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Start Free TrialThis privacy notice (this "Privacy Notice") describes how Incompass Labs, Inc. ("us", "we", or "our") collect, handle, share and use the personal data / personally identifiable information ("Personal Data") of individuals ("you" or "your") who:
We shall act as an independent controller of your Personal Data that is collected or received in accordance with this Privacy Notice. If we process Personal Data as a data processor, we will process such Personal Data in accordance with the terms of the contract we have with the third party for whom we act as data processor, and this Privacy Notice shall not apply to the processing of such Personal Data.
This Notice does not apply to individuals who are applying for a role with us, or if who are a current employee or staff member of ours.
To receive this notice in another format please contact us using the contact details in section 14 below.
You may provide to us (whether by uploading, email or otherwise) the following types of Personal Data when using the Website, or when otherwise interacting with us, which we may then collect, use, store and/or transfer in accordance with this Privacy Notice:
| Type of Personal Data | Personal data includes: |
|---|---|
| Contact Data |
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| Identity Data |
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| Financial Data |
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| Profile Data |
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| Transaction Data |
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| Marketing and Communications Data |
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We may receive the following types of Personal Data which is automatically collected or logged from our information systems or third parties when you access and use the Website or otherwise interact with us, which we may then collect, use, store and/or transfer in accordance with this Privacy Notice:
| Type of Personal Data | Personal data includes: |
|---|---|
| Technical Data |
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| Usage Data |
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| Monitoring Data |
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Please see section 5 below for details on how we use cookies.
We do not collect any special categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Under Age 13 in the EEA or UK. The features, programs, promotions and other aspects of our Services requiring the submission of Personal Data are not intended for children. We do not knowingly collect Personal Data from persons under the age of 13. Parent or guardians of a child under the age of 13 believing such child has disclosed Personal Data to us, can contact us using the contact details at section 14 below. A parent or guardian of a child under the age of 13 may review and request deletion of such child's Personal Data as well as prohibit the use thereof.
Under Age 18 in the United States. Persons under 18 years of age in the United States may have the Personal Data that they have provide to us deleted by sending an email to us using the contact details at section 14 below requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your Personal Data does not ensure complete and comprehensive removal of that data from all systems.
This section sets out how we use the Personal Data that we obtain or receive and our lawful basis under the data protection laws of the EEA and UK for doing so:.
| Purpose | Type of Personal Data | Lawful basis for processing | Details |
|---|---|---|---|
| To monitor the use of the Website |
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| To operate our business and to improve the functionality and content of the Website. |
| To contact you who request such contact (including via the contact us page) |
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| To respond to your contact requests. |
| To create and maintain your accounts |
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| To enable you to use the Website, including access to your account. |
| To manage and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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| To manage our business and ensure the effective provision of the Website. To prevent fraud. |
| To undertake identification verification |
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| To protect our business and to prevent fraud. |
| To use data analytics to improve the Website |
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| To keep the Website updated and relevant and to optimize it. To develop our business and inform our marketing strategy. |
| To send personal marketing and promotional materials to you as individuals, including newsletters |
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| To promote our products and services. |
| To send marketing and promotional materials to you in a business context, including newsletters |
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| To promote our products and services. |
| To enable you to complete a survey |
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| To obtain feedback from you on our products and services so that we can make improvements to them. |
If you have provided consent to processing and subsequently withdraws that consent, we may still process your Personal Data where we have another lawful basis for doing so.
Where we need to collect Personal Data by law or under the terms of a contract that we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have with you.
We may share your Personal Data with the following categories of third parties:
| Third Party | Description |
|---|---|
| Service Providers | Our service providers include third parties that provide us with services such as IT services, hosting services, administration services and other business process services, marketing services. Such third parties will act as our processors. |
| Professional advisors | We may need to provide your Personal Data to our professional advisers that provide services to us. Our professional advisors include lawyers, accountants, bankers, auditors and insurers. Such third parties may act as our processors or independent controllers. |
| Authorities | We may disclose Personal Data where required in order to respond to requests from regulatory or governmental authorities, court orders, legal process, or to establish or exercise our legal rights or defend against legal claims. It may also be necessary for us to share Personal Data in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law. In such circumstances, we will take appropriate measures to ensure that the recipient understands the sensitive nature of the Personal Data that they may receive. |
| Other Third Parties | We may share your Personal Data with third parties to whom we may choose to transact business with. We may share your Personal Data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (including in relation to restructuring/insolvency situations). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice. Your Personal Data may be a transferred asset in any sale of all or part of our business. |
| Affiliates | Your Personal Data might also be transmitted within the group of which we are members for internal administrative purposes. |
We require all our data processors and any other third party that we provide your Personal Data to respect the security of your Personal Data and to treat it in accordance with applicable law.
We do not allow our data processors to use your Personal Data for their own purposes and only permits them to process your Personal Data for specified purposes and in accordance with our instructions.
Please see Section 7 below for information on international transfers to such third parties.
Please see our cookies policy.
We may send you marketing communications (including newsletters) if you have requested such communications from us or if you have purchased goods or services from us and you have not opted out of receiving future marketing communications.
We will obtain your explicit consent before we share their Personal Data with any company outside of our group of companies for marketing purposes.
If you do not wish to receive marketing information from us, you can opt-out by contacting us using the contact details at section 14 below or by clicking the opt-out link in our electronic marketing communications.
Your Personal Data collected by us in the UK or the EEA may be transferred outside of the UK or the EEA (as applicable) to those third parties specified in section 4 above; however, in such circumstances we will ensure contractual or other measures that have been adopted or approved by the UK Government, or the European Commission o (as applicable) are taken (such as ensuring applicable standard contractual clauses are in place).
You can obtain more information about the countries to which your Personal Data is transferred and copies of the additional measures put in place by contacting us using the contact details at section 14 below.
The security of your data is very important to us. We have implemented appropriate security measures preventing your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, you should know that no website operator, including us, can fully eliminate security risks associated with Personal Data. While we have endeavored to create a secure and reliable Website for users, the confidentiality of any communication or material transmitted to/from the Website or via e-mail cannot be guaranteed.
We do not make any decisions regarding you solely using automated decision making (including profiling) based on your Personal Data.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for Personal Data are available from us on request using the contact details at section 14 below.
If you are resident in the European Economic Area or the United Kingdom you have the following rights, as a data subject, under applicable data protection laws in relation to your Personal Data:
| Your right | Description |
|---|---|
| Request access to your Personal Data | This enables you to receive a copy of its Personal Data that we hold and to check that we are lawfully processing it. You will not have to pay a fee to access their Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. |
| Request correction of the Personal Data that we hold about you | You can require us to correct any mistakes in your Personal Data. You must provide us with enough information to identify you (e.g., username, institution's details) and let us know the information that is incorrect and what it should be replaced with. |
| Request erasure of your Personal Data | This enables you to ask us to delete or remove your Personal Data where there is no permitted reason for us to continue to process it. You can ask us to erase your Personal Data where:
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| Object to processing of your Personal Data | Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms. |
| Request restriction of processing of your Personal Data | This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
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| Request the transfer of your Personal Data to you or to a third party | You can require us to provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated Personal Data that you initially provided consent for us to use or where we used the Personal Data to perform a contract with you. |
| Withdraw consent at any time where we are relying on consent to process your Personal Data | This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with access to the Website, our premises or comply with any contract we have with you. We will advise you if this is the case at the time that you withdraw consent. |
To exercise any of the rights set out above, please contact us using the contact details provided in section 14 below. Where you have any such rights under applicable laws, we will respond to your request to exercise such rights within one (1) month of receiving the request, unless the request is complex, in which case it may take longer.
We may need to request specific information from you to help us confirm your identity and your right to access the Personal Data (or to exercise any of its other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask it for further information in relation to your request to speed up our response.
Please be aware that there are exceptions and exemptions that apply to some of the rights, which we will apply in accordance with the applicable data protection laws.
In addition to the above rights, you have the right to lodge a complaint with a supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority and if you reach out using the contact details provided in section 14 below in the first instance.
If you are a resident of California (including California business contacts), Colorado, Connecticut, Utah, or Virginia, the law in your state provide you with the following rights with respect to your Personal Data:
Your California, Colorado, Connecticut, Utah, and Virginia Privacy Rights
In addition, and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Notice, what information we may have "sold" or "shared" about you. For the 12-month period prior to the date of this Privacy Notice, we have not sold or shared any Personal Data except for sharing with third parties in accordance with section 4 above.
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Data we have collected about you by contacting us using the contact details provided in section 14 below.
We will respond to your request in compliance with the requirements of your state's applicable laws. Please note that we are only required to honor California requests to know twice in a 12-month period.
When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide us with additional information such as your email address. We may also use a third-party verification provider to verify your identity.
Residents of Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by contacting us using the contact details provided in section 14 below. We will respond to appeals from Virginia and Connecticut residents within 60 days. We will respond to appeals from Colorado residents within 45 days.
If you make a request under your state privacy law, we will not discriminate against you in any way. For example, we will not deny you discounts or other benefits or impose penalties on you or provide you with or suggest that you will receive a different level or quality of benefits or services.
You may permit an authorized agent to submit a request to know or to delete your Personal Data. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Data.
Some internet browsers include the ability to transmit "Do Not Track" signals. Since uniform standards for "Do Not Track" signals have not yet been adopted, we do not process or respond to "Do Not Track" signals.
Our Website may contain links to other websites. These websites may have separate privacy and data collection practices, independent of our practices, and your use and access to such sites is subject to those terms and policies. We have no responsibility or liability for these independent policies or actions and we are not responsible for the privacy practice or the content of such websites.
To ask any questions regarding this Privacy Notice or to exercise any rights, please contact us using the following contact details:
Address: 210 South 25th Street, Philadelphia, PA 19103
Email: support@incompass.io
This Privacy Notice may be revised from time to time, including where we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display a "Last Updated" date in at the top of this Privacy Notice so it is clear when there has been a change. If we make any change to this Privacy Notice regarding use or disclosure of Personal Data, we will provide notice on the Website and as otherwise required. Small changes or changes that do not significantly affect your privacy interests may be made at any time and without prior notice.
