STANDARD PRIVACY POLICY (US)
EFFECTIVE DATE: 1 FEBRUARY, 2018

IDENTY Inc, and its affiliates and subsidiaries (collectively, “Identy” or “we”), have created and adopted this Privacy Policy (“Policy”) to demonstrate their firm commitment to your privacy. This Policy applies to all Identy products and services that do not have a separate privacy policy or that link to this Policy (collectively, the “Services”), and describes how we collect, use and share your personal information, and what your rights are. In order to fully understand your rights, we encourage you to read this Policy and to consult our Terms of Use.

1. ACCEPTANCE OF PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Policy and consent to the collection, storage, use and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access to or use of our Services.

2. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Policy at any time. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

3. DEFINITION OF PERSONAL INFORMATION

Generally speaking, personal information is any data that can be used to identify or contact you. However, while our Policy broadly addresses all types of personal information that we may collect, some of the data we describe below may not be considered personal information according to the data protection laws of the jurisdiction in which you reside. Therefore, you should understand that certain parts of this Policy will not apply to you depending on the laws of the jurisdiction in which you reside.

4. COLLECTION OF INFORMATION

Each time you visit our Services, we collect information you provide to us and about your use of our Services as described below. For example, during your visit to our Services you may complete an order form, enter a request or submit other information to us which may be considered personal information. To provide you with our Services, we may require certain information from you because such information is relevant to a specified purpose. Any additional information you provide to us is voluntary. Please be aware that you can choose whether to provide us with the types of information described below, but your choices may affect our ability to offer you part of or all of our Services.

Information you provide to us when accessing or using our Services. When you access or use our Services, we collect information you provide to us, including, but not limited to:

  • Mobile data. Our Services include mobile applications that collect information about you and your device, such as your IP address, location or device information, and any other information provided by your mobile device. If you do not want us to collect your location information you can disable the GPS or location-tracking function on your device.
  • Third-party plugins. We may have integrated third-party plugins in our Services, and the use of such third-party plugins results in data collection by both Identy and the relevant third-party. For example, our Services may feature a Facebook Like button and other widgets, such as the “Share” button or interactive mini-programs. If you use or interact with a third-party plugin, then both the third-party company and Identy will collect information about your access and use of our Services. Please see Section 6 for further information.
  • Cookies and similar tracking technologies. We use both first-party and third-party cookies, and other similar tracking technologies on our Services. A cookie a small data file that is stored on your device and collects information such as your IP address or information about your use of and/or activities on our Services (e.g., what pages you visited, or on which part of our Services you spent the most time). Please see section 7 below for more information.
  • Log data. We collect log data about your use of our Services, which may include your IP address, IP data and the time of your access or use of our Services, page views, the referring URLs, and any other information about your activities on our Services.
  • Accessing and using our Services in any other way. When you use or access our Services, we may collect information such as search terms, interactions with other users, and any other activities on our Services.
5. PURPOSE OF COLLECTION

Generally, we collect your personal information for the purposes of providing you with and improving upon our Services. However, we also collect your personal information for the purposes listed below. If we identify any new purposes outside of the stated purposes listed below, we will provide you with notification as required by applicable law or, if the purpose involves the use of sensitive information (e.g., biometric data), we will seek your prior consent.

  • Fulfilling your requests and orders for our products, programs, and services;
  • Providing customer service and support;
  • Delivering newsletters to market products and services which we think may be of interest to you - you may unsubscribe at any time by following the instructions included in such emails or by contacting us at contact@identy.io;
  • Allowing you to communicate with other users;
  • Protecting, optimising, developing, and operating our Services;
  • Billing you for products and services you request;
  • Communicating with you;
  • Complying with legal obligations, and resolving any disputes;
  • Enforcing our agreements with third parties;
  • Detection, prevention, and investigation of potential or actual fraud or other harmful activity; and, Advertising our Services or the services and products of third parties.
6. INFORMATION SHARING

We will share your personal information with third parties only in the ways that are described in this Policy.

  • Third parties authorised by you. We will disclose your personal information to a third party with your authorisation, such as your bank.
  • Third-party service providers. We may provide your personal information to companies that provide services to help us with our business activities, such as shipping your order or offering customer services. These companies are authorised to use your personal information only as necessary to provide these services to us.
  • Compliance with legal obligations. We may also disclose your personal information as required by law, such as: to comply with a subpoena or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights; to protect your safety or the safety of others; to investigate fraud; or, to respond to a government request.
  • Business transaction. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may disclose your personal information to a third party involved in the transaction as permitted by applicable law.
  • Affiliated businesses. Identy may share your personal information with affiliates to provide you with our Services, to improve or develop our Services, or for promotional offers that may be of interest to you. You may opt-out of such sharing at any time by contacting us at contact@identy.io.
  • Third-party plugins. Your interactions with third-party plugins are governed by the privacy policy of the company providing the third-party plugin. Identy is not responsible for the privacy and security practices of such third parties, and it is your choice to use such third-party plugins. We encourage you to read the privacy policy of any third party you interact with on or through our Services.
  • Protection and safety of Identy and others. We are committed to providing a safe environment on our Services. Identy may disclose your personal information for purposes of: fraud prevention and detection; protecting the rights, property, and safety of Identy, you, or others; and, enforcing or applying our Terms of Use and other agreements.
  • Cookies. Please see below
7. COOKIES & SIMILAR TRACKING TECHNOLOGIES

Generally, we use cookies, web beacons, and tags to: optimise and improve our Services; identify your device; distinguish you from other visitors; record your IP address to understand your use of our Services; provide user authentication; monitor and maintain information about your use of our Services; identify the name of the website from which you linked to Identy; and, to conduct fraud prevention and management services.

We do not use these technologies for tracking of any information about your use of other websites or services except as stated herein. Any information that is obtained through cookies, web beacons and similar tracking technologies may be shared with or obtained by third-party service providers on our behalf.

COOKIES

A cookie is a small text file that is stored on a computer or device when you visit our Services. If you reject our cookies and/or similar tracking technologies, you may still use our Services, but your ability to use some or all of our Services, such as contests or surveys, will be limited.

We use both session ID cookies and persistent cookies. A “session ID” cookie expires when you end your session (i.e., close your browser). We use session cookies to make it easier for you to navigate our Services. A “persistent” cookie remains on your hard drive which means that when you end your session and return to the same website later, the cookie information is still available. We set a persistent cookie to store your passwords so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance their experience on our Services.

We use the following types of cookies:
  • Strictly Necessary Cookies. These cookies are essential because they enable you to move around our Services and use certain features on our Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some Services cannot be provided.
  • Performance/Analytics Cookies. These cookies collect information about how you use a website. For example, a performance/analytics cookie will collect information about which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is used to improve how our Services work.
  • Functionality Cookies. These cookies allow us to remember the choices you make and to tailor our Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username.
  • Targeting/Advertising Cookies. These cookies are used to provide advertisements that are more appealing to you and your interests, and to help measure the effectiveness of an advertising campaign. For example, a targeting/advertising cookie can remember that you have visited a website, and it may share this information with other organisations, such as advertisers. This means that after you have visited our Services, you may see advertisements about our products and services elsewhere on the Internet.
  • Third-Party Cookies. We may place cookies from third-party service providers that fall into one of the above categories, who may use information about your visits to other websites to target advertisements for products and services available from Identy. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies.
WEB BEACONS / GIFS

Web beacons, or “clear gifs,” are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive or device, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

We and our third-party service provider employ web beacons for the reasons stated above (under “Cookies”), but primarily to help us better manage content on our Services by informing us which content is effective.

8. HOW TO MANAGE COOKIES & SIMILAR TRACKING TECHNOLOGIES

Below we describe how you can manage first-party or third-party cookies.

  • Our Cookies (or, “First-Party Cookies”). You can use the browser with which you are viewing our Services to enable, disable, or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please be advised that if you set your browser to disable cookies, you may not be able to access parts of our Services or our Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
  • Third-Party Cookies. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to http://www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising entities or only receive advertising provided by specific advertising entities.
9. DATA RETENTION

We will retain your personal data, including biometric data, for as long as needed to satisfy the initial purpose for which your data was collected, and to comply with our legal obligations, resolve disputes, and enforce our agreements but not longer than 12 months after the last time you interacted or used the Service.

At such time, we will securely and permanently dispose of your personal data, including biometric data, according to recognized industry standards.

10. SECURITY

Our Services have security measures in place to protect against the loss, misuse and alteration of the personal information under our control. Identy will endeavour to use appropriate security measures including firewalls and monitoring.

However, no data transmission over the Internet or storage of data can be guaranteed as 100% secure, thus we cannot ensure or warrant the security of any personal information you transmit to or store with us, and you transfer and store such data at your own risk. You are also responsible for the security of your personal information by taking precautionary measures, such as keeping your account password confidential and using secure wireless connections.

11. CHILDREN’S PRIVACY

We do not knowingly request or collect personal information from any person under the age of 16 without prior verifiable parental consent. Children under 16 should not provide personal information to us on our Services. Please notify us if you know of any children using our Services so we can take action to prevent access to our Services and delete their information.

12. “DO-NOT-TRACK” SIGNAL

You may disable cookies through your browser settings, but Identy does not change the way it responds to a “Do-Not-Track” signal.

13. LINKS TO 3RD PARTY SITES

Our Services include links to other websites whose privacy practices may differ from those of Identy. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to be aware when you leave our Services and carefully read the privacy policy of any website you visit. This Policy only applies to the information collected through the Identy Services.

14. ACCESS RIGHTS TO INFORMATION

If you wish to access, correct, delete or update your personal information, please email us at contact@identy.io. We will respond to reasonable requests in accordance with relevant data protection laws.

15. INTERNATIONAL USERS & DATA

As a global organisation, Identy may store, use, transfer, and otherwise process your personal information in countries outside of the country of your residence, including the United States and possibly other countries. By using our Services, you consent to Identy’s transfer to and handling of your personal data in a jurisdiction which may have different data protection rules than the country in which you reside.

16. CONTACT US

If you have any questions about this Policy, our data handling practices, or your dealings with our Services, you can contact us at privacy@identy.io

IDENTY Inc
8 The Green, Suite 7471 Dover, DE 19901
United States

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