July 1st, 2019
InConnect is dedicated to offer intelligent and customized protection solutions to customers for modern connected lifestyles. As part of this fundamental obligation, InConnect is committed to the appropriate protection and use of personal information (sometimes referred to as "personally identifiable information" or "PII").
If you have any questions, please contact us at firstname.lastname@example.org .
Personal Information InConnect collects and controls
We collect information about you only if we need the information for some legitimate purpose. InConnect will have information about you only if (i) you have provided the information yourself, (ii) InConnect has automatically collected the information, or (iii) InConnect has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
We only collect the information that we actually need. Some of that is information that you actively give us when you sign up for an account, register for an event, ask for customer support, or buy something from us. We store your name and contact information, but we don't store credit card numbers (except with your permission and in one of our secured payment gateways).
When you visit one of our websites or use our software, we automatically log some basic information like how you got to the site, where you navigated within it, and what features and settings you use. We use this information to improve our websites and services and to drive new product development.
Information entrusted to InConnect and purpose
You may entrust information that you or your organization (“you”) control, to InConnect in connection with use of our services or for requesting support for our products. This includes information regarding yourself, your family, your location, your home and its safety measures, your connected devices, your assets and your means of transportation. The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for support or other services. Our applications only process PII that is required to provide our services. All the information entrusted to InConnect is collectively termed “service data”.
What we do with your information
We use your information to provide the services you've requested, create and maintain your accounts, and keep an eye out for unauthorized activity on your accounts. We also use it to communicate with you about the products you're currently using, your customer support requests, new products you may like, chances for you to give us feedback, and policy updates. We analyse the information we collect to understand user needs and to improve our websites and services.
You can decline certain kinds of information use either by not providing the information in the first place or by opting out later. You can also disable cookies to prevent your browser from giving us information, but if you do so, certain website features may not work properly.
We limit access to your personal information to our employees and contractors who have a legitimate need to use it. If we share your information with other parties (like developers, service providers, domain registrars, and reselling partners), they must have appropriate security measures and a valid reason for using your information, typically to serve you.
We keep your personal information for as long as it is required for the purposes stated in this Privacy
Policy. When we no longer have a legitimate need to process your information, we will delete, anonymize, or isolate your information, whichever is appropriate.
Information that InConnect processes on your behalf
If you handle other people's data using InConnect apps, such as information about your family members, you are entrusting that data to us for processing. If you use an InConnect mobile app and give the app access to your photo library, you are entrusting data to us. The data you entrust to us for processing is called service data.
You own your service data. We protect it, limit access to it, and only process it according to your instructions. You may access it, share it through third-party integrations, and request that we export or delete it.
We hold the data in your account as long as you choose to use InConnect products or services. After you terminate your account, your data will be automatically deleted or anonymized from our active databases within 6 months and from our backups within 3 months after that.
If you are in the European Economic Area and you believe that someone has entrusted your information to us for processing (for instance a company whose services you use), you can request certain actions from us regarding your data. To exercise those data rights, please contact the person or company that entrusted the data to us and we will work with them on your request.
The legal grounds we have to use your personal information
InConnect generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection. The law in Europe allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As
a result, when we process your personal information, we will rely on one of the following processing conditions:
Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting us at email@example.com.
Automatic collection of personal information
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites' features. Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
By navigating on our web sites or entering your login details to access areas reserved for registered users, you agree that we can place these cookies on your computer or internet enabled device.
InConnect uses Google Analytics. More information about how Google Analytics is used by InConnect can be found here: http://www.google.com/analytics/learn/privacy.html
InConnect understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide our services.
Sharing and transfer of personal information
InConnect and third party sub-processors: In order to provide services and technical support for our products, the contracting entity within InConnect engages other group entities and third parties.
Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the InConnect group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyse and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within InConnect.
InConnect does not transfer any personal information outside of the EEA. InConnect will not transfer the personal information you provide to any third parties for their own direct marketing use.
In general, you are not required to submit any PII to InConnect online, but we may require you to provide certain PII in order for you to receive detailed information on your safety situation or additional information about our services and events. InConnect may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an personal safety scores or e-newsletters, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will remove your information promptly, although we may require additional information before we can process your request. Anonymized data for statistical analysis may be retained by us, but this will never contain PII.
If InConnect processes personal information about you, you have the following rights:
Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.
Other rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting InConnect at info@InConnect.io and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
Data security and integrity
InConnect has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than 2 years.
Changes to this statement
InConnect may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
Policy questions and enforcement
InConnect is committed to protecting your personal information. If you have questions or comments about our administration of your personal information, please contact us at firstname.lastname@example.org. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
If you contact us about this privacy statement, we will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds. In any event, you always have the right to lodge a complaint with the Dutch regulator in charge of protecting personal information, the Dutch Data Protection Authority / De Autoriteit Persoonsgegevens (AP).
InConnect, July 1st 2019