The InnoFaith Products and Services can either be branded under the brand names InnoFaith or Sylton.
What kinds of information do we collect?
We collect and use the following information to provide, improve, protect, and promote our Products and Services. We will only process this information if there is a lawful purpose for it as described in article 6, sub 1 of the GDPR.
- Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for an account and one of our free or paid Services or purchase one of our Products (such as your name, email address, phone number, payment info, and physical address). We will use this information only where there is a contractual necessity to do so (GDPR article 6, sub 1b), including billing, payment processing, account management, and administrative purposes. We also process such information where we are required to retain it by law (GDPR article 6, sub1c).
- We keep records of the communications between you and InnoFaith (e.g., we may send you Service-related emails). We may decide to retain communications throughout our relation to ensure that we can provide the service that you need and expect based on our legitimate interest (GDPR article 6, sub 1f).
- Your Data. The InnoFaith cloud services are designed as a simple way for you to store your files, documents, photos, notes, messages, and so on (“Your Data”), collaborate with others, and work across multiple devices and services. To make that possible, we encrypt, store, process, and transmit Your Data as well as information related to it on your behalf. This related information includes things such as a) your profile information that makes it easier for you to collaborate and share Your Data with others b) Anonymous data and session metadata such as the size of the session, creation timestamp, collaborators, usage activity, devices types, light modes, face positions, concerns, products and treatments, to further improve our Products and Services, making them more relevant for you, c) personal data to further improve our Products and Services, making them more relevant for you, with the explicit consent of the data subject.
- You may choose to store your contacts on our Services to allow you to share and collaborate on Your Data, send messages, and invite others to use our Services. By storing the contacts on our Services, you consent that we process the data on your behalf, including back-up and facilitating access to the contact data in the Services by you and those you authorize (GDPR, article 6, sub 1f).
- Device and usage information. We collect information related to how you use our Products and Services. This includes IP addresses, the type and version of the browser or app and device you use, identifiers associated with your devices, and actions you take in your account (such as sharing, editing, viewing, creating, and moving sessions or catalogues). We use this information based on our legitimate interest to improve our Products and Services (GDPR article 6, sub 1f).
- Tracking information. Your devices (depending on their settings) have unique identifiers and may also transmit location information to the Services. We use such device information to protect our intellectual property, detect abuse and identify and troubleshoot bugs (GDPR article 6, sub 1f).
- Email address. By using our Products and Services you agree to receive information about upgrades and other relevant marketing materials from time to time (GDPR article 6, sub 1f). If you do not want to receive such communications from us, click the ‘unsubscribe’ link in the corresponding emails.
- Analytical information. We collect information that your browser sends whenever you visit our online Services. This log file information may include your computer’s IP address, browser type, browser version, the pages of our online Services that you visit, the time and date of your visit, the time spent on those pages and other statistics related to your website visit. We use this information in a legitimate interest to monitor the usage of our website and to improve it where and when necessary (GDPR article 6, sub 1f).
With whom is this information shared?
We may share information as discussed below, but we will not sell it to advertisers or other third parties. These third parties will access your information to perform tasks on our behalf. As controller, we will remain responsible for their processing of your information per our instructions.
- InnoFaith uses distributors for support and distribution of the Services. Distributors receive contact information of all Service users within their district and the Services they use.
- Other applications. You can choose to connect your InnoFaith account with third-party services – for example, via InnoFaith APIs. By doing so, you are enabling InnoFaith and those third parties to exchange information about you and data in your account so that InnoFaith and those third parties can provide, improve, protect, and promote their services. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.
- Law & Order and the Public Interest. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of InnoFaith or our users; (d) protect InnoFaith’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest. Your information may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
InnoFaith has taken appropriate technical and organizational measures by following strict internal policies and procedures and using the latest technologies to protect your information against loss or unlawful processing. We use a wide variety of controls to help keep the information collected through our Services secure. If you are under the impression that your personal data is not sufficiently protected or have reason to believe that your data has been abused, contact us by email at firstname.lastname@example.org.
As user of our Products and Services, you have specific rights when it comes to the way we process your personal data. You may submit requests to us regarding your personal data by sending us an email at email@example.com. We will respond as soon as possible, but within one month, to your request.
- Reviewing, adjusting or removing data – You have the right to review your personal data, to correct it and to remove it, unless your request violates our legal and contractual obligations. Additionally, you have the right to revoke your consent to process your personal data or to object against the processing of your personal data by us.
- Data portability – You have the right to data portability. That means that you can request us to transfer the personal data we have on you in computer files to you or another party appointed by you.
- Identity verification – You have the possibility to manage your own data in the app and/or portal we facilitate. The authentication you go through to access the portal provides us with sufficient verification of your identity.
For requests that cannot be handled in the app and/or portal we are obliged to verify your identity. We can do this in one of the below ways:
- We ask you to send a copy of your personal identity along with the request. In this copy of your identity card or passport, please hide your picture, the MRZ (machine readable zone, de lines with numbers at the bottom of a passport), passport number and social security number. We also urge you to protect the information using a password or encryption to protect your privacy if you send this information by email;
- We set up a video call in which you would show your face together with your identity card, such as a driver’s license or passport;
- You submit your request during a meeting with one of our staff who will perform the verification based on your identity card, such as a driver’s license or passport.
In some cases, we may not be able to verify your identity adequately based on the information you have provided. We will then contact you for additional verification. All information you provide us with for the verification will solely be used for this verification.
- Contractual or legal obligations – It may happen that we cannot comply with your request to review, adjust, or remove personal data because we have a contractual or legal obligation that prohibits us from doing so. In such cases we will let you know the reason why we cannot help you.
- Withdrawing your consent – You may revoke the consent that you have given us for the processing of personal data at any time. Please be aware that withdrawing only applies to the future processing of your personal data. Processing that took place before your withdrawal is not affected.
- Right to object – You have the right to object against data processing (including profiling) which is based on a legitimate interest at any time. To do so contact our privacy officer at firstname.lastname@example.org.
- Submitting a complaint – You may contact us if you have a complaint about the way we process your personal information through email@example.com. You also have the right to complain about our processing of your personal data to the competent data protection supervisory authority.
When you sign up for an account with us, in accordance with the law, InnoFaith does not retain your data any longer than is required for attaining the purposes for which they were collected.
When you cancel your InnoFaith cloud storage subscription, you will be offered the option to immediately remove all data that is no longer required for attaining the purposes for which they were collected. If you fail to comply to your payment and/or other commitments, we may suspend our services to you and after 3 months we may initiate deletion of your data.
Please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary, to comply with our legal obligations, resolve disputes, or enforce our agreements.
Where is the data stored?
Your information may be transferred to, and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
When you sign up for an InnoFaith cloud storage service for your data (“Your Data”), you will be offered a choice where you like your data (“Your Data”) to be stored.
All other data is stored in the European Union.
Data may also be stored locally on the devices you use to access our Services.
If we are involved in a reorganization, merger, acquisition, or sale of our assets, your data may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
How to contact us
Do you have any questions or concerns about InnoFaith, our Services, and privacy? Contact our Data Protection Officer at firstname.lastname@example.org.