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Effective Date: January 1, 2024

Inbenta (“Inbenta,” “we,” “our,” or “us”) provides Chatbot, Knowledge, Search and Messenger services to its customers and partners. This privacy policy applies to Inbenta’s public-facing website and applications, including inbenta.com and all related websites, web-based services, Inbenta Chatbot, mobile apps, and products 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.

When we refer to “personal data,” we mean information about an identified individual or about an individual whom we could identify. Subject to applicable law, personal data generally does not include publicly available information or anonymized or de-identified data.

This privacy policy does not apply to third-party websites, products or services, even if they link to the Inbenta Sites and Services or embed the Inbenta Chatbot (or another Service offered by Inbenta). We recommend that you review the privacy practices of those third parties before connecting or accessing third-party websites and sharing any personal data, including with the Inbenta Chatbot as deployed by any third-party. See the Links to Other Websites section for more information.

Similarly, this privacy policy does not apply to our careers pages hosted by LinkedIn or BambooHR or to personal data we collect or use about job applicants or employees. We collect, use, and disclose personal data about job applicants or employees for different reasons than other personal data we may collect, use, or disclose. For information about how we collect, use, or disclose personal data about job applicants or employees, please contact us using information in the Contact Us section.

Without prejudice to your rights under applicable laws, this privacy policy is not contractual and does not form part of your contract with us or our affiliates or subsidiaries.

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 Chatbot, and individuals who use Inbenta products integrated into other communication channels, because we collect, use, and disclose information differently depending on how you interact with us.

This privacy policy applies to the following types of individuals and our collection, use, or disclosure of these individuals’ personal data:

  • An Inbenta Site Visitor: You visit or interact with the Inbenta Sites, whether or not with the Inbenta Chatbot.
  • An Inbenta Chatbot User: You interact with the Inbenta Chatbot, whether it is hosted on the Inbenta Sites or by a third party, or you load a page containing the Inbenta Chatbot. For example, you visit a third-party website that has the Inbenta Chatbot installed.
  • An Inbenta Integrated Product User: You interact with an Inbenta product that is integrated into a communication channel managed by a third party, such as WhatsApp.

You may be included in some or all of these categories.

For example, if you visit the Inbenta Sites, you are an Inbenta Site Visitor, and the “If you are an Inbenta Site Visitor” section explains how we may collect, use, or disclose your personal data. If you visit a third-party site that has the Inbenta Chatbot, and you load the Inbenta Chatbot or interact with the Inbenta Chatbot, you are an Inbenta Chatbot User. The “If you are an Inbenta Chatbot User or load the Inbenta Chatbot” section explains how we may collect your personal data through the Inbenta Chatbot and how we may use or disclose it. And if you visit a page on the Inbenta Sites that has the Inbenta Chatbot, and you load the Inbenta Chatbot or interact with the Inbenta Chatbot, you are both an Inbenta Site Visitor and an Inbenta Chatbot User.

We encourage you to read this privacy policy thoroughly. For more information, contact us using the information in the “Contact Us” section.

2. IF YOU ARE AN INBENTA SITE VISITOR

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.

We collect identifiers, Internet or other electronic activity information, geolocation data, electronic information, and professional or employment-related information about Inbenta Site Visitors. We get this information automatically, from you, and from others, and we can use this information for multiple purposes, such as providing and enhancing the Inbenta Sites. We may disclose this information to other entities both inside and outside of our corporate family.

If you load or interact with the Inbenta Chatbot on our Sites, the “If you are an Inbenta Chatbot User or load the Inbenta Chatbot” section explains how we may collect your personal data through the Inbenta Chatbot and how we may use or disclose that data.

a. Types of Personal data We Collect About Inbenta Site Visitors and Why

We may collect the following categories of personal data about Inbenta Site Visitors, for the purposes stated in the chart.

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

b. How We Collect Information About Inbenta Site Visitors

We may collect personal data about Inbenta Site Visitors from the following sources:

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

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

c. Parties To Whom We May Disclose Information About Inbenta Site Visitors

We disclose personal data about Inbenta Site Visitors as follows:

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 products and 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

Our service providers and third-party vendors

We use third-party vendors to perform operational functions related to the Inbenta Sites.  Some of these vendors (e.g., marketing automation vendors 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

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
  • Electronic information
  • Professional or employment-related 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

3. IF YOU ARE AN INBENTA CHATBOT USER OR IF YOU LOAD THE INBENTA CHATBOT

Inbenta Chatbot Users are individuals who load the Inbenta Chatbot on a page, whether on the Inbenta Sites or on a third-party site, or who interact with the Inbenta Chatbot.

We collect identifiers, biometric information, Internet or other electronic activity information, and geolocation data about Inbenta Chatbot 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 Chatbot, however. That information is collected by our customer using the Inbenta Chatbot and may only be accessed by our customer. For information about how that information is used, please read our customer’s privacy policy.

a. Types of Information We Collect About Inbenta Chatbot Users and Why

We may collect the following categories of personal data about Inbenta Chatbot Users, for the purposes stated in the chart.

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 Chatbot
  • 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

b. How We Collect Information About Inbenta Chatbot Users

We may have collected personal data about Inbenta Chatbot Users from the following sources stated in the chart.

Sources of Personal Data Categories of Personal Data We Collect

Automatically

We may collect personal data from you automatically when you load the Inbenta Chatbot or as you interact with the Inbenta Chatbot.  We usually store the data we collect automatically about Inbenta Chatbot 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

c. Parties To Whom We May Disclose Personal Data About Inbenta Chatbot Users

We disclose personal data about Inbenta Chatbot Users as follows:

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 products and 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 Chatbot.  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 Chatbot and services and provide, improve, and personalize the Inbenta Chatbot 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
  • 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

d. Additional Information For Inbenta Chatbot Users

We may use aggregated, de-identified, or anonymized information about how you use the Inbenta Chatbot or from which domains or websites you load the Inbenta Chatbot to improve the functionality of the Inbenta Chatbot and improve our service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends. Please see the Aggregated, De-Identified, or Anonymous Information section for more information.

When you interact with the Inbenta Chatbot, you generate personal data that includes the substance of your communications through the Inbenta Chatbot. We do not collect the content or substance of your interactions with the Inbenta Chatbot. Rather, that information is collected (through Inbenta’s servers) by the company providing the website that has the Inbenta Chatbot, and you should refer to the privacy policy of that company or website to understand how it may collect, use, or disclose your personal data contained in the content or substance of your interactions with the Inbenta Chatbot. We do not determine the purpose or means of processing that information. For example, our website, www.inbenta.com, uses the Inbenta Chatbot. The information automatically sent by loading the Inbenta Chatbot or interacting with the Inbenta Chatbot is governed by this section of our privacy policy. If you decide to interact with the Inbenta Chatbot, the content or substance of your interactions with the Inbenta Chatbot is governed by the If You Are An Inbenta Site Visitor section.

4. IF YOU ARE AN INBENTA INTEGRATED PRODUCT USER

Inbenta Integrated Product Users are individuals who use or interact with an Inbenta product integrated with a third-party 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 product.

We collect identifiers about Inbenta Integrated Product 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.

We do not collect the content or substance of your communications submitted to the Inbenta integrated product, however. That information is collected by our customer managing the third-party channel integrated with the Inbenta product and may only be accessed by our customer. For information about how those communications may be used, please see our customer’s privacy policy.

a. Types of Information We Collect About Inbenta Integrated Product Users and Why

We may collect the following categories of personal data about Inbenta Integrated Product Users, for the purposes stated in the chart.

Category of Personal Data Examples  Purpose of Collection and Use
Identifiers User ID associated with the channel that the Inbenta product 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 

b. How We Collect Information About Inbenta Integrated Product Users

We may have collected personal data about Inbenta Integrated Product Users from the following sources stated in the chart.

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 Product integrated with the channel.  We usually store the data we collect automatically about Inbenta Integrated Product 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

c. Parties To Whom We May Disclose Personal Data About Inbenta Integrated Product Users

We disclose personal data about Inbenta Chatbot Users as follows:

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 products and 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 products.  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 products and services and provide, improve, and personalize the Inbenta products 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

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

d. Additional Information For Inbenta Integrated Product Users

We may use aggregated, de-identified, or anonymized information about how you interact with the Inbenta product integrated with your chosen communication channel to improve the functionality of the Inbenta products and improve our service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends. Please see the Aggregated, De-Identified, or Anonymous Information section for more information.

When you interact with the Inbenta product integrated with your chosen communication channel, you generate personal data that includes the substance of your communications with the Inbenta product. We do not collect the content or substance of your interactions with the Inbenta product. Rather, that information is collected (through Inbenta’s servers) by the company managing the channel with which the Inbenta product is integrated, and you should refer to the privacy policy of that company to understand how it may collect, use, or disclose your personal data contained in the content or substance of your interactions with the Inbenta product. We do not determine the purpose or means of processing that information.

a. Usage Info and Cookies

When you access the Inbenta Sites and Services (including loading or interacting with the Inbenta Chatbot), 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. We may also use web beacons, pixels, or similar collection mechanisms.

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.

The additional information we may collect include device ID, browser type and version, the operating system of your device and language, country, the date and time of visits, the pages viewed, time spent on the Inbenta Sites and Services, and the websites visited just before and just after an Inbenta Site or Service.

We use cookies to collect this information. Cookies are small data files sent by a website and stored on the computer or device at the request of that site. Cookies store information related to a user’s browser to enable us to recognize your device on return visits to the Inbenta Sites and Services and to remember your preferences.

Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. If you want to block the use and saving of cookies from the Inbenta Sites and Services on to the computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Services and external serving vendors. Please note that if you choose to erase or block your cookies, certain parts of our Services may not function correctly. For information on how to disable cookies in your browser, refer to your browser’s documentation. In addition, our Cookie Policy has additional relevant information.

We may also use web beacons, pixels, or similar collection mechanisms, and in certain circumstances may collect IP addresses, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.

The Inbenta Sites and Services currently use Google Analytics. Please read “How Google uses data when you use our partners’ sites or apps,” which you can find at www.google.com/policies/privacy/partners/, for information about how Google Analytics collects and processes data. If you wish to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

b. Do-Not-Track

The Inbenta Sites and Services do not support Do-Not-Track functionality. Do-Not-Track is a preference you can set on your web browser to inform websites that you do not want to be “tracked’ by third parties. Inbenta does not respond to Do-Not-Track Signals as it does not track you when 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. If an individual comes to an Inbenta Site directly with a Do-Not-Track signal enabled on such individual’s browser, Inbenta does not look for the Do-Not-Track signal or respond to it.

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. However, we do not display advertisements on the Inbenta Sites and Services.

You may be able to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads. Some of these third parties may use cookies and other technologies to collect information about your online activities over time and across third-party websites or online services to deliver advertising based on your interests and preferences, as inferred from your browsing history. Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information that those third-party Providers collect about your visits to this site and elsewhere over time.

To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit http://optout.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit https://optout.networkadvertising.org to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”). Note that electing to opt-out does not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests. This opt-out works through cookies set on a particular browser, so if you delete cookies from a web browser, or use a different browser, you will need to opt out again.

Your choice to opt out on a particular browser or device applies only to the collection and use of information from that particular browser or device. Opting out on a particular device does not opt you out of information collection on other devices, nor does it limit cross-device sharing on those other devices. If you use different browsers on a device or multiple devices, for each browser and device you wish to opt out, please opt out each device and browser separately at http://optout.aboutads.info and at https://optout.networkadvertising.org.

Depending on where you live or are located, you may have additional rights.

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 Chatbot.

Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. We use this information as described in the If You Are An Inbenta Site Visitor section. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy policy. We do not use these technologies to collect information that is inconsistent with your intent, and we do not use it to record sensitive information related to credit cards. We do not provide information gathered to third parties other than our service providers.

We do not use session replay technology in the Inbenta Chatbot. If the Inbenta Chatbot is loaded on a third-party site, please be aware that if the third-party site uses session-replay or similar technologies, the third-party site may be able to reconstruct how you interacted with the Inbenta Chatbot. See the Links To Other Websites section for more information.

6. AGGREGATED, DE-IDENTIFIED, OR ANONYMOUS INFORMATION

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

7. YOUR CHOICES

You have certain choices with respect to your personal data.

a. Update Your Communications Preferences

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.

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.

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.

8. LOCALIZATION OF DATA STORAGE AND PROCESSING

a. Location of the Inbenta Sites and Services

The Inbenta Sites and Services are operated in the United States. If you are located outside of the United States, any information you provide to us is transferred to, processed, and/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 and/or to perform any requested transaction.

b. Transfers

The provision of these 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 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 these services you acknowledge and consent to the processing of your data in the United States.

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.

Inbenta complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Inbenta has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF. Inbenta has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Inbenta is responsible for the processing of personal data it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. Inbenta complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Inbenta’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Inbenta may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Inbenta commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

In addition to participating in the DPF, we also use the EU Standard Contractual Clauses as issued by the European Commission as well as the U.K. International Data Transfer Agreement as secondary measures. Where needed based on our data transfer impact assessments, we implement additional technical and/or organization measures intended to adequately protect your data.

9. DATA SECURITY

We have taken steps to secure and protect your personal data from loss, unauthorized access, unauthorized disclosure, misuse, destruction, or alteration. However, 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.

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.

The fact that we link to a website is not an endorsement or representation of an affiliation with that website. You should carefully review the applicable privacy policies before using or engaging with any Third-Party Site on any of the Inbenta Sites or Services.

The Inbenta Sites and Services may include social network sharing widgets that may provide information to their associated social networks or third parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the widget appears. If you use social networking tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.

11. CHILDREN’S PRIVACY

The Inbenta Sites and Services offered are not directed to or intended for use by children under 13 years of age. We do not knowingly collect or solicit personal data from anyone under the age of 13, or knowingly allow such persons to register for our services, without parental consent. No one under age 13 may provide any personal data to Inbenta or on the Inbenta Sites and Services. If you are under 13, 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 an individual under age 13 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 an individual under age 13, please contact us at privacy@inbenta.com.

12. ADDITIONAL INFORMATION FOR INDIVIDUALS IN 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. You may have certain rights under Brazilian law, which you may exercise by emailing us at privacy@inbenta.com or by filling in our online webform.

Inbenta Brasil Consultoria E Tecnologia LTDA may be contacted as follows:

Av. Paulista, 2028 – 10º andar – Bela Vista
São Paulo – SP
01310-200
privacy@inbenta.com

If you are in Brazil and we are processing your personal data outside of Brazil, the particular entity that is the controller of your data may vary. Please contact Inbenta Brasil Consultoria E Tecnologia LTDA for more information at privacy@inbenta.com.

If the LGPD is applicable to you, you may have the right to:

  • confirm that your personal data is being processed;
  • access your personal data;
  • correct incomplete, incorrect or out-of-date personal data;
  • have anonymized, blocked, or deleted any unnecessary, excessive, or non-compliant personal data;
  • request that a data controller moves your personal data to another service or product provider (data portability);
  • delete your personal data (with exceptions);
  • be given information on public or private entities with whom, and how your personal data has been shared;
  • be given information about your rights to not give consent to process your personal data, and consequences of refusal; and


Note that we may have to process your personal data as a condition of providing a product or service or to handle a request to exercise one of the LGPD rights. For example, if you ask us to provide you with information about our products and services, we must process your personal data in order to provide you with the information you requested. The LGPD requires that we specially highlight this fact.

You can exercise your LGPD rights by emailing us at privacy@inbenta.com or by filling in our online webform.

You can lodge a complaint regarding your LGPD rights with Brazil’s Autoridade Nacional de Proteção de Dados (ANPD). If you are a Brazilian resident, you may also lodge a complaint with Consumer’s rights authorities (PROCON) of your Brazilian state of residence.

13. ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA OR UNITED KINGDOM

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 UK GDPR governs processing of personal data by organizations in the United Kingdom or about individuals located in the United Kingdom.

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

You may have certain rights under EU and UK law, which you may exercise by emailing us at privacy@inbenta.com or by filling in our online webform.

We process your personal data based upon your consent, as necessary to perform a contract with you or that we are entering into with you, based on legitimate interests, or as required by our legal obligations within the European Economic Area or United Kingdom.

Inbenta Technologies Inc. and Inbenta Holdings Inc., Spain Branch may be contacted as follows:

Inbenta Technologies Inc.
950 West Bethany Drive, Suite 400
Allen, TX 75013 USA
privacy@inbenta.com 
Inbenta Holdings Inc. 
Spain Branch
Carrer d’Aribau, 64 baix
08011, Barcelona, Spain
privacy@inbenta.com 

In addition, we have appointed a data protection officer, who may be contacted for EEA inquires as follows:

Aribau 64
BJ, 08011 Barcelona, Spain
dpo@inbenta.com

Basis for processing your Personal Data. We process your personal data based upon your consent, as necessary to perform a contract with you or that we are entering into with you, based on legitimate interests, or as required by our legal obligations within the European Economic Area or United Kingdom. If you would like more information about the legitimate interests and bases for processing in particular processing operations, we invite you to contact us at privacy@inbenta.com.

Examples of personal data processed based upon your consent. If we are directing marketing communications to you, in your individual capacity, we do so with your consent unless an exception applies (such as to send you direct marketing about similar products or services to ones you have already purchased from us). If you wish to withdraw your consent, you may unsubscribe through the email or contact us at privacy@inbenta.com. Withdrawing your consent does not affect processing operations we have already completed based upon your consent.

Examples of personal data processed based upon a contract with you. If we have entered into a contract with you, in your individual capacity, we process your personal data as necessary to enter into and perform our obligations under the contract. These can include, for example, processing your payment information to collect payment and your contact information.

Examples of personal data processed based upon legitimate interests. We may process your personal data for our legitimate interests or the legitimate interests of third parties, which include advertising or market and opinion research, as far as you have not objected to the use of your data; entering into a contract with a third party (which could include your employer) and performing our obligations under that contract; the examination and optimization of processes for needs analysis; the further development of services and products as well as existing systems and processes; the disclosure of personal data within the framework of due diligence in the course of company sale negotiations; for comparison with European and international anti-terrorist lists, insofar as this goes beyond the legal obligations; the enrichment of our data, e.g., by using or researching publicly accessible data; statistical evaluations or market analysis; benchmarking; the assertion of legal claims and defense in legal disputes which are not directly attributable to the contractual relationship; the restricted processing of data, if a deletion is not possible or only possible with disproportionately high effort due to the special type of storage; the development of scoring systems or automated decision-making processes; the prevention and investigation of criminal offenses, if not exclusively for the fulfillment of legal requirements; and complying with our legal obligations in countries outside of the European Economic Area or the United Kingdom. If you would like more information, or to object to a particular processing operation based upon legitimate interests, please contact us at privacy@inbenta.com.

Our use of automated decision-making. We may engage in decision-making or profiling in the course of our processing operations. We do not, however, engage in solely automated decision-making, including profiling, that in our view would produce legal effects or similarly significantly affect you.

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 applies 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; and
  • withdraw your consent for processing.


These rights are not absolute and may be subject to limitations or restrictions. For more information, or to exercise your rights, please contact us at privacy@inbenta.com.

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.

14. ADDITIONAL INFORMATION FOR INDIVIDUALS IN 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. You may have certain rights under Japanese law, which you may exercise by emailing us at privacy@inbenta.com or by filling in our online webform.

Inbenta Japan LLC may be contacted as follows:

T010-0966 Akita-ken Akita-shi
Sanno 1-10-22 Ishikawa Jumusho
Bill 1F A
privacy@inbenta.com

If Japanese law applies to your personal data, you may have the right to:

  • access your personal data;
  • ask us to cease providing your personal data in identified form to a third party;
  • understand the purposes of which we are using or disclosing personal data;
  • consent to our processing your personal data for new purposes;
  • correct personal data that is not factual;
  • ask us to cease using your personal data or to delete your personal data; and
  • appoint an agent to make these requests on your behalf.

These rights are not absolute and are subject to multiple exceptions. For example, we may decline to provide you with access to your personal data if doing so would be likely to harm the life, body, property, or other rights or interests of you or someone else or would be likely to seriously interfere with the proper implementation of our businesses. If we decline to do what you have requested in full or in part, we will strive to explain the reason why to you.

We may charge you a reasonable fee if you request to access your personal data or to understand the purposes of our use or disclosure of your personal data. The fee will be reasonable based upon our actual expenses in responding to your request.

You can exercise your rights under the Act on the Protection of Personal Information by emailing us at privacy@inbenta.com or by filling in our online webform.

15. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

a. The California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, gives California residents enhanced rights with respect to their personal data that is collected by businesses. This section explains what rights California residents may have under the CCPA. California residents may exercise their rights by emailing us at privacy@inbenta.com, by filling in our online webform, or writing us at our headquarters office in Texas.

First, California residents may opt-out of having their Personal Data sold to or shared with other persons or parties. As explained below, Inbenta does not sell or share Personal Data.

Second, California residents have a right to know:

What specific pieces of information a business has about the resident;

Categories of personal data it has collected about the resident;

Categories of sources from which the personal data is collected;

Categories of personal data that the business sold, shared, or disclosed for a business purpose about the resident;

Categories of third parties to whom the personal data was sold, shared, or disclosed for a business purpose; and

The business or commercial purpose for collecting, selling, or sharing Personal Data.

Third, California residents can request that the personal data a business has collected from them be deleted from the business’s systems and records, subject to certain exceptions.

Fourth, California residents can request that inaccurate personal data a business maintains about them be corrected.

Fifth, California residents can request to limit the use of their sensitive personal data. Inbenta does not use or disclose sensitive personal data.

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.

The CCPA defines “sale” to include data transfers for monetary or other valuable consideration. We do not sell or share your personal information to third parties. As stated above in the data collection sections, we collect and transmit your data to third-party service providers in order to deliver services to you. We do not have actual knowledge that we have sold or shared the Personal Data of California residents under 16 years of age.

To make a “request to know,” “request to delete,” or “request to correct” your Personal Data, please fill in our online webform or send us an e-mail at privacy@inbenta.com. If you email us, please put in the subject line of your email the right you are seeking to invoke: “California Request to Know,” “California Request to Delete,” or “California Request to Correct”.

You may also submit these requests by mailing your request to:

Inbenta Technologies Inc.
950 West Bethany Drive, Suite 400
Allen, TX 75013

We will confirm receipt of your request to know, delete, or correct within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal data within 45 days of receipt of your request but can use an additional 45 days, but we will let you know if additional time is needed.

When contacting us, we may ask you to provide certain, limited personal data, such as your name, e-mail address and/or username to verify your request and to match with our records and systems. We will not retain this Personal Data or use it for any other purpose. To inquire about exercising these rights, please contact us at privacy@inbenta.com.

b. California’s “Shine The Light” Law

We do not respond to requests under California’s “Shine The Light” law (California Civil Code § 1798.83) because in the immediately preceding calendar year we have not disclosed the types of personal data requiring disclosure under that law.

16. ADDITIONAL INFORMATION FOR CONNECTICUT RESIDENTS

We may be subject to the Connecticut Data Privacy Act based on our interactions with Connecticut residents and our use of their personal data. This law provides Connecticut residents enhanced rights with respect to their personal data when they are not acting solely in a commercial or employment context (such as a B2B communication) with interacting with us. This section explains what rights Connecticut residents may have under the CTDPA. Connecticut residents may exercise those rights by emailing us at privacy@inbenta.com or by filling in our online webform.

In this section, “CTDPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Connecticut resident. CTDPA personal data does not include de-identified or publicly available information, as defined in the Connecticut Data Privacy Act.

First, a Connecticut resident may have the right to confirm whether we are processing CTDPA personal data concerning them and to access their CTDPA personal data.

Second, a Connecticut resident may have the right to correct inaccuracies in their CTDPA personal data we hold.

Third, a Connecticut resident may have the right to request we delete CTDPA personal data concerning them.

Fourth, a Connecticut resident may also request to receive their CTDPA personal data in a portable and, if technically feasible, readily usable format.

Fifth, a Connecticut resident may opt out of processing their CTDPA personal data for purposes of targeted advertising, the sale of their CTDPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Connecticut resident. We do not sell CTPDA personal data or process CTDPA personal data for purposes of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning Connecticut residents.

To exercise your rights, please fill in our online webform or email us at privacy@inbenta.com. If you email us, please put in the subject line of your email the right you are seeking to invoke: “Connecticut Right to Access,” “Connecticut Right to Correct,” “Connecticut Right to Delete,” “Connecticut Right to Portability,” and “Connecticut Right to Opt Out.”

You may submit multiple requests at once through our webform or in an email. There is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests. For requests other than a Right to Opt Out, we are permitted to use commercially reasonable efforts to authenticate you are who you say you are and if you are making a request on behalf of another, that you have the authority to do so. If we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you. If we cannot authenticate you or your authority, we will deny the request. If you submit a Right to Opt Out request, we are permitted to deny the request if we have a good faith, reasonable and documented belief that the request is fraudulent, and we will tell you that and why.

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your personal data) without undue delay and within 45 days after we receive your request. We may extend that deadline by 45 days, to 90 days in total, in some cases. If we extend the deadline, we will tell you that and why.

Connecticut’s law includes exceptions for personal data regulated under other laws or maintained for certain reasons or in certain contexts. For example, it does not apply to publicly available information, including information that we reasonably believe Connecticut residents have lawfully made available to the general public. As another example, we will not delete personal data when it is necessary to maintain that personal data to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not. You may appeal our decision by emailing us at privacy@inbenta.com with the subject line “Appeal of Request” and including our response to your request. We will also include this information in our response to your request. If you appeal our decision, we have 60 days to respond.

In addition, when you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookie, Pixel, and Session Replay Policy section for targeted advertising, which we may disclose or make available to advertising and social media networks.

17. ADDITIONAL INFORMATION FOR COLORADO RESIDENTS

We may be subject to the Colorado Privacy Act based on our interactions with Colorado residents and our use of their personal data. The Colorado Privacy Act provides Colorado residents enhanced rights with respect to their personal data when acting in an individual or household context. This section explains what rights Colorado residents may have under the CPA. Colorado residents may exercise those rights by emailing us at privacy@inbenta.com or filling in our online webform.

In this section, “CPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Colorado resident. CPA personal data does not include de-identified or publicly available information, as defined in the Colorado Privacy Act.

First, a Colorado resident may opt out of processing their CPA personal data for purposes of targeted advertising, the sale of their CPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Colorado resident. We do not sell CPA personal data or process CPA personal data for purposes of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning Colorado residents.

Second, a Colorado resident has the right to confirm whether we are processing CPA personal data concerning them and to access their CPA personal data. As part of a request for access, the Colorado resident may also request to receive their CPA personal data in a portable and, if technically feasible, readily usable format.

Third, a Colorado resident may have the right to correct inaccuracies in their CPA personal data we hold.

Fourth, a Colorado resident may have the right to request we delete CPA personal data concerning them.

To exercise your rights, please fill in our online webform or email us at privacy@inbenta.com. If you email us, please put in the subject line of your email the right you are seeking to invoke: “Colorado Right to Access,” “Colorado Right to Correct,” or “Colorado Right to Delete.”

You may submit multiple requests at once through our webform or in an email. There is no cost for submitting your first request; if you submit multiple requests in a twelve-month period, we may charge you a fee for answering your request. We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if you are submitting the requesting on behalf of another, that you have the authority to do so. So we may need to ask you for more information, in light of the rights exercised, the type, sensitivity, value, or volume of personal data, the level of possible harm if we improperly grant the request, and the cost to us. If we cannot authenticate you or your authority, we will deny the request.

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your personal data) without undue delay and within 45 days after we receive your request. We may extend that deadline by 45 days, to 90 days in total, in some cases. If we extend the deadline, we will tell you that and why.

The Colorado Privacy Act includes exceptions for personal data regulated under other laws or maintained for certain reasons or in certain contexts. For example, the Colorado Privacy Act does not apply to publicly available information, including information that we reasonably believe Colorado residents have lawfully made available to the general public. As another example, we will not delete personal data when it is necessary to maintain that personal data to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not. You may appeal our decision by emailing us at privacy@inbenta.com with the subject line “Appeal of Request” and including our response to your request. We will also include this information in our response to your request. If you appeal our decision, we have 45 days to respond. We may also extend our deadline by 45 days, to 90 days in total, in some cases. If we extend the deadline, we will tell you that and why. If you have concerns about the results of your appeal, you may contact the Colorado attorney general.

In addition, when you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookie, Pixel, and Session Replay Policy section for targeted advertising, which we may disclose or make available to advertising and social media networks.

18. ADDITIONAL INFORMATION FOR VIRGINIA RESIDENTS

We may be subject to the Virginia Consumer Data Protection Act based on our interactions with Virginia residents and our use of their personal data. The Virginia Consumer Data Protection Act provides Virginia residents enhanced rights with respect to their personal data when acting in an individual or household context. This section explains what rights Virginia residents may have under the CDPA. Virginia residents may exercise those rights by emailing us at privacy@inbenta.com or filling in our online webform.

In this section, “CDPA personal data” refers to personal data that is linked or reasonably linkable to an identified or identifiable Virginia resident. CDPA personal data does not include de-identified or publicly available information, as defined in the Virginia Consumer Data Protection Act.

First, a Virginia resident may opt out of processing their CDPA personal data for purposes of targeted advertising, the sale of their CDPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Virginia resident. We do not sell CDPA personal data or process CDPA personal data for purposes of targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning Virginia residents.

Second, a Virginia resident has the right to confirm whether we are processing CDPA personal data concerning them and to access their CDPA personal data.

Third, a Virginia resident may also request to receive their CDPA personal data in a portable and, if technically feasible, readily usable format.

Fourth, a Virginia resident may have the right to correct inaccuracies in their CDPA personal data we hold.

Fifth, a Virginia resident may have the right to request we delete CDPA personal data concerning them.

To exercise your rights, please fill in our online webform or email us at privacy@inbenta.com. If you email us, please put in the subject line of your email the right you are seeking to invoke: “Virginia Right to Access,” “Virginia Right to Portability,” “Virginia Right to Correct,” or “Virginia Right to Delete.”

You may submit multiple requests at once in an email. There is no cost for submitting your first two requests; if you submit more than two requests in a twelve-month period, we may charge you a reasonable fee to cover the administrative costs of complying with your requests or decline to act on your requests. We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if we are unable to do so, we may request that you provide additional information reasonably necessary to authenticate you. If we cannot authenticate you or your authority, we will deny the request.

If you submit a request, we will tell you what the result is of your request (including, if you submit a Right to Access, your personal data) without undue delay and within 45 days after we receive your request. We may extend that deadline by 45 days, to 90 days in total, in some cases. If we extend the deadline, we will tell you that and why.

The Virginia Consumer Data Protection Act includes exceptions for personal data regulated under other laws or maintained for certain reasons or in certain contexts. For example, the Virginia Consumer Data Protection Act does not apply to publicly available information, including information that we reasonably believe Virginia residents have lawfully made available to the general public. As another example, we will not delete personal data when it is necessary to maintain that personal data to comply with a legal obligation.

If we don’t grant your request, we will tell you why we did not. You may appeal our decision by emailing us at privacy@inbenta.com with the subject line “Appeal of Request” and including our response to your request. We will also include this information in our response to your request. If you appeal our decision, we have 60 days to respond.

In addition, when you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookie, Pixel, and Session Replay Policy section for targeted advertising, which we may disclose or make available to advertising and social media networks.

19. 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.

20. CONTACT US

For more information or if you have questions or concerns about our privacy practices, please contact us by email at privacy@inbenta.com

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