WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO. WE WILL ALSO SEND YOU AN EMAIL DESCRIBING SUCH CHANGES. PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE MAKE TO THIS PRIVACY POLICY.
1. INTRODUCTION
Infisign Inc. (“Infisign,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Infisign’s Platform (the “Platform”) through Infisign’s website at https://www.infisign.io/ (the “Website”) or Infisign’s mobile application (the “App”).
Infisign is a Business to Business (“B2B”) Information Technology Software As A Service (“SAAS”) product that provides support to services based on Identity Access Management (“IAM”). Infisign as a cutting-edge IAM platform, revolutionizes digital security by leveraging decentralized identity, password less authentication, federation, and privileged access management (“PAM”) capabilities. With its unique approach, Infisign addresses the challenges of traditional IAM systems and offers a comprehensive solution for modern identity management.
Infisign is committed to protecting the privacy of its Users whose information is collected and stored while using Infisign’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.
The capitalized terms have the same meaning as ascribed in our Terms of Use or Terms of Service as applicable, unless otherwise noted here.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.
IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT privacy@infisign.io.
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
2. WHAT INFORMATION DO WE COLLECT?
When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username, phone number, and other personal information. The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us at privacy@infisign.io.
a. Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.
3. HOW DO WE COLLECT INFORMATION?
We collect personal information from you in the following ways:
1. At registration on our Website, App, or Platform;
2. In email, text, and other electronic messages between you and our Website, App, or Platform;
3. Through mobile and desktop applications your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website, App, or Platform;
4. When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
5. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform;
6. When you subscribe to a newsletter;
7. From your responses to a survey;
8. From forms filled out by you; and
9. From records or copies of correspondences (including email addresses) if you contact us;
We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:
1. Usage details;
2. IP addresses;
3. Information obtained through browser cookies;
4. Web beacons on our Website; and
5. Other tracking technologies.
4. HOW DO WE USE YOUR INFORMATION?
We use the information that you provide to:
1. Provide you with information, products, or services requested from us;
2. Present our Website, App, and Platform and their contents to you;
3. Provide you with notices about account and/or subscription, including expiration and renewal notices;
4. Notify you about changes to our Website, App, and Platform and any products or services;
5. Allow you to participate in interactive features on our Website, App, and Platform;
6. Improve the Website, App, and Platform;
7. Improve our customer service;
8. Administer contests, promotions, and surveys or other Website, App, and Platform features;
9. Process transactions;
10. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent; and
11. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 16, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.
5. OUR COOKIE POLICY
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”
We use Cookies on our Website and App to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. You can set your browser to refuse all or some browser Cookies. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.
We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at privacy@infisign.io.
6. HOW DO WE PROTECT INFORMATION WE COLLECT?
Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who may access your personal information that we store and/or process on our Platform and servers in order to provide our Services to you. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third party credit card processor on our behalf. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.
7. DATA SECURITY MEASURES.
a. Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.
b. Fair Information Practice Principles. In the event of a personal data breach, we will notify you within seventy-two (72) hours via (i) email and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
c. Open-Source Software: We use the following open-source software in the provision of our Services:
Name of Open-Source Software
Website
Hyperledger Foundation
https://www.hyperledger.org/projects/aries
OpenID Foundation
https://openid.net/
8. DISCLOSURE OF PERSONAL INFORMATION
There are times when we may share Personal Information that you have shared with us may be shared by Infisign with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Infisign may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:
Disclosure of Personal Information.
1. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
2. We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
3. We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
4. We may disclose personal information for any other purpose for which you have provided it.
5. We may only disclose personal information as described in this Privacy Policy or your consent.
Other Disclosure of Personal Information.
1. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use or Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Infisign our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Infisign, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Third Party Disclosure.
1. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
2. We do not provide non-personally identifiable visitor information for marketing purposes.
Choices Users Have About How Infisign Uses and Discloses Information.
1. Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly.
2. Disclosure of Users’ Information for Third-Party Advertising. Users can opt-out by emailing us their opt-out request at privacy@infisign.io. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Infisign for product purchases, warranty registration, or other transactions.
3. Disclosure of User’s Information for Targeted Advertising. Users can opt-out by (i) logging into the Website, App, or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, as long as Cookies are not disabled or (ii) emailing us their opt-out request at privacy@infisign.io.
9. GOOGLE ADSENSE AND GOOGLE ANALYTICS
Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners.
We have implemented advertising features on our Website, App, and Platform including: (a) remarketing with Google AdSense; and (b) Google Demographics and Interests Reporting.
We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.
10. FOR OUR EUROPEAN CUSTOMERS AND VISITORS
We are headquartered in the United States of America (“U.S.A.”). Most of the operations are located in the U.S.A. Your Personal Information, which you give to us during registration or use of our Website, App or Platform, may be accessed by or transferred to us in the United States. If you are visiting our Web site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.
1. If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).
2. Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.
3. In such situations, however, we will still respond to let you know of our decision.
4. As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.
a. EU Standard Contractual Clauses. On June 4, 2021, the EU promulgated a new set of SCCs (the “New SCCs”), which replaced the old SCCs which had been in place for over a decade. We now comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US and other countries for Processing, as defined in the GDPR. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and conditions in the new SCCs will govern.
b. The New SCCs.
The New SCCs took effect on June 27, 2021.
As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries including the US for processing by us.
You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such Personal Data.
You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the New SCCs rules that apply to Data Importers.
c. Our GDPR Compliance Commitment.
We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect to the transfer or your Personal Data for Processing outside the EU.
As a Data Importer, a User may contact us as set forth in Subsection 11(d) below with respect to the Personal Data we store and process on you.
We hereby notify you that we will be processing, as defined in the GDPR, the Personal Data of your Authorized Users (i.e., those individuals whom you have authorized to access our Platform and to use our Services) in the U.S.A for us to be able to provide the Services to you that we have agreed to do in our definitive service agreement between you and us.
Upon request, we will provide you with a list of your Personal Data that we will process and a copy of the New SCCs under which we will transport your Personal Data for processing.
We hereby warrant that, at the time of agreeing to the SCCs for the transport of your Personal Data, we have no reason to believe that the laws and practices applicable to us as a data processor and a data importer, including those of the U.S.A. are not in line with the requirements of the New SCCs.
If we cannot satisfy any request or dispute to your satisfaction, we will agree to arbitrate or litigate the dispute in the EU jurisdiction in which you reside.
We will only transfer your Personal Data to a third country in accordance with documented instructions from you.
Your Personal Data will be transferred and stored in an encryption format.
Only our employees, who have a need to access your Personal Data to enable us to meet our contractual and legal obligations to you, will be given access to your Personal Data.
Such employees will be given a User Name and Password to access your Personal Data.
We will keep an automated record of all persons who have accessed your Personal Data.
d. Rights of Data Subjects. To make any of the following requests, with respect to this Privacy Policy, our Terms or Use, and/or Personal Data, please contact us (i) via email at privacy@infisign.io, or (ii) by writing to us at Infisign Inc., 22 Henry Road, Branchburg, NJ 08876.
1. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
2. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
3. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
4. Erasure: You can request that we erase some or all of your Personal Information from our systems.
5. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
6. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
7. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
8. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority in the EU. You may contact the UK’s Information Commissioner at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
We will respond to your inquiry within thirty (30) days of the receipt.
11. FOR OUR BRAZILIAN CUSTOMERS AND VISTORS
This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in Brazil (“consumers” or “you”). We comply with the Lei Geral de Proteção de Dados (General Data Protection Law, or LGPD) and any terms defined in the LGPD have the same meaning when used in this Section.
a. Brazilian Data Protection Officer. We have appointed a Brazilian Privacy and Data Protection Officer, Srinivasan MS, privacy@infisign.io, to make sure the privacy rights of our Brazilian users are protected in compliance with LGPD.
b. Data Breach: In the event of a personal data breach, we will notify the User within 72 hours via (i) email, and/or (ii) our Platform notification system on our Website/Platform. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
12. FOR OUR CANADIAN CUSTOMERS AND VISOTRS
This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in Canada (“consumers” or “you”). We ensure with the Personal Information Protection and Electronics Document Act of 2000 (“PIPEDA”) and any terms defined in the PIPEDA have the same meaning when used in this Section.
a. Definition of Personal Information. Any information about an identifiable individual. Whatever may be the physical form or characteristics of a particular regime for “business contact information” (name, position, title, address, professional phone number, etc.)
b. Right to Access Personal Information. You can request to access your personal information we hold about you. We will first confirm whether you have requested such information, explain how we have used your information, provide a list of names with whom your information has been shared and provide a copy of your information in an accessible format and make alternative formats available if requested.
c. Right to Correction/Limited Right to Deletion. You can request us to correct or delete your information IF you demonstrate that the personal information we hold on you is inaccurate. We will delete or correct your information within thirty (30) calendar days. When we delete/correct your personal information we will inform the third parties with whom we have shared your information.
d. Right to be Forgotten. Your information will be kept with us for as long as it is required for the fulfillment of the purposes of Infisign Platform. Unless we otherwise give you notice, we will retain your Information on the Infisign Platform on your behalf until such times as you or we terminate your User Account.
e. Data Breach Notification. We will send a notification to you as soon as feasible regarding the information of any breach that creates a “real risk of significant harm” to you. We keep a record of every data breach and, on request, provide the Office of the Privacy Commissioner with access to the record.
f. Canadian Privacy Officer. We have appointed a Canadian Privacy and Data Protection Officer, Srinivasan MS, privacy@infisign.io, to make sure the privacy rights of our Canadian users are protected in compliance with PIPEDA.
g. Two Factor Authentication. You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Infisign Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Infisign account unless they have access to your login information.
h. Contact Information. You may contact us (i) at privacy@infisign.io or (ii) by writing to us at Privacy Officer, at Infisign Inc., 22 Henry Road, Branchburg, NJ 08876 to (i) make a Personal Information Request, (ii) correct or delete your personal information, (iii) discuss our Privacy Policy and/or anything that has to do with it. We will respond within thirty (30) calendar days of receiving such a request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.
13. FOR OUR CALIFORNIA CUSTOMERS AND VISITORS
1.California Civil Code. Infisign does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@infisign.io or write us at Infisign Inc., 22 Henry Road, Branchburg, NJ 08876. Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at privacy@infisign.io or write us at Infisign Inc., 22 Henry Road, Branchburg, NJ 08876.
2. CPRA. This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Privacy Rights Act that is effective from January 1, 2023 (“CPRA”) and any terms defined in the CPRA have the same meaning when used in this Section.
a. Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. We require such Personal Information to be able to provide to you, our Services. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
b. Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.
c. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.
d.Non-Discrimination Right. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
e. Financial Incentives. However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
f. Contact Information. You may contact us (i) at privacy@infisign.io, or (ii) by writing to us at Privacy Officer, at Infisign Inc., 22 Henry Road, Branchburg, NJ 08876 to (i) make a Personal Information Request, (ii) lodge a complaint about our use or storage of your Personal Information, (iii) ask us to delete such Personal Information, and/or (iv) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.
g. Under 16. We will not sell your Personal Information of any Users, including any persons under the age of 16.
h. Opt In Consent. We will only process, collect, use and store your Personal Information upon receiving your express consent to do so. YOU EXPRESSLY AGREE THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO WINXO COLLECTING, USING, PROCESSING, DISCLOSING, STORING, AND RETAINING YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, OUR TERMS OF SERVICE, AND OUR TERMS OF USE WHEN YOU CHECK THE APPLICABLE BOX SIGNIFYING YOUR CONSENT. YOU EXPRESSLY AGREE THAT THIS CONSENT IS FREELY GIVEN, EXPRESS, AND AFFIRMATIVE.
i. Right to Opt-Out. At any time, upon your request, we will stop selling your Personal Information (sometimes called your Opt Out-Right). You may send the request to Opt Out (i) to privacy@infisign.io, or (ii) by writing to us at Privacy Officer, Infisign Inc., 22 Henry Road, Branchburg, NJ 08876.
j. Data Protection Officer. We have appointed a Privacy and Data Protection Officer, Srinivasan MS at privacy@infisign.io to make sure the privacy rights of our Users are protected.
k. Personal Information that We Store. For your information, we store/collect the following Personal Information on you:
Name
Business Address
Business Email Address
Business Telephone Number
IP Address
Geolocation
Business Title
Employer
13. OTHER STATE PRIVACY RIGHTS.
This Privacy Policy explains how we collect, use, and disclose your Personal Information in the Sections above. This Section describes how to exercise your rights under the various state privacy laws as detailed below (“State Privacy Laws”)
1. Massachusetts. The Massachusetts Data Protection Law (201 CMR 17.00), sets standards for the protection of personal information of residents of Massachusetts. Residents of Massachusetts have the following rights under Massachusetts law (i) the right to request access to their personal information that is held by us and to receive a copy of that information; (ii) the right to request the correction of any inaccurate or incomplete personal information; (iii) the right to request that we delete your personal information; (iv) the right to opt-out of the collection, use, or disclosure of your personal information for marketing purposes; (v) the right to be notified in the event of a data breach involving their personal information; and (vi); the right to Opt-in for collection, use or disclosure of Sensitive Personal Information. Further, you have the right to file a complaint with the Massachusetts attorney general if you believe we have violated the Massachusetts Data Protection Law by calling (617) 727-8400 or filing a complaint at https://www.mass.gov/how-to/file-a-consumer-complaint.
2. Colorado. The Colorado Privacy Act (Colo. Rev. Stat. § 6-1-1301 et seq.) protects the privacy of Colorado consumers. Residents of Colorado have following privacy rights (i) you have the right to opt out of the processing of your personal data for the purposes of targeted advertising, the sale of your personal data or profiling in furtherance of decisions that produce legal or similarly significant effects; (ii) you have the right to confirm whether we are processing personal data concerning you and to access your personal data; (iii) you have the right to correct inaccuracies in your personal data; (iv) you have the right to delete your personal data; and (v) when accessing your data, you have a right to obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
3. Connecticut. Infisign does not sell, trade, or otherwise transfer to outside third parties your “Personal Data” as the term is defined under Connecticut’s Privacy Act and Act Concerning Personal Data Privacy and Online Monitoring. Connecticut Laws permits residents of Connecticut who are Users of our Website, App, or Platform that are Connecticut residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. Further, Users have the right to (i) confirm whether or not we are processing the your personal data and access such personal data, unless such confirmation or access would require us to reveal a trade secret; (ii) correct inaccuracies in the User’s personal data; (iii) opt out of the processing of the personal data for the purposes of targeted advertising, sale, or profiling in furtherance of solely automated decisions; and (iv) you have the right to obtain a copy of your personal data processed by the controller, in a portable and, to the extent technically feasible, readily usable format.
4. Utah. On March 24, 2022, Utah enacted the Utah Consumer Privacy Act (UCPA § 13-61-102(1)) which will go into effect on December 31, 2023. The UCPA gives residents of Utah who are users of our Website and App the right to (i) you to opt out of the processing of your personal data for the purposes of targeted advertising, the sale or profiling; (ii) correct inaccuracies in your personal data; (iv) delete your personal data; and (v) obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
5. New York: The New York Privacy Act sets strict rules about how businesses must handle consumers’ personal information and gives individuals new rights concerning data. New York residents have the rights to (i) access, correct, deletion, and disclosure regarding your Personal Information; and (ii) know what personal information is being collected about them, how it is being used, and with whom it is being shared.
6. Virginia. The Virginia Consumer Data Protection Act (Va. Code § 59.1-571 et seq.) effective from January 1, 2023 provides Virginia residents with certain rights regarding the collection, use, and sharing of their personal information namely (i) the right to know what personal information is being collected about them, how it is being used, and with whom it is being shared; (ii) the right to request that a business delete personal information that the business has collected from the resident; (iii) the right to non-discrimination for the exercise of their privacy right; (iv) the right to access the personal information held about them, including the categories of personal information collected, used, shared, and the categories of third parties with whom the information is shared; (v) the right to obtain a copy of their personal information in a structured, commonly used and machine-readable format.
To exercise any of the rights mentioned under Section 11(b), please (i) send an email to privacy@infisign.io, or (ii) write to us at Privacy Officer, Infisign Inc., 22 Henry Road, Branchburg, NJ 08876.
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. We have appointed a Privacy and Data Protection Officer, Srinivasan MS to make sure the privacy rights of our Users are protected.
15. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@infisign.io.
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.
16. CAN-SPAM ACT OF 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
not use false or misleading subjects or email addresses;
identify the email message as an advertisement in some reasonable way;
include the physical address of Infisign Inc., which is 22 Henry Road, Branchburg, NJ 08876;
monitor third-party email marketing services for compliance, if one is used;
honor opt-out/unsubscribe requests quickly; and
give an “opt-out” or “unsubscribe” option.
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@infisign.io and we will promptly remove you from all future marketing correspondences.
17. MODIFICATIONS TO OUR PRIVACY POLICY
We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web page with a hyperlink thereto. We will also send you an email describing such changes. Please regularly review this Privacy Policy. Notwithstanding if you continue to use our services, you are bound by any changes that we make to this Privacy Policy.
18. LIST OF THIRD-PARTY SERVICE PROVIDERS
Infisign uses the following third-party service providers for the provision of services as detailed under the Terms of Use or Terms of Service, as applicable
Amazon Web Services Inc. (North Virginia, US)
Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/
Address: 410 Terry Avenue North, Seattle, WA 98109-5210
Stripe, Inc.
Email: info@stripe.com
Address: 510 Townsend St, San Francisco, CA 94103
Google Cloud
Website: www.support@google.com">www.support@google.com
Telephone: (855) 817-0841
Microsoft Azure
Website: https://support.microsoft.com/en-us/contactus/
Address: 1 Microsoft Way, Redmond, WA 98052-6399
MongoDB Enterprise
Website: https://www.mongodb.com/
1633 Broadway 38th floor, New York, NY 10019, United States
Docker Hub
Website: https://www.docker.com/
Docker, Inc. 3790 El Camino Real # 1052, Palo Alto, CA 94306
Telephone: (415) 941-0376
Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@infisign.io.
19. COPYRIGHT INFRINGEMENT/DMCA NOTICE
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
1. Your physical or electronic signature;
2. Identification of the copyrighted work(s) that you claim to have been infringed;
3. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;
4. Sufficient information to permit us to locate such material;
5. Your address, telephone number, and email address;
6. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
7. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
Infisign’s Copyright Agent to receive DMCA Takedown Notices is Arunachalam S., at dmca@infisign.io and at Infisign Inc., Attn: DMCA Notice, 22 Henry Road, Branchburg, NJ 08876. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Infisign Inc. in connection with the written notification and allegation of copyright infringement.
20. ANTI-BRIBERY COMPLIANCE
Infisign Inc. represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Infisign represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”). Infisign further represents and warrants that, to its knowledge, neither it nor any of the Officials has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Infisign, or (B) the obtaining or retention of business by Infisign. Infisign further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Officials.
21. CONTACT US
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
Privacy Officer: Srinivasan MS
Email: privacy@infisign.io
Address: Infisign Inc., 22 Henry Road, Branchburg, NJ 08876
PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE OR OUR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.