INXPO, Inc. (either “INXPO,” “we,” or “us”) provides online marketing, corporate communications, sales enablement, video, and training platforms. INXPO collects, uses, discloses, transfers, and otherwise processes data, including any information that may be used, either alone or in combination with other information, to personally identify a natural person (“Personal Data”), in several ways, as described herein. INXPO is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”), together with our Terms of Use and any other document referred to therein, describes how INXPO treats personal data when you, the user, access the INXPO platform, mobile application or website located at https://www.inxpo.com (the “Website”), or if you otherwise communicate with us, for example by requesting information related to our services.
If you choose not to provide any requested Personal Data, you may be unable to access certain areas of the Website, register to use or purchase our products or services, or receive communications from us regarding our products or services or the Website.
Our Site may contain links to third-party websites and services that are not owned or controlled by INXPO. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk. This Policy only applies to Personal Data collected by INXPO, and does not apply to any Personal Data collected by any third party. We encourage you to familiarize yourself with privacy policies applicable to any websites and services operated by third parties as we are not responsible for the privacy practices of any third parties. Type of Information INXPO Collects.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY ALL OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT ACCESS OR USE THE WEBSITE.
We may receive and/or collect information, including Personal Data, in the following ways:
1. Personal Data in Connection with User Account Registration and User Account-Related Activities - Certain areas and features of the Website, such as registration of a user account or profile for purposes of participation in a virtual event hosted by us, entering protected web pages, or opting to receive further information about INXPO products or services may require you to provide INXPO with certain Personal Data such as your name, email address, address, company name, job title, phone number, and other business or contact information. No transaction payment data is collected or stored by INXPO. The foregoing types of Personal Data may also be collected by the company sponsoring a virtual event hosted by us (a “Sponsor”) that you register for or participate in. INXPO is not responsible for Sponsor’s privacy practices involving your Personal Data. We encourage you to review the Sponsor’s privacy policy in advance of registering for or participating in a virtual event.
2. Your Activities On and Use of the Website - INXPO may automatically collect information about your activities on and/or usage of the Website. Activity information we automatically collect may include which web pages you visited, the Uniform Resource Locator (“URL”) identifying the website you came from or visit after you leave the Website, the average time you spent on the Website, information, including Personal Data, you’ve previously shared with INXPO, your domain, your computer’s Internet Protocol(“IP”) address, etc. (defined below). In addition, if you are logged into a password protected area, we may associate that information with your account. To accomplish this we may use the following:
a. Web Beacons - Web Beacons are strings of code placed on a webpage in conjunction with Cookies (defined below). Web Beacons are able to track the number of users that visit a website and, in conjunction with cookies, identify the IP address and personalize the website experience. Web Beacons may also be used to collect anonymous and/or aggregate, unidentifiable information such as how many users attended a virtual event.
b. IP Address - The IP address is the numerical label associated with the location of your computing device.
c. Cookies - In some cases, INXPO may use HTTP cookies (web cookies, Internet cookies, browser cookies), Flash Cookies (cookies that are not related to a specific browser, further described below), clear GIFs (a.k.a. web beacons), and log file information (a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software) to: (a) store information so that you will not have to reenter it during your visit or the next time you visit the event; (b) provide customer, personalized content and information; or (c) monitor aggregate metrics such as total number of visitors, pages, viewed, and similar information. A cookie is a small amount of data, which often includes a unique identifier that is placed on your computer or on your mobile phone/tablet (collectively referred to herein as a “device”) browser from a website’s computer and is stored on your device’s hard drive. There are two different types of cookies: session cookies and persistent cookies. Session cookies are held temporarily and disappear when you close your browser. Persistent cookies may be used by your browser on subsequent visits. Cookies are widely used to provide certain features of website, to make websites perform more efficiently, and to provide information to the owners of the website. Each INXPO event and/or webcast can send its own cookie to your browser if your browser’s preferences allow it. For events and webcasts, cookies record information about your online preferences and allow us to present content to your interests. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued or not to receive cookies at any time. If you do not opt in to receiving cookies and/or set your device to not receive cookies, certain personalized features cannot be provided to you, and accordingly you may not be able to take full advantage of the Website’s features.
d. Third-Party Cookies - You may be presented with cookies from third-party websites and providers that are not related to INXPO. For example, when you view a webpage with content embedded from a third-party provider, you may be presented with cookies from such provider. INXPO does not control the dissemination of these third-party cookies. In general, you should check the third-party websites for more information regarding that third-party’s data practices and policies. In addition, INXPO provides an optional single sign-on using social networks including, but not limited to, Facebook, Twitter, LinkedIn, Google and Microsoft LiveId. If you are logging into an INXPO event using a social network credential, the applicable third party, and not INXPO, will set cookies. INXPO does not control or have any access to the cookie information these social networks may set.
e. Local Shared Objects (Flash Cookies) - INXPO uses the Adobe Flash Player to deliver certain video content services. To improve the user experience, Local Shared Objects (otherwise known as Flash Cookies or LSOs) are used to provide features such as auto-resume and for saving your preferences. Flash Cookies are stored on a user’s device much the same as cookies are, however it is not possible to manage them at browser level in the same way. To disable or delete flash cookies, see http://www.adobe.com/products/flashplayer/security. Please be aware that removal or restricting the use of cookies may affect the features available to you for applications from the Website, within INXPO events, or for our products or services.
f. Local Storage - . INXPO uses browser local storage on personal computers and mobile devices to deliver its services.
3. Content - Any Personal Data or content that you voluntarily upload or otherwise disclose while on the Website (such as, through use of an INXPO blog), including but not limited to information disclosed on discussion boards, in messages and chat areas, within a profile page, or images or any other content you provide (“Content”), becomes publicly available and can be collected and used by others. In addition, if you are given the ability to log into your account with any social networking website, or post Content on such site, other third-party website, or through the Website, such Content may be made available to other parties and associated with your Personal Data. Personal Data uploaded in association with any INXPO event or webcast is only used for and shared with the particular customer of INXPO for that event. Data that is in an aggregate, de-identified form that is no longer considered Personal Data and does not allow the identification of individual users may be used by INXPO for purposes of research and analysis.
1. Operation, Maintenance and Flagging - If you submit Personal Data through the Website, INXPO may use it to operate, maintain, and provide you with the general and personalized features and functionality of the Website, provide you with the INXPO products and services you request or order, complete transactions, or communicate with you. We may also use such Personal Data to process any flagging activity or correspondence you send to us.
2. Messaging - Your user account registration information may be displayed in password protected areas to other users. If you choose to receive email from INXPO, we may use clear GIFs (a.k.a. web beacons) in HTML-based emails sent to you to track which emails are opened by recipients.
3. No Commercial Marketing - INXPO will not use your email address or other Personal Data to send commercial or marketing messages for our benefit without your consent, except as part of a specific program or feature or other business relationship for which you opt in. We will not share your Personal Data with third-party marketers.
4. Non-Marketing or Administrative Uses - INXPO may use your email address without your consent for non-marketing or administrative purposes, such as notifying you for customer service reasons.
5. Quality & Features - INXPO may use Personal Data and certain non-personally identifiable information in furtherance of its legitimate interest to improve the quality and design of the Website and to create new features, promotions, functionality, and services by storing, tracking, analyzing, and processing user preferences and trends, as well as user activity and communications, to improve or personalize your experience, to improve or manage the Website or products and services, to provide features available on the Website, to operate and improve our products and services, for market research, to analyze the Website, and to ensure the technical functionality and security of the Website.
6. URLs & IP Address - When you visit the Website through a referral, INXPO automatically receives the URL of the site from which you came. We also receive the Internet protocol (IP) address of your computer, your computer operating system and type of web browser you are using, as well as the name of your Internet service provider (“ISP”). This information may be used by INXPO in furtherance of its legitimate interests to analyze overall trends, determine the domain from which you came, who visits the Website, to understand the needs of Website visitors, or to help us improve the INXPO service.
You have the following rights with respect to the Personal Data we hold about you:
(1) The right to know what Personal Data we hold about you. If you would like to know what personal data we hold about you, please contact us at privacy@inxpo.com;
(2) The right to correct, amend, change and delete Personal Data about you. If you have questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at privacy@inxpo.com;
(3) The right to opt out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at privacy@inxpo.com; and
(4) If you are a resident of the European Union (the :EU”), you may have the right to lodge a complaint relating to our processing of personal data about with a data protection authority (“DPA”) of the EU Member State in which you reside.
We share Personal Data about you with third parties for the purposes detailed below. Please note that this Policy does not apply to third parties, INXPO is not responsible for the privacy practices of third parties, and that you should consult the respective privacy policies of third parties for more information on their practices.
1. To Conduct Our Business - INXPO shares Personal Data with your consent or as necessary with third-party service providers to complete any transaction or provide any product or service requested or authorized. INXPO also shares Personal Data with third-party service providers, suppliers, or agents working with INXPO or on INXPO’s behalf, such as data storage service providers, human resources service providers, marketing automation services, and data analysis companies, including Google.
2. Law Enforcement - INXPO may disclose Personal Data about you to public authorities, such as law enforcement, if we believe in good faith that we are required to do so in order to comply with laws or regulations, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose Personal Data in special circumstances when we have reason to believe that disclosing Personal Data is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use or other user agreement, or to protect the safety or security of our users, the Website or the general public.
3. Sale of Business - We reserve the right to transfer Personal Data to a third-party such as a subsidiary, parent company, co-owner or cooperator of the Website and/or INXPO, or a successor entity in the event of a sale, merger or other transfer of all or substantially all of our assets, provided that the third-party agrees to adhere to the terms of this Privacy Policy and INXPO provides you with notice of the same.
INXPO may share your information with OTC Markets Group Inc. (“OTC Markets Group”) for the purpose of providing INXPO products or services and in accordance with this Privacy Policy. The use of your information by OTC Markets Group is subject to the OTC Markets Group Privacy Policy, which can be found at http://www.otcmarkets.com/privacy-statement. Additionally, OTC Markets Group and/or INXPO may share your information with BetterInvesting and BetterInvesting may use your information in accordance with the terms of this Privacy Policy and the OTC Markets Group Privacy Policy, as applicable. For the avoidance of doubt, OTC Markets Group may share your information with presenters of the event that you attended and the associated presenting companies.
INXPO takes reasonable steps to prevent the loss, misuse and unauthorized access, disclosure, alteration and destruction of Personal Data about you. In addition, INXPO takes appropriate security measures to safeguard Personal Data about you once we have received it. Despite these efforts to store Personal Data collected on and through the Website and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. We do not warrant or represent that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.
INXPO will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected. INXPO will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. INXPO retains most Personal Data for up to five (5) years from the date it is no longer used and may retain some personal data for a longer period, to comply with our legal obligations, in relation to that Personal Data.
California Civil Code Section 1798.83 permits users that are residents of California to request certain information regarding INXPO’s disclosures of Personal Data to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email INXPO at privacy@inxpo.com.
The California Online Privacy Protection Act (“CalOPPA”) requires INXPO to disclose how it responds to Do Not Track Signals in your web browser. INXPO does not interpret or respond to Do Not Track Signals. You may set your web browser to not accept new cookies or web beacons or disable cookies altogether. Please note that doing so may hinder your experience on the Website. Please see the Help section of your browser for instructions on managing security preferences.
The Website is not directed to children younger than thirteen (13) years of age. We do not intend to collect Personal Data from children under 13. If you are under 13, please do not use the Website and do not send any information about yourself to us.
Some elements of the Website and/or our products and services may be hosted on servers located in countries outside the United States. The laws applicable to the protection of Personal Data in such countries may be different from those applicable in your home country. In particular, if you are located within the European Union (the “EU”)/European Economic Area (the “EEA”) or Switzerland, please note that Personal Data collected by us may be transferred outside those countries. By using the Website or our products or services, you consent to Personal Data about you being transferred outside your own country and, where applicable, outside the EU, EEA or Switzerland.
INXPO complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from the EU and/or Switzerland. INXPO has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, including the Supplemental Principles (collectively, the “Principles”). A violation of our commitment to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. INXPO confirms that it will process data from Switzerland in the same fashion as it processes data from the European Union. Therefore, INXPO has included Switzerland in the subsequent text of this privacy policy. If there is any conflict between the policies in this Policy and the Principles, the Principles shall govern. To learn more about the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield programs, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.
This Privacy Shield Policy supplements, but does not replace, all other policies, practices, and procedures at INXPO, including any confidentiality agreements, privacy notices, or other agreements, as well as applicable laws. INXPO affirms that while it understands that certification to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield is voluntary, effective compliance is compulsory. The Principles apply to INXPO immediately upon certification.
INXPO remains responsible and liable under the Principles if third-party agents that it engages to process Personal Data on its behalf do so in a manner inconsistent with the Principles, unless INXPO proves that it is not responsible for the event giving rise to the damage.
In compliance with the Principles, INXPO commits to resolve complaints about your privacy and our collection or use of Personal Data about you within 45 days. Persons from the EU and Switzerland who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@inxpo.com.
If an issue cannot be resolved by INXPO’s internal dispute resolution mechanism, INXPO has chosen JAMS, an alternative dispute resolution provider, to be its independent recourse mechanism for the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. INXPO agrees to be bound by any decision of JAMS. Individuals may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield to address complaints. More information about JAMS is available at http://www.jamsadr.com. In the event that INXPO or JAMS determines that INXPO did not comply with this Policy, INXPO will take appropriate steps to address any adverse effects and to promote future compliance. Under certain circumstances, individuals may invoke binding arbitration before the Privacy Shield Panel for residual claims not otherwise resolved. In the event INXPO becomes subject to an order for non-compliance with the Principles, INXPO shall make public any relevant sanctions or other findings.
Any human resources data complaints can be addressed to the relevant EU data protection authorities (“DPAs”) directly. INXPO will cooperate and comply with any decision of a DPA.
Please contact INXPO (see contact information below) to be directed to the relevant DPA. Additionally, with respect to complaints concerning human resources data that is transferred from the EU to the United States, we have agreed to participate in the dispute resolution procedures of the DPAs. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. INXPO will cooperate with the appropriate DPAs during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States under the Privacy Shield.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanisms, you may be able to invoke binding arbitration.
In cases of onward transfer to third parties of data of EU, EEA, or Swiss individuals received pursuant to the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield, INXPO is potentially liable.
From time to time we may change this Policy with or without prior notice to you. You can tell when changes have been made to the Policy by referring to the “Last Updated” legend on top of this page. Please review this Policy regularly to ensure that you are aware of any changes. If we materially change the ways in which we use and disclose Personal Data, we will post a notice on the Website and send an e-mail to our registered users. Your continued use of the Website and/or our products and services following any changes to this Policy constitutes your acceptance of any such changes made.
Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to the INXPO Privacy Officer (“Privacy Officer”) at:
INXPO, Inc.
770 N. Halsted Street
Suite 6S
Chicago, IL 60642
Phone: (312) 962-3708
Email: privacy@inxpo.com
International
Steven Taylor, DPO & Regional Privacy Counsel
Legal Department
60 Fenchurch Street
London EC3M 4BA
United Kingdom
We seek to promptly respond to and resolve any questions or concerns you may have.