Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- Policy Scope
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- How we transfer information we collect internationally
- Other important privacy information
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Subscribers has engaged.
Subscribers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.
We collect information under the direction of our Subscribers and have no direct relationship with individuals whose personal information we process in connection with our Subscriber’s use of our Services. If you are an individual who interacts with a Subscriber using our Services (for example, you are a customer of one of our Subscribers) and would either like to amend your information, have your information deleted, or no longer wish to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.
What information we collect about you
We ask for and may collect personal information about you such as your name, address, phone number, email address, and credit card information, as well as certain related information like your organisation / university name and website name, when you register for an account to use the Our Service (an “Account”).
We refer to any information described above as “Account and Profile Information” for the purposes of this Policy. By voluntarily providing us with Account and Profile Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Information may also be collected when you submit a support ticket or engage in our live chat feature to receive product support or for informational purposes. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you may be asked to provide contact information, a summary of the problem you are experiencing, and other relevant documentation that would be helpful in resolving support related issues.
How We Use Information That We Collect
We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to:
(a) provide, operate, maintain, improve, and promote the Services;
(b) enable you to access and use the Services;
(c) process and complete transactions, and send you related information, including purchase confirmations and invoices;
(d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
(e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at [email protected] or following the unsubscribe instructions included in our marketing communications;
(f) process and deliver contest or sweepstakes entries and rewards;
(g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
(h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
(i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; and
(j) for other purposes for which we obtain your consent.
Legal Basis for Processing (EEA only):
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where:
(a) we have your consent to do so,
(b) where we need the personal information to perform a contract with you (e.g. to deliver the Our Services you have requested), or
(c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further at the bottom of the document.
Sharing Of Information Collected
Third-Party Service Providers:
We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:
In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.
The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We may share information, including personal information, with any member of the International Institute on Ageing, United Nations-Malta (INIA).
With Your Consent:
We may also share personal information with third parties when we have your consent to do so.
International Transfer of Information Collected
Our provides online forms and workflow automation tools. We primarily store personal information about Website Visitors and Subscribers within the European Economic Area (the “EEA”), the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which Our has operations for the purposes described in this Policy.
Whenever INIA shares personal information originating in the European Economic Area (EEA) with INIA entity outside the EEA, it will do so on the basis of its approved binding corporate rules known as Our Service Agreement, which establish adequate protection of such personal information and are legally binding on INIA.
If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information, you acknowledge that your personal information may be transferred to the United States and other jurisdictions in which we operate.
We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to [email protected].
How Long We Retain Your Personal Information:
For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with our internal Data Retention Policy.
Your Privacy Rights
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at [email protected]. Subscribers to our Services may update or change their Account and Profile Information by editing their profile or organization record or by contacting [email protected] for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email [email protected]. Requests to access, change, or remove your information will be handled within thirty (30) days.
An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Subscriber should direct his/her query to the Subscriber (the data controller). Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at [email protected].
If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Websites or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.
Additional Rights for EEA and Certain Other Territories:
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:
- Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
- Right to object to processing: You may have the right to request that Zendesk stop processing your personal information and/or to stop sending you marketing communications.
- Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
- Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.
If you would like to exercise such rights, please contact us at the contact details in Contact Section at the bottom of this document. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. A list of contact details for the EU data protection authorities is available here.
Children’s Personal Information
We do not knowingly collect any personal information from children under the age of Adult Consent, however that age is defined in your locality or region of the world according to local legislation or International Law. Should a regional, local law exist on adult consent, then it is accepted that the age of consent in your locale is 16 (sixteen) years of age. If you are under the age of adult consent, please do not submit any personal information through our Websites or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Websites or Services without their permission. If you have reason to believe that a child under the age of adult consent has provided personal information to us through the Websites or Services, please contact us at [email protected], and we will use commercially reasonable efforts to delete that information.
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
Changes to This Policy
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Websites and the Services.
If you have questions regarding this Policy or about INIA privacy practices, please contact us by email at [email protected].