ITN International Inc. (“ITN”, “itn”, “us”, “we”, or “our”) operates the www.itnint.com website and a series of other websites, web applications, mobile applications (collectively, the “Sites”), as well as, email communications, mobile messaging, social media interaction, products and related software applications (the “Communications Tools”).
Our commitment to your privacy, is based on the following principles which we apply to our use of both your personally identifiable data (“Individual Data”) and to certain anonymous information we collect when you visit our Sites (“Technical Information”, and together with Individual Data, “Your Data”):
We collect Your Data in the following basic ways:
On the Sites, we may request certain Individual Data, for purposes such as registering for an event, participating in discussion groups, submitting inquiries and comments, or when subscribing to or using one of our Services. This may include name, title, company/organization name, postal address, email address, work, home and mobile phone numbers. See our Frequently Asked Questions (FAQs) for a list of specific data elements we may request and collect.
We or our authorized vendors may collect Technical Information that is not associated with any individual User. This information includes:
In addition, we will use Your Data to:
We will only use Your Data in reliance on a valid legal basis for such use. Our goal and commitment is to inform you when we would like to use Your Data, the purposes for which we will use it and the legal basis for our use. We may ask for your express consent to the use of Your Data. There may be a contractual relationship between you and ITN (the contract does not have to be in writing) where we need to use Your Data to provide you with the services you are entitled to under the agreement. We will tell you when we are relying on our obligation to comply with our contractual obligations to you for the use of Your Data. Under limited circumstances, we may rely on a “legitimate interests assessment” where we take into account your expectations about our use of Your Data and the limited way we will use Your Data, always seeking to maximize your privacy.
Our collection and use of any of Your Data is subject to the laws and regulations of the countries and political subdivisions in which you reside or of which you are a citizen. We are and remain committed to complying with all such legal obligations and use these legal requirements as the minimum beginning point for our use and collection of Your Data. Included in these laws and regulations are (a) the General Date Protection Regulation (“GDPR”), which governs among other things, consents, uses and cross-border transfers of personal data concerning European Economic Area, Swiss and United Kingdom residents and citizens, and (b) the California Online Privacy Protection Act, governing such matters with respect to California residents. If you have any questions regarding this Privacy Statement or you feel that the Sites are not following these legal requirements or our stated information policy, please contact us by email to firstname.lastname@example.org or at the address set forth below. You may also contact us at that address if you have any concerns about the accuracy of, or wish to correct, your Individual Data we have collected from you.
While no data transmission over the Internet can be guaranteed to be 100 percent secure, we take reasonable and appropriate measures designed to protect the security of data transmitted to us upon receipt. ITN uses reasonable efforts to maintain the accuracy and integrity of Your Data and to update it as appropriate. ITN has implemented physical and technical safeguards to protect Your Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored data is stored on a secure network with firewall protection, and access to ITN’s electronic information systems requires user authentication via password or similar means. ITN also employs access restrictions, limiting the scope of employees who have access to your Data.
Further, ITN uses secure encryption technology to protect certain categories of personal data.
ITN has been certified under both the European Union and Swiss the Privacy Shield frameworks (collectively, “Privacy Shield”) to establish and maintain an adequate level of “Personal Data” (as defined in the GDPR) privacy protection. Privacy Shield to the processing of Personal Data of individuals located in the European Economic Area, the United Kingdom and Switzerland.
The Federal Trade Commission (FTC) has jurisdiction over ITN’s compliance with the Privacy Shield/ITN will renew its Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, ITN will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Personal Data are accurate and that we have appropriately implemented these practices. Specifically, as part of the verification process, ITN will undertake the following:
Confirm that you are made aware of the process for addressing complaints and any independent dispute resolution process (ITN may do so through its Sites, customer contracts, or both);
Review its processes and procedures for training our employees about ITN’s participation in the Privacy Shield program and the appropriate handling of Personal Data; and
ITN will prepare an internal verification statement on an annual basis.
ITN has designated the Technology Department to oversee its information security program, including its compliance with the Privacy Shield program. The Technology Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to email@example.com.
ITN will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. ITN personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that ITN has undertaken to protect Personal Data.
In compliance with the Privacy Shield Principles, ITN commits to resolve complaints about your privacy and our collection or use of your Personal Data. Anyone with questions or concerns about the use of their Personal Data should contact us at: firstname.lastname@example.org.
If your question or concern cannot be satisfied through this process ITN has further committed to refer unresolved privacy complaints under Privacy Shield to an independent dispute resolution mechanism.
If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by ITN, Data Subjects under the GDPR may bring a complaint before the EU DPA independent recourse mechanism (“IRM”). Finally, as a last resort and in limited situations, Data Subjects may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
ITN commits to cooperate with EU data protection authorities (“DPAs”) and comply with the advice given by such authorities with regard to data transferred. ITN further commits to cooperate with the Swiss Federal Data Protection and Information Commissioner with regard to data received from Switzerland.
ITN commits to resolve complaints about your privacy and our collection or use of your personal information. Data Subjects with a question or concern about the use of their Personal Data should contact us at: email@example.com
We will only retain Your Data in accordance with the legitimate needs of our business and as required or permitted by applicable law. We will not retain any unused Personal Data on our systems longer than necessary for legitimate business purposes or we no longer have a valid legal basis for retaining the information.
We respect enhanced user privacy control and support the development and implementation of a standard “Do Not Track” (DNT) browser feature, designed to provide users universal and persistent control over the collection, sharing and use of information by third parties regarding their web-browsing activities. Once the specification is finalized we intend to honor user’s requests with respect to browser tracking.
The Sites are not targeted at, directed to or intended for the use of children under the age of thirteen. No person under the age of thirteen should use any Site or under any circumstances provide any Individual Data or other information at a Site. If you become aware that any individual under the age of thirteen has used any Site, please contact us immediately at firstname.lastname@example.org. By use of any Site you represent and warrant that you are over the age of thirteen.
California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Individual Data to any third parties for their direct marketing purposes. As stated in this Privacy Statement, we will not sell your Individual Data to other companies and we will not share it with other companies for them to use for their own marketing purposes without your consent. For further information concerning your California Privacy Rights including “Do Not Track,” visit https://oag.ca.gov/sites/all/files/agweb/pdfs/cybersecurity/making_your_privacy_practices_public.pdf
We do not knowingly allow other parties to collect personally identifiable information about your online activities over time and across third-party web sites when you use the Sites. We provide information about the opt-out or opt-in choices available to users.
We routinely update this Privacy Statement to provide additional explanation and clarification of our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to our Sites. You can determine when this Privacy Statement was last revised by referring to the Effective Date above on this page. We will also provide an archive of our past privacy policies with the ability to plainly see the changes from one to another. Any changes to this Privacy Statement will also be announced on our home page.