Privacy Policy

Introduction

Inguro OÜ, Address: Harju maakond, Tallinn, Kesklinna linnaosa, F. R. Faehlmanni tn 5, 10125 (further referred to as “Inguro,” “we,” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy together with our Terms of Use and any other documents referred to in them) applies to the Inguro website (https://inguro.com/) and desktop application (collectively, “Application”) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled by us.

In this Privacy Policy, the term “personal data” means information that relates to an identified or identifiable natural person. “Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of data concerning health or sex life.

We know that you are concerned about how we use and disclose personal data, and we are committed to complying with data protection and privacy laws that apply to us. This Privacy Policy tells you about how we protect your privacy and the personal data we process about you.

We wish to remind you that this Privacy Policy applies to personal data that we process when you use the Application. It does not apply to any links to third-party websites, applications, or services you may encounter when using the Application. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

By using the Application, you agree to the privacy practices described in this Privacy Policy.

Information We May Collect from You

(i) Data You Provide in the Application

We may collect the following information from our users that may, in certain circumstances, constitute personal data:

User’s full name (for individuals)
Name of organization (for legal entities)
List of employees (for legal entities only)
Billing name
Billing address
Email address
Email password
LinkedIn ID
Mailing address
Application password
Any other information you provide to us
Information we receive about you from third parties.

(ii) Data Collected Automatically

The Application may automatically collect the following information from you that in certain circumstances may constitute personal data:

We and our third-party partners use cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”).
These tracking technologies collect information about how you use the Application (e.g. actions you take in the Application), information about your browser, and online usage patterns (e.g. IP address, browser type, browser language, browser UserAgent heading containing browser version and operating system type), and information about the devices you use to access the Application (e.g. device type, model and manufacturer, device operating system brand and model, device hard disk drive, Mac network interface controllers, operating system version, information regarding the location of your device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may also collect the configuration of the Application when you use it and the time and date of your use of the Application.
We also collect analytics data and use third-party analytics tools to help us measure traffic and usage trends for the Application.

The Purposes for which We use the Data

We use the collected personal data for the following purposes:

To verify your identity
To determine your eligibility to use the Application
To communicate with you
To prevent and investigate fraud, unauthorized use, and other misuses
To operate and improve our products and services
To audit and analyze the Application, and
To ensure the technical functionality and security of the Application.

We use the data collected automatically for the following purposes:

To improve customer service
To personalize user experience
To provide features available in the Application
To develop, improve, and protect the Application;
For market research;
To audit and analyze the Application;
To ensure the technical functionality and security of the Application;
To remember information so that you will not have to reenter it during your visit, or the next time you visit the Application;
To provide custom, personalized content, and information, including targeted content and advertising;
To monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns in our Application;
To provide for the security of the Application; and
To differentiate between the devices you use to access the Application in order to prevent desynchronization of the user database.

How We Disclose Data

We do not sell, lease, rent, or otherwise disclose the personal data relating to our users to third parties unless otherwise stated below.

The personal data collected in the Application may be disclosed in the following manner:

(i) Personal data you provide in the Application:

We may disclose personal data you provide to the Application with the following categories of third parties:

To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties
To our subsidiaries and affiliates; or a subsequent owner, co-owner or the operator of the Application and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock or assets or other corporate reorganization, following this Privacy Policy
To other third parties, if we determine that such disclosure should be made for reasons of national security, law enforcement, or other issues of public importance; and
To other third parties, if we secure your prior consent to such disclosure.

(ii) Data collected automatically:

The data collected automatically in the Application may be disclosed to the following categories of third parties:

To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
To our subsidiaries and affiliates; or a subsequent owner, co-owner, or the operator of the Application and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock or assets or other corporate reorganization, following this Privacy Policy. Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users.

Your Rights

You have the following rights concerning the personal data we hold about you:

The right to know what data we hold about you. If you would like to know what personal data we hold about you, please contact us at team(AT)inguro(DOT) com. We seek to promptly respond to your inquiry.
The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated. The easiest way to correct, delete, or update the personal data you have provided to the Application is to log in to the Application and enter the necessary changes in the account settings of the Application. If you have additional questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at team(AT)inguro(DOT) com. Please note, however, that we may not be able to modify or delete information in all circumstances, including if we are required by federal or state law to keep certain information about you for a certain period.
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 email messages and text messages, give you the 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 team(AT)inguro(DOT) com.
The right to have your personal data deleted.
If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request.
The right to restrict the processing of your information.
When you contest the accuracy of your information, believe we process it unlawfully, or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing.

Customers from California

California law provides California customers with specific rights with regard to the collection, sale, and disclosure of their personal information. If you are a California resident, you have the following rights:

The right to request that we delete any personal information about you which we have collected from you. Nevertheless, we will not be required to comply with your request to delete your personal information if it is necessary for us to maintain your personal information for the reasons provided under California Civil Code Section 1798.105(d).
The right to request that we disclose to you the following:
– The categories of personal information we have collected about you;
– The categories of sources from which your personal information is collected;
– The business or commercial purpose for collecting or selling your personal information;
– The categories of third parties with whom the business shares your personal information; and
– The specific pieces of personal information we have collected about you.
The right not to be discriminated against because you have exercised any of your rights under the CCPA.
We do not sell your personal information or collect data to facilitate or enable third parties to advertise to you.

Data Security

The security of personal data is important to us. For example, your user account is protected by a password, and the servers we use are secured and protected by a firewall. In addition, encrypted browsing is the default browsing mode in the Application. Even so, we cannot guarantee that your personal data are always secure because data security measures in use from time to time may be vulnerable. Consequently, please be mindful of the risks that personal data about you may be exposed to when you use the Application.

We also periodically review and adjust security safeguards as the threat landscape evolves. Ultimately no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In case any information under our control is compromised as a result of a breach of security, our policy is to take reasonable steps to investigate the situation and, where appropriate, communicate with affected individuals.

International Transfers of Personal Data

Information collected through our website may be stored and processed in Estonia or any other country in which we or our affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our affiliates or service providers maintain facilities and to the use and disclosure of information about you as described in this Privacy Policy.

Children’s Privacy

You must be at least eighteen (18) years of age to register with and use the Application. This Application is not directed to children under 13. We do not intend to collect personal data from children under 13.

Changes to the Privacy Policy

From time to time we may change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of this page. If we materially change how we use and disclose personal data, we will post a notice in the Application and send an email to our registered users. Your continued use of the Application following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

Payments and payment providers

You will be able to generate invoices for the use of the platform directly in your profile. In this case, we will process your account data to calculate the amount of money payable and provide you with the invoice.

For payments, you will be prompted to a third-party payment processing provider, who will store and process your payment information. Please note that we do not receive your payment details from them, but only payment confirmations and details of the transactions you perform. Payment processors are independent controllers over your payment information which includes your payment card data.

The applied legal basis for processing information about payments is the performance of the contract with you (GDPR Art. 6.1.b). We also retain financial information to analyze our financial performance in our legitimate interests (GDPR Art. 6.1.f) and to comply with applicable accounting and financial laws (GDPR Art. 6.1.c)

Website, sales, and marketing activities

The following data collection activities are present on our website:

Collection of visitor logs (device, browser information, IP address) to ensure fraud prevention and manage user sessions, stored for 6 months of your last visit. The applied legal basis is our legitimate interests (GDPR Art. 6.1.f)
Cookies – for more information please visit our Cookie Policy;
Visitor traffic analysis, done by using third-party analytics providers. This activity, depending on the method used, is performed based either on your consent (cookie tracking) or our legitimate interests (GDPR Art. 6.1.f)
Provision of a free eBook and other useful materials, which a website visitor may obtain by providing their email address, first and last name. We will also use this information to send you direct marketing messages. The processing is based on your consent (GDPR Art. 6.1.a)
Organization of our own webinars and participate in third-party webinars. We will also use this information to send you direct marketing messages. The processing is based on your consent (GDPR Art. 6.1.a)

We store marketing data for 12 months of the last communication with you. For the activities that are based on consent, you can withdraw your consent at any time by contacting us directly. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out of the e-mail subscription by clicking the appropriate button in our emails to you.

Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Application, or the protection of the personal data we hold about you, please contact us via email at team(AT)inguro(DOT) com or by mail at Inguro OÜ, registry code: 16269023, address: Harju maakond, Tallinn, Kesklinna linnaosa, F. R. Faehlmanni tn 5, 10125 Attention: Privacy. We seek to promptly resolve any concerns you may have.