Privacy Policy

Privacy Policy

Effective date: August 15, 2018

 

1. Introduction

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”).

 

2. General and Scope

Our Privacy Policy is designed to inform you of our policies and practices regarding the collection, use, and disclosure of personal data when you use the Sites or you or we use the Communication Tools and the choices you have associated with that data, whether you’re an ITN customer, a client’s customer, or an individual using one of our products or services or visiting one of our Sites.

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 will describe Your Data we will collect;
  • We will inform you clearly about our collection and use of Your Data;
  • We will either seek your express informed consent or rely on other lawful bases for the use of Your Data – either way, we will inform you of the basis for our use of Your Data;
  • We will give you control over the privacy preferences that apply to Your Data, including the rights to (a) change your mind about our use, (b) have access to change or correct inaccurate aspects of Your Data, and (c) require that we delete all or parts of Your Data;
  • We will not sell or rent Your Individual Data to others;
  • We endeavor to maximize the protection of Your Data, and provide you with prompt notice in the unlikely event that a data loss incident or breach occurs; and
  • We will endeavor to be completely transparent and open about our data privacy policies and practices.

3. How do We Collect Your Data?

We collect Your Data in the following basic ways:

  • You give it to us when you register on or one of our Sites or for one of our Services or when interacting at one of the Sites.
  • You give it to us in email inquiries or in your public comments;
  • We automatically collect Technical Information when you visit our Sites; and
  • We obtain legally available information from outside sources, including commercially available geographic and demographic information along with other publicly available information, such as public posts to social networking sites.

4. What Information Do We collect?

On the Sites, we may request certain Individual Data, for purposes such as registering for an event, conference, tradeshow or 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.

We or our authorized vendors, customers, or partners may collect Technical Information that is not associated with any individual User.  This information includes:

  • how many visits we have to the Sites,
  • when those Sites are visited,
  • browser types used for Site visits,
  • name of the Internet service providers,
  • the Internet Protocol (IP) address through which you access the Internet;
  • pages that you access while at one of the Sites, and
  • the Internet address of the website from which you linked directly one of the Sites.

5. How Do We Use Your Data Collected at Our Sites?

  • We do not sell or rent any Individual Data supplied by you. We occasionally work with other companies, consultants, and contractors to provide limited services on our behalf, such as website hosting, public relations, mailing, answering customer questions about products and services, and sending information related to our Services. We will only provide those companies the Individual Data they need to perform the service for which they are retained and they agree to treat information confidentially and to only use it for the purposes of providing services under our agreement with them.
  • We may use Your Data to provide you with more effective customer service and to improve the Sites and any related products or services we may provide or make available.
  • We may use your Individual Data to provide you with important information about your use of the Services.
  • We may use Technical Information to periodically analyse Site logs to assess aggregate usage trends in order to better serve the needs of Users and maximize the User viewing experience. Under some circumstances this information may be used for purposes of systems administration, fraud prevention or server troubleshooting and security. This information may also be used to help improve the Sites, analyse trends, and administer the Sites.
  • We may disclose Your Data if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on us or the Sites; (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of our employees and staff, agents, users of our products or services, or members of the public, or (d) effect any merger, acquisition, or sale of all or a portion of our assets, in which case you will be provided notice of the following via email and/or a prominent notice on the relevant Site, (i) the change in ownership, (ii) the uses of Your Data in the transaction, and (iii)choices you may have regarding Your Data. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.

In addition, we will use Your Data to:

  • Provide information or a Service requested by or consented to by you.
  • Assist in the performance of our activities and public interest functions.
  • Comply with relevant contractual obligations with you and other third parties.
  • Improve Site performance and content, including trouble shooting and diagnostics.
  • Improve your engagement and interaction with ITN.
  • Improve our engagement and interaction with you.
  • Confirm your identity.
  • Process a request or payment submitted to us.

6. Legal Bases for Using Your Data

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.

 

7. Compliance

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 privacy@itnint.com 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.

 

8. Data Security

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 will take all steps reasonably necessary to ensure that Your Data is treated securely and in accordance with this Privacy Policy and no transfer of Your Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Data and other personal information.

 

9.Privacy Shield

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.

ITN complies with Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Economic Area, the United Kingdom and Switzerland to the United States.  ITN has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

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.

Privacy Shield Renewal

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:

Review this Privacy Policy, including the sections which address the Privacy Shield to ensure that these policies accurately describe the practices regarding the collection of Personal Data;

Ensure that this Privacy Policy accurately informs you of ITN’s participation in the Privacy Shield program and where to obtain a copy of additional information (e.g., a copy of this Privacy Policy);

Ensure that this Privacy Policy continues to comply with the Privacy Shield principles;

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.

Privacy Shield Oversight

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 privacy@itnint.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.

Privacy Shield-Related Complaints

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: privacy@itnint.com.

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: privacy@itnint.com

ITN notifies individual Data Subjects about its adherence to the Privacy Shield through this Privacy Policy.

Data Retention

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.

 

10. “Do Not Track” Notice

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.

 

11. Children/Minors

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 privacy@itnint.com.  By use of any Site you represent and warrant that you are over the age of thirteen.

 

12.Your California Privacy Rights

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

 

13.California Web Site Data Collection

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.

 

14.Links To Third Party Sites

Our Service and the Sites may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

15.Changes to this Privacy Statement

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.

 

16.Contacting ITN

If you would like to contact us with your views about our privacy practices, or with any inquiry relating to your personal information, or if you do not wish us to continue using your information as outlined above, you can do so by sending an email to privacy@itnint.com or a letter to our Corporate Offices at ITN International, Privacy Policy, 7972 Old Georgetown Road, Suite C, Bethesda, MD 20814 – USA. You can also contact us at +1 801 676 7900 ext. 106.

The authorized EU representative for ITN is Beverley Honey. The contact details related for privacy practices and inquiries can be made by sending an email to: gdpr@itnint.com

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