INOC, a division of ITsavvy LLC (“INOC”, “Company”, “us” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy (the “Privacy Policy”).
Our Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website at www.inoc.com (the “Website”). If you are a resident of Europe, please see our European Privacy Notice, which also describes our collection and processing of personal data as part of our business.
This policy applies to information we collect:
It does not apply to information collected by:
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website, our contracted services, or interact with us via the methods described above. By accessing or using our Website, our contracted services, or interacting with us via the methods described above, you agree to this Privacy Policy.
This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website, our contracted services, or interaction with us via the methods described above, after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. Please note that we use the term Website in the rest of the document to generically refer to all the information we collect as described in this Introduction.
INOC, a division of ITsavvy LLC, is the controller of your Personal Data (as defined below). At this time, INOC is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so. INOC may be contacted in any manner set forth below in the Contact Information section of this Privacy Policy.
We collect several types of information from and about users of our Website:
We collect this information:
The information we collect on or through our Website consists of:
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
When you visit or leave our Website by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.
The technologies we use for this automatic data collection may include:
We may use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of certain targeted advertising, and learn more about your options related to such advertising, by using the links below:
Some content or applications, including advertisements, on the Website may be 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 our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, 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 parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We use information that we collect about you or that you provide to us, including any Personal Data:
With your consent, we may also use your information to contact you about our own goods and services that may be of interest to you, including through newsletters. If you wish to opt out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by sending an email stating your request to info@inoc.com. For more information, see Choices About How We Use and Disclose Your Information.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:
We may also disclose your Personal Data:
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser's DNT option in your browser's preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals when you use our services and products or interact with our Website or online services.
We have implemented measures designed to secure your Personal Data from accidental loss, and from unauthorized access, use, alteration, and disclosure. When Personal Data is transmitted, it is protected with encryption, such as the Secure Socket Layer (SSL) protocol.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website/Client Portal, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or contracted services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any Personal Data to or on our Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us by emailing info@inoc.com.
We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on our Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to date active and deliverable email address for you, and for periodically accessing our Website and reviewing this Privacy Policy to check for any changes.
If you have any questions, concerns complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website (www.inoc.com/contact-us).
To Contact INOC, please use the information below:
Contact: Rick Smith
Title: VP, Cybersecurity Compliance
Phone: +1.608.201.0204
Email: rsmith@inoc.com
The General Data Protection Regulation (“GDPR”) imposes certain rules in respect of data protection of individuals, and these rules apply to organisations who process personal data related to the offering of goods and services to individuals in the European Economic Area (“EEA”), including the European Union (“EU”). Switzerland and the United Kingdom (or “UK”) have also implemented their own versions of the GDPR.
INOC is a division of ITsavvy LLC (and referred to herein as “INOC” or the “Company”). INOC is committed to complying with the GDPR and the United Kingdom extension thereof and this privacy policy contains important information on who we are, how and why we collect, store, use and share personal information, the rights in relation to personal information and how to contact us and supervisory authorities in the event that our European, Swiss, or United Kingdom customers have a complaint.
This section of the privacy policy (the “GDPR Policy”) applies solely to persons located in the EU, Switzerland, or the United Kingdom, as applicable, at the time of personal data collection by or on behalf of the Company.
The Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we look after your personal data when you visit our our website at www.inoc.com (the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you, and about how we process your personal data as part of our business. Please see the Glossary (below) for more information regarding the terms used herein.
This privacy notice aims to give you information on how the Company collects and processes your personal data as part of our business, including any data you may provide through the Website.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
ITsavvy LLC is the controller and responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Please contact our representative below, with any inquiries relating to this GDPR Policy.
INOC, ITsavvy LLC
Rick Smith
VP, Cybersecurity Compliance
Phone: +1.608.201.0204
Email: rsmith@inoc.com
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority in the country or state where you work, normally live or where any alleged infringement of data protection laws occurred within the United Kingdom, Switzerland or the EU.
This version was last updated on April 4, 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, as used in this GDPR Policy, means any information about a European or United Kingdom individual from which that person can be identified. It does not include data where the individual’s identity has been removed (anonymous or de-identified data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications. You have the right to withdraw consent to marketing at any time by contacting us as set forth in Contact Details.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us as set forth in Contact Details if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To enroll your employer as a new customer | (a) Identity (b) Contact |
Performance of a contract with our customer |
|
To provide our services, including: (a) To monitor our customers’ networks |
(a) Identity |
(a) Performance of a contract (b) Necessary for our legitimate interests (for running our business, providing administration and IT services, managing our business relationships) |
| To notify you about changes to our terms or Privacy Policy | (a) Identity (b) Contact |
(a) Performance of a contract (b) Necessary to comply with a legal obligation |
| To administer and protect our business and our Website (including for information security purposes, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, providing administration and IT services, for managing network security) (b) Necessary to comply with a legal obligation |
| To make suggestions and recommendations to you about goods or services that may be of interest to your employer | (a) Identity (b) Contact (c) Technical |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To comply with reporting requirements |
(a) Identity (b) Contact (c) Technical |
Necessary to comply with a legal obligation |
| For own our internal analytics and business intelligence |
(a) Identity (b) Contact (c) Technical |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established, and you may utilize, the opt-out procedures and preferences set forth in our Privacy Policy.
We may use your Identity, Contact, and Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time. To opt-out of our marketing communications, please see our Contact Details. To opt-out of third parties’ marketing communications, please consult such parties’ respective terms and privacy policies.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us as set forth in Contact Details.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
To the extent within our control, we request that all third parties who process your personal data on our behalf respect the security of your personal data and treat it in accordance with the law, and only process your personal data for specified purposes and in accordance with our instructions.
Your personal data will be transferred outside the EU, United Kingdom or Switzerland.
Whenever we transfer your personal data out of these areas, we will do so in accordance with the GDPR and its corresponding regulations in Switzerland and the United Kingdom, which may mean that we will process your personal data in countries which the EU has designated as “adequate” or using other permissible transfer mechanisms, such as the Standard Contractual Clauses.
Please contact us as set forth in Contact Details if you want further information on the specific mechanism used by us when transferring your personal data outside of Europe or the United Kingdom.
We have put in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data. Please see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
INOC, a division of ITsavvy LLC, commits to comply with the EU-U.S. Data Privacy Framework (the “EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. INOC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
To confirm our participation, you may search for our company name on the Data Privacy Framework website, at https://www.dataprivacyframework.gov/s/participant-search.
If you have a complaint about our handling of your personal data, please reach out to our contact below:
INOC, ITsavvy LLC
Rick Smith
VP, Cybersecurity Compliance
Phone: +1.608.201.0204
Email: rsmith@inoc.com
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, INOC commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
In case you wish to initiate a complaint about our handling of EU or UK personal data, you can also contact, free of charge, our independent recourse mechanism, who can be reached here:
Netherlands
Autoriteit Persoonsgegevens
Hoge Nieuwstraat 8
P.O. Box 93374
2509 AJ Den Haag/The Hague
Tel. +31 70 888 8500
Fax +31 70 888 8501
Website: https://autoriteitpersoonsgegevens.nl/
Member: Mr Aleid Wolfsen - Chairman of the Autoriteit Persoonsgegevens
You may also, under certain conditions, as set forth in the EU-U.S. DPF or UK Extension to the EU-U.S. DPF, be able to invoke binding arbitration through the International Centre for Dispute Resolution-American Arbitration Association.
We commit to perform onward transfers of EU and UK personal data solely subject to mechanisms approved by the applicable European or United Kingdom authorities, and accept all liability for such onward transfers under applicable law.
Our company, and its compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF are subject to the investigatory and enforcement powers of the Federal Trade Commission.
Please note that, under some circumstances, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us as set forth in Contact Details.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request, in an effort to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us as set forth in Contact Details.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, including providing you products or services you have requested.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
