Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

  1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 We, us, our

 Inguo.io, Inc

 Personal information 

 Any information relating to an identified or identifiable individual 


2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:

 Categories of Personal Information

 Specific Types of Personal Information Collected

 Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online   identifier, Internet Protocol address, email address, account name, social security   number, driver’s license number, passport number, or other similar identifiers)

 Real name, email address

 Information that identifies, relates to, describes, or is capable of being associated with,   a particular individual, including, but not limited to, his or her 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.

 Name, company name, industry, country, phone   number, company website, company address

 Internet or other electronic network activity information (e.g., browsing history, search   history, and information regarding a consumer’s interaction with an Internet Web site,   application, or advertisement)

 The inguo.io page you are visiting.

 The address of the web page you visited   immediately before, if any (the “referrer”).

 Date and time of your visit.

 Properties of your device, particularly its   operating system, the browser you use and your   browser’s display window size.

 Your device’s IP address on the internet.

 ID numbers which we store on your device. With   these ID numbers we can recognize your device   as a website user. Technically, these ID numbers   are stored in so-called cookies or eTags.

 Device IDs that consist of individual   characteristics of your device. Based on these   device identifiers, we can also recognize your   device as a website user. Examples of such   device identifiers are The “identifier for   advertisers” of the Apple operating system iOS.   The “advertising ID” of the operating system   Android

 Your actions when interacting with our web   application and the results returned from these   actions.

 Geolocation data

 Country

 Professional or employment-related information

 Name, email, phone number, home address,   employment history, education history

This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing said products and services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and via our websiteand apps. However, we may also collect information:

  • From publicly accessible sources (e.g., LinkedIn);
  • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
  • From a third party with your consent (e.g., your company);
  • From cookies on our website; and
  • Via our IT systems, including:
    • Our web application;
    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.

4. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a  proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contractual obligations  with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party (defined below); or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We use (process) your personal information for the following reasons:

 To fulfill subscription requests, orders for software and services made online and to provide other information you request.

 To provide customer support, and communicate with you about your orders, purchases or accounts with us, requests, questions and   comments

 To prevent and detect fraud or other illegal activity

 Conducting checks to identify our customers and verify their identity

 Screening for financial and other sanctions or embargoes

 Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and   safety regulations

 Ensuring business policies are adhered to, e.g. policies covering security and internet use

 Operational reasons, such as improving efficiency, training and quality control

 Ensuring the confidentiality of commercially sensitive information

 Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other   efficiency measures

 Preventing unauthorized access and modifications to systems and to protect the security and integrity of our website, systems, servers,   and other technical assets

 Updating customer records

 To anonymize some of this data where we want to gain insights about history, processes, operations and customer experiences that do not   require information that can be associated with an identifiable individual

 Marketing our services and those of selected third parties to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.

 To meet legal requirements, or as required by a judicial process or a government request, and to establish, exercise or defend a legal claim.

 To comply with industry standards and our policies

The above table does not apply to special category personal information, which we will only process with your explicit consent.

5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside inguo.io for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at privacy@inguo.io; or
  • Using the “unsubscribe” link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We may share personal information with:

  • Service providers we use to help deliver our products and services to you, such as payment service providers, vendors and subcontractors;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers so that they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose. We have not sold or disclosed to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

8. Where Your Personal Information is Held. Information may be held at our offices and our systems, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information..

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or
  • Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: [Andorra, Argentina, Canada (only commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay, and USA (if the recipient belongs to the Privacy Shield)]. Non-EEA countries (other than those countries the European Commission has assessed as providing an adequate level of protection for personal information) do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses by sending a request to privacy@inguo.io.

If you would like further information, please contact us  (see “How To Contact Us” below).

11. Your Rights Under the GDPR.

 Right to Access

 The right to be provided with a copy of your personal information (the right of access)

 Right to Rectification

 The right to require us to correct any mistakes in your personal information

 Right to be Forgotten

 The right to require us to delete your personal information—in certain situations

 Right to Restriction of Processing

 The right to require us to restrict processing of your personal information—in certain circumstances,   e.g. if you contest the accuracy of the data

 Right to Data Portability

 The right to receive the personal information you provided to us, in a structured, commonly used and   machine-readable format and/or transmit that data to a third party—in certain situations

 Right to Object

 The right to object:

  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

 Right Not to be Subject to   Automated Individual Decision-   Making

 The right not to be subject to a decision based solely on automated processing (including profiling)   that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

12. Your Rights Under the CCPA. Residents of the State of California have the right under the California Consumer Privacy Act of 2018 (CCPA) to the extent that the CCPA applies to the processing by us of their personal information and certain other privacy and data protection laws, as applicable, to exercise free of charge:

 Disclosure of   Personal   Information   We Collect   About You

 You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.

 Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

 Personal   Information   Sold or Used   for a   Business   Purpose

 In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the   right to know:

 The categories of personal information about you that we sold and the categories of third parties to whom the personal   information was sold; and

 The categories of personal information that we disclosed about you for a business purpose.

 You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection   laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of   the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you   subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of   your personal information, please contact us (see “How To Contact Us” below).

 Right to   Deletion

 Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

 Protection   Against   Discrimination 

 You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This   means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to   you, if that difference is reasonably related to the value provided to our business by your personal information.


13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

16. Changes to This Privacy Notice. This privacy notice was published on 5/27/2020.

We may change this privacy notice from time to time–when we do, we will inform you via our website.  Your continued use of the website following the posting of changes to this Privacy Policy means you accept those changes.

17. How to Contact Us. Please contact us by email if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

 Our contact details 

 privacy@inguo.io 


18.
Your Acceptance of these Terms.  By using this website, you accept and agree to the terms of this Privacy Statement.

19. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).