User Data Rights

INO.com, Inc. is committed to protecting and respecting your privacy. We believe in full transparency when it comes to how we use and protect your personal information. This includes informing you of your rights regarding your personal information that we store.

General Data Protection Regulation (GDPR)

This General Data Protection Notice sets out how we may use, process and store your personal information. We receive that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.

The law that governs personal data in the EU:

REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”). More information on GDPR.

California Consumer Privacy Act (CCPA)

The CCPA (California Civil Code §§ 1798.100 to 1798.199) grants California residents new rights with respect to the collection of personal information.

These rights include:

• The right to know what information is being collected and request the details of the information that is being collected.
• The right to be forgotten upon verified request.
• The right to say “no.”

Use the steps outlined in Data Subject Rights to execute these rights.

Information We Collect From You

When you take an action on the website:

When you sign up for an account, newsletters or direct marketing emails, we may collect your name, email address, zip code, country, language preference, IP address, or other information such as your phone number or postal address.

We may also collect other information that you voluntarily submit in a form on the site or that you share when you contact us.

When you visit the website:

• We may collect technical information about your use of the website, browser type and version, device, and operating system.
• We may also collect your IP Address determine your location
• We may collect the URL information of the webpage you are visiting.

Why Do We Collect Information From You

We may collect and process your information for the following purposes:

• To provide goods or services to you under contract.
• To provide information about our products and services that you have consented to receive.
• To send newsletter emails or direct marketing emails, if you have opted in.
• To record information about email opens or clicks.
• To show interest-based content depending on your geolocation determined by your IP address.

How Do We Share This Information

• To enable our advertising partners to deliver personalized messages that match your interests, including interest-based advertisements.
• Wherever we use Legitimate Interests as a legal basis, we do not serve targeted ads to our users. We only serve contextual ads based on the content of the newsletter.
• Other Third Parties: We may transfer your personal information, with your consent, to a third party as listed in the Consent Management Portal. We will continue to ensure the confidentiality of any personal information and give you notice before personal information is transferred. If there are material changes in relation to the processing of your personal information, we will give you an opportunity to consent to such changes.

If you do not wish to have your email address and contact information used by us to promote our own or third parties’ products or services, you can opt-out by clicking the ‘unsubscribe’ button present in the footer of every email that you receive.

Legal Basis of Processing This Information

• Consent: We will ask for your consent to use your information to show you targeted advertising and profiling, and if you ever share sensitive personal information with us.
• Contractual relationships: If you have signed a contract with us, we’ll need to process your personal information.
• Legal obligations: When strictly necessary, we’ll process your personal information due to a binding legal obligation on us.
• Legitimate interests: So long as our use is fair, balanced, and doesn’t unduly impact your rights, we will collect and process your personal information when we have a legitimate interest that serves our mission, our services, or our activities.

Processing Your Sensitive Personal Data

We do not seek to collect or otherwise process your sensitive personal information (i.e. about race or ethnicity, political opinions, religious or philosophical beliefs, etc.) except where:

• the processing is required or permitted by applicable law; or
• we have obtained your prior explicit consent — for example, when you volunteer to complete an opinion survey that includes your voting intentions.

Use of Cookies

We, as well as other companies, use tracking technologies to collect and store data about your computer or mobile device and your activities on this website. A cookie is a small file that a website places on your computer to store information. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies contain no personally identifiable data, so the protection of your privacy is ensured. Depending on your settings, your Internet browser will automatically accept Cookies. However, you can change your browser settings at any time by visiting the links below.

• Cookie settings in Internet Explorer
• Cookie settings in Microsoft Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS.

If you do not accept the cookies you will still be able to browse our site, but some parts of the site may not work. Read More About Cookies

Google Analytics Cookies:

Google Analytics cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google and how to opt-out of tracking.

Web Beacons and Flash Cookies:

Web beacons, which are also known as clear GIFs, Web bugs or pixel tags, are often used in combination with cookies. They are images (often transparent) that are part of webpages. Web beacons let us collect various site usage information such as pageviews, email opens, and for other related website statistics.

A Flash cookie, also known as a local shared object, is a text file that is sent by a Web server to a client when the browser requests content supported by Adobe Flash, a popular browser plug-in. We may use flash cookies to improve the user’s experience.

Third-Party Cookies:

Some content, including advertisements, on our website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third-party tracking technologies or how they may be used. We urge you to contact the service provider directly if you have any concern about your personal data residing in their systems.

Data Retention Policy

We do not keep your personal information for longer than required. We will keep your personal information:

• For as long as required by law.
• Until we no longer have a valid reason for keeping it.
• Until you request us to remove your information.

How Do We Manage Data On Children

In compliance with Children’s Online Privacy Protection Act (“COPPA”), this Site is not directed at children under the age of 13 and we do not intend to collect any personal identifiable information, such as name, home address, e-mail address, telephone number, or social security number, from children under the age of 13. If you are under the age of 13, please do not provide us with your personal identifiable information.

If you are under the age of 16 (EU & elsewhere), please ask your parent/guardian for their consent before submitting your personal information to this site.

If you have any reason to believe that a child under the age of 13 or 16 has provided us with his or her personal identifiable information, please contact us immediately for removal of that information from our databases.

Data Subject Rights

INO recognizes your legal rights to your data as outlined by the GDPR and CCPA. Contact us at privacy support to access the following rights:

• the right to access personal data held about them;
• the right to object to processing (for example, direct marketing);
• the right to data portability;
• the right to complain about processing carried out by the data controller;
• the right to object to automated decision making;
• the right for the personal data being updated; and
• the right to be forgotten.

Additionally, if you do not want us to use cookies to serve you interest-based advertisements on behalf of our business partners, you may opt out using the Digital Advertising Alliance’s opt-out mechanism, which is available here, and Network Advertising Initiative’s opt-out mechanism, which is available here.

Please note that there are additional companies listed on these sites than those that drop cookies when you visit our website.

Where Do We Store Our Data

We store our data in the US. Wherever we transfer your data outside the US, we do it with the user’s consent. We take sufficient measures to safeguard all personal data that we capture.

ARBITRATION & CLASS ACTION WAIVER

You and INO.com further agree that all disputes arising under this agreement shall be resolved exclusively through binding arbitration before a forum located in Anne Arundel County, Maryland, USA. Any arbitration shall be conducted in our respective individual capacities only and not as a class action or other representative action. You are waiving your right to file a class action or seek relief on a class basis. You also understand that by agreeing to this section, you are giving up the right to litigate in court and agree that any dispute resolution proceeding will only consider your individual claims.

Information Disclosed in Connection with Business Transactions.

Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

Changes To This Notice

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Notice, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site.

If you have any questions about these User Data Rights, the practices of this site, or your dealings with this site, please contact us by sending a letter or email to:

INO.com, Inc.
1 Pennsylvania Plaza
39th Floor
New York, New York 10119

Contact us at privacy support.