Privacy Policy

Basic Privacy Policy

Last updated: January 23, 2020

This Privacy Policy describes how InterWorking Labs ("IWL," "we," "our" or "us") collects, uses, and shares information in connection with your use of our websites, services, products, tools, and applications (collectively, the "Services").

This Privacy Policy does not apply to information our customers may collect or process when using our Services.

If you are looking for California CCPA-specific information, check our CCPA Privacy Notice, which is incorporated by reference into this Privacy Policy.

We may collect and receive information about users of our Services ("users," "you," or "your") from various sources, including, but not limited to, contact forms; emails; social media interactions; telephone calls; letters; information you provide through your use of the Services; and from third-party websites, services, and partners.

We recommend that you read this Privacy Policy in full, including the Additional Disclosures referenced at the bottom of this document, to ensure you are fully informed. If you have any questions about this Privacy Policy or IWL's data collection, use, and disclosure practices, please contact us at info@iwl.com.

  • Information We Collect
    • Information You Provide The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you, explicitly or implicitly via the context, at the point we ask you to provide that information.
      • Communications If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.
    • Information We Collect When You Use Our Services
      • Cookies and Other Tracking Technologies As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
    • Information We Receive from Third Parties
      • Third-Party Partners We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.
  • How We Use Information We use the information we collect in various ways, including to:
    • Provide, operate, and maintain our Services
    • Provide support to you
    • Improve, personalize, and expand our Services
    • Understand and analyze how you use our Services
    • Develop new products, services, features, and functionality
    • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes
    • Process your transactions
    • Send you text messages and push notifications
    • Find and prevent fraud
    • For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency
  • How We Share Information We may share the information we collect in various ways, including the following:
    • Vendors and Service Providers We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our Services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
    • Aggregate Information Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can not reasonably be used to identify you.
    • Advertising We may work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Services, and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. To learn more about these programs, or opt-out of personalized ads, visit the Digital Advertising Alliance’s Self-Regulatory program for Online Behavioral Advertising at https://www.aboutads.info, or the Network Advertising Initiative at https://www.networkadvertising.org.
    • Third-Party Partners We may share information about users with third-party partners in order to receive additional publicly available information about you.
    • Analytics We use analytics providers such as, but not limited to, Google Analytics. Analytics may use cookies, browser fingerprinting, hidden images, or other mechanisms to collect information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/.
    • Business Transfers Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
    • As Required By Law and Similar Disclosures We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
    • With Your Consent We may share information with your consent.
  • Legal Basis for Processing Personal Information

    Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

    However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our products, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

    In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

    If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

  • Third-party Services

    You may access other third-party services through the Services, for example by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review their privacy policies.

  • Security

    IWL is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet cannot be guaranteed to be 100% secure.

  • Data Retention

    We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  • Your Data Protection Rights Under the General Data Protection Regulation (GDPR)

    If you are a resident of the EEA, you may have the following data protection rights:

    • If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing info@iwl.com.
    • In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. You can exercise these rights by emailing info@iwl.com.
    • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing info@iwl.com.
    • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

    We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

  • Your Choices

    You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

    Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Services may no longer work for you. You may continue to receive advertising material but it may not be tailored to your interests.

    Many browsers have an option to send a Do Not Track request. At the present time we do not honor that request. However, our analytics providers may.

  • Children's Privacy

    IWL does not knowingly collect information from children under the age of 13, and children under 13 are prohibited from using our Services. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at info@iwl.com.

  • Changes to this Privacy Policy

    This Privacy Policy may be modified from time to time, so please review it frequently.

  • International Data Transfers

    We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

  • Contact Us

    If you have any questions or concerns about this Privacy Policy, please feel free to email us at info@iwl.com.

    The data controller of your personal information is IWL.

  • Additional Disclosures

CCPA Privacy Notice

Last Updated: January 23, 2020

IWL is not subject to the California Consumer Privacy Act (CCPA).

IWL is, however, voluntarily conforming to the underlying principles of the CCPA in how we think about customer trust and data privacy.

We are providing this CCPA-specific privacy notice to supplement the information and disclosures already contained in our Privacy Policy. This notice applies to individuals residing in California from whom we collect Personal Information.

We do not sell your Personal Information, however we do use it.

The chart below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve months.

The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices may be found in our Privacy Policy.

Category Examples
Identifiers Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
Categories of Personal Information in Cal. Civ. Code 1798.80(e) Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of Protected Classifications under California or Federal Law Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Internet or Other Electronic Network Activity Information Browsing history, search history, and information regarding a consumer's interaction with an internet website, application or advertisement.
Geolocation Data Precise physical location.
Sensory Information Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information Job application or resume information, past and current job history, and job performance information.
Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
Inferences Drawn from Personal Information Consumer profiles reflecting a consumer's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Category We Collect We Disclose We Sell
Identifiers Yes Yes No
Categories of Personal Information in Cal. Civ. Code 1798.80(e) Yes Yes No
Characteristics of Protected Classifications under California or Federal Law No N/A N/A
Commercial Information Yes Yes No
Biometric Information No No N/A
Internet or Other Electronic Network Activity Information Yes Yes No
Geolocation Data No N/A N/A
Sensory Information No N/A N/A
Professional or employment-related information Yes Yes No
Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) No N/A N/A
Inferences Drawn from Personal Information Yes Yes No

Use of Personal Information

The CCPA defines various business and commercial purposes for collecting, using, and disclosing Personal Information. While we collect, use, and disclose Personal Information pursuant to our Privacy Policy as a whole, we here further clarify that this includes Personal Information in accordance with the specific CCPA business and commercial purposes below:

  1. Auditing related to a current interaction with you and concurrent transactions, including, but not limited to auditing compliance with this specification and other standards.

  2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  3. Debugging to identify and repair errors that impair existing intended functionality.

  4. Short-term, transient use.

  5. Contracting with service providers to perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  6. Undertaking internal research for technological development and demonstration.

  7. Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

  8. Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

  9. For other purposes for which we provide specific notice at the time the information is collected.

Collection and Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we may have collected Personal Information from general sources including you, your use of our services, your devices, our affiliates, our vendors, and our service providers. More specific information about Personal Information we collect is laid out in this notice and in our Privacy Policy, which we update from time to time.

As also explained in our Privacy Policy, we share your Personal Information with the following categories of CCPA third parties:

  1. Affiliates.

  2. Vendors and service providers, including for data analytics and marketing and advertising our products and services to you.

  3. Third parties integrated into our services.

  4. Third parties as required by law and similar disclosures.

  5. Third parties in connection with a merger, sale, or asset transfer.

  6. Other third parties for whom we have obtained your permission to disclose your Personal Information.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected or disclosed by us; (2) purposes for which categories of Personal Information are collected by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Limitation of Dissemination We neither rent, sell, nor share your Personal Information with nonaffiliated companies for their direct marketing purposes, unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, you may send a request to us at info@iwl.com.

Contact Information

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights, please email us at info@iwl.com or write to us at:

IWL
PO Box 66190
Scotts Valley, CA  95067
ATTN: Legal