Privacy Policy

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TRUSTe

Effective Date: August 14, 2025

Inbenta Holdings Inc. and its affiliates (“Inbenta,” “we,” “our,” or “us”) provide SaaS (Software as a Service) offerings powered by advanced artificial intelligence technologies, including machine learning (ML), natural language processing (NLP), and large language models (LLMs),This privacy policy applies to Inbenta’s public-facing website and online services applications, including www.inbenta.com and all related websites, web-based services, mobile apps, and services that may be integrated with third-party communication channels (the “Inbenta Sites and Services”).

This privacy policy explains what personal data we collect from visitors to the Inbenta Sites and Services, how we use and share that information, and the rights and choices you have in connection with that information, including how you can limit certain uses and sharing of your information.

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TABLE OF CONTENTS

This privacy policy is provided in a layered format. You can jump to a specific section by clicking on the section below.

1. WHO YOU ARE

Depending upon how and why you interact with the Inbenta Sites and Services, the types of personal data we collect, use, or disclose may vary. Our privacy policy is organized to explain how we use personal data about visitors to the Inbenta sites, about individuals who use the Inbenta online services, and individuals who use Inbenta services integrated into other communication channels, because we collect, use, and disclose information differently depending on how you interact with us.

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1.1. IF YOU ARE AN INBENTA SITE VISITOR OR INTERACT WITH US

As an Inbenta Site Visitor, you visit and interact with the Inbenta sites.  For example, if you visit www.inbenta.com, you are an Inbenta Site Visitor for those interactions.  Additionally, if you interact with us through other means, you also fall within this category of data subject.

We collect identifiers, Internet or other electronic activity information, geolocation data, electronic information, professional or employment-related information, audio, video, and transcripts involving Inbenta Site Visitors or Individuals Interacting With Us.  We obtain this information automatically, directly from you, and from other sources, and we may use it for multiple purposes, including providing and enhancing the Inbenta sites and services, responding to inquiries, or supporting interactions.  We may disclose this information to other entities both inside and outside of our corporate family.

Some features of the Inbenta Sites use AI technologies to enhance user experience. Safeguards to ensure transparency and fairness are governed by the Use of Artificial Intelligencesection.

If you load or interact with a Inbenta service on our site, the “If You are an Inbenta Online Service User or Load an Inbenta Service” section explains how we may collect your personal data through the Inbenta service and how we may use or disclose that data.

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Category of Personal data
Examples
Purpose of Collection and Use

Identifiers

First and last name, contact information, device ID or IP address and user-generated content (including reviews and feedback)

  • Provide and enhance the Inbenta Sites
  • Detect and prevent fraud
  • Market or advertise to you
  • Communicate with you
  • Comply with legal or regulatory obligations

Internet or other electronic activity information

Browsing history on the Inbenta Sites; clickstream data; browser and operating system type; navigation paths; data/time stamps; cookie identifiers; and other information about device characteristics and how you interact with the Inbenta Sites and Services

  • Provide and enhance the Inbenta Sites
  • Detect and prevent fraud
  • Market or advertise to you
  • Communicate with you
  • Comply with legal or regulatory obligations

Geolocation information

Geolocation information based on your IP address, country

  • Provide and enhance the Inbenta Sites
  • Detect and prevent fraud
  • Market or advertise to you
  • Communicate with you
  • Comply with legal or regulatory obligations

Electronic information

Session replay

  • Provide and enhance the Inbenta Sites

Professional or employment-related information

Employer name, professional contact information

  • Detect and prevent fraud
  • Market or advertise to you
  • Communicate with you
  • Comply with legal or regulatory obligations

Audiovisual information

Audio, video, and transcripts from call recordings

  • Enhance the Inbenta Sites and Services
  • Training
  • Services implementation guidance
Sources of Personal Data
Categories of Personal Data We Collect

Directly from you We may collect personal data from you when you interact with the Inbenta Sites or our services, submit inquiries or request information from us, or otherwise contact or communicate with us.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information
  • Electronic information
  • Professional or employment-related information
  • Audiovisual information

Automatically We may collect personal data from you automatically when, logged in, you visit the Inbenta Sites, as you load the Inbenta Sites, or as you interact with us.  These services may record mouse clicks, page views, mouse movements and scrolling activity and are used by Inbenta to analyze trends and administer the Inbenta Sites.  See the Cookie, Pixel, and Session Replay Policy section.

  • Identifiers
  • Internet or other electronic network activity
  • Geolocation information
  • Electronic information

Third parties We may collect personal data from third-party social media platforms and sites, such as when you engage with our social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities or forums.  Please note that online forums may be publicly accessible and other individuals may view information you post in the forums.

  • Identifiers
  • Internet or other electronic activity information
  • Professional or employment-related information
Categories of Third-Party Recipient and Purpose for Disclosure
Categories of Personal Data We May Share

Inbenta group companies We may disclose personal information to other companies under common ownership or control.  We do so to provide you with the requested services, to take actions based on your requests, or to manage our ongoing business operations.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information
  • Electronic information
  • Professional or employment-related information
  • Audiovisual information

Our service providers and third-party vendors We use third-party vendors to perform operational functions related to the Inbenta Sites, services, and communications. Some of these vendors (e.g., marketing automation vendors, communication systems, or hosting providers) may have access to your personal data, but only as necessary to provide services to us. If the third-party vendor is our service provider, we have agreements in place with the vendors requiring your information to be kept confidential and reasonable data security measures to be used to protect it.

  • Identifiers
  • Internet or other electronic activity information
  • Electronic information
  • Professional or employment-related information
  • Audiovisual information

Government entities We may disclose personal data to government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or for the protection of the rights, property, or safety of our company or third parties. We may also disclose personal data in relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use, including with entities assisting us with an investigation, or as may be required by applicable law.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information
  • Electronic information
  • Professional or employment-related information
  • Audiovisual information

Business partners We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal data to our third-party business partners and service providers in order to maintain and operate the Inbenta Sites and Services and provide, improve, and personalize the Inbenta Sites and Services, including to fulfill requests for the services, and for other technical and processing functions, such as sending emails on our behalf and technical support.

  • Identifiers
  • Internet or other electronic activity information
  • Electronic information
  • Professional or employment-related information

Successor organizations Subject to applicable law, we reserve the right to transfer some or all personal data in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.  If any such transaction occurs, the purchaser will be entitled to use and disclose the personal data collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal data as described in this privacy policy.

  • Identifiers
  • Internet or other electronic activity information
  • Electronic information
  • Professional or employment-related information
  • Audiovisual information

1.2. IF YOU ARE AN INBENTA ONLINE SERVICE USER OR IF YOU LOAD AN INBENTA SERVICE

Inbenta Online Service Users are individuals who load an Inbenta service on a page, whether on the Inbenta sites or on a third-party site, or who interact with an Inbenta service.

We collect identifiers, Internet or other electronic activity information, and geolocation data about Inbenta Online Service Users.  We get this information automatically.  We can use this information for multiple purposes, such as providing and enhancing the Inbenta Sites and Services or detecting and preventing fraud, and we may disclose this information to other entities both inside and outside of our corporate family.

We do not collect the content or substance of your communications submitted through the Inbenta service, however.  That information is collected by our customer purchasing the Inbenta service and may only be accessed by our customer.  For information about how that information is used, please read our customer’s privacy policy.

Some features of the Inbenta Services use AI technologies to enhance user experience. Safeguards to ensure transparency and fairness are governed by the Use of Artificial Intelligence section.

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Category of Personal Data
Examples
Purpose of Collection and Use

Identifiers

Device ID; IP address

  • Provide and enhance the Inbenta Sites and Services
  • Customize your experience
  • Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
  • Comply with legal or regulatory obligations

Internet or other electronic activity information

Clickstream data; browser and operating system type; navigation paths; data/time stamps; cookie identifiers; or other information about device characteristics and how you interact with the Inbenta service

  • Provide and enhance the Inbenta Sites and Services
  • Customize your experience
  • Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
  • Comply with legal or regulatory obligations

Geolocation information

Geolocation information based on your IP address

  • Provide and enhance the Inbenta Sites and Services
  • Customize your experience
  • Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
  • Comply with legal or regulatory obligations
Sources of Personal Data
Categories of Personal Data We Collect

Automatically

We may collect personal data from you automatically when you load the Inbenta service or as you interact with the Inbenta service.  We usually store the data we collect automatically about Inbenta Online Service Users in identifiable form for a limited period of time.  In special circumstances, like extended investigations about technical attacks, we may preserve log data longer, for analysis.  We store aggregate statistics about use of content delivery networks indefinitely, but those statistics don’t include data identifiable to you personally.

  • Identifiers
  • Internet or other electronic network activity
  • Geolocation information
Categories of Third-Party Recipient and Purpose for Disclosure
Categories of Personal Data We May Share

Inbenta group companies

We may disclose personal information to other companies under common ownership or control.  We do so to provide you with the requested services, to take actions based on your requests, or to manage our ongoing business operations.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information

Our service providers and third-party vendors

We use third-party vendors to perform operational functions related to the Inbenta services.  Some of these vendors (e.g., hosting providers) may have access to your personal data, but only as necessary to provide services to us.  If the third-party vendor is our service provider, we have agreements in place with the vendors requiring your information to be kept confidential and reasonable data security measures to be used to protect it.

We may share personal data with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information

Government entities

We may share personal data with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or for the protection of the rights, property, or safety of our company or third parties.

We may also share personal data in relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use, including with entities assisting us with an investigation, or as may be required by applicable law.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information

Business partners

We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal data to our third-party business partners and service providers in order to maintain and operate the Inbenta services and provide, improve, and personalize the Inbenta services, including to fulfill requests for the services, and for other technical and processing functions, such as sending emails on our behalf and technical support.  

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information

Successor organizations

Subject to applicable law, we reserve the right to transfer some or all personal data in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.  If any such transaction occurs, the purchaser will be entitled to use and disclose the personal data collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal data as described in privacy policy.

  • Identifiers
  • Internet or other electronic activity information
  • Geolocation information

1.3. IF YOU ARE AN INBENTA INTEGRATED SERVICE USER

Inbenta Integrated Service Users are individuals who use or interact with an Inbenta service integrated with a third-party communication channel managed by a third party, who is an Inbenta customer.  For example, an Inbenta customer may offer a WhatsApp channel that is integrated with an Inbenta service.

We collect identifiers about Inbenta Integrated Service Users automatically.  We can use this information for multiple purposes, such as providing and enhancing the Inbenta Sites and Services or detecting and preventing fraud, and we may disclose this information to other entities both inside and outside of our corporate family.

If the Inbenta Integrated Service you interact with includes AI-based functionality, your inputs may be processed by underlying AI models to support natural language understanding and response generation. This processing is conducted in accordance with applicable privacy and security measures. Additional safeguards to ensure transparency and fairness are governed by theUse of Artificial Intelligence section.

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Category of Personal Data
Examples
Purpose of Collection and Use

Identifiers

User ID associated with the channel that the Inbenta service is integrated with (e.g., for WhatsApp a phone number or for Facebook a Facebook ID)

  • Provide and enhance the Inbenta Sites and Services
  • Customize your experience
  • Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
  • Comply with legal or regulatory obligations
Sources of Personal Data
Categories of Personal Data We Collect

Automatically

We may collect personal data from you automatically when you interact with the Inbenta Service integrated with the channel.  We usually store the data we collect automatically about Inbenta Integrated Service Users in identifiable form for a limited period of time.  In special circumstances, like extended investigations about technical attacks, we may preserve log data longer, for analysis.  We store aggregate statistics about use of content delivery networks indefinitely, but those statistics don’t include data identifiable to you personally.

  • Identifiers
Categories of Third-Party Recipient and Purpose for Disclosure
Categories of Personal Data We May Share

Inbenta group companies

We may disclose personal information to other companies under common ownership or control.  We do so to provide the requested services, to take actions based on your requests, or to manage our ongoing business operations.

  • Identifiers

Our service providers and third-party vendors

We use third-party vendors to perform operational functions related to the Inbenta services.  Some of these vendors (e.g., hosting providers) may have access to your personal data, but only as necessary to provide services to us.  If the third-party vendor is our service provider, we have agreements in place with the vendors requiring your information to be kept confidential and reasonable data security measures to be used to protect it.

We may share personal data with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.

  • Identifiers

Government entities

We may share personal data with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or for the protection of the rights, property, or safety of our company or third parties.

We may also share personal data in relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use, including with entities assisting us with an investigation, or as may be required by applicable law.

  • Identifiers

Business partners

We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal data to our third-party business partners and service providers in order to maintain and operate the Inbenta services and provide, improve, and personalize the Inbenta services, including to fulfill requests for the services, and for other technical and processing functions, such as sending emails on our behalf and technical support.  

  • Identifiers

Successor organizations

Subject to applicable law, we reserve the right to transfer some or all personal data in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.  If any such transaction occurs, the purchaser will be entitled to use and disclose the personal data collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal data as described in privacy policy.

  • Identifiers

2. USE OF ARTIFICIAL INTELLIGENCE

Some of Inbenta’s Services incorporate artificial intelligence (AI) technologies, including natural language processing (NLP), machine learning (ML), and large language models (LLMs), to deliver conversational and automated experiences. When you interact with these features, the information you provide (such as questions, inputs, or feedback) may be processed by automated systems solely to generate relevant responses or improve service performance.

Where our services involve the processing of personal data by AI systems, we implement additional technical and organizational safeguards to promote transparency and fairness. These measures aim to mitigate potential discriminatory impacts and help individuals understand how their data may be used in connection with automated processing. Our practices comply with applicable data protection and AI governance laws and regulations. For further information about our AI governance practices, including risk mitigation, please refer to our Trust Center.

Please note that Inbenta’s AI-powered services are not intended for, and must not be used in, prohibited or high-risk scenarios as defined under applicable regulations. This includes, but is not limited to: the manipulation of individuals through subliminal techniques or exploitation of vulnerable groups (such as minors or persons with disabilities); social scoring systems that evaluate individuals based on personal characteristics or behavior; real-time or remote biometric identification in public spaces; indiscriminate extraction or scraping of personal or biometric data from publicly accessible sources; biometric classification systems that infer sensitive attributes such as race, gender, religion, or sexual orientation; and any automated processing that could significantly affect individuals’ rights or freedoms. The use of Inbenta’s services to generate or disseminate deepfakes, engage in impersonation, voice or image cloning, political manipulation, or mass surveillance is strictly prohibited. Inbenta’s systems are also not designed to support AI applications in high-risk domains—such as healthcare, law enforcement, access to essential services, recruitment, credit assessment, or judicial processes—where elevated accountability and governance are required. Furthermore, customers are not permitted to disable or circumvent human oversight mechanisms, and the deployment of Inbenta’s AI technologies must not result in unlawful or disproportionate interference with individuals’ fundamental rights.

3. COOKIE, PIXEL, AND SESSION REPLAY POLICY

a. Usage Info and Cookies

When you access the Inbenta Sites and Services (including loading or interacting with the Inbenta services), our servers automatically collect and record the IP address associated with your computer and some additional information, such as your device ID and browser type and version.  This information is used to help us administer the Inbenta Sites and Services, and it is transmitted automatically by your web browser.  This information may be appended to your profile information to remember your preferences and diagnose technical problems.

This information may be stored in cookies.  If you do not wish to accept cookies, you can turn them off in your browser or select your preferences in our Cookie Policy.

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b. Do-Not-Track

The Inbenta Sites and Services do not support Do-Not-Track (DNT) functionality.  Do-Not-Track is a preference you can set on your web browser to inform websites that you prefer not to be “tracked’ by third parties.  Inbenta does not respond to Do-Not-Track signals because it does not track your activity once you leave an Inbenta site.  Inbenta’s third-party service providers, who provide ad serving, retargeting services and web analytics services to Inbenta, may not respond to Do-Not-Track signals.  Inbenta does not control these third parties, and their tracking technologies are either technically necessary or used only with your explicit consent, which you can manage through your preferences.  If you visit an Inbenta site with Do-Not-Track enabled in your browser, Inbenta does not detect or respond to the Do-Not-Track signal.

c. Interest-Based Advertising

Interest-based ads, also known as personalized ads, are ads that are targeted to you based on your web browsing and app usage over time and across websites or apps.  For example, the Inbenta Sites and Services may use third-party ad servers, retargeting services, and web analytics systems, such as Google, to analyze aggregate web usage statistics and provide the ability to display targeted advertisements to you based on your visit to our website.   Inbenta does not display advertisements on the Inbenta sites nor within any of our services, but our customer purchasing the Inbenta service you interact with may make different choices not controlled by Inbenta, and you should refer to the privacy policy of that company or website to understand how it may display ads to you.

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d. Session Replay

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with the Inbenta Sites and Services through behavioral metrics, heatmaps, and session replay.  We do not use session replay technology in the Inbenta services.

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4. AGGREGATED, DE-IDENTIFIED, OR ANONYMOUS INFORMATION

We may create aggregated, de-identified, or anonymous information from personal data by removing certain data components that makes the data identifiable (such as your name, email address, or linkable tracking ID), or through aggregation, obfuscation or other means for us to use  to understand how to improve or enhance the Inbenta Sites and Services.  Subject to applicable law, such aggregated, de-identified, or anonymized information is not personal data and our use of such information is not subject to this privacy policy.

5. YOUR CHOICES

You have certain choices with respect to your personal data.  Any individual may have the right to opt-out of sharing their personal information, if such personal information is disclosed to a third-party or is used for a materially different purpose for which it was initially collected or subsequently authorized by the individual.  If you wish to exercise this right, please contact privacy@inbenta.com.

a. Update Your Communications Preferences

At the time of data collection, individuals are provided with clear information and options to exercise choice regarding the use or disclosure of their personal information, including via consent disclaimers in our webforms, configurable cookie settings through the cookie banner, and links to our privacy policy embedded in key user interfaces.

We may use your contact information to send you email messages regarding updates to the Inbenta Sites and Services, such as the publication of new Inbenta information and content, promotional offers, or to communicate with you about the Inbenta Sites and Services.  You may opt-out of receiving these emails at any time via our Preference Center.  Please be advised that you may not be able to opt-out of receiving certain messages from us, including legal notices.

In order to opt-out of third-party communications, you need to contact the applicable third party.  If you have any questions relating to opting-out, please contact us at privacy@inbenta.com.

b. Exercise Rights Based on Your Residency or Location

Residents of certain states or countries may have additional or different rights as described elsewhere in this privacy policy.

6. LOCALIZATION OF DATA STORAGE AND PROCESSING

a. Location of the Inbenta Sites and Services

The Inbenta Sites and Services are operated from various locations globally; however, Inbenta’s headquarters and management are in the United States.  If you are located outside of the United States, any information you provide to us may be transferred to, processed, or maintained in the United States.  If you are located outside of the United States, the transfer of personal data may be necessary to provide you with the requested information and services, or to perform any requested transaction.

b. Transfers

The provision of Inbenta services may involve the processing of personal data by companies located in countries outside the European Economic Area (international data transfers). However, it is only done with companies that are in countries that offer an adequate level of protection or have made available to us Standard Contractual Clauses (SCC) in accordance with the decision of the European Commission to Data transfers from controllers in the EU to processors established outside the EU.

Specifically, information we collect from you might be processed in the United States, and by using Inbenta services you acknowledge and consent to the processing of your data in the United States for the purpose of providing such services to you.

c. EU-U.S. Data Privacy Framework with UK Extension, and Swiss-U.S. Data Privacy Framework

European data privacy laws restrict the transfer of personal data out of Europe, in particular to the United States, where we are located.  To address those restrictions, we comply with certain frameworks agreed to by the United States and the European Union, Switzerland, and the United Kingdom, through which we can transfer personal data out of Europe.  We also use contracts and agreements issued by the European Commission and the United Kingdom to comply with the transfer restrictions.

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7. DATA SECURITY

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, disclosure, alteration, or destruction. These include encryption, access controls, secure storage, data minimization, and internal security policies.

However, while we strive to ensure the confidentiality, integrity, and availability of your data, there is always some risk involved in transmitting information over the Internet, and we cannot fully eliminate security risks associated with the storage and transmission of personal data.

Use of AI systems is governed by the safeguards described in the Use of Artificial Intelligence section.

To learn more about our security and compliance practices, please visit our Trust Center.

8. LINKS TO OTHER WEBSITES

The Inbenta Sites and Services contains links to other websites, including social networking websites, mobile applications, or Internet locations (collectively “Third-Party Sites”).  We have no control over and are not responsible for third-party websites, their privacy practices, their content, or any goods or services available through the Third-Party Sites.  Our privacy policy does not apply to Third-Party Sites; any information you provide to a Third-Party Site is subject to that Third-Party Site’s privacy policy or privacy policy.

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9. CHILDREN’S PRIVACY

The Inbenta Sites and Services offered are not directed to or intended for use by minors.  We do not knowingly collect or solicit personal data from minors, or knowingly allow such persons to register for our services.  No minor may provide any personal data to Inbenta or on the Inbenta Sites and Services.  If you are a minor, please do not attempt to register for the Inbenta Sites and Services or send any information about yourself to us, including your name, address, telephone number, or email address.  If we learn that we have inadvertently collected personal data from a minor without parental consent, we will take steps to delete the data as permitted by law.  If you believe that we might have any information from or about a minor, please contact us at privacy@inbenta.com.  

10. ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS

Inbenta Sites and Services may be accessed via the Internet from various locations.  We provide additional information about our controllers and data protection officers (as applicable) and privacy rights for certain jurisdictions where Inbenta has a presence.

Where applicable law requires, you have rights related to the use of AI and automated processing, including the right to be informed when AI systems are involved, the right to request human review of automated decisions, and the right to transparency regarding the logic and safeguards applied. For more information, please see the Use of Artificial Intelligencesection.

10.1. BRAZIL

The Lei Geral de Proteção de Dados (LGPD) regulates the collection, use, and disclosure of personal data of individuals in Brazil and by companies located in Brazil. If we are processing your personal data in Brazil, the controller of your data is Inbenta Brasil Consultoria E Tecnologia LTDA.

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10.2. EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND

a. General

The General Data Protection Regulation (GDPR) governs processing of personal data by organizations in the European Economic Area or about individuals located in the European Economic Area. The current members of the European Economic Area are Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, and Sweden.

The Data Protection Act 2018 (UK GDPR) governs processing of personal data by organizations in the United Kingdom or about individuals located in the United Kingdom.

The Federal Act on Data Protection (FADP) governs processing of personal data by organizations in Switzerland or about individuals located in Switzerland.

The controller of the Inbenta Sites and Services is Inbenta Technologies Inc. and our representative in Europe is the Inbenta Holdings Inc. Spain Branch.

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Inbenta Technologies Inc.
950 West Bethany Drive, Suite 400
Allen, TX 75013 USA
privacy@inbenta.com

Inbenta Holdings Inc.
Spain Branch
Tarragona 161, 9th floor, 08014 Barcelona,Spain

privacy@inbenta.com

b. Retention

We retain personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

c. Data Subject Rights

If the GDPR, UK-GDPR or FADP apply to your personal data, you may have the right to:

  • access your personal data;
  • rectify inaccurate personal data about you;
  • erase of your personal data;
  • place restrictions on processing your personal data;
  • object to processing your personal data;
  • receive your personal data in a portable format;
  • withdraw your consent for processing;
  • be informed about how, why, for how long your data is processed, and to which third-parties your data is disclosed; and
  • not to be subject to a decision based solely on automated processing.

These rights are not absolute and may be subject to limitations or restrictions. You can exercise your GDPR, UK-GDPR and FADP rights by emailing our DPO or by filling in our online webform. Our DPO can be contacted as follows:

Tarragona 161, 9th floor, 08014 Barcelona, Spain
privacy@inbenta.com

We will confirm receipt of your rights request within 10 days of receipt of your request, along with a description of the steps we will take to verify and respond. According to the requirements of the GDPR and UK-GDPR, we must provide the requested information or delete your personal data within 30 days of receipt of your request.

You also have the right to lodge a complaint with a supervisory authority. If you are in the European Economic Area or would like to contact a European supervisory authority, their contact information is here. If you are in the United Kingdom or would like to contact the UK Information Commissioner’s Office, you can do so here. If you are in Switzerland or would like to contact the Federal Data Protection and Information Commissioner (FDPIC), you can do so here.

10.3. CANADA

The Personal Information Protection and Electronic Documents Act (PIPEDA) regulates the collection, use, and disclosure of personal information of individuals in Canada and by companies located in Canada in the course of a commercial activity. If we are processing your personal information in Canada, the controller of your data is Inbenta Technologies Inc. Canada.

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10.4. JAPAN

The Act on the Protection of Personal Information regulates the collection, use, and disclosure of personal data by organizations in Japan. The personal information handling business operator in Japan is Inbenta Japan LLC.

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10.5. CALIFORNIA (U.S.)

Inbenta is covered under the CCPA as we collect and process the Personal Data of California residents. This privacy policy provides the required notices to California residents. The CCPA also prohibits covered businesses from providing discriminatory treatment to California residents if they exercise their rights under the Act.

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10.6. OTHER U.S. STATES

We may be subject to other state data privacy laws based on our interaction with residents of those states and our use of their personal data. These laws provide said individuals enhanced rights with respect to their personal data when interacting with us. This section explains what rights said individuals may have under the mentioned laws.

Please note the rules implementing some of these laws have not yet been finalized. We will update our processes, disclosures, and this notice as these implementing rules are finalized, and as otherwise necessary.

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11. UPDATES TO THIS PRIVACY POLICY

We may update this privacy policy from time to time. The “effective date” at the top of this privacy policy indicates when this privacy policy was last revised. Any changes are effective when we post the revised privacy policy on the Inbenta Sites and Services. We encourage you to routinely review this privacy policy to learn about updates to our privacy practices.

12. CONTACT US

For more information or if you have questions or concerns about our privacy practices, please contact us as it follows:

Inbenta Technologies Inc.
950 West Bethany Drive, Suite 400
Allen, TX 75013 USA
privacy@inbenta.com