Last Revised: June 6, 2021
IGMR Research Ltd. and our affiliates (“Intelligo”, “we”, “our” or “us”), puts great efforts in communicating our data practices and in making sure that the data we process is safe and used properly.
- Website visitors, prospective clients or partners (“Visitors”) who visit or interact with our website (such as https://intelligo.ai/ and its subdomains), participate in our events/webinars, online ads and content, emails or communications under our control (collectively, the “Sites”);
- Customers (“Customers”) and their authorized Users (“Users”) who have engaged with us, including account, contact and activity data relating to their use of the Intelligo Clarity SaaS Platform (available at: intelligo.ai) and other tools and features provided by us as part of the services (the “Platform”; together with the Site – “Service”);
- Applicants (“Applicants”) of our Customers about whom our background checks are conducted through the Service and by our Customers and their Users.
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Roles & Responsibilities
- Additional Information and Contact Details
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 5 below), please avoid any interaction with us or any use of our Services (or certain parts of our Services). If you are a User of the Platform on behalf of any of our Customers or if you are an Applicant, we suggest that you contact your account administrator or the Customer who requested the background check with any questions.
1. Data Collection
Intelligo collects data regarding our Visitors, Users and Customers (“you” or “your”), as well as their Applicants. Such data is typically collected and generated through automatic means, directly from you, through interactions with us or with our Services; from our Customers, who provide us with their Users’ data; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives. When the data relates to Applicants, it may be collected directly form the Applicant by the Customer or by Intelligo through public or private records following which it will be submitted to the Service.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):
Data automatically collected or generated: when you visit, interact with or use our Services, including any e-mail or text messages sent to you via our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of our Service Providers (as detailed in Section 5 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 6 below). Such data mainly consists of technical or aggregated usage data, such as IP address, non-identifying data regarding a device, operating system and browser, locale and language settings used and User activity on our Services. Such data mostly serves us to better understand how you our Users typically use and engage with our Services and to improve our marketing campaigns and engagements, as well as the overall performance of our Services.
Data received when you contact us: you may contact us for support, learning more about our Services and offerings, or for any other reason. In doing so, you may provide us Personal Data such as your name, email, workplace and position and any other data you choose to provide or that we may require in order to properly review your inquiry. Similarly, you can provide us with your Personal Data when you attend our events, webinars or when you contact us via our online chat or via social media (such as LinkedIn, Twitter or Facebook).
Data received from third-parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our Service Providers (defined below), and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
Data received from Users: you may provide us with your Personal Data voluntarily, such as your name, workplace and position, contact details (such as business e-mail, phone and address), account login details (such as usernames and hashed passwords), as well as any other data you choose to provide when you use our Services or create a User account. You may also provide us additional details concerning your organization (our Customer), such as billing details, billing contacts and authorized signatories on behalf of the Customer, business needs and preferences. To the extent that such data concerns a non-human entity, we do not regard it as “Personal Data” and this Policy shall not apply to it.
Data concerning Applicants: Intelligo provides wide data coverage to improve the accuracy of background checks and offer timely and intelligible results so our Customers (investors and alike) can make informed decisions regarding their business. For purposes of Intelligo background checks, Intelligo receives from the Customer data concerning Applicants which the Users submit to the Service. Intelligo may also obtain data on Applicants via public records. Such data may include, but is not limited to, the following:
- Name, date of birth, and government issued identification numbers such as Social Security number, passport number, and driver’s license or permit numbers;
- Contact information, including phone number, email and postal address;
- Professional information, including education (degrees, certifications, academic records, qualifications) and employment (previous employers, roles and employee record information);
- Legal Information, including court cases, arrests and warrants;
- Asset information, including property, trademarks registered, patents, and vehicles;
- Regulatory information including, sanctions, disqualifications, political exposure, Anti-Money Laundering & Terrorism activities, enforcement actions and so forth; and
- Financial information, including income, salary, billing rate, payments, and benefits.
2. Data Uses
Intelligo processes your Personal Data as well as other types of Personal Data of Applicants as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Visitors, Users, Customers, as well as Applicants, ourselves and our Services.
Specifically, we use your data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our Users and allow them to access and use our Services;
- To provide our Users and Customers with customer care, assistance and technical support services;
- To train and improve our algorithms, and to further develop, customize and improve the Services, and to improve user experience, based on common or personal preferences, experiences and difficulties;
- To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- To contact you with general or personalized service-related messages (such as password-retrieval or billing), or with promotional messages (such as newsletters, special offers, new features etc.) in accordance with Section 7 below, and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners and Customers may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations.
With respect to Applicants, we may use their data for the following purposes:
- To facilitate, operate, and provide our Services;
- To train our algorithms, and to further develop, customize and improve the performance of our Services,
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we may use to provide and improve our services;
- To provide our Customers with insights regarding their Applicants’ background for risk mitigation measures.
3. Data Location
We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States, the European Union, Israel, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
4. Data Retention
We retain your Personal Data for as long as it is reasonably necessary to provide our Services; to maintain and expand our relationship and provide you with our Services and offerings; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
5. Data Sharing
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data (or to Applicants’ Personal Data), in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), data analytics services (including Google Analytics, as further explained below), marketing and advertising services, data and cyber security services, fraud detection and prevention services, customer engagement services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to Personal Data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Sharing Data with our Customers and their Users: reports regarding Applicants are typically available to Users within the Customer’s account. Users’ data is shared with the administrator of the same Customer’s account to which such User belongs (including data and communications concerning such User’s account). Administrators can also enable authorized Users to have access to Personal Data concerning Applicants or concerning other Users. In such cases, sharing such data means that the administrator or other Users of the account may access it on behalf of the Customer, and will be able to monitor, process and analyze the Personal Data contained therein. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer). Please note that Intelligo is not responsible for, and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the ‘data controller’ of such data (as further described in Section 10 below).
Protecting Rights and Safety: we may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Intelligo, any of our Visitors, Users or Customers, as well as Applicants, or any members of the general public.
Additional Sharing: Intelligo may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
We and our Service Providers use “cookies” and other technologies for performance, tracking, analytics and personalization purposes and in order to provide you with a better experience. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies: cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session – these are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings (except with regard to essential cookies, which are required to provide the Services). Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset instructions, etc. Our Customers may also use our Services to send their Users on the same Customer account notifications, messages and other updates regarding their or your use of the Services. You can typically control your communications and notifications settings from your Intelligo User profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use of the Services (like password resets or billing notices).
Notifications and Promotional Communications: we and our authorized partners (e.g., event or webinar co-sponsors) may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Platform or Sites, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Intelligo at any time by sending an e-mail to: firstname.lastname@example.org changing your communications preferences in your User profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry standard security, confirmed also by Intelligo’s ISO/IEC 27001:2013 compliance certification. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites, Platform or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
9. Data Subject Rights
Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR), such as the right to request access to, and rectification or erasure of your Personal Data held with Intelligo, or to restrict or object to such Personal Data’s processing, or to port such Personal Data (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: email@example.com. Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding data we process on our Customer’s behalf, please contact the administrator of such Customer’s account directly. For example, if you are a User or an Applicant and you wish to access, correct, or delete data processed by Intelligo on behalf of our Customer, please direct your request to the relevant Customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer and its Users.
10. Roles & Responsibilities
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “data controller”, who determines the purposes and means of processing; and the “data processor”, who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Intelligo is both a “data controller” and “data processor” of its Users data. Such data is partially processed by Intelligo for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst other aspects of Users’ data will be processed by us on our Customer’s behalf, as a ‘processor’.
Intelligo is the “data processor” of its Customer’s Applicants data, which we only process on behalf of our Customer, who is the “data controller” of such data. In such instances, our Service Providers processing such data will assume the role of “sub-processors”.
Accordingly, Intelligo processes Applicants Personal Data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer. The Customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to their Applicants whose Personal Data may be processed – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents (if applicable) from such individuals as required under such laws.
11. Additional Information and Contact Details
Our Services are not designed to attract children under the age of 16: we do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
Effective Date: June 6, 2021