INK CONTENT, INC.
Modified and Effective on October 8, 2021
If you have questions or complaints regarding the Company’s Privacy Statement or associated practices, please contact us at email@example.com.
1. Information You Choose To Submit
As part of the Required Information and in order to provide the Services to you, we store all the content you provide, including but not limited to accounts created for team members, files, pictures, project information, and any other information that you provide to the Services you use. The Company also may collect certain information for auditing and license compliance verification, including data regarding the number of words or documents checked or processed, server IP addresses, email addresses of Users, domain counts and other information deemed relevant, to ensure that the Service is being Used in accordance with the terms of the Software as a Service Agreement.
2. Information We Automatically Collect
We and our third-party service providers may use such Usage Data for a variety of purposes including to diagnose problems with our servers and software, to administer the Site and Services, to gather demographic information and to target advertising to you on the Site and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Site or through the use of the Services in a manner that does not identify personally any specific individual. The Usage Data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.
We, and our vendors, analytics providers, and advertising service providers may use tracking technologies, such as cookies, local storage, and pixel tags.
Cookies and Local Storage
Cookies are used for a variety of purposes including the following:
(a) to track your preferences, such as the address or local zip code you enter;
(b) to access your information when you sign in so we can provide you with your personalized content;
(c) to display the most appropriate advertisements, based on your interests and activity on our Services; and
(d) to help us improve the Services by analyzing and estimating our traffic and use of features on the Services. You can find more information about cookies and how they work at http://www.allaboutcookies.org/.
A Flash cookie is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you onto your device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit here. If you choose to adjust your Flash privacy settings on your device some features of the Services may not function properly.
We may also use "pixel tags," which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.
We may use pixel tags, either provided by us or by our third party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Pixel tags may also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
(a) Generally. We may use other companies under agreements with us to serve third-party advertisements when you visit the Site and use the Services. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies' use of their tracking technologies is subject to their own privacy policies, not this one.
(b) Targeted Advertising. In order to serve offers and advertisements that may be of interest to our users, we may display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Information to our advertisers when you interact with an advertisement.
(c) Your Ad Choices. Some of the third party services providers and/or Advertisers may be members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may want to visit www.networkadvertising.org, which provides information regarding targeted advertising and the "opt-out" procedures of NAI members. You can opt-out of our use of your Web site viewing behavior data to serve you interest-based advertising on third-party sites and email newsletters here www.aboutads.info.
If you are accessing the Services through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device's application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information, visit www.aboutads.info.
Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.
(d) Mobile. We may from time to time offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorize us to:
(i) locate your hardware;
(ii) record, compile and display your location; and
3. Information We Receive From Other Sources
4. How we use your personal data
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf our Site, or use certain other site features in the following way, including Personal Information and Usage Data:
- to enable you to use our Services, to create an account or profile, to process information you provide via our Site or Services (including verifying that your email address is active and valid) and to process your transactions;
- to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys and processing survey responses;
- to provide you with information, products, or services that you have requested or that we otherwise believe will interest you, including special opportunities from us and our third-party partners, improve the features algorithms, and usability of our Site, and/or Services;
- to tailor content, recommendations, and advertisements we and third parties display to you, both on the Site and elsewhere online;
- to calculate aggregate statistics on the number of unique devices using our Site, Services and to detect and prevent fraud and misuse of those;
- for internal business purposes, such as to improve our Site and Services;
- to administer and process contests, sweepstakes, and promotions;
- to comply with regulatory and legal obligations; and
5. Legal basis for processing your data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
- Where you have provided consent for us to use your Personal Data.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Where the Company needs to collect and process Data by law, or under a contract that it has entered into with you, and you fail to provide the required Data when requested, the Company may not be able to perform its contract with you.
6. Social Network and Platform Integration
7. Our Information Sharing Practices
The Company uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on the Company’s behalf.
INK Company Affiliates.
The Company may share Data about the Company’s customers with its affiliates to the extent such sharing of data is necessary to fulfill a request you have submitted via our Sites or for customer support, marketing, technical operations and account management purposes.
The Company may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of a business of the Company and/or its subsidiaries or to (1) conform to legal requirements or comply with legal process served on the Company or this website; (2) protect and defend the rights or property of the Company and this website; (3) enforce its agreements with you, or (4) act in urgent circumstances to protect personal safety or the public. In individual instances, the Company may also share with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Data.
Any Data or other information you choose to submit in communities, forums, blogs or chat rooms on our Sites may be read, collected and used by others who visit these forums. If you identify any User Content as public, you are authorizing us to share such information publicly. For example, you may elect to make certain of your User Contents (such as your alias, bio, email or photos) publicly available. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas.
8. Users Residing Outside of the United States and Consent to Transfer
The Services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to and processed in the United States. By using the Site or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen
9. For EU, UK and Swiss Individuals: How does the invalidation of Privacy Shield Affect Transfers of the Company Service Data from EEA or UK to the United States?
On July 16, 2020, the Court of Justice of the European Union (“CJEU”) issued a ruling invalidating the EU-U.S. Privacy Shield program. The Company customers can continue to use the Services and transfer data in compliance with European law such as the GDPR and UK data privacy law, as the Company has Model Clauses incorporated into its data processing agreements in place. In addition, despite the CJEU ruling and while government discussions regarding possible replacement of the Privacy Shield mechanism proceed, the Company will continue to protect European data according to the standards of the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and applicable EU law regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and Switzerland to the United States.
Pursuant to the Privacy Shield Frameworks, EU, UK and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You also have the right to correct, amend, or delete the personal information we hold about you if incorrect or not processed in compliance with the Privacy Shield Principles. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable time frame.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than the parties listed in this Privacy Statement, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request at email@example.com.
The Company’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, the Company remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless the Company proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, the Company commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact the Company at firstname.lastname@example.org. The Company has further committed to refer unresolved privacy complaints covering non-Human Resource data under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/bbb-eu-privacy-shield-consumers/ProcessForConsumers for more information and to file a complaint. If your concern continues to be unresolved, you may pursue binding arbitration through the Privacy Shield Arbitration Panel. To learn more about the Privacy Shield Panel, please visit https://www.privacyshield.gov/article?id=F-The-Arbitration-Panel.
The Company is subject to the investigatory and enforcement powers of the US Federal Trade Commission. The Company may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
The Company primarily stores Data about the Company’s customers and Data about attendees in the United States. To facilitate the Company’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. This Privacy Statement shall apply even if the Company transfers Data about the Company customers or Data about attendees to other countries.
10. For EU and UK Individuals: Your Rights Under GDPR and UK Data Protection Law
If you reside or otherwise find yourself in the territory of Europe or in the UK, we are committed to facilitate the exercise of your rights granted by the EU General Data Protection Regulation and any applicable UK data protection regulation. Otherwise, you can contact us at email@example.com at any time to discuss your privacy concerns. Privacy rights under the EU General Data Protection Regulation and UK Data Protection Law include:
Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or concerns you can contact us any time.
Right of access, objection, restriction of processing, erasure, and portability. You also have the right to withdraw your consent at any time when we process your personal data based on your consent. To exercise these rights, please contact us. Requests to access, change, or delete your information will be addresses within a reasonable timeframe. Please note that if you have registered for an account with the Company, you may generally update your user settings, profile, organization’s settings or event registration by logging into the website or Services with your username and password and editing your settings or profile.
Right to opt-out to direct marketing. You have the right to opt-out at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, or by adjusting your preferences under your profile details on the Company Site. Please note that we reserve the right to send you other communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them.
Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. Contact details for the EU data protection authorities can be found at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Please do not refer GDPR questions or complaints to BBB EU Privacy Shield.
11. How to Exercise Your Rights
To exercise your rights, please contact us by using the information in the “Contact Us” section 18 below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
As described above, we may also process Data submitted or collected by a third party. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Data concerned. We are not responsible for and have no control over the privacy and data security practices of our customers or such third parties, which may differ from those set forth in this Privacy Statement. If your data has been submitted to us by or on behalf the Company customer (or user) and you wish to exercise any rights you may have under applicable data protection laws, please inquiry with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the Company customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
12. Choice/Opt-Out From Communications
We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third party partners, users may elect to modify their preferences by emailing firstname.lastname@example.org. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third-party. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
13. Retention Periods and Deletion
The Company retains your personal information to the extent necessary to reasonably serve customer relations, to meet our compliance and legal obligations, to enhance security and fraud prevention, and for audit purposes. For example, we may retain your information during the time in which you have an account to use our Site or Services and for a reasonable period of time afterward. We may also retain your information during the period of time needed for Us to pursue our legitim business interest, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements. We determine the appropriate retention period for the data on the basis of the amount, nature and sensitivity of your data processed, the potential risk of harm from unauthorized use or disclosure of your data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
If you would like to modify or delete from our database any Personal Information you previously submitted to us, please let us know by emailing email@example.com. Please note that any Personal Information that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain information you may not be able to order services in the future without re-submitting such information.
We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Data we process or use. For example, when you submit any form requiring registration, we use a secure server. The secure server software (SSL) helps protect your information as it travels over the Internet by encrypting that information before it is sent to us. Please note that while we have implemented industry-standard security mechanisms and procedures to protect data from loss, misuse and unauthorized access, disclosure, alteration and destruction, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions.
15. Links to Other Websites and Public Forums
16. Children's Privacy
The Services are intended for a general audience and are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target the Services to children under the age of 13.
18. Contact Us