Last Updated: April 22, 2022
We provide additional information for residents of California and residents of the United Kingdom, Switzerland, the European Economic Area (collectively, "Europe" or "European") below.
Personal information we collect
Information you provide to us:
- Contact and account information, such as your first and last name, email address, phone number, and mailing address.
- Payment and transaction information, such as information regarding your enrollment in our premium services. Payments will be processed by our payment service provider, Recurly. Please see the "Recurly" section below for additional information regarding how Recurly handles your personal information.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.
- Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our activities and publications, and details about how you engage with our communications.
Information we obtain from third parties:
- Other Sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources, lead generators and data providers.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:
- Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
We use the following tools for automatic data collection:
- Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
How we use your personal information
To operate our Services:
- Provide, operate, maintain, secure and improve our Services.
- Process transactions initiated by you and send you notices about your transactions and network activity.
- Provide information about our Services.
- Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
- Resolve disputes, collect fees, and troubleshoot problems.
- Understand your needs and interests, and personalize your experience with our Services and our communications.
- Verify your identity.
- Respond to your requests, questions and feedback.
For research and development. To analyze and improve the Services and to develop new products and Services, including by studying use of our Services.
Marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:
- Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the "Opt out of marketing communications" section below.
To comply with law. As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. To: (a) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To create anonymous data. To create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and to promote the Services.
How we share your personal information
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, fraud detection, payment processing, and database management).
Advertising partners. We may share your personal information with third party advertising companies, including for the interest-based advertising purposes described above.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Opt out of marketing communications. You may opt out of marketing communications by clicking the unsubscribe link at the bottom of the communication. INO.com subscribers may also opt out on the subscription management page. INO.com subscribers may also opt out by contacting an INO.com representative and requesting to cancel your service. After you opt out, you may continue to receive service-related and other non-marketing emails.
Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
Use the following links to learn more about how to control cookies and online tracking through your browser:
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
Payments on our Services are handled by Recurly. The information you provide to Recurly in connection with your payment information and transactions is handled in accordance with Recurly's terms and privacy policies. Your payment data is stored by Recurly.
Other sites, mobile applications and services
Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child's parent or guardian as required by law, we will delete it.
By using our Services, you understand and acknowledge that your personal information will be transferred from your location to INO.com's or INO.com's service providers' facilities and servers in the United States.
How to contact us
Please direct any questions or comments about this Policy or privacy practices to INO.com. You may also write to us via postal mail at:
1 Pennsylvania Plaza
New York, New York 10119
Additional information for California residents
This section applies only to California residents. For purposes of this section, "personal information" has the meaning given in the California Consumer Privacy Act of 2018 ("CCPA") but does not include information exempted from the scope of the CCPA.
Your California privacy rights. The CCPA grants individuals whose information is governed by the CCPA the following rights:
- Access. You can request a copy of the personal information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the personal information that we have collected from you.
- Opt out of sale of your personal information. We do not sell personal information. Like many businesses, we use services that display interest-based ads to users around the web. We offer instructions on how to limit online tracking in the "Online tracking opt out" section above.
You are entitled to exercise the rights described above free from discrimination.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
How users in California can exercise their rights
You may exercise your California privacy rights described above as follows:
Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
Visiting Our Data Rights Request Page to submit a CCPA request.
- Right to opt out of sale of personal information. We offer instructions on how to limit online tracking in the "Online tracking opt-out" section above.
- Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Authorized agents. California residents can empower an "authorized agent" to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
Notice to European residents
Scope. This section applies if you are a User in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, and, to the extent applicable, Switzerland) and the UK.
Controller. INO.com is the controller of the personal information we collect.
EU representative. We have appointed VeraSafe as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. To contact VeraSafe, please visit https://www.verasafe.com/privacy-services/contact-article-27-representative.
Alternatively, you may call VeraSafe at +420 228 881 031, or write to VeraSafe Ireland Ltd., Unit 3D North Point House North Point Business Park New Mallow Road, Cork T23AT2P, Ireland.
|Processing purpose||Legal basis|
|To operate our services||Processing is necessary to perform the contract governing our provision of our services or to take steps that you request prior to signing up for the services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request.|
|For research and development;
For marketing and advertising purposes;
For compliance, fraud prevention and safety;
Creation of anonymous data
|These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the services.|
Retention. We retain 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 establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, 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.
Cross-border data transfer. If we transfer your personal information from Europe to another country such that we are required to apply appropriate safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.
Your rights. European data protection laws may give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by messaging INO.com or sending a request to our postal address provided above. 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 our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
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