Our Privacy Policy governs the manner in which Innovorg Inc. (“we”/”us”/”Innovorg”) collects, uses, maintains and discloses Information collected from users (each, a “User”) of the www.innovorg.com website (“Site”) and Innovorg’s skill building and talent analytics solution (the “Platform”). This Privacy Policy applies to the Site and Platform and all products and services offered by Innovorg (collectively, the “Products”).

Personal Information

We may collect personal information from Users of the Website or Platform in a variety of ways, including, but not limited to, when Users use our Site, submit a contact form, and in connection with other activities, services, features or resources we make available in our Products. Users may be asked to provide personal information, as appropriate, including name and email address. Users may, however, use our Products without providing their personal information. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Products. Non-personal identification information may include the browser name, type of mobile device, language preference, the type of computer and technical information about Users means of connection to our Products, such as the operating system and the Internet service providers utilized and other similar information.

Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information:

Innovorg collects and uses Users personal information for the following purposes:

To personalize user experience: We may use information in the aggregate to understand how our users as a group use the services and resources provided in our Products.

To improve our Products: We continually strive to improve our product offerings based on the information and feedback we receive from you.

To improve customer service: Your information helps us to more effectively respond to your customer service requests and support needs.

To process transactions: We may use the information users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Products.

Sharing your Personal Information

We do not sell, trade, or rent users Personal Information to others. We may share generic aggregated demographic information not linked to any personal information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as human resource services. We may share your information with these third parties for those limited purposes to provide you with the Products.

Third party websites

Users may find advertising or other content on our Products that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Products. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Residents of the European Economic Community (“EEC) and the UK

If you are a resident of the EEC or the UK, you have certain data protection rights. Innovorg takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out below. Note that where we act as a data processor on behalf of our customers, you will be required to contact the data controller directly to exercise your rights.
In certain circumstances, where we act as data controller, you have the following data protection rights:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests. You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

Access, Correction and Accuracy

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.

California Privacy Rights

This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act (the “CPRA”, collectively with the CCPA the “California Privacy Legislation”).

For more details about the Personal Information Innovorg has collected over the last 12 months, please see the section “Information you provide us” above. We collect this Personal Information for commercial purposes described above. Innovorg does not sell (as that term is defined in the California Privacy Legislation) the Personal Information we collect.

Subject to certain limitations, the California Privacy Legislation provides California consumers the right to request to know more details about the categories or specific pieces of Personal Innovorg – Privacy Policy – May 31, 2023 5 Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the California Privacy Legislation by contacting us at the contact information below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Changes to this Privacy Policy

Innovorg has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using these Products, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Products. Your continued use of the Products following the posting of changes to this policy will be deemed your acceptance of those changes.

Your Privacy Rights

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Contacting Us

If you have any questions about this Privacy Policy, privacy practices related to our Products, or your dealings with our Products, please contact Privacy Officer at privacy@innovorg.com