Privacy Policy

inSeption Group, LLC (hereinafter referred to as “inSeption”, “us,” “we,” “our,” or “Organization”) have created this Privacy Policy and Cookie Notice to apply to all users of this website (the “Website”), mobile applications, and all digital assets contained or offered therein (collectively, our “Services”). The Privacy Policy describes, among other things, the types of information we collect from you when you use our Services, how we use it, and how you can access your information. The Organization will at times collect, maintain, use, and share your information as is necessary to provide services to you, meet certain business needs and functions, and comply with laws and regulations.

The Cookie Notice in Section II below explains how we use cookies and similar tracking technologies. Visitors to the Website are given an initial opportunity to opt in (i.e., consent to) the collection and use of cookies and similar tracking technologies. If you no longer agree to the use of cookies and similar tracking technologies, you may opt-out (i.e., disable the use) of cookies by changing or withdrawing your cookie consent, or by not using or terminating your continued use of our Services. Please note that if you choose to disable cookies and similar tracking technologies that we use, your user experience on the Services may be impacted.

This Privacy Policy and Cookie Notice is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

If you are coming to our Services from the [European Union (EU), European Economic Area (EEA), or United Kingdom (UK)], or certain U.S. States, you may be entitled to certain individual rights under applicable Data Protection Laws. Please see the Notice to Certain Residents of Data Subject Rights for more information.

By using the Services and providing us with your Information (defined below), you agree to the practices described in this Privacy Policy and Terms & Conditions referenced below and to the updates to these policies posted here from time to time.  By using our Services, you consent to these policies.  If you have any privacy or data use concerns, please contact us as set out below under the heading Contact Us.

To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Effective Date” date shown below.

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information, which are described in more detail below: (A) information you provide to us, (B) information we automatically collect, and (C) information we receive from third parties. All of the information listed in (A)–(C) above, is detailed below, and hereinafter referred to as “Information.” The information covered herein is referred to collectively as “Information,” and may include “Personal Information” or “Personal Data” as those terms are defined under applicable law. Specifically, Information includes any information relating to an identified or identifiable natural person, who could be identified either directly or indirectly by reference to an identifier such as name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

A. Information You Provide to Us:

In using our Services, you may provide us with Information, including, without limitation:

1. Your contact information including name, position title, company name, email address, and telephone number(s) and
2. Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Sensitive Information. We may need to collect or process Information that is deemed “sensitive information” or “sensitive data” under certain laws. We may process the following categories of sensitive information when you use our Services:

• Geolocation information, such as your physical location if you have enabled location services on your device;
• Authentication data such as account personal information and log in credentials, including unique identifiers, such as username, account number, and password;
• Payment and transaction information including credit or bank card information in combination with any required security or access code collected for purpose of processing payment for our products or Services;
• Racial or ethnic origin information;
• Sexual orientation information;
• Biometric information;
• Social security number;
• Driver’s license number;
• State identification card number;
• Passport number;
• Citizenship and immigration status.

When required by applicable law, we will collect consent prior to processing certain categories of sensitive Information.

B. Information We May Automatically Collect:

We may also collect information about you from your visit to our Website including:

1. IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider), your company, or your institution;
2. Date and time of your visit or use of our Website;
3. Type of computer, web browsers, search engine used, operating system, or platform you use;
4. Data identifying the web pages you visited prior to and after visiting our Website or use of our Services;
5. Your movement and activity within the Website, which is aggregated with other information; and
6. Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).

C. Cookies and Other Tracking Technologies

We collect this Information directly and through the use of third parties by using certain technologies such as cookies, web beacons, and other technologies, as further described in our Cookie Notice, below. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons to collect similar or identical information. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.

D. Information We May Receive from Third Parties

We may collect additional Information about you from others such as credit bureaus, affiliates, other companies, third-party websites, and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you.

Please keep in mind that when you provide Information to us on a third-party website or platform (for example, via our applications), the Information you provide may be separately collected by the third-party website or the Social Media Platform.

The Information we collect is covered by this Privacy Policy, and the Information the third-party website or Social Media Platform collects is subject to the third-party website or platform’s privacy practices. We encourage you to be aware when you leave our Services and to read the privacy policies of other sites that may collect your Information. You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. COOKIE NOTICE

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

A. What is a cookie?

Cookies are small text files that are placed on the hard drive of your computer by websites that you visit. Cookies are widely used and have many purposes, including for marketing, profiling, and analysis. Cookies are used to make websites work more efficiently as well to provide information to the owners of the websites about user browsing behavior.

Through our use of cookies and similar tracking technologies, we can tailor our Services to your personal needs and improve user-friendliness.

You can opt-out of each cookie category (except strictly necessary cookies) by changing your cookie consent settings.

B. How do we use cookies?

The Services use cookies. We use cookies to improve your site experience, to assess content usage, to distinguish you from other users of our Services and to support the marketing of our services and products. These cookies may store information about you and your use of our Services. By continuing to use our Services, you agree to the storing of cookies on your device, or you can opt-out from non-required cookies. You can change your preferences below.

C. Cookies and Technologies Used on the Services

Browser Cookies.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Services.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies.  We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit.  Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information.  Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.  Cookie management tools provided by your browser will not remove Flash cookies.

Web Beacons.  Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).  We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services.  These technical methods may involve the transmission of information either directly to us or to a third party authorized by us to collect information on our behalf.  Our Services use retargeting pixels from Google, Facebook, and other ad networks.  We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

Analytics.  Analytics are tools we use, such as Google Analytics and HubSpot Analytics to help provide us with information about traffic to our Website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.  Learn more about Google’s Privacy Policy here: https://policies.google.com/privacy?hl=en-US. You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

Mobile Application Technologies.  If you access our Website and Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location. You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

Opting Out of Direct Marketing. We, or third-party service providers with whom we collaborate or contract with to perform services on our behalf, may deploy cookies and may use your Information to text, email, or contact or share with you information that we believe may be useful to you, such as information about products or services provided by or through us through permissible targeted advertisements or related to our Website. You affirmatively consent to receive these communications. To help exercise choices regarding the marketing information you receive, you may also review the following links:

• You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

• You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

• You can opt-out of having your activity on our Website made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

D. Managing Cookie Preferences

Your consent applies to the following domain: http://www.inseptiongroup.com. Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that disclosing information to these online tracking technologies is deemed to be a “sale” or “sharing” under certain laws, you can opt out of these online tracking technologies by submitting a request via email at privacy@inseptiongroup.com or by broadcasting an opt-out preference signal, such as the Global Privacy Controls (GPC). Please note that some features of our website may not be available to you as a result of these choices.

III. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information above for things that may include, but are not limited to, the following:

1. To respond to your inquiries and provide you with requested information such as our newsletters;
2. To process your request for services;
3. For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
4. To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;
5. Maintain, improve, customize, or administer our Services, perform business analyses, or other internal purposes to improve the quality of our business, resolve technical problems, or improve security or develop other products and services;
6. To comply with our Terms & Conditions;
7. To comply with any applicable laws and regulations and respond to lawful requests; and/or
8. For any other purposes disclosed to you at the time we collect your Information.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing Your Information

We may share your Information as disclosed at the time you provide your Information, as set forth in the Privacy Policy and in the following circumstances:

• Third-Party Service Providers.  We may share your information with third-party service providers that perform certain business functions or services on our behalf (such as process your transactions, manage our databases, maintain your account, perform analyses, provide customer service, or send communications for us). These companies are authorized to use your personal Information only as necessary to provide these services to us.

• Disclosure of Customer Information for Legal and Administrative Reasons.  We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate with or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates, and any of our or their officers, directors, employees, attorneys, agents, contractors and partners, and the Services users; (v) to enforce or apply our Terms of Service; and (vi) to verify the identity of the user of our Services.

• Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates. “Affiliates” means any entity controlled by, controlling, or under common control with us. Our affiliates will use and distribute your information in accordance with the terms of this Privacy Policy. If you do not want us to share your Information with our subsidiaries and affiliates, please contact us via the Contact Us section below.

• Business Transfers. Your Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You consent to any and all such Conveyances of your Information.

• Online Communications. If you chose to share with us comments, post a review, participate in a survey, provide a testimonial, or other Information you consent and agree that we may make it available generally to the public and it will not be returned to you unless we receive such a request in writing from you and determine, in our sole discretion, to honor such request.

• De-Identified or Aggregated Data. We may aggregate, anonymize, and/or de-identify any Information collected from you so that such Information can no longer be linked to you or your device. We may use aggregated, de-identified or anonymized Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

• With Your Consent. Except as provided in this Privacy Policy, we will not sell, rent, or license your Information we have collected to any third party without your consent and shall share your Information consistent with this Privacy Policy with your consent.

C. Sale or Sharing of Your Information

For purposes of this Privacy Policy, “sell,” “sold,” or “sale” means the disclosure of Information for monetary or other valuable consideration but does not include, for example, the transfer of Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. “Sharing” means disclosing or making available Information to a third-party for purposes of cross-contextual behavioral or targeted advertising. While we do not disclose information to third parties in exchange for monetary compensation, we disclose identifiers and Internet and network activity information to third-party advertising networks and analytics providers for purposes of marketing and advertising, and to improve and measure our ad campaigns. Such disclosures may be considered “sales” or “sharing” of Information under applicable laws. We do not sell or share your Information.

D. Use and Disclosure of Sensitive Information

We do not collect, use, or disclose sensitive Information beyond the purposes authorized by applicable law. Accordingly, we only use and disclose sensitive Information as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) with our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

IV. LINKS TO OTHER WEBSITES

Our Website may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as LinkedIn (“Social Media Platforms”) or may redirect you off our Website to other websites for information, other services, or to receive special offers or for transactions or purchases. We are not responsible for the privacy and security practices of those websites or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other party’s website or content do not constitute or imply an endorsement or recommendation by us of the linked website and/or content. We also have no control over websites that link to our Website.

V. INFORMATION SECURITY AND DATA RETENTION

We use commercially reasonable safeguards to provide our Services. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties.  We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us at our contact information below so that necessary measures can quickly be taken.

VI. CONSENT

By submitting your Information to us, you agree that we may collect, use, and disclose such Information as set forth in this Privacy Policy and as permitted or required by law. If you wish to withdraw consent, please see the Contact Us section below.

VII. YOUR CHOICES

A. Marketing Communications.

If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see How to Contact Us below for more information.

B. Text Messages.

You may sign up to receive text messages from us or a third party service provider on behalf of us (e.g., text marketing). By signing up for text messaging services or otherwise opting in to receive text messages (opting in via short code or entering your phone number into an on-site collection widget), you agree that you have provided inSeption or its third party service providers with prior express written consent to be contacted by text message, including recurring automated promotional and personalized marketing text messages.

By providing prior express and/or prior express written consent, you agree to receive text messages under the Telephone Consumer Protection Act and related state laws, including by the use of an automatic telephone dialing system (“ATDS”) to deliver text messages to the mobile phone number which you provided to inSeption. While you consent to receive messages sent using an ATDS (or “autodialer”), the foregoing shall not be interpreted to suggest or imply that any or all of [CLIENT_SHORT] mobile messages are sent using an autodialer. We will use the Information provided by you in connection with the text messaging services in accordance with this Privacy Policy. Your consent is not a condition of any purchase or use of our Services and your consent to be contacted as described is voluntary. The number of text messages you receive may vary based upon the text messaging services(s) you sign up for. Message and data rates may apply.

You may revoke your consent and opt out to discontinue text messages at any time. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed).

C. Opting Out of Direct Marketing by Third Parties.

To exercise choices regarding the marketing information you receive, you may also review the following links:

1. You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at aboutads.info/appchoices.
2. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
3. You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

D. Location Choices

You may be able to change the privacy settings of your mobile device at any time to turn off the sharing of this location information with our Website. If you choose to turn off location services, this could affect certain features or services of our Website. If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

VIII. NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS

A. Notice of Privacy Rights for Residents of Certain U.S. States

Residents of certain U.S. states may have rights and choices regarding their personal information. To the extent any data protection law applies to our collection of your personal information, this supplemental section of our Privacy Policy outlines the individual rights you may be entitled to and how to exercise those rights.
Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.

• Right to Know and Access. You may have the right to request that we confirm whether we process your personal information, and to request information about our collection and use of your personal information, including whether we sell or share your personal information. You also have the right to request access to personal information we may process about you.

• Right to Data Portability. Where the processing is carried out by automated means, and subject to certain exceptions, you may have the right to request and obtain a copy of your personal information that you previously provided to us in a portable format. In addition, to the extent technically feasible, you may have the right to obtain your personal information in a readily usable format that allows you to transmit the personal information to another data controller without hindrance.

• Right to Request Correction of Inaccurate Personal Information. To the extent that we may maintain inaccurate personal information, you may have the right to request that we correct such inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

• Right to Request Deletion. You may have the right to request that we delete certain personal information or records provided by or obtained about you, with certain exceptions and limitations as allowed under law.

• Right to Opt Out of the Sale and Sharing of Personal Information. You may have the right to opt out of the processing of your personal information for the purpose of selling or sharing your personal information for cross-context behavioral advertising. We do not sell or share your personal information.

• Right to Opt-Out of the Use of Personal Information for Targeted Advertising and Profiling. You may have the right to opt out of the processing of your personal information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not use your Information for targeted advertising or profiling purposes.

• Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to request that we limit the ways we use and disclose your sensitive personal information to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or as authorized by law.

• Right to Non-Discrimination. You may have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or Services for no fee, if you have exercised your right to opt-out.

• Right to Disclosure of Direct Marketers. You may have a right to know the categories and names/addresses of third parties that have received personal information for their direct marketing purposes upon simple request, and free of charge.

• Right to Appeal. You may have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeal request via the information in the How to Contact Us section below or using the Your Privacy Choices form. Within the certain timeframe of receipt of your appeal, as proscribed by the applicable law we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Attorney General or another authority which we will help you identify.

To learn more about whether you are guaranteed certain rights, or to submit a request to exercise your rights, please contact us using any of the methods in the How to Contact Us section or using the Your Privacy Choices form.

B. Notice to Individuals in the European Economic Area and the UK

This section applies only to individuals coming to our Services from within the European Union (EU), the European Economic Area (EEA), and the United Kingdom (UK), and only if we collect through the Services any Information from  you that is considered “Personal Data,” as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
Unless otherwise stated, we are the Data Controller for the Information we process.

1. Your Data Protection Rights

To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:

• Restrict the way we process and share your Information;
• Transfer your Information to a third party;
• Provide you with access to your Information;
• Remove your Information if no longer necessary for the purposes collected;
• Update your Information so it is correct and not out of date; and/or
• Object to our processing of your Information.

You may also revoke your consent for processing of your Information. If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us using the information in the Contact Us section.

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we are happy to try and resolve it directly. Please contact us using the information in the Contact Us section.

2. Lawful Basis for Processing Your Information

The lawful basis for our processing of your Personal Data will depend on the purposes of the processing. For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract or a potential contract with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:

• Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting our Services; (ii) communicating with current and potential customers, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the Company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, Services, and employees, including fraud protection.

• Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e- commerce transactions in which you purchase a service from us.

• Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on Company Services through cookies and similar technologies when consent is required by applicable law.

• Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.

If the processing of your Information is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the How to Contact Us section, below, to review or modify your consents.

3. Consent to Transfer

We are operated in the United States, and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party providers in accordance with applicable data protection laws and regulations.

4. Retention

We will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:

• Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction Information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).

• Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.

• Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your information, we delete all Information in accordance with our routine record keeping policies.

IX. CHILDREN’S INFORMATION

We do not target our Services to minors, who are under thirteen (13) (or a higher age threshold where applicable). By continuing to use our Services, you certify that you are not under thirteen (13) years of age. We do not intend to collect or process any Information from anyone under the age of thirteen (13). If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

X. Exercising Your Data Subject Rights

To exercise any of the rights described above, please submit a verifiable consumer request to us via the methods described below. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request.

If permitted by the applicable data protection law, you may use an authorized agent to submit requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant under applicable law. Only you or your authorized agent may make a verifiable consumer request related to your Information. We may deny a request from an authorized agent that does not submit proper verification proof. You may also make a verifiable consumer request on behalf of your minor child.

XI. DIFFICULTY ACCESSING OUR PRIVACY POLICY

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

XII. “DO NOT TRACK” SIGNALS

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

XIII. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. If you provide us an email address, we will provide any updated Privacy Policy to you. In that email, we will provide the option to opt-out of receiving further emails. It is your obligation to check our current Privacy Policy for any changes.

XIV. CONTACT US

If you have any questions about this Privacy Policy, Cookie Notice, or the Information we have collected about you, please contact us at the following:

Email: privacy@inseptiongroup.com

Call us: (267) 498-5090

Write us:

inSeption Group

870 W Main Street
Lansdale, PA 19446

Effective Date – August __, 2024