INTTRA Privacy and Security Policy
Last Revised on November 29, 2017
inttra Inc., participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. INTTRA is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
inttra is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. INTTRA complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, INTTRA is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, INTTRA may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Collection and Use of Personal Data
inttra and/or its affiliates and third party service providers may use the personal data to:
- perform the Services or in connection with the operation of the Services;
- monitor and analyze System activity including how the System is used, and the volume and frequency of access, so as to improve the System and the Services;
- contact you regarding your inquiries, your use of the System, changes to the System or the Services and to otherwise operate the System;
- comply with any applicable law or other legal or regulatory requirements, to respond to a request or subpoena by a government, regulatory or judicial authority, where necessary in connection with a dispute, actual or potential litigation or other legal process or an internal or external audit, or where otherwise necessary to protect the interests of inttra, its affiliates, third party service providers or other participants in the System; and
- supplement your personal data with third party sources for background verification.
With your consent, inttra and/or its affiliates may use the personal data to market products and services of inttra and/or its affiliates and third party service providers to your Company through use of post, fax or by e-mail; please note that if inttra sends marketing materials to you we will include a working unsubscribe link so you can unsubscribe.
inttra will also send you Service related e-mail announcements on rare occasions when it is necessary to do so. For instance, if Service is temporarily suspended for maintenance, we might send you an e-mail. You do not have an option to opt out of these e-mails, which are not promotional in nature.
In addition, any third party offering a service directly to your Company in connection with our Services or on our Websites (including, without limitation, live chat service providers, e-mail service providers and recruiting platforms) (collectively “Partners”) may use your personal data to: (a) provide the Services; (b) contact you regarding your inquiries; and (c) market its products and services to your Company through use of post, fax or by e-mail. If you do not want us to share your personal data with these companies, contact us at firstname.lastname@example.org.
Third party personal data may also be entered on our System, such as if your Company has elected to use an administrator to enter the personal data about its users. If this data is collected on our System, it will only be used for the stated purpose for which it was collected.
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com.
User Data Supplementation
We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:
- Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.
- Human resource information and basic business contact information when candidates are presented through recruitment agencies and when we use Salesforce.com to work on business contact leads.
Disclosure of Personal Data
In certain situations, inttra may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. inttra and/or its affiliates, third party service providers and Partners may disclose your personal data to:
- any affiliate, agent or sub-contractor of inttra, and/or its third party service providers or Partners, as applicable, including companies that provide technical services to inttra, such as data processing companies. These companies are authorized to use your personal data only as necessary to provide these Services to us. For the avoidance of doubt, a carrier that is a participant in the System is not considered to be a company that provides technical services to inttra;
- any affiliate, agent or sub-contractor of inttra and/or its third party service providers or Partners, as applicable, for the purposes of operating the System and, with your consent, for the marketing and/or provision of third party services. As stated above, all of the third parties offering services through the System may receive your personal data;
- any affiliate, agent, sub-contractor or adviser of inttra and/or its third party service providers or Partners, or a government, regulatory or judicial authority, as applicable, in connection with an internal or external audit or examination, a dispute or actual or possible litigation, a request, subpoena or similar legal process, to satisfy a port, state or customs security initiative, or where disclosure is otherwise permitted or required by law;
- any affiliate, agent, sub-contractor or adviser of inttra, and/or its third party service providers or Partners, or a participant in the System, or a government, regulatory or judicial authority, as applicable, where necessary to protect the interests of inttra, the public, or other participants in the System, for example, in the event of suspected fraud or illegal activity; and
In the event that inttra, or any of its assets, are acquired or become the subject of a merger, then your personal data may be transferred with the business or disclosed to potential acquirers or others involved in any such transaction, but shall not otherwise be sold or rented to any third party. You will be notified of this change as described below in “Changes to this Policy”.
You acknowledge that inttra is not responsible for information or data in the possession of third parties, except for data processors acting on behalf of inttra, regardless of how such data was obtained. Please consult the privacy policies of these third parties to learn how they may use or disclose your information. You may be contacted directly by an individual carrier.
Aggregate or other information not identifiable with any individual may be used or disclosed for other purposes, and to other parties, as deemed appropriate by inttra subject to any obligations of confidentiality under the Agreement(s) and applicable laws.
inttra will retain your information for as long as your account is active or as needed to provide you Services, comply with our legal obligations, resolve disputes and enforce our Agreements.
While no security procedures are fool-proof, inttra maintains industry standard appropriate technical and organizational measures to minimize the risk of unauthorized access to the data transmitted to and from, presented, and stored by inttra. The security of your personal data is important to us. When you log into our System using your User ID and password, we encrypt the collection and transmission of all information using secure socket layer technology (SSL). However, inttra cannot guarantee the security of your personal data during its transmission to inttra. You shall take commercially-reasonable efforts to ensure the secure transfer of all data sent by you across data networks.
inttra’s information security measures are designed to:
- ensure the security and confidentiality of personal data;
- identify potential threats or hazards to the security or integrity of personal data and protect against any anticipated threats or hazards; and
- protect against accidental or unauthorized destruction or loss or unauthorized disclosure or access to or use of the personal data.
To access certain parts of the System you will be required to create and maintain a user name and password, which will allow you as a User to access the secure customer section of the System. It is your responsibility to keep your user name and passwords secure and to not share this information with others. If you have any questions about security on our website, you can contact us at firstname.lastname@example.org.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
inttra Partners with a third party to either display advertising on our Websites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on the Websites and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Notice, Access and Choice
If you would like to access the personal data we hold about you to update it, please log into the appropriate part of the System and update this data within your account. You can also contact us at the e-mail address below to access and update your personal data we hold about you.
You may have certain rights under applicable data protection laws which may include the right for you to receive a copy of the personal data that inttra holds about you.
You may withdraw your consent for the processing of your personal data at any time, but if you do so, inttra may not be able to provide certain Services to you, including access to parts of the Websites. To cancel your account or request we no longer use your information to provide you Service or as otherwise outlined herein let us know by one of the these methods:
- Send an e-mail with your request and current contact information to email@example.com; or
- Send a letter with your request and current contact information to inttra Inc., Attention: Legal Department, One Upper Pond Road, Morris Corporate Center 2, Building D, Parsippany, NJ 07054.
Use of System
Use of Corporate Web Site
On our corporate website, www.inttra.com, we have certain functionality. This includes testimonials, for which we have obtained the Users permission to post their personal data. If Users wish to update or delete their testimonial, they can contact us at firstname.lastname@example.org.
Also, if you choose to use our referral service to tell a friend (email a friend, refer a friend, send to a friend, email a page, invite a friend) about any of our Websites, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. inttra does not store this information.
Information Related to Data Collected through the Platform Services
Information Related to Data Collected for our Customers:
inttra collects information under the direction of its Customers, and may have no direct relationship with the individuals whose personal data it processes. If you are a customer or employee of one of our Customers and would no longer like to be contacted by one of Us or Partners that use our Service, please contact the Customer or Partner that you interact with directly. We may transfer personal data to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
Access and Retention of Data Controlled by our Customers:
- inttra acknowledges that you have the right to access your personal data. inttra may have no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the Customer (the data controller). If requested to remove data we will respond within 30 days.
- inttra will retain personal data we process on behalf of our Customers for as long as needed to provide Services to our Customers. inttra will retain this personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Changes to this Policy