1. Information Provided Directly By You
We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, complete an Innago form, survey, questionnaire or application, contact customer support, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, business name, business address, business title, phone number or any other personal information you choose to provide.
2. Information Collected Through Your Use of Our Services
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages that have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users and us. We may collect information relevant to a specific task. For example, this includes your bank account and routing numbers when collecting or delivering payment. For customer verification purposes, we may also collect your social security number and your birth date. The following are situations in which you may provide Your Information to us. When you:
- fill out forms or fields through our Services;
- register for an account with our Service;
- order services or products from, or through our Service;
- sign documents using our Services;
- store documents using our Services;
- submit “screening reports” (credit, criminal, eviction history);
- add sub-users such as maintenance personnel or property managers;
- provide responses to a survey or questionnaire;
- join or enroll in an event through our Services;
- sign up for any newsletters or other materials through our Services;
- provide information to us through a third-party application, service or website;
- communicate with us or request information about us, or our Services or products, whether via email or other means;
- participate in any of our marketing initiatives, including, contests, events, or promotions; and
- participate in forums, reviews or provide or post user generated content or other submissions.
3. Information Collected Automatically
We may automatically collect information through the use of various technologies, including, but not limited to Cookies, Pixel Tags and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.
4. Information Collected From Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Innago account with a social media service, e.g. LinkedIn, Facebook or Twitter, or if you engage with a separate application or website that uses our API, or whose API we use, we may receive information about you or your connections from that website or application. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.
5. Cookies, Log Files and Anonymous Identifier
- When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
- Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site or App.
- Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
- When we use session Cookies to track the total number of visitors to our Website or App, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).
- We may also employ Cookies so that we remember your computer or device when it is used to return to the Site or App to help customize your Innago experience. We may associate personal information with a Cookie file in those instances.
- Innago may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.
- When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.
6. Table of Cookies
The following is a list of the possible Cookies we may use in our Services. Please note that the names of Cookies and other technologies may change over time.
|Innago Token||Session||This is used to verify a visitor’s authentication and maintain session data.|
|Innago_Tracking_Email||12 months||If you enter a visitor enters their email address somewhere on the Innago website, this is used to pass that email address into our database.|
|utm_medium||12 months||This is used to track the medium a visitor came from (e.g. organic, referral, email, etc.)|
|utm_source||12 months||This is used to track the source a visitor came from. (e.g. Google, Bing, etc.)|
|utm_campaign||12 months||This is used to track the digital marketing campaign a visitor came from. Campaigns are an internal organizational datapoint attached to digital advertisements.|
|utm_term||12 months||This is used to track the keywords a visitor used that brought them to the website|
7. Information Third Parties Provide
We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and other users. This includes, without limitation, identity data, contact data, marketing and communications data, behavioral data, technical data and content data.
8. Device Information
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
9. Location Information
When you use the Services we may collect your precise location data. We may also derive your approximate location from your IP address.
10. Call and SMS Data
In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection and storage of this information.
11. Aggregated Data
Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions) unless they have received parental or legal guardian consent to use our Services. Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.
13. The Legal Basis and Reasons For Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:
- It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in;
- It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;
- To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support;
- To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and account management related messages;
- To send promotional communications that you have consented to receive or have expressed a legitimate interest in receiving;
- It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you; and
- It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
14. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. The GDPR and certain jurisdictional laws may not allow the exclusion or limitation of certain liability for data security. If these laws apply to you, some or all of the above limitations may not apply to you. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
15. How We Use Information We Collect
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared in that manner. We will use this information in order to:
- Operate and provide our Services;
- To facilitate payments to and from your bank account in coordination with our secure third party payment service provider;
- Improve our internal operations, systems, products, and Services;
- Provide users with customer support including, sending you related information, including confirmations, technical notices, updates, security alerts, and administrative messages;
- Understand you and your preferences to enhance your experience and enjoyment using our Services;
- Analyze, improve and manage our Services and operations;
- Resolve problems and disputes, and engage in other legal and security matters;
- Protect, investigate, and deter against fraudulent, unauthorized use or illegal activity
- Send you communications we think will be of interest to you, including information about our services, products, promotions, news, and events of Innago; and
- Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
16. How We Share Information We Collect
- If you are a tenant, or a prospective tenant applicant, we share your Personal Information with your landlord or the property management company that uses our Services to manage your residential leasing arrangement;
- With third party Service Providers to enable them to provide the Services you request including, without limitation, maintenance and service personnel and subcontractors of your landlord or property management company;
- With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate;
- With Innago subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
- With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, court or legal process;
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- If we otherwise notify you and you consent to the sharing; and
- In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
- We may disclose Your Information as follows:
- To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
- As required by law or ordered by a court, regulatory, or administrative agency;
- As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
17. User-Created Content and Public Sharing
- You will need to contact Innago in the event that you wish to have this personally identifiable information removed from our Service. Please note that responding to your request may not ensure complete or comprehensive removal from the internet if the content or information has been reposted by another party. To request removal of content or information from our Services, please contact us at firstname.lastname@example.org.
18. Analytic Services Provided By Others
19. Links to Third-Party Websites
20. Promotional Information Opt Out
21. International Privacy Practices
In order to provide our products and services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Union (“EU”) or European Economic Area (“EEA”) and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EU and EEA to the extent feasible under applicable law. By accessing and using the Innago Website, App or our Services, users who reside, or are located, in countries outside of the United States, agree and consent to the transfer to, and processing of, personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different, and may be less protective, than those required under the laws of their residence or location.
22. EU/EEA/UK Privacy Rights
Under the GDPR (or the UK GDPR if you are located in the United Kingdom), you have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
- Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below
- Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
- Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
- Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
- Right to Complain. If you’re based in the EU, you can file a complaint with the supervisory authority in your Member State. By way of example, and without limitation, if you reside in the United Kingdom you can file a complaint with the Information Commissioner’s Office here https://ico.org.uk/. Please contact the supervisory authority in your Member State.
23. Sharing Information With Law Enforcement
- Innago is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Innago receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
- Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), Innago may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Innago will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.
24. Account Information
You may correct your account information at any time by logging into your online account. You may cease using your account at any time. If you wish us to delete your account, please email us at email@example.com Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.
25.Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 1 year and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).
26. California Privacy Rights
- Information We Collect. We collect information that identifies directly or indirectly, with a particular person or a device (“personal information”). Below is a list of the categories of personal information we have collected about California residents in the past 12 months:
- Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers..
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Professional or employment-related information. Current or past job history or performance evaluations.
- Direct Collection. We collect information directly from you when you fill out forms or fields through our Service; register for an account; order products or services from, or through our Service; provide responses to a survey or questionnaire; join or enroll in an event through our Service; sign up for any newsletters or other materials; provide information to us through a third-party application, service or website; communicate with us or request information about us, or our products or Service, whether via email or other means; and participate in any of our marketing initiatives.
- Indirect Collection. We may Collect Information Indirectly from you through the use of various technologies, including, but not limited to Cookies, Pixel Tags and Web Beacons.
- Our Use of Personal Information.
- How We Share Personal Information.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial information.
- Internet or other similar network activity.
- Professional or employment-related information.
- Disclosures of Personal Information.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial information.
- Internet or other similar network activity.
- Professional or employment-related information.
- California Residents Under the Age of 16. We do not sell the Personal Information of California residents under 16 years of age.INDIVIDUAL RIGHTS AND CHOICES FOR CALIFORNIA RESIDENTS
- Right to Access Specific Information and to Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The categories of personal information that each recipient received.
- The specific pieces of personal information we collected about you.
- Right to Request Deletion
You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete your personal information from our records
- Exercising Your Rights to Access, Data Portability, and Deletion
We will not discriminate against you because you exercise any of the rights provided by the California Consumer Privacy Act.
- Other California Privacy Rights
- Do Not Track. Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. We do not take any action in response to this signal.
27. Contact Us
If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Our office address: 1308 Race Street, Ste. 100, Cincinnati, Ohio 45202
Last updated: February 27, 2023