Updated: 31-Dec-2018

Effective: 1 -Nov-2018

General

At Innowrap Technologies (“Innowrap,” “we,” or “us”), we respect your online privacy. This Privacy Policy describes how we collect, use, and share information in connection with our mobile app Upscaler, owned and operated by Innowrap, as well as our on-demand services delivered via our mobile app, mobile site, or software development kit (SDK) (collectively, the “Services”). It also explains your rights and choices with respect to such information and the steps you can take to protect your privacy.

Please read this Privacy Policy carefully and write to us at banca@innowrap.com if you have any questions. As a condition of using the Services, you consent to the terms of this Privacy Policy as it may be updated from time to time.

Information that We Collect:

We and our service providers collect a variety of information through the Services, including:

• Registration information. During the registration process for creating a user account, we request your user id and email address or phone number.
• Information provided by your employer or other organization. We receive information from our customers and organizations, who invite their employees or members to use the Services. This may include your name, phone number, email address, date of birth, employee number, department, designation or job title within your company, general location, and other information associated with your employee profile.
• User content, social activities, messages, and survey information. We collect information when you use and interact with the Services, such as when you participate in Poll or survey, view products, campaigns, news, notification or undergo training through the Services.
• Device information. We may request access to information stored on your device, such as contacts in your phone or address book and files or photographs that you upload to the Services. This information may include third-party names, email addresses, phone numbers, and physical addresses and will be used to provide the Services and certain features of the Services to you.
• Usage details.We collect certain information about how you use the Services, such as time, frequency, duration, and pattern of use, features used, information regarding active and inactive users.
• Information collected automatically. When you use our Services, we or our third-party service providers may automatically receive and record certain information. For example, we collect Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, platform (such as iOS or Android), device make and model, operating system type and version, and other visitor details (such as usage details described above). We link this automatically collected data to other information we collect about you. To obtain such information, we or our partners, affiliates, or service providers may use the following technologies to recognize your device and collect information about your Services usage:
• Server logs. When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use server logs or applications that recognize your device and gather information about its online activity.
• Cookies. We also use cookies on the Services. Cookies are small files that are stored on your device by your web browser. A cookie allows us to recognize whether you have visited before and may store user preferences and other information. We use temporary and permanent cookies to enhance your experience of our Services. Temporary cookies will be removed from your computer each time you close your browser. If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.
• Web beacons, tags, pixels, scripts, and similar technologies. The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “tag” or “pixel”), scripts, and similar technologies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For example, it may allow an email sender to determine whether a user has opened a particular email.
• Local Storage Objects. We use Local Storage Objects (LSOs), such as HTML5, to store content information, preferences, and to keep you signed-in. Third parties with whom we partner to provide certain features on our site may also use LSOs such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
• Device IDs. We may use device identifiers (such as tokens that identify your specific device or installation of the Noticeboard app and mobile advertising IDs like Apple’s IDFA or Google’s Advertising ID) to send push notifications and to collect information for analytics purposes, including as described in the section below titled “Third-Party Analytics.”

We may combine information collected through the Services with information that we collect in other contexts, such as information from our email communications or phone calls with you. We will treat such combined information in accordance with this Privacy Policy.

How We Use Information that We Collect

We and our service providers use the information that we collect for a variety of purposes, including:

• Providing the Services. To provide our Services to you, fulfill the terms of any agreement you have with us, respond to your requests, and for other purposes related to managing our business.
• Communicating with you. To communicate with you regarding your account, send notifications from groups or administrators, and provide you with important updates regarding our Services.
• Sending newsletters or other promotional messages. To send you newsletters or other promotional messages regarding our Services, new services, releases, and upcoming events.
• Conducting analytics and improving our Services.To count and recognize visitors to the Services, analyze how visitors use the Services, personalize your experience, improve the Services, create new products and services, and conduct analytics, including as described in the section below titled “Third-Party Analytics.”
• Compiling aggregated and de-identified information. To compile aggregated and de-identified statistics or reports that we may share with our affiliates, business partners, or other third parties.
• Legal purposes. For legal or other necessary purposes, including as described below in the section below titled “How We Share Information.”

How We Share Information

We share information with third parties for a variety of reasons, including as follows:

• Affiliates. We share information with our corporate affiliates to provide the Services to you and to fulfill the purposes described in this Privacy Policy.
• Service providers. We use third-party service providers to help us manage and improve our Services. These service providers may collect and use your information to assist us in achieving the purposes discussed in this Privacy Policy. For example, we may use third parties to assist with data storage, database management, analytics (including as described in the section below tiled “Third-Party Analytics”), and communicating with users.
• Your employer or organization. We allow your employer or other organization to access certain information about your account. For example, we may provide them with information about whether your account is active, your pending invitations, tasks assigned to you, responses that you send, and other information about your use of the Services.
• Other users of the Services. We allow you to share information directly with other users of the Services. For example, if you send messages, post questions or comments, respond to surveys or requests to rate the mobile apps, or use other features of the Services, then such information may be seen by other users of the Services. Please ensure when using these features that you do not submit any information that you do not want to be shared with other users or the public.
• Third-party plugins. The Services may integrate third-party plugins (such as a Facebook “like” button and Twitter “follow” button). Even if you do not click on these plugins, they may collect information about you, such as your IP address and the pages that you view on our Services. They also may set and/or access a cookie or use similar tracking technologies. These plugins are governed by the privacy policy of the company providing them.
• Business transfers. We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets. If Innowrap is involved in a merger, acquisition, or sale of all or a portion of its business or assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.
• Legal purposes. We may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:
• To comply with applicable law or a court order, subpoena, or other legal process;
• To investigate, prevent, or take action regarding illegal or prohibited activities, suspected fraud, violations of our rules or terms and conditions, or situations involving threats to other users, our property, or the property or physical safety of any person or third party; and
• To establish, protect, or exercise our legal rights or defend against legal claims.
• Aggregated and de-identified information. We may share aggregated and de-identified information regarding visitors and users with our affiliates, business partners, or other third parties.

Third-Party Analytics

We partner with certain third parties to collect information to engage in analytics, auditing, research, and reporting, including to analyze trends, administer the Services, track users’ movements on the Services, and gather demographic information about our user base as a whole. These third parties may use server logs, web beacons, tags, pixels, scripts, device IDs, and similar technologies, and they may set and access cookies on your computer or other device to track your online activities over time and across unaffiliated websites and services.

In particular, our Services use firebase analytics to help collect and analyze certain information for the purposes discussed above. You may learn more about Firebase Analytics’ data practices by clicking here.
Please note that our Services do not respond to browser Do Not Track signals at this time.

Your Rights and Choices

We provide you with choices to review, access, and update your information or to exercise your data protection rights, as follows:

• You may correct, update, or remove information associated with your account by requesting your employer.
• You may have additional rights under applicable laws to request access to, correction of, deletion of, or restrictions on the processing of certain information. You also may have rights under applicable laws to opt out of or withdraw consent to further processing, request copies of your data, or lodge a complaint with a data protection authority in your jurisdiction. To make such request and/or inquire about such rights, please send us an email at banca@innowrap.com with “Attn: Privacy/Legal” in the subject line. For your protection, we may only implement requests related to information that we have associated with the email address you use to send us your request, and we may need to verify your identity before implementing your request.

Information Security and Retention

We adopt reasonable physical, technical, and administrative security measures to protect against unauthorized access, alteration, disclosure, or destruction of your information. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information.

We and our service providers may retain and use your information for as long as reasonably necessary for our legitimate business purposes, to provide the Services to you, to fulfill the purposes described in this Privacy Policy, or as necessary to comply with our legal obligations, resolve disputes, and enforce our rights.

Links from Our Services

The Services may contain links to websites or mobile apps of other third parties, If you follow a link to any of these websites or apps, please note that these websites and apps (and any services that may be accessible through them) have their own privacy policies. We are not responsible for the privacy practices of other websites or apps or the information you share through such other websites or apps. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites and apps. This Privacy Policy applies solely to information collected in connection with the Services.

Children’s Information

The Services are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws. We request that such individuals do not provide information to us through any of the Services.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive information (e.g., social security numbers, financial account information, information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or sexual orientation) on or through the Services or otherwise to us.

Amendments to This Privacy Policy

We may amend this Privacy Policy periodically in the future. Amendments to this Privacy Policy will be posted to this URL and in our mobile apps and will be effective when posted unless otherwise indicated. You should frequently visit this Privacy Policy to check for amendments. Your continued use of the Services following the posting of any amendment, modification, or change to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Services if you do not accept the terms of this Privacy Policy or any modified version of this Privacy Policy.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us at banca@innowrap.com with “Attn: Privacy/Legal” in the subject line.