UPDATED: November 2019

This Privacy Policy explains how Itaca Technologies LLC. (“ItacaTech”) collects, uses, and discloses information you provide to us or which we otherwise collect in providing products or services to you (“Information”), including “Personal Data” by which we mean information that allows us to determine your identity when you engage with us.

The use of our products and services (“Itaca Technologies Offerings”) is subject to the terms of the applicable customer agreement, the use of our website is subject to the ItacaTech Website Terms and Conditions of Use, and the terms of this Privacy Policy are incorporated into each and form part of those agreements.

Data Collection
What We Collect Via Your Interactions
How We Use Information Collected From Interactions
Exercising Your Rights In Europe
Opting Out Of Marketing Emails
What We Collect Via ItacaTech Offerings And How We Use It
Other Collection Practices
Data Collection Practices Associated With Apps
How ItacaTech Shares Your Information
Lawful Basis For Transferring Your Data
How We Secure Your Information
ItacaTech Also Observes The Following Practices
Updates To This Privacy Policy
Contact ItacaTech
Links to Related Agreements, Policies and Information

Data Collection

There are two primary ways in which ItacaTech collects Information from you: through Interactions and through ItacaTech Offerings.
Interactions. When you interact online or offline with ItacaTech, we may receive your Information, including your Personal Data. For example, we receive your Information when you:

    • Visit and use ItacaTech’s websites
    • Download materials through the websites
    • Provide or update account information through the websites
    • Register or attend ItacaTech-hosted or sponsored events (such as promotional events, webcasts, contests or hackathons)

We collect Information about you from other sources such as public databases, joint marketing partners, social media platforms, conference/event hosts, and partners when you interact with them.
We refer collectively to these contacts as “Interactions” and we explain below how we use the Information we collect through them.

ItacaTech Offerings. We also collect Information, including Personal Data, when necessary to provide our ItacaTech Offerings to you or to fulfill our legitimate interests, as described below. We may ask you for this data directly, or in some cases, we may collect it when certain features are enabled in our ItacaTech Offerings. For example, we collect your Information when you (or someone you work with):

    • Trial or order any of our ItacaTech Offerings
    • Interact with ItacaTech online or offline, including when you request support services
    • Use ItacaTech Offerings to process information
What We Collect Via Your Interactions

We (or others acting on our behalf) may collect your Information, including your Personal Data, through the Interactions described above. Categories of Personal Data we collect include such things as:

    • Name
    • Email address
    • Physical address, including country
    • Employer
    • Title/Position
    • Payment details
    • Phone number
    • User name / user ID
    • IP address

We collect Personal Data in various ways, such as when you manually key in your Personal Data to our website forms or provide it to us or others from whom we receive marketing leads. IP addresses are collected on an automated basis through your use of the website services using cookies, web beacons, and like technologies. We may infer your location from your IP address. For more on the use of cookies and like technologies, see our ItacaTech Cookie Policy.

How We Use Information Collected From Interactions.

ItacaTech uses the Information it collects from your Interactions to deliver services to you in accordance with our terms, to satisfy our legal obligations, or to satisfy our legitimate interests, as described below. We take seriously the need to balance our legitimate interests with your privacy rights and summarize for you here how we use your Information, including Personal Data.

We use your Information to:

      • Fulfill your orders or respond to your requests for information.
        To satisfy your requests for website materials such as marketing collateral or white papers, we collect and use your name and email address.
      • Improve and develop the website services.
        We collect Information via cookies and like technologies as set forth in our ItacaTech Cookie Policy to help us fulfill our legitimate interest in improving our website services and make them more relevant to you.
      • Issue you ItacaTech accounts for access to online communities and forums.
        When you join our online communities and forums, we collect your Personal Data so you can participate. The guidelines associated with those communities and forums recommend not sharing private or proprietary information on them, as many aspects of them are public.
      • Send administrative information.
        We may need to notify you (or we may choose to inform you) when we make updates to our terms or policies or make changes to our website services. We will use your name and email address to send these administrative notices to you, which due to their nature are treated differently from marketing communications from which you can opt out.
      • Manage your ItacaTech account.
        In order to perform the services under the contract between you and ItacaTech, we need to collect certain Information from you such as your contact and payment details. Without this Information, we may not be able to deliver the services or comply with our legal obligations.
      • Send you marketing communications.
        Where we have your consent to do so (if required), we will email you product announcements, educational materials or information about special offers or upcoming online or offline events. In accordance with applicable law, we give you the choice to opt out of receiving these materials.
      • Invite you to participate in surveys, studies, and assessments of ItacaTech Offerings.
        We use your Personal Data to request feedback from you about our ItacaTech Offerings so that we can fulfill our legitimate interest in improving them and continue to grow our business. Your participation in user surveys is voluntary and subject to your consent, the terms of your agreements with us, and this Privacy Policy.
      • Personalize your experience.
        We use your Personal Data to satisfy our legitimate interest in presenting you with content tailored to your interests using cookies, web beacons, and like technologies. (For more information see the ItacaTech Cookie Policy)
      • We may also receive your location information in connection with certain services. You can update your device location setting permissions at any time to disable collection.
      • Diagnose and fix technical issues, monitor for security, and otherwise protect our property.
        We do this to satisfy our legitimate interest in anticipating and recognizing potential threats to the operation and security of our website services to help keep them online and secure. We may process your Personal Data, in particular your IP address, for this purpose.
      • To comply with any applicable law, regulation, legal process, or governmental request, or to protect our legal rights.
      • For any other purpose disclosed to you in connection with our website services from time to time.
        If we process your Personal Data for a purpose other than that set out above, we will provide you with information prior to such processing.
Exercising Your Rights in Europe

If you are in the European Union or the United Kingdom, you have the right to: request access to and correction of your Personal Data; restrict or object to the processing of your Personal Data; and request your Personal Data be “forgotten” (technically erased). If you would like to exercise these rights, contact us at: compliance@itacatech.com. Please describe the nature of your request and the Personal Data it relates to, and we will comply as soon as reasonably practicable, consistent with applicable law. We will verify your identity before we comply with your request, and therefore, ask for your cooperation with our identity verification process.

If we process your Personal Data based on your consent, you may withdraw your consent at any time. We will let you know if we are seeking to rely on your consent at the time we collect your information.

Opting Out of Marketing Emails

If you no longer want to receive marketing-related emails from ItacaTech on a go-forward basis, please send an email to that effect to: compliance@itacatech.com. Alternatively, you may use the “unsubscribe” feature in our email messages.

What We Collect Via Our ItacaTech Offerings and How We Use It

On-premises Product Data. We collect and process different types of product data (as described below) when you deploy the ItacaTech Offerings on-premises (“ItacaTech On-premises Offerings”) to serve our legitimate interest of improving our products and services. We work hard to help ensure a balance between our legitimate interests and your privacy rights.

    • License Usage Data is Information that allows us to identify your account entitlements, such as license consumption and license type, in our systems through an assigned license ID.
    • Aggregated Usage Data is Information about your operating environment and session, such as your network and systems architecture, page loads and views, and searches by type. We aggregate this Information to analyze usage patterns. Once we verify that the data received is from a valid ItacaTech product, we discard the license ID. We hash user IDs connected to page view activity before analysis by ItacaTech. For more on Aggregated Usage Data, see ItacaTech’s Documentation (Share Performance Data). ItacaTech uses Aggregated Usage Data to fulfill our legitimate interest in enhancing the ItacaTech Offerings. For example, we may use this data to:
        • Better understand how our users configure and use ItacaTech On-premises Offerings
        • Determine which configurations or practices optimize performance (e.g., best practices)
        • Benchmark key performance indicators (“KPIs”)
        • Perform data analysis and audits
        • Identify, understand, and anticipate performance issues and the factors that affect them
        • Improve the operation of the ItacaTech Offerings
        • Develop new features and functionality
    • Support Usage Data is Aggregated Usage Data, but the license ID persists so that the Information can be linked to your account. We use this data to analyze performance information, troubleshoot issues, personalize your experience, suggest other ItacaTech Offerings that may be of interest to you, or provide guidance to help you optimize your use of your ItacaTech On-premises Offering.

In our paid ItacaTech On-premises Offerings, you have the option of configuring your settings to opt out of providing License Usage, Aggregated Usage and Support Usage Data. For opt-out instructions, see ItacaTech’s Documentation (Share Performance Data).

ItacaTech Cloud Offerings Service Data. We collect and process data generated by your use of ItacaTech’s cloud-based offerings, such as the ItacaTech Cloud and services (“ItacaTech Cloud Offerings”). We collect this data to help fulfill our contractual obligations to you and to serve our legitimate interest in improving the service. We work hard to help ensure a balance between our legitimate interests and your privacy rights.

Service Data is Information generated by your use of the ItacaTech Cloud Offerings such as page views, interactions, errors, number of active and licensed users, number of searches, source types and format (e.g., json, xml, csv), and app workflows. ItacaTech uses Service Data to provide and enhance the ItacaTech Offerings. For example, we may use this data to:

      • Help analyze and troubleshoot issues
      • Personalize your experience and suggest other ItacaTech Offerings that may be of interest to you
      • Provide guidance to help you optimize your usage
      • Analyze behavior and performance across deployments
      • Benchmark KPIs (data aggregated and pseudonymized)
      • Perform data analysis and audits
      • Identify, understand, and anticipate performance issues and the factors that affect them
      • Improve the operation of ItacaTech Offerings
      • Develop new features and functionality

Service Data is collected by ItacaTech as part of the ItacaTech Cloud Offering, including free or trial offers, and may contain incidental pieces of identifying information necessary to monitor the health, performance or security of your deployment. ItacaTech restricts access to this information, and where feasible, aggregates and pseudonymizes it.

Location Data is data we collect in certain ItacaTech Offerings (“apps” and “add-ons”, as discussed below) that associates your end users’ mobile device with an identifier for your app to help us improve the user experience and personalize your services and content. Depending on your configuration of the ItacaTech Offerings, it may be that location information on your end users is shared with ItacaTech, however, you can disable this function if you so choose (or advise your end users about how to disable it) through the location setting on their mobile device.

For more information about the data collected through use of your ItacaTech Offerings, see our Documentation for the relevant ItacaTech Offering (e.g., Share Performance Data for ItacaTech Enterprise).

Other Collection Practices

We also collect Personal Data from you to fulfill our contractual commitments to you. For example, we collect contact information such as name, address (email and physical) and phone number to enter you into our customer database systems and manage your account. This may also include Information about billing and payments, customer service, support services, or software updates.

We share this Information with our affiliates, vendors and partners who help us service your account and with whom we have written agreements protecting the confidentiality, privacy and security of your Information. We do not sell this Information.

Data Collection Practices Associated with Apps

The ItacaTech Offerings are extendible using software applications commonly called “apps”, “add-ons” or “technical add-ons” that we offer. We refer to these collectively as “Apps”. These Apps are versatile and have access to a broad set of web technologies that can be used to collect and use your Information. This Privacy Policy only applies to Apps developed by ItacaTech.

ItacaTech requires other App developers to comply with applicable privacy and data protection laws, but cannot guarantee that they do so. You should familiarize yourself with the privacy policies and license agreements that apply to those Apps.

ItacaTech collects data generated from the use and performance of Apps that inter operate with ItacaTech Offerings, such as crash information, version, session duration, user engagement, and number of downloads, active/licensed users, and log ins. We may share this information with App developers so they can improve and enhance the performance of their Apps.

How ItacaTech Shares Your Information

ItacaTech may disclose Information to third parties in the following ways:

    • Affiliates. We may disclose Information to our affiliates subject to this policy in order for them to help administer or service the ItacaTech Offerings. ItacaTech is the party responsible for the management of jointly-used Personal Data.  ItacaTech maintains intra-partners agreements with its affiliates covering the use of Personal Data within the ItacaTech family of companies.
    • Service Providers. We may disclose Information to our service providers (e.g., infrastructure as a service, order fulfillment, professional/customer/support services), pursuant to written agreements with confidentiality, privacy and security obligations. ItacaTech maintains a list of sub-processors who process Personal Data as part of the ItacaTech Offerings, which ItacaTech updates, as needed.
    • App Developers. We may disclose Information about App use and performance with App developers so that they can improve and enhance the performance of their Apps. App developers will be identified to you when you download and use their Apps pursuant to their license terms, including their privacy policies.
    • Partners and Sponsors. We may disclose contact and account Information to our partners and event sponsors (identified at time of registration or event participation) pursuant to written agreements with confidentiality, privacy and security obligations. They may use the Information to assess your interest in ItacaTech Offerings, conduct user research and surveys, or send you marketing communications, subject to the terms of their privacy policies. We may also share On-premises Product Data and Service Data from ItacaTech Cloud Offerings with partners who provide you with support services.
    • Compliance and Safety. We may disclose Information as necessary or appropriate under applicable laws (including laws outside your country of residence) to: comply with legal process or requirements; respond to requests from public and government authorities (including those outside your country of residence); enforce our terms and conditions; and protect our operations or those of any of our affiliates; and our rights, privacy, safety, or property, and/or that of our affiliates, you or others.
    • Merger, Sale, etc. We may disclose Information in the event of a proposed or actual reorganization, merger, sale, joint venture, corporate transaction, assignment, transfer, or other disposition of all or any portion of ItacaTech business, assets or stock (including Information regarding any bankruptcy or similar proceedings).
    • Other Users. We may disclose Information to other users of the service in aggregated format, provided it does not include Personal Data. This may include “best practices” tips, KPIs, benchmark data or other such aggregated information useful to the user community.
Lawful Basis for Transferring Your Data

ItacaTech is committed to uphold the privacy principles articulated in the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Principles”) regarding the collection, use, and retention of personal information transferred from the European Union, the EEA, the United Kingdom, and/or Switzerland, as applicable, to the United States in reliance on Privacy Shield. ItacaTech has self-certified to the Department of Commerce that it adheres to the Privacy Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Principles, the Privacy Principles will govern. ItacaTech certifications to these Privacy Shield Frameworks may be found here.

How We Secure Your Information

ItacaTech takes reasonable technical and organizational measures to safeguard Personal Data against loss, theft, and unauthorized access, disclosure, alteration, misuse, or destruction. Unfortunately, no data transmission, software, or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of an account has been compromised), please notify us immediately in accordance with the “Contact ItacaTech” section below. If ItacaTech learns of a breach of its systems, ItacaTech may notify you or others consistent with applicable law and/or as agreed in our contract with you. ItacaTech may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the ItacaTech Offerings and the Information you provide to us.

ItacaTech Also Observes the Following Practices

Retention Period. We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by applicable law. Information you store in our ItacaTech Cloud Offerings is portable by you at the end of the term of your agreement with ItacaTech. We retain your contract information for the duration of your contract with us and thereafter as required or permitted by law. See Data Retention Policies for further details.

Use of ItacaTech Offerings by Minors. The ItacaTech Offerings are not directed to individuals sixteen (16) and under or those not of the age of majority in your jurisdiction, and we request that these individuals not provide Personal Data through the ItacaTech Offerings.

Cross-border Transfers. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers which are located outside of your country of residence, including to the United States. Different data protection rules than those applicable in your country may therefore apply. As indicated above, ItacaTech has certified to the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks for the transfer of Personal Data from the EEA, the United Kingdom, and Switzerland to the U.S. We put in place adequacy mechanisms to protect your Personal Data in our agreements with our service providers.

Links to Other Parties. The ItacaTech Offerings may contain links to or facilitate access to other websites or online services. This Privacy Policy does not address, and ItacaTech is not responsible for the privacy, information, or practices of other parties, including any App developer, App provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer. The inclusion of a link within the ItacaTech Offerings does not imply endorsement of the linked site or service by us or our affiliates. ItacaTech encourages you to review the privacy policies and learn about the privacy practices of those companies whose websites you choose to visit. We list below links to resources about many of the other parties with whom we interact as described in this Privacy Policy:

      • For partners
      • For App developers/providers listed on ItacaTech’s app ecosystem.
      • For other marketplaces where ItacaTech Apps may be found
      • For industry content providers (such as providers of research, white papers, etc.)
      • For industry award providers (such as those listed on itacatech.com)
      • For resources (such as source code repositories, sample data sources, customers, etc.) mentioned in blogs and press releases.
      • For other providers, sponsors, or speakers at events in which ItacaTech is involved.
      • For social media platform providers (such as Twitter, LinkedIn, YouTube, or Facebook).

Updates to this Privacy Policy. We may change this Privacy Policy from time to time and will post our updates here. We will also communicate any material changes of the Privacy Policy to you.

Contact ItacaTech

If you have any questions or comments about this Privacy Policy, the information practices of the ItacaTech Offerings, or your dealings with ItacaTech, you can contact us at any time:

ITACA TECHNOLOGIES LLC
Attention: Legal Dept.
Fort Lauderdale, FL
compliance@itacatech.com

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

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