entry into a contract with you.
13. De-identifying data and creating aggregated information.
This could include any personal data we process about you.
Legal Basis: Necessary for our legitimate interests (to use personal information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, and information about the device from which you access ourServices. De-identified and/or aggregated information is used for several purposes, including research, industry analysis, analytics, and any other legally permissible purposes.)
We may share any personal information we collect with the following categories of third parties:
Other Users of IDIGITALIP’s Services. When you use theServices to collaborate or interact with others, we will share certain information with your collaborators. For example, you can create content, which may contain information about you, and grant permission to others to see, share, edit, copy, and download that content based on settings you or your administrator (if applicable) select. In addition, some of the collaboration features of the Services display some or all your profile information to otherService users when you share or interact with specific content. For example, when you comment, we display your profile picture and name next to your comments so that other users with access to the comment know who made it.Similarly, when you join a team, your name, profile picture and contact information will be displayed in a list for other team members so they can find and interact with you. Please note that while we require all our users to comply with our acceptable use policy (you may request a copy by emailing to email@example.com), we are not responsible for privacy practices of users who receive information about you through the Services.
The Public. Content can be made publicly available by you or others collaborating on it, and in such cases any information about you included in such content is also publicly available and can be indexed by search engines. You can check at any time whether content is public or private by viewing the content’s settings. In addition, in connection with your posting of content on IDIGITALIP Community, we will publicly share your picture, name, user handle, and Twitter (or other social networking site)handle (to the extent you have provided us with this information).
Third-Party Platforms and Services. We will share your personal information with third-party platforms and/or services if you have expressly consented or requested that we do so. Please note we do not endorse, screen, or approve, and are not responsible for, the practices or conduct of such third-party services.
Advertising Partners. Through our Services, we allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions under the Your Choices heading below.
Disclosures to Protect Us or Others. We will access, preserve, and disclose information we have associated with you to competent law enforcement bodies, regulatory and government agencies, courts or other third parties if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) enforce IDIGITALIP’s policies and contracts; (iv) collect amounts owed to us; (v) prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Disclosure in the Event of Merger, Sale, or Other AssetTransfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information maybe sold or transferred in accordance with our legitimate interests in administering our business as part of such a transaction, as permitted by law and/or contract.
All information processed by us may be transferred, processed, and stored anywhere in the world, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistently with the requirements of applicable laws.
Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from theEuropean Commission and “adequacy regulations” from the Secretary of State in the UK.
Where the transfer is not subject to an adequacy decision or regulations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this PrivacyPolicy. These include implementing the European Commission’s StandardContractual Clauses and Standard Contractual Clauses adopted pursuant to or permitted under Article 46 of the UK GDPR.
Our Standard Contractual Clauses can be provided on request. We have also implemented Standard Contractual Clauses with our third-party service providers and partners and further details can be provided upon request.
IDIGITALIP relies on Standard Contractual Clauses for the transfer of personal data. In addition, IDIGITALIP continues to comply with theE.U. - U.S. Privacy Shield Framework - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union andSwitzerland to the United States.
IDIGITALIP is responsible for onward transfers to our agents under the Privacy Shield Framework. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, IDIGITALIP is subject to the regulatory enforcement powers of the U.S. Federal TradeCommission.
If you have any questions or concerns related to our Privacy Shield certification or to resolve any complaints about our collection or use of your personal information, you should first contact us using the information set forth below.
IDIGITALIP has further committed to refer unresolved complaints related to personal information to JAMS Privacy Shield DisputeResolution Program, an independent dispute resolution provider located in theUnited States made available free of charge. For more information or to submit a complaint visit: https://www.jamsadr.com/eu-us-privacy-shield.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution options do not satisfactorily resolve your concerns.
General. You have the right to opt out of certain uses of your personal information.
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.
Cookies and Interest-Based Advertising. You have the right to decide whether to accept or reject cookies. If you are in theEuropean Union, you can change your cookie preferences through our cookie consent tool, which you can access at any time by clicking the “cookie settings” in the footer of our website (you may need to log out of your IDIGITALIP account to access the footer). You can also stop or restrict the placement ofTechnologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not respond to DNT signals or similar mechanisms transmitted by web browsers.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
Please note that if you use our Services on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the individual rights requests referenced above.
When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. You may request deletion of your personal information at any time as noted in “Your Privacy Rights”, above, but that will require you to delete your account with us, as we need your personal data to maintain your account.
We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of theServices. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
IDIGITALIP collects the following Categories of Personal Information:
IDIGITALIP Discloses to the following Categories of Third Parties for a Business Purpose:
As defined by the CCPA, IDIGITALIP does not sell personal information of California residents, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age.
Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to log in to your account or verify your email address.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.
If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise your right by contacting us as described below with the subject line “Nevada Do Not SellRequest” and providing us with your name and the email address associated with your account. As defined by Nevada Revised Statutes Chapter 603A, we do not currently sell Personal Information of Nevada residents.
The Services are not directed to children under 13, and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account, or, if appropriate and possible, seek written consent from such child’s guardian.
If you are in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
IDIGITALIP, 800 S. Douglas Rd., Suite 450, Coral Gables, FL33134, USA.