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Privacy Policy

i360, LLC Privacy Policy
Last Updated: June 8, 2022

This Privacy Policy was developed to explain our practices regarding personal information we collect from you or about you on our sites online, offline via written or verbal communications with us, i360’s desktop and/or mobile-based software applications (collectively referred to as “apps”), social networking presence, or from other sources. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We recommend that you read this entire Privacy Policy to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Policy, you may scroll down to the section(s) of interest to you:

• Personal Information We Collect and How We Use It
• Information We Collect by Automated Means
• With Whom We Share Your Information
• Automated Decisions About You
• User-Generated Content
• Links to Other Sites
• How We Protect Personal Information
• How Long is Personal Information Retained
• Your Personal Information Rights
• Children
• State Required Notices
• Updates to Our Privacy Policy
• How to Contact Us

Personal Information We Collect and How We Use It

We may collect personal information from individuals through our websites or by other means (such as email, mail, phone, apps, our affiliates, business partners, and other third parties such as commercial data vendors and public databases). The principal ways you may provide the information and the types of information you may submit, as well as the ways we may use the information, are listed below.
Business Alerts, Newsletters and Other Communications – You may provide personal information such as your name and contact details to receive business alerts, newsletters, and other communications (including emails). It is in our legitimate business interests to use the information you provide to send you the communications and information you have requested and to communicate with you about our products and services. If you no longer want us to send you business alerts, newsletters, or other communications, you may unsubscribe at any time by contacting us via the contact information provided in the “How to Contact Us” section of this Privacy Policy.

Business Purposes – On our websites and apps you may be able to register using your personal information to gain access to information related to your business relationship with i360 or i360 products. We use these details to provide you with access to information about your business relationship with us and to facilitate your use of the websites or apps. You may also choose to provide, or we may obtain, your personal information at conferences. It is in our legitimate business interests to use this information so that we can manage our business relationships and carry out marketing and sales activities.
You may also choose to connect to us via social networking services (e.g., Facebook or LinkedIn). When you connect to us via a social networking service, we may collect personal information that you have provided to that service in accordance with the service’s applicable terms of use and your privacy settings within that social networking service. We may also choose to supplement information you have provided to us to give us better insight into your needs and improve our business as permitted law.

Careers – Individuals may apply for jobs through our websites, third-party job posting sites, or physical locations. The information job seekers provide through this process is often maintained by third-party service providers. This information may be maintained in locations within the United States, accessible to our global recruiting team, and be shared with our corporate affiliates for the purpose of evaluating you for positions within our company. The information submitted by job seekers, such as name, contact details, and any other information relevant to the application is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interests to use this information in the selection process and to communicate with you, and it will be necessary to provide us with this information so that we can assess your application.
To allow the Company to meet certain government recordkeeping and reporting obligations (particularly in the U.S.), job seekers may choose to provide sensitive personal information, such as race, gender, disability status, or ethnic background. This information will not be considered in evaluating candidates’ qualifications for employment.

Contact – If you contact us with questions, requests, or comments through the “Contact” link on our website or via the contact information provided in the “How to Contact Us” section of this Privacy Policy, we may process your personal information to verify your identity or to track the inquiry internally to ensure we respond to your questions, requests, or comments.
Contractual Obligations – If you are a vendor or a contractor, we may ask you to provide personal information such as your name, photo, contact details, or business and financial details to establish and administer your account, process payments, and for compliance with internal and legal requirements. We use your information for this purpose so that we can comply with our contractual obligations to you.
Data From Other Information Providers and Customers – i360 obtains personal information from other information providers and its customers with legal and contractual obligations to lawfully provide such information to i360. Such information may include demographic information, contact information, and survey information.

Feedback – You may be able to submit feedback on our websites. If you choose to give us your feedback, we may ask you for your personal information. We may also ask you about your experience using our websites. It is in our legitimate business interests to use the information you provide to enhance our websites, evaluate the quality of our products, or to communicate with you about products and services.
Incidents and Allegations – When you provide information about an incident or allegation, detailed personal information including your name, contact details, and any relevant information about the incident or allegation may be collected. We use these details to investigate and comply with any applicable company or legal requirement. We may transfer and disclose your information to third parties as required during the investigation or to comply with any legal obligation related to the information you provide.

Information Technology/Physical Security – We may collect personal information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems. Likewise, to ensure physical security of our facilities we may, where permitted under local law, document your presence, verify your identity, utilize surveillance systems, and/or use location tracking while you are on Company property.

Non-Personal Information – We may collect and share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties.
Opt-In Information – We may obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities). If we ask for your consent to process your personal information, you may request to withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy. We may also present you with the opportunity to consent to the sharing of your information with third parties. If you agree to have your personal information shared, your personal information will be disclosed to the third-party subject to the privacy notice and business practices of that third party.
Other Uses of Information – We may use the personal information you provide to us for internal general business purposes in accordance with our legitimate business interests. These purposes include administration of our websites, data analytics, fraud prevention, and compliance with our legal obligations, standards, policies, and procedures (i.e., due diligence checks and sanction screening where applicable).

Publicly Available Information – We obtain personal information that is lawfully made available from federal, state, and local government records. We also obtain personal information from third parties which have lawfully collected such information directly from consumers, government records, from widely distributed media, or other sources which have the right to share such information with the third party. We use all the foregoing publicly available information to advance our legitimate business interests, including, but not limited to, providing data and technology services to our customers, in accordance with applicable law.

Information We Collect by Automated Means

When you visit and interact with our websites and apps, we may collect other information that does not inherently reveal your specific identity, to learn how to best tailor our websites for our visitors and for our legitimate business interests. Examples of what other information we may collect and how we and third-party service providers may collect this information include:

Aggregated Information – Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who have a particular telephone area code). Aggregated data is treated in accordance with this Privacy Policy.
App Usage Data – When you download and use an i360 app, we and our service providers may track and collect app usage data such as your device information, your device’s phone number, the date and time the app on your device accesses our servers, geolocation data, actions taken using the app, and information that has been downloaded from the app.

Browser and Device Information – Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system name and version, device manufacturer and model, internet browser type and version and the name and version of the online services (such as the apps) you are using. We use this information to ensure that the online services function properly, to measure the usages of our website and services, and for similar purposes in our legitimate business interest.

Cookies – Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other aggregated website traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while online. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the online services or to send you advertisements and marketing emails. We may also use cookies or other technologies to track responses to our online advertisements and marketing emails. You can opt out of such interest-based advertising using cookies set by participating NAI members at: http://optout.networkadvertising.org/#!/. Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that the company or companies from which you opt out will no longer show ads that have been tailored to your interests. If you do not want information collected by cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager. If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals except in jurisdictions where we are required to do so by law.

IP Address – Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the online services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, apps, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our online services. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.
Geolocation Based Services – We may collect geolocation data (i.e., the physical location of your device) if you have consented to us doing so, by, for example, using satellite, cell phone tower, Wi-Fi signals, or other technologies. We may use your device’s physical location to provide you with location-based services and content. For example, if you download one of our apps for use in performing activities for a non-profit organizations, political organization, or other entity, we may collect the geolocation of your mobile device (if you consent to the collection of this data) to provide information for the benefit of you and other users.

Pixel Tags or Similar Technologies – Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, Facebook Pixels, and similar services which use cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. These services may collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out by downloading the Google Analytics opt-out browser add-on, available at
https://tools.google.com/dlpage/gaoptout. You can learn about Facebook’s practices by going to https://www.facebook.com/ads/about/?entry_product=ad_preferences
and opt-out by visiting http://www.aboutads.info/choices.

With Whom We Share Your Information

We may share your information as disclosed at the time you provide it and/or in the following circumstances:

Business Transfers – We may disclose your personal information, usage information, and other information about you to parties acquiring part or all our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Corporate Affiliates – We share personal information and the information you provide within our company and with our affiliates for purposes described in this Privacy Policy. We do this because our affiliates may assist us in carrying out our legitimate business interests.

Customers – For a customer to use i360’s products, it must enter into a contract with i360. i360’s products containing personal information are used by approved non-profit organizations, political organizations, and companies to advance their efforts which typically include outreach to relevant audiences. Many of these services are described in greater detail on our website, https://www.i-360.com.
Law Enforcement Agencies, Courts, Regulators, Government Authorities or other Third Parties – We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, Terms of Use, and other agreements or to protect the rights, property, or safety of i360, our customers, or others (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services, or the public.

Third-Party Service Providers – In order to carry out your requests, to make various features, services, and materials available to you through the services, to respond to your inquiries, and for other purposes described in the “How We Use Your Information” section of this Privacy Policy, we may share your personal information or usage information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our sites; analyze data; provide customer service; manage payments; marketing and advertising companies (e.g., The Trade Desk); e-commerce activities, or assist with risk management, compliance, legal and audit functions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
Usage Data – When you use i360 products (e.g., apps), for example, as an employee, volunteer, or representative of an i360 customer, you are agreeing that i360 has the right to share information related to your usage of the i360 product with the corresponding i360 customer.

Automated Decisions About You

Automated processing may be used when evaluating large numbers of applicants for job vacancies. For these purposes we would request that you create a profile and answer some job-related questions to evaluate your skills as compared to the published job requirements. An algorithm may then be used to determine which candidates will be allowed to proceed to the next step within the selection process. We consider this data and process to be relevant because it will assist us to select the applicant most suitable for our vacancies. The outcome of the evaluation may have an impact on whether you are offered a role for the vacancy to which you applied.

You can contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by us if required by local law.
User-Generated Content

Some of our services and social networking features may enable you to submit your own content for public posting. Information you post in this fashion becomes public information and is not subject to this Privacy Policy. Certain areas of our websites and our social media pages may enable users to submit personal information to i360. Such information will be used in accordance with the website’s Privacy Policy. Postings, letters, and other submissions become the property of i360 and may be reproduced in whole or in part, including your name, for any purpose and in any manner.

Links to Other Sites

Our websites, apps, and other communications may provide links to other websites. To the extent that any linked services are not provided by i360, we are not responsible for the services, or any of the content found on these websites. If you provide information on and use third-party services or websites, the privacy policy, and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

How We Protect Personal Information

In proportion to the sensitivity of the information, we maintain reasonable administrative, technical, and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse, or unauthorized access, disclosure, alteration, or destruction of the information you provide. However, we cannot guarantee the security of your personal information, as no electronic data transmission or storage of information is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations. All information provided to i360 is transmitted using SSL (Secure Socket Layer) encryption. We also protect your information by placing it on a secure portion of our site that is only accessible by certain qualified employees of i360. Unfortunately, however, no Internet activity is 100% secure. While we strive to protect your information, we cannot ensure or warrant the security of such information.

How Long is Personal Information Retained

We will keep your personal information for a reasonably necessary period as permitted by applicable law. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data as required by applicable law.

Your Personal Information Rights

You may have certain rights regarding your personal information, subject to local law. These include, but may not be limited to, the following rights to:

• Access your personal information;
• Delete your personal information; and
• Opt out of the sale of your personal information.

We encourage you to contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy if you wish to exercise any of these rights. We will respond to you within a reasonable time and within the time limits established by applicable law.

Children

Our services are not directed to children under 18. We do not knowingly collect personal information from anyone under 18. If you become aware that we have collected personal information from a child under the age of 18 without parental consent, please let us know so we can take appropriate action.
State-Based Notices

California: California consumers can click here to access i360’s California Consumer Privacy Notice.

Nevada Residents: If you are a Nevada resident, Nevada law allows you to opt-out of the sale of certain personal information called “covered information.” Covered information includes a Nevada resident’s name, address, and any telephone numbers. If you wish to opt-out of i360’s potential sale of any of your covered information it may possess, you may email [email protected] with your request. To expeditiously process your request, please include “Nevada Consumer Privacy Request” in the subject line of your email and your full name and physical address in the body of your email.

Updates to Our Privacy Policy

We may modify or update this Privacy Policy from time to time. We will always indicate at the top of the Policy when it was most recently updated. Any changes will be effective immediately upon the posting unless otherwise indicated. We urge you to periodically review our Privacy Policy to understand any changes that may have occurred.

How to Contact Us

If you have questions about this Privacy Policy, a data privacy-related requests or questions, or otherwise wish to contact us, you can reach us as follows:

By mail:
i360
PO Box 662
Arlington, VA 22216

By email:
[email protected]

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