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Privacy Policy

Last updated:
November 2nd, 2023

Wildfell Software LLC

1001 Wade Ave Ste 327

Raleigh, North Carolina,

USA

We care about your privacy and want you to be informed about how your personal information is used. This Privacy Policy describes the types of Personal Data Wildfell Software LLC dba IGOR (“IGOR,” “we,” “us,” or “our”) may collect from all visitors, users, Subscribers, and Authorized Users ("User," “you,” or "your") or that you may provide to us when accessing and using the Site, our web and mobile applications, or other parts of the Subscription Services (collectively, the "Services"). It also describes our policies and procedures on the collection, use, maintenance, protection, and disclosure of your Personal Data when you access and use the Services and tells you about your privacy rights and the choices you may have with respect to your Personal Data.

We use your personal data to provide and improve our Services. 

If you are a user of our Services, or just visiting our website, this policy applies to you.

Capitalized terms not otherwise defined herein have the meaning set forth in our Subscription Agreement and Authorized User Agreement, which are hereby incorporated by reference.

Please read this Privacy Policy carefully before accessing and using the Services. By using the Services or browsing our website, You agree to the collection and use of information in accordance with this Privacy Policy.

Updates

We reserve the right to modify this Privacy Policy at any time by posting an updated Privacy Policy on the Site. If we make changes, we will notify you by revising the date at the top of the policy. If we make any material changes, we may, at our sole discretion, provide active Subscribers and their Authorized Users with an email notice of those changes. You are responsible for regularly reviewing this Privacy Policy, and your continued use of the Services after we make changes is deemed to be acceptance of the updated Privacy Policy. If any modification is unacceptable to you, you shall cease using the Services, including any Subscription Services to which you have subscribed. If you have any questions about this Privacy Policy or if you wish to exercise any of your rights under this Privacy Policy, you may contact us at support@igorlabapp.com

1. Personal Data We Collect About You

To provide the Services, we may collect Personal Data from you. “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We collect Personal Data from the following categories of sources: (a) directly from you; (b) indirectly/automatically from you; (c) from our Subscribers using the Subscription Services; and (d) from third parties.

1.1 Personal Data We Collect Directly From You

While you are accessing or using our Services, including our Subscription Services, we may ask you to provide us with certain Personal Data about you that is necessary to provide you with our Services, and you may also choose to provide us with additional Personal Data.

You may also provide us with information about you when you fill out a contact form, when you subscribe to our Subscription Services, provide feedback, or request customer support, which may include the following:

 

1.1.1 Contact Information: first and last name, email address, billing address, mailing address, business address, job title, and telephone number;

1.1.2 Personal Data: first and last name, address, and telephone number;

1.1.3 Business Information: business name and address;

1.1.4 Payment Information: our third-party Payment Processor may also collect your credit card number information and provide us with your name, type of service purchased, the date and time of the transaction if you are a Subscriber purchasing Subscription Services;

1.1.5 Account Information: initials, email address, job title, display name, profile picture, account activity, and other text, images, data files, or other information that you post, add, create, input, upload, share, store, access, distribute, submit, link, or otherwise make available in or to your account (“User Content”). The Primary Account Holder may also receive User Content that you make available through the Subscription Services, as detailed in our Subscription Agreement and Authorized User Agreement;

1.1.6 Mobile Device Information: we may access and receive information that you provide us access to, including your camera, when uploading photographs to the Subscription Services;

1.1.7 Communication Information: any content of any communications you send and/or receive through the Services or through other communication, such as email, to or from us;

1.1.8 Customer Testimonials: any customer testimonials and comments on our Services, which you provide us through consent; and

1.1.9 Feedback and Support: information you provide through our customer service helpdesk or via email, including subjects, descriptions, request type, and attachments.

We will not ask or require you to provide sensitive information such as information related to your finances, health, marital status, or any other information not required to provide the Services. We will not ask for, and you should not provide us with, information regarding protected classifications, including: race, color, religion, age, sex/gender, gender identity, sexual orientation, marital status, medical condition, and disability information (as described under the appropriate state or federal law).

1.2 Information We Automatically Collect From You

While you are accessing and using our Services, we may automatically collect certain information from you. This information may include, but is not limited to:

1.2.1 Your device's internet protocol address (e.g. IP address), browser type, and version;

1.2.2 Access date and time, pages or sections of our Services that you visit and the time spent on those pages or sections, and other actions while using the Services;

1.2.3 Geolocation data, such as the precise or approximate location determined from your IP address;

1.2.4 When you access the Services through a computer or mobile device, we may collect certain information automatically, including, but not limited to, the type of device you use, including the hardware model, your device's unique ID, the operating system and version, unique device identifiers, cookie data, time-zone settings; and

1.2.5 Other diagnostic data.

The information we automatically collect from you is only statistical data and does not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways to help us improve our Services and deliver a better and more personalized service. We use these technologies for a number of purposes, including enabling you to use the Services, facilitating the functioning of and your access to the Services, better understanding how you navigate through the Services, and detecting and preventing fraud.

The technologies we may use for this automatic data collection may include:

Cookies and other tracking technologies

Cookies are small files generated by web servers that are sent to and stored in your browser when you access a website. Cookies are typically used to keep track of the settings users have selected and actions they have taken on a site. We use persistent cookies (they remain in your browser for a predetermined length of time, even when you go offline) and session cookies (they are deleted as soon as you close your web browser). We use cookies to track the use of and to improve our Services and for the safety and security of our Services.

We may use cookies for important reasons, such as:

  • For system monitoring/debugging and to analyze the effectiveness and overall performance of our websites and web application.

  • To ensure the safety and security of our Site and our Web and Mobile Applications.

  • To provide our site visitors and customers with the best experience possible.

We use both Session and Persistent Cookies for the purposes set out below:

 

Necessary / Essential Cookies

Type: Session and Persistent Cookies

Purpose: These Cookies are essential to provide you access to our website, and any Services that may be available through the website. These Cookies are essential for system monitoring/debugging, site security, stability, and effectiveness. Disabling these Cookies may therefore prevent you from accessing our website, and any Services that may be available through the website.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Purpose: These Cookies identify if users have accepted the use of cookies on the website.

 

Functionality Cookies

Type: Persistent Cookies

Purpose: These Cookies allow us to remember the choices you make when you access the website or use the Services. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website or Services.

 

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties (e.g. Google, Inc.)

Purpose: These Cookies are used to track information about traffic to the website and how users use the website. For example, we may use Google Analytics to collect information on the activities of visitors to our website, including page views, sources and time spent on the website. To protect your privacy, the information is depersonalized and cannot be tracked back to individuals. We may also use these Cookies to test new pages, new features, or new functionality of the website to see how our users react to them.

Given the core role of some Cookies in enhancing site functions or usability, completely disabling cookies may prevent users from using our Services.

Web Beacons.  Certain sections of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit us to determine whether you performed a specific action, for example, if you visited our Services or opened an email.

 

1.3 Third-Party Use of Cookies

 

Some content or applications on or connected to the Services are served by third parties, including payment processors and content and application providers. These third parties may use cookies, web beacons, or other tracking technologies to collect information about you when you access or use our Services. The information they collect may be associated with your Personal Data, and/or they may collect information related to 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. You should contact the responsible provider directly if you have any questions about an advertisement or other targeted content. For more information about how to opt out of receiving targeted advertising from many providers, see the Network Advertising Initiative’s opt-out page and Google Ads setting page.

 

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. We may use Google Analytics as a third-party tracking service for our website, but we don’t use it to track you individually or collect your Personal Data. We may use Google Analytics to collect information about how our website performs and how our users navigate through and use the website. Google Analytics gathers non-personally identifying information over time, such as your IP address, browser type, internet service provider, referring and exit pages, timestamps, and similar data about your site use. We do not link this information to your Personal Data, such as your username. Google provides further information about its own privacy practices and offers a browser add-on to opt out of Google Analytics tracking. You can access Google Analytics’ privacy policy here.

1.4 Personal Data We Collect from Our Subscribers and Authorized Users

If you are an Authorized User of our Subscription Services, the Subscriber who invited you may collect your Personal Data or other information about you while using our Subscription Services. The Personal Data requested and collected by Subscribers is entirely up to the Subscriber, but may include such Personal Data as first and last name, email address, physical address, and phone number, and any other Personal Data that may be requested when a Subscriber invites you to create an associated User account (“User Account”), or when you provide any User Content to your account that is associated with the Subscriber's account ("Primary Account").

We do not control the types of Personal Data that our Subscribers may choose to collect or manage using the Subscription Services. We require all our Subscribers to obtain your permission to share your Personal Data, and by accessing and using the Services, you acknowledge and agree to such disclosure of information.

Our Subscribers control and are responsible for correcting, deleting, or updating the Personal Data that they collect from you through the Subscription Services and are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent before transferring the Personal Data to us for processing purposes. Certain information, such as timestamps of actions and electronic signatures, are part of the audit trail provided by the Subscription Services and cannot be deleted by you or by Subscribers.

2. How We Use Your Personal Data

We use the Personal Data you provide or we collect:

2.1 To present our Services to you;

2.2 To provide and maintain the functionality of the Services, including to monitor the usage of our website and our Subscription Services;

2.3 To notify you about changes to our Services;

2.4 To allow you to participate in interactive features of our Services when you choose to do so;

2.5 To provide customer support;

2.6 To create and manage your account;

2.7 To allow you to log into the Services;

2.8 To process payments for Subscription Services;

2.9 To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those you have already purchased or enquired about, unless you have opted not to receive such information;

2.10 For our internal business purposes, such as data analysis, audits, and so forth;

2.11 To gather analysis or valuable information so that we can improve our Services;

2.12 To fulfill our obligations and enforce our rights arising from any contracts you entered with us;

2.13 To detect security incidents and protect against deceptive, illegal, or unauthorized activities;

2.14 To comply with the law;

2.15 To evaluate and/or conduct a divestiture, restructuring, dissolution, merger, or other transfer or sale of some or all of our assets;

2.16 In any other way we may describe when you provide the information; and

2.17 For any other purpose with your consent.

3. How We Share and Disclose Your Personal Data

Where permissible under applicable law, we may share your information in the following situations:

3.1 With Service Providers.  We may share your Personal Data with service providers, contractors, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes we disclose it to them. The service providers that we use include, but are not limited to, customer support and customer relationship management (CRM) services, cloud infrastructure providers, email marketing services, services for payment processing, and services that allow us to monitor and analyze the use of our Services.

A list of our current Service Providers (all of which are located in the United States):

Suitedash uses the following payment processing services:

Braintree : Payment processing services

Stripe : Payment processing services

3.2 With Other Users.  If you are an Authorized User, when you associate your account with the Primary Account to use the Subscription Services, the Personal Data contained in your profile or in the User Content that you provide or submit to your account will be accessible by the Subscriber and by any Authorized User who is granted access to your User Content by the Subscriber or Team Admins (appointed by the Subscriber).

3.3 For Business Transfers.  We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

3.4 As Aggregated Information.  We may disclose aggregated information about our Users and information that does not identify any individual, business partners, or any other third party.

3.5 To Enforce Our Agreements.  We may disclose your Personal Data to enforce and administer our Terms of Use, Subscription Agreement, End User Agreement, or any other applicable agreements between us and you ("Contracts"). You acknowledge and agree that we may rely upon these Contracts as a legal basis for processing your Personal Data.

3.6 To Protect Our Rights.  We may disclose your Personal Data to protect the rights, property, or personal safety of our company, its employees, advisors, contractors, representatives, members, and the public.

3.7 For Legal Compliance.  We may disclose your Personal Data to comply with the law, a court order, or legal process, including to respond to (a) notices of intellectual property infringement, (b) claims that User Content violates the rights of third parties, (c) government or regulatory request, and/or (d) investigate the use of or respond to alleged violations or infringement of third-party content. 

3.8 With Your Consent.  We may disclose your Personal Data for any other purpose with your consent.

4. How We Secure Your Personal Data

We take the security of your Personal Data seriously and have implemented robust technical safeguards to protect it. To ensure the privacy and security of your information, we utilize industry-standard practices such as Transport Layer Security ("TLS") for encrypting data during transit and KMS encryption for safeguarding User Data while at rest. In addition, your account information is password-protected for your privacy and security. You should always take steps to protect the confidentiality of the password you select. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

Remember that no method of transmission over the Internet or method of electronic storage is 100% secure. Despite our commitment to employing commercially reasonable measures to safeguard your Personal Data, we cannot assure its complete and absolute security. If you have any questions about our Services’ security, contact us at support@igorlabapp.com

5. How You Can Manage Your Personal Data

You may correct or amend the information we hold about you. Most of your account information can be changed in the account profile section of the Subscription Services. If you wish to delete any or all of your Personal Data (subject to certain exceptions), please contact us at support@igorlabapp.com. After receiving proof of your identity, we will do our best to respond to your request within thirty (30) days of receipt. You are responsible for keeping your Personal Data up to date.

Please be aware that many Users of the Services work in regulated industries and are thus bound to adhere to regulatory guidelines and standards, including FDA 21 CFR Part 11 & GLP. The Services offer certain features designed to help Users comply with such regulatory guidelines and standards, including electronic signatures to verify authorship or approval of procedures and reports, or a full audit trail of User activity and authorship/ownership of data submitted and stored using the system. Thus, in connection with the provision of the Subscription Services, and in accordance with our Subscriber Agreement and/or Authorized User Agreement, we may require that some of your Personal Data be provided with the User Content that you upload or otherwise share through the Subscription Services, and such User Content is and will remain the property of the Primary Account Holder.

Because of this overlap between your Personal Data and the User Content you submit through the Services, some of your rights regarding your Personal Data may be limited. For example, if you are an Authorized User, your User Account is associated with a Subscriber's Primary Account, and we will not be able to remove your name and email address when your account is terminated, as this information is part of the electronic signature audits created by the Subscription Services. Also, we will not be able to delete your Personal Data when it is related to your User Content, as your User Content is associated with the Primary Account and is owned and controlled by the Subscriber.  

6. Retention of Your Personal Data

We may retain your Personal Data for as long as your account is active (or, if you are an Authorized User, for as long as the Subscriber's Primary Account, that your account is associated with, is active) or as needed to provide you with the Subscription Services. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will archive and stop actively using any Personal Data we have of you within twelve (12) months from when the Primary Account Holder cancels the Subscription Services. We will delete your Personal Data from our backup archives no later than five (5) years after the cancellation of the Primary Account that your User Account was affiliated with or other such period of time as necessary to comply with our legal obligations.

We will also retain statistical data for internal analysis purposes for any period of time we choose unless we are legally obligated to retain this data for longer periods.

7. Consent to Processing of Your Personal Data in the United States

Please be aware that your Personal Data may be processed by us (and third parties on our behalf as further described in this Privacy Policy) outside of your home country, including the United States, where data protection and privacy regulations may not offer the same level of protection as privacy laws in your country. If you create an account with us, you agree to this Privacy Policy and consent to the transfer of all information you provide to us to the United States. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal 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.

8. Opting Out of Personalized Ads

You may choose to opt out of receiving emails and newsletters from us and delete, disable, and manage browser cookies and flash cookies.

​8.1 Marketing Emails Opt-Out.  If you no longer want to receive marketing emails from us, you may click the “Unsubscribe” link in any promotional email we send and follow the instructions provided or contact us at support@igorlabapp.com. Please note that it is impossible to unsubscribe from email communication that is directly related to, and required for, our provision of the Services.

​8.2 Tracking Opt-Out.  You can opt out of accepting cookies (or browser cookies) by activating the appropriate setting on your browser or setting your browser to alert you when cookies are being sent. However, if you disable or refuse, you may not be able to access and use some parts of our Services. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on managing Flash cookies, please visit Adobe’s Flash player settings page.

9. Third-Party Websites

We may provide links to third-party websites within the Services, but this Privacy Policy does not apply when you access third-party websites directly from the Services. Please note that we have no control or responsibility over third-party data collection, use, or disclosure practices. You will be subject to the third-party’s privacy policies when you click on links that take you to external websites. If you access and transmit information to third-party websites, you do so at your own risk. You should carefully review the privacy policy of any third-party website you visit before using it or disclosing your Personal Data to its provider.

10. Personal Data of Minors

The Services are intended for individuals 16 or older. If you are under 16, you may not use the Services nor have an account with us. We do not knowingly collect information from or direct any of our content specifically to children under 16. If we learn or have reason to suspect that you are a User under the age of 16, we will have to close your account. If you believe we might have any information from or about a child under the age of 16, please contact us at support@igorlabapp.com.

11. Supplemental Notice to California Residents (CCPA Addendum to Our Privacy Policy)

Users of the Services that reside in California may have additional rights afforded to them under California privacy laws.

11.1 Additional Definitions Applicable to California Privacy Laws

“CCPA” or “California Consumer Privacy Act” means California Civil Code § 1798.100 et seq.

"Consumer," "Business," "Sell," and "Service Provider" will have the meanings given to them in the CCPA.

“Personal information” identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, email address, internet browsing history, geolocation data, and inferences from other personal information that could create a profile about your preferences and characteristics. Under CCPA, personal information does not include: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; (c) information excluded from the CCPA's scope, such as: (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (ii) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

11.2 California Consumer Privacy Act ("CCPA")

11.2.1 Your Rights.  If the processing of your Personal Information is subject to the CCPA, you have the right to:

11.2.1.1 Request us to disclose the categories and specific pieces of Personal Information we collect, use, disclose, and sell;

11.2.1.2 Know the categories of Personal Information that we collect and the purposes for which we collected or used such Personal Information and whether that information is sold or shared;

11.2.1.3 Know the categories of sources from which the Personal Information was collected;

11.2.1.4 Know the categories of third parties with whom we shared or to whom we sell your Personal Information;

11.2.1.5 Know whether we collected or sold your Personal Information for business or commercial purposes;

11.2.1.6 Request deletion of Personal Information we collected from you, subject to certain exceptions;

11.2.1.7 Opt-out of the sale of Your Personal Information; and

11.2.1.8 Not receive discriminatory treatment by us for exercising your rights set out in the CCPA.

 

We may deny your deletion request if retaining the information is necessary for us, or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it

 

11.2.2 Categories of Personal Information Collected by Us

The following is a list of categories of personal information which we may collect or may have collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such Personal Information directly to us.

Category A: Identifiers

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Parties with whom this category of Personal Information may be shared include: Service providers, payment processors, our Affiliates, our business partners, third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Subscription Services, and Authorized Users of the Subscription Services whose account is linked to the same Primary Account as yours.

 

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Parties with whom this category of Personal Information may be shared include: Service providers, payment processors, our Affiliates, our business partners, third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Subscription Services, and Authorized Users of the Subscription Services whose account is linked to the same Primary Account as yours

 

Category C: Protected classification characteristics under California or federal law

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information

Examples: Records and history of products or services purchased or considered.

Collected: No.

Category E: Biometric information

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

​Category F: Internet or other similar network activity

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Parties with whom this category of Personal Information may be shared include: Service providers, payment processors, our Affiliates, our business partners, third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Subscription Services, and Authorized Users of the Subscription Services whose account is linked to the same Primary Account as yours.

Category G: Geolocation data

Examples: Approximate physical location.

Collected: Yes.

Parties with whom this category of Personal Information may be shared include: Service providers, payment processors, our Affiliates, our business partners, third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with our Subscription Services.

 

Category H: Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information

Examples: Current or past job history or performance evaluations.

Collected: No.

​Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

​Category K: Inferences drawn from other personal information

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

For information about what categories of Personal Information we may collect, or may have collected from our Users in the twelve (12) months preceding the date this Privacy Policy was last modified, the sources of such information, the purposes for collecting and using that information and what types of third-party service provider we may share that information with please see the following sections in this Privacy Policy titled: “Personal Data We Collect About You”; “How We Use Your Personal Data;” and “How We Share and Disclose Your Personal Data.” For more information about how to review and change your Personal Data collected through the Services, please see the section titled “How You Can Manage Your Personal Data.”

Such categories of Personal Information may be collected, used or disclosed for business and commercial purposes, which may include the examples set forth in Section 2 title “How We Use Your Personal Data.’

11.2.3 Exercising Your CCPA Rights

To exercise any of your rights under the CCPA, and if you are a California resident, you can contact us via email at support@igorlabapp.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable request related to your Personal Information.

Your request to us must:

  • Provide sufficient information that allows us to reasonably verify you are the person we collected personal information of, or an authorized representative; and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide the required information if we cannot:

  • Verify your identity or authority to make the request; and

  • Confirm that the Personal Information relates to you.

We will disclose and deliver the required information free of charge within forty-five (45) days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional forty-five (45) days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the twelve (12) months preceding the verifiable request's receipt. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

11.3 Do Not Sell My Personal Information

As a California consumer, you have the right to opt out of the sale of your Personal Information. To make such a request, please contact us by email at support@igorlabapp.com.

In the past 12 months, we have not sold your Personal Information.

We may use Google Analytics to gain insights regarding how users interact with our website. See the heading titled “Google Analytics'' of this Privacy Policy for more information about our use of Google Analytics and the categories of Personal Data collected by Google Analytics.

You can opt out of receiving personalized ads as served by our service providers by following the instructions presented on the following third-party websites:

The opt-out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.

11.4 Minors

Our Services are intended for individuals 16 or older. If you are under the age of 18 and registered with our Services, you have the right to request and obtain the removal of content or information you have publicly posted under the California Business and Professions Code Section 22581. Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online, as the law may not permit or require removal in certain circumstances.

11.5 Do not Track Features

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. However, there is no uniform technology standard for recognizing and implementing DNT signals. As such, we do not currently respond to or support DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

11.6 California’s Shine the Light Law

Under California's Shine the Light Law, California Consumers may request the type of Personal Information we disclosed to third parties for their direct marketing purposes and a list of those third parties (if any). We do not presently disclose Personal Information for marketing purposes.

To make any requests regarding your California Privacy Rights, please contact us by email at support@igorlabapp.com.

12. Supplemental Notice To Individuals that Reside In the European Economic Area (GDPR Addendum)

Users of the Services that are residents of the European Economic Area (EEA) and European Union Member States (including the United Kingdom and Switzerland) may have additional rights afforded to them under the EU General Data Protection Regulation (GDPR).

12.1 Making a Request in Relation to Your Personal Data

The GDPR gives EEA consumers various rights with respect to the Personal Data we collect, including the right to (subject to certain limitations):

12.1.1 Request copies of your Personal Data; 

12.1.2 Access, update, or delete the Personal Data we have on you;

12.1.3 Request that we correct any information you believe is inaccurate, or request us to complete information you believe is incomplete;

12.1.4 Request erasure of your Personal Data that we have collected, under certain conditions;

12.1.5 Request that we restrict the processing of your Personal Data, under certain conditions;

12.1.6 Object to processing of your Personal Data, under certain conditions;

12.1.7 Request that we transfer the data we have collected to another organization, or directly to you, under certain conditions;

12.1.8 Withdraw consent at any time where we are relying on consent to process your Personal Data. 

Please note that we may ask you to verify your identity before responding to such requests. You will not have to pay a fee to access your Personal Data or exercise any other rights. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authority about our collection and use of your Personal Data.

12.2 Controller’s Details

Please note that you will be required to contact the data controller directly to exercise your rights if we act as a data processor on behalf of our Subscribers. To determine the contact details of the applicable controller of your Personal Data, you may contact us at support@igorlabapp.com.

12.3 Legal Basis for Processing

We need a lawful basis to collect, use and disclose your Personal Data as a controller. Our lawful basis will depend on the information and the context in which it is processed. Generally, we rely on the following lawful bases for processing Personal Data:

​12.3.1 Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for pre-contractual obligations thereof;

12.3.2 Consent: You have given your consent for processing your Personal Data for one or more specific purposes;

12.3.3 Legal Obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.

12.3.4 Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us;

12.3.5 Vital Interests: Processing Personal Data is necessary to protect our vital interests or those of another natural person;

12.3.6 Public Interests: Processing Personal Data is related to a task that is carried out in the public interest or the exercise of official authority vested in us; and

12.3.7 Payment: Processing Personal Data is necessary for payment processing purposes.

By creating a Primary Account or User Account and/or using the Services, you are agreeing to the terms outlined in, as applicable, our Subscriber Agreement, the Authorized User Agreement, and any other agreements pertaining to your access and use of the Services ("Contracts"). You acknowledge and agree that we may rely upon these Contracts as a legal basis for processing your Personal Data.

Contact Us

If you have any questions or complaints about this Privacy Policy or our handling of your Personal Data, please contact us at support@igorlabapp.com.

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