Introduction

At inPhronesis (“we”, “us”, or “our”) we are committed to safeguarding the privacy of our website visitors and the users (“user” or “you”) of the inVision services.

A reference to “inPhronesis”, “we”, “us”, or the “Company” is a reference to inPhronesis, Inc. and it relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data.

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy.  Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

Responsible inPhronesis entity

inPhronesis is the controller of your Personal Data as described in this Privacy Policy, unless specified otherwise.

Please note that this policy applies where we are acting as a data controller with respect to the Personal Data of our website visitors and inVision users.  For many corporate users of the inVision services, inPhronesis is acting as a data processor for your corporate entity, and we will be bound by their data sub-processor requirements. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement.

Processing activities covered

This Privacy Statement applies to the processing of Personal Data collected by us when you:

• Visit our websites (such as inPhronesis.com) that display or link to this Privacy Statement
• Visit our branded social media pages
• Receive communications from us, including emails, phone calls, texts or fax
• Use our inVision services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data
• Register for, attend, or take part in our events, webinars, or contests

Processing of Personal Data is required for receiving certain products or services.

Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.

What Personal Data do we collect?

The Personal Data we collect directly from you may include identifiers, professional information, commercial information, and internet activity information.  We collect this information in the following situations:

• If you express an interest in obtaining additional information about our services, request support, use our “Contact Us” form, register for an event or webinar, we may require you to provide us with you contact information such as your name, job title, company name, phone number, email address, or username and password.
• If you interact with our websites, services, or emails, we may automatically collect information about your device and your usage of our websites, services or emails. This may include IP addresses, cookies, web beacons, or similar technologies and may qualify as Personal Data.
• If you interact with our inVision service, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data.
• If you communicate with us via phone, we may (with your consent) record the call.

Personal Data we collect from other sources

We also collect information about you from other sources including third parties and publicly available information.  We may combine this information with Personal Data provided by you.  This helps us to update, expand, and analyze our records, identify new customers, and create more tailored service offerings that may be of interest to you.  We may collect such Personal Data from the following sources:

• Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information.
• Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services.

Use of your Personal Data

We collect and process you Personal Data for the following purposes.  Where required by law, we obtain your consent to use and process your Personal Data, otherwise we rely on another authorized legal basis, such as a) performance of a contract or b) legitimate interest.

• Providing necessary functionality for our website and services. We process your Personal Data to perform our contract with you or your corporation for the use of our websites and services and to fulfill our obligations under the applicable terms of use and service; if we have not entered into a contract with you or your corporation, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request.
• Promoting the security of our websites and services. We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others.
• Managing user registrations. If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service.
• Handling contact and user support requests. If you fill out a “Contact Us” web form or request user support, or if you contact us by other means including via a phone call, text, or email, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you.
• Managing event registrations and attendance. We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform our contract with you.

Complying with legal obligations. We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.

Your rights relating to customer data

As described above, we may also process Personal Data submitted by or for a customer to our inVision services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data (see the “Responsible inPhronesis entity” section above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement. If your data has been submitted to us by or on behalf of a inPhronesis customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the inPhronesis 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.

Additional Disclosures for Minors

Our websites and services are not directed at minors/children. We do not knowingly collect Personal Data from children under the age of 16 unless the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section below and we will take steps to delete their Personal Data from our systems.

Additional Disclosures for California Residents

The California Consumer Privacy Act requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data. We may share Personal Data with third parties or allow them to collect Personal Data from our sites or Services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use the inPhronesis websites or Services to interact with third parties or direct us to disclose your Personal Data to third parties.

Additional Disclosures for European Residents

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at support@inphronesis.com or by mail using the details provided below:

inPhronesis, LLC
37 N Orange Avenue, Suite #332
Orlando, FL  32804

Last Updated: May 27, 2022