Last updated: July 12, 2021
WARSHAW GROUP d/b/a INTELLIS LABS
PRIVACY POLICY
Dated July 12, 2021
Warshaw Group d/b/a Intellis Labs (“Intellis,” “us,” our” or “we”) is committed to protecting your privacy. “You/your/user(s)” means you as a user of our Services (as defined below), including any information, tools and services available from the Services. This privacy policy (“Privacy Policy”) applies to all users of www.intellis.io (the “Website”), the Intellis mobile applications (the “Mobile Apps”) and the tools and services made available to users through, on or by the Website or the Mobile Apps (together with the Website and Mobile Apps, the “Services”).
This Privacy Policy is designed to explain the information we collect and how we use it to provide our Services both to you and to our business partners (“Partner(s)”). It describes the Personal Information (as defined below) we collect about you through your use of the Services, why we collect it, how we use it, and when we share it with our Partners and other third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information.
In providing our Services to our Partners, we act as a data processor of user information on our Partners’ behalf, collecting and processing your Personal Information for the purpose of providing the Services on behalf of our Partner, including allowing you to access and use our Mobil Apps, which may be white labeled or branded by our Partners (“Partner Services”). For example, when you download a Mobile App powered by us but made available to you by one of our Partners (e.g., “One Voice,” “OV,” or 1199 SEIU United Healthcare Workers East), we will collect and process your Personal Information for the purpose of performing our Services on behalf of our Partner and in accordance with the terms of this Privacy Policy.
NOTE: When you visit our Partner’s websites, use a Mobile App made available by or through our Partners, or use the Partner Services, your use of and access thereof is also subject to the terms of use and privacy policy of the applicable Partner. We have no control how they collect, use, share, or safeguard your personal information and recommend you review the applicable Partner’s privacy policy.
When you visit our Website and access and/use our Services directly (i.e., not through one of our Partners but directly with us), we are acting as a data controller and are collecting, using, processing, sharing your Personal Information for the purpose of providing our Services directly to you (i.e., not through or on behalf of our Partners) and will do so in accordance with the terms of this Privacy Policy.
By accessing and using the Services you are agreeing to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to provide you with the Services, including any specific products or services made available through the Services, we may not be able to provide the Services or those other products or services to you.
1. Types of Information We Collect
a. Personal Information that we collect about you. We collect Personal Information about our users. “Personal Information” is information relating to an individual that can be used to contact or identify you or individuals about whom you enter information as part of your use of the Services (e.g., if you complete the “Contact Us” form on the Website, if you are taking a survey, or if you enter a survey participant’s personal information into the Services), such as first name, last name, e-mail address, phone number, street address, company name and address, title, gender, age, username and/or e-mail address in combination with a password or security questions and answers, account numbers or credit/debit card numbers, and any security codes, access codes, or passwords, IP addresses, browser information, or other unique device identifier, as well as information that is linked to the forgoing information.
b. Aggregated Information. After stripping out any information that directly identifies you, or directly relates to you, from the Personal Information that we collect about you, we may combine that information with information we collect about other users (“Aggregate Information”).
c. Cookies which collect information about users of our Website. We may also use tools such as cookies to gather information. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website. We use session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device for a finite period of time) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions.
d. Unique Device Identifiers. Like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
e. User-Provided Information. We collect information that you provide directly to us when you engage in the following:
We may correlate this information with other Personal Information we have about you. We collect e-mail lists, usage and engagement data, and information related to marketing services.
f. Hardware; Browser; IP Address. We may collect information from your use of the Website including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name, through the use of Cookies, web beacons or other technologies. This information may include the following: your browser and mobile device type, operating system and name of your Internet service provider; web pages you visit on the Website; IP address, browser type, profile information, geo-location information; information about your interactions with e-mail messages, such as whether the messages were opened and the links clicked in those e-mails; and standard server log information. If you are using a mobile device, we may also receive your UDID, or another unique identifier, and mobile operating system.
g. Geolocation. If you access the Website through a desktop or mobile device or use a Mobile App, we will collect, monitor and/or remotely store geo-location data.
h. Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example, we may collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, mailing list providers and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.
We use third-party services, such as Google Analytics and Google AdWords to track and analyze online behavior of our Users. These services may help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly.
When you interact with Intellis through social media networks, such as when you follow us, share content or contact us through Facebook, Twitter, Instagram, YouTube or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question.
2. How We Use Your Information
a. Personal Information. We may use your Personal Information for the following representative purposes:
b. Aggregated Information. We may use Aggregated Information for the following representative purposes:
c. Targeting. We may use Personal Information and Aggregated Information that we collect to target and measure the performance of advertisements to users through the Services and as may be otherwise implemented or served to users outside of the Services on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Website; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.
3. Lawful Processing; Legitimate Interests. Our Processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:
4. How We Share and Disclose Personal Information
a. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Services or provide your Personal Information at any time. If you choose not to provide any Personal Information that is necessary for us to provide you with specific products or services, we may not be able to provide those programs, products or services to you.
b. We may disclose your Personal Information to third parties that help us bring you the services and products we offer and to create, operate, and maintain our Services. For example, we may work with third parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails and user surveys; (c) assist us with search engine optimization, marketing, advertising, and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; and (g) provide other services designed to assist us in developing and running our Website and maximizing our business potential. We require that these outside companies agree
to keep all information shared with them confidential and to use the information only to perform their obligations to us.
c. We may disclose Personal Information to our Partners in order to provide the Services. We may also share Aggregated Information with our Partners to help them better understand and improve their use of the Services.
d. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
5. Use of Aggregated Information.
a. We use Aggregated Information to maintain and administer the Website, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Information with third-parties, including your employer (if they are part of the Corporate Giving program) and our merchant partners. We may share this information without express notice to you or consent from you, and we may, subject to applicable laws, exploit, use and disclose Aggregated Information without limitation of any kind. We authorize certain service providers, corporate customers, and merchant partners to utilize Aggregated Information for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.
b. The Services use Cookies. Cookies help us remember you when you return to the Website. Cookies also hold information to personalize and enhance your experience and to gather Website statistical data, such as which pages are visited, the Internet provider's domain name and the addresses of the sites you visited immediately before coming to and immediately after leaving the Website. The information in the cookies lets us trace your "clickstream" activity (i.e., the paths taken by users of the Website as they move from page to page) to enable us to better serve you by revealing which portions of the Website are the most popular. We may also allow our affiliates and service providers and advertisers to serve cookies from the Services to allow them to assist us in various activities such as doing analysis and research on the effectiveness of the Website, its content and advertising. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies. For more information, see: www.networkadvertising.org.
c. Cookies and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.
d. We may combine the information collected through Cookies and other analytical tools with other information we may have collected from you. This information may be used to improve the Website, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes. We may use and share aggregated and anonymous information to conduct market research and analysis for ourselves and/or for our business partners. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us.
e. The Website contains links to and/or enables certain third-party functionalities to enhance your experience on the Website, including social plug-ins, tools and APIs. Prior to using any third party functionalities (e.g., Facebook “Like” button) on the Website, you should consult the privacy notices of the third party providers of such functionalities (e.g., Facebook). The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices in respect of their own processing of your Personal Information. Your communications and interactions with such third parties in respect of their own processing of your Personal Information are solely between you and them and are at your own risk.
6. Data Retention.
a. We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
b. Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
c. Where we are processing Personal Information as set out in this policy, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 8, Deleting, Changing & Updating Your Personal Information).
d. Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
7. Opting-Out
a. Unsubscribe. You may opt out of: (a) receiving e-mail communications such as e-mail newsletters and promotional e-mails by following the instructions provided at the bottom of each e-mail, clicking the “unsubscribe” button at the bottom of e-mails we sent you; and/or (b) receiving promotional e-mail communications and newsletters by e-mailing us at info@intellis.io and including the word “UNSUBSCRIBE” in the subject text. If you do not receive a response from us to any e-mails you send to us within ten (10) business days, please send us another e-mail as your original e-mail may not have been received.
Opting out of receiving Services communications will not affect your receipt of service-related and administrative communications, such as payment confirmations, updates to our Terms of Use and this Privacy Policy, as we must be able to communicate with you regarding your purchase.
b. Google Analytics, Facebook, and Apple. Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display and retarget our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located at https://adssettings.google.com/authenticated. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located at https://tools.google.com/dlpage/gaoptout. We may also work with Facebook and Apple to provide analytics and advertising retargeting in connection with our Website, including our mobile applications.
For more information about Facebook’s privacy practices, visit https://www.facebook.com/about/privacy, and to opt-out you can visit https://www.facebook.com/help/568137493302217.
For Apple’s privacy policy, click here http://www.apple.com/privacy/privacy-policy/ and learn how to control what you share and opt-out of sharing here https://www.apple.com/privacy/control/.
c. Ad Industry Opt-Outs. You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/.
You may can opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/ or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/.
When using the ad industry opt out tools, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.
d. Cookies. You can opt out of accepting Cookies or disable them from your browser. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting Cookies or can disable them entirely. If you opt out of Cookies, you will not be able to take advantage of various features of the Website that are available to other users. For example, we may use Cookies to recognize you by name when you return to this Website so you don’t have to login again and provide your password each time.
e. Text Messages. If after signing up to receive more information about products or services made available by us or through the Services, you would like to change or update your contact preferences, you may do so by contacting us by phone at the toll-free phone number (855) 856-4438 or by e-mail at info@intellis.io . With regard to automated text communications, if you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying STOP to any text you receive from us.
8. Deleting, Changing & Updating Your Personal Information (for Users outside of the EEA or UK)
a. You may correct, update or revise your Personal Information that is inaccurate or request that we delete your Personal Information from our system. In certain cases, you may also have a right to: (i) to restrict or limit the ways in which we use your Personal Information; (ii) to object to the processing of your Personal Information; and (iii) to obtain a copy of your Personal Information in an easily accessible format.
b. If you withdraw your consent to the use or sharing of your Personal Information for the purposes set out in this Privacy Policy, you may not have access to the related services, and we might not be able to provide you with certain or any services.
c. To submit a request, please send an e-mail message to info@intellis.io . We do not want to take any action regarding your Personal Information at the direction of someone other than you and may therefore ask you for information verifying your identity.
9. BASIS FOR CONTINUED USE OF YOUR PERSONAL INFORMATION. Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third-parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
10. European Economic Area (“EEA”) and UK Users
a. Data Transfers. For Users visiting the Website and using our services from within the EEA or the UK, we may need to transfer your Personal Information to countries outside the EEA or the UK, including to the USA because we are headquartered there. In cases where we do transfer your Personal Information to countries outside the EEA or the UK, we will take reasonable steps in accordance with applicable privacy and data protection requirements.
b. Your Rights. You have certain rights in relation to your Personal Information. If you would like further information in relation to these or would like to exercise any of them, please contact us using the details at the bottom of this privacy policy at any time. The following rights are most relevant to the services that we provide:
i. Right of access. You have the right to ask us to provide you with copies of Personal Information that we hold about you and further details of how we use it and look after it as well as confirmation as to whether your Personal Information is being used by us.
ii. Right to update. You have the right to ask us to update and correct any out-of-date or incorrect Personal Information that we hold about you free of charge.
iii. Right to delete. In certain cases, you have the right to request that we delete or destroy any Personal Information we hold about you.
iv. Right to restrict use: You have a right to ask us to restrict the way that we process your Personal Information in certain specific circumstances.
v. Right to object. You have a right to ask us to consider any valid objections which you have to our use of your Personal Information where we process your Personal Information on the basis of our or another person's legitimate interests.
We will consider all such requests to exercise your rights, and provide our response, within a reasonable timeframe (and, in any event, any timeframe required by law). Please note that these rights do not always apply in all cases. If we cannot meet your request, we will explain why.
c. Complaints. If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority), but we hope that you will contact us first at info@intellis.io to provide us with an opportunity to address your concern, or write to us at Warshaw Group d/b/a Intellis Labs, Attn: Privacy Office, 600 5th Avenue, 2nd Floor, New York, NY 10020.
11. Notice to Californian Users Regarding Your Privacy Rights
a. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. Intellis does not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at contact us via e-mail at info@intellis.io or write to us at Intellis, Inc., Attn: Privacy Office, 600 5th Avenue, 2nd Floor, New York, NY 10020. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
b. California Consumer Privacy Act. The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, described in this Section.
i. Your Rights. California residents may exercise the following rights by contacting us by phone at the toll-free phone number 212-966-4056 or by e-mail at info@intellis.io , or as described at the end of this document:
c. Requesting Access to or Deletion of Personal Information. If you are a California resident, you have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months.
In order to verify your request, you will need to provide us with sufficient information to identify you individually so that we can comply with you request, including the name you provided to us when you created your account(s) (i.e. your legal first, last name or variants thereof, e.g. nicknames, aliases, titles (“Mr.”, “Mrs.”, “Dr.”, “Jr.”, etc.), the e-mail address(es) you use to correspond with us and any other e-mail addresses you have used with us in the past, your mailing address, including the state and city you reside in currently.
To make an information access and/or deletion request you may contact us by phone at the toll-free phone number 212-966-4056 or by e-mail at info@intellis.io .
d. Notice Disclosures. Depending on the circumstances and which Service you use, we have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months:
e. Non-Discrimination. We will not discriminate against you for exercising any of your rights under California law, including:
f. Do Not Track. Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" requests or signals at this time.
12. Children
This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at contact us via e-mail at info@intellis.io or write to us at Warshaw Group d/b/a Intellis Labs., Attn: Privacy Office, 600 5th Avenue, 2nd Floor, New York, NY 10020 so that we may delete and remove such information from our system.
13. Security.
We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, i
limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.
14. Third-Party Website
While visiting the Website, you may link to websites operated by third parties or you may have come to the Website using a link found in another website. We do not make any representations or warranties about any third-party website, we have no control over them or the information, services, products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website's privacy policy before providing Personal Information.
15. Changes to Our Privacy Policy
We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.
16. Contact Us
If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at info@intellis.io or write to us at Warshaw Group d/b/a Intellis Labs, Attn: Privacy Office, 600 5th Avenue, 2nd Floor, New York, NY 10020.
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