Privacy Policy and Terms

Last Modified: July 23, 2020

1. Our Commitment to Privacy / Introduction

1.1 We, InfoTrust, LLC, being the owner and operator of the taginspector.com website, respect the privacy of your information.

1.2 This website is referred to in this Privacy Policy as “our website” or “our site”. This Policy applies where we are acting as a data controller with respect to the personal data of taginspector.com; put simply, where we determine the purposes and means of the processing of that personal data.

1.3 We provide this explanation about our online information practices as a show of our commitment to protect your privacy. We do not sell or rent personally-identifying information collected during your use of our website without your permission. In accordance with this Privacy Policy or otherwise upon notification to you at the time of data collection or transfer, we may share your personally-identifying information with a third party. You will always have the option of not permitting the transfer by not using the particular services for which the information is collected or shared.

2. How we use your personal data

2.1 In this section we outline:

The general categories of personal data that we may process;
For data that we do not obtain directly from you, the source and specific categories of that data;
The purposes for which personal data is processed;
The legal basis for processing your personal data.

2.2 We only process your personal data where applicable law permits or requires it, including where the processing is necessary for the performance of our service requested by you, where the processing is necessary to comply with a legal obligation that applies to us, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent.

2.3 We may collect and process data about your use of our website and services (“usage data“). The categories of usage data may include your name, email, job title, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system (Google Analytics) and user input. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.4 We may use your personal information to improve our marketing and promotional efforts, to statistically analyze site usage, to improve our content and product offerings, and to customize our site’s content, layout, and services.

2.5 We may use your information to deliver information to you that, in some cases, is targeted to your interests, such as articles, targeted banners, new services, advertisements, and promotions. You can opt out of receiving this information by so indicating in your registration/preferences file or otherwise notifying us in writing. We may ask you to provide us voluntarily with additional information regarding your personal or business interests, experience, or requests, which we may use to customize our services for you.

2.6 We may collect and process your account data (“account data“).The categories of account data may include your name, email address, phone number, job information, and company information. The source of the account data is your IP information, cookie ID, and/or the information you have submitted to our website. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.7 We may collect and process personal information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

2.8 We may collect and process personal information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.9 We may collect and process personal information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping] The legal basis for this processing is our legitimate interests, namely the communications with users or interested parties.

2.10 We may collect and process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

2.12 The following is a list of the third parties we utilize to store data (3rd parties): Salesforce, Zoom Webinar, Google Drive, HubSpot, Google Analytics, Google Cloud Services, Amazon AWS, Intercom, and QuickMail.

2.13 The following is a list of where we collect data on our website (taginspector.com):

Contact forms
Content forms (registering for webinars and downloading content)
Blog subscription form
Tags
Account registration forms

2.14 We will only process personal data in ways that are compatible with the purpose that Tag Inspector has collected it for, or for purposes the individual later authorizes. Before we use your personal data for a purpose that is materially different from the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Tag Inspector maintains reasonable procedures to help ensure that personal data is reliable for its intended use, accurate, complete, and current.

3. Providing your personal data to others

3.1 We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering our relationship with you, including third-party service providers who provide services to us or on our behalf. Third-party service providers may include, but are not limited to data storage or hosting providers. These third-party service providers may be located outside of your home jurisdiction.

3.2 We may disclose your personal data to any member of our group of companies (InfoTrust, LLC and Tag Inspector) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.4 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.5 We may transfer personal data to our third-party agents or service providers who perform functions on our behalf including: website hosting, customer relationship management storage, and cloud data storage. Where required by applicable law, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the applicable law requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal data in accordance with our obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of personal data that we transfer to them.

4. Security

4.1 We employ reasonable and current security methods designed to prevent unauthorized access, maintain data accuracy, and ensure correct use of information and to comply with any law, rule, or regulation, including, without limitation, all laws, rules, and regulations regarding the use, transmission, storage, and security of personal data.

4.2 To use some of our services, you may be required to set up a password-protected account or profile on our website. We recommend that you do not divulge your password to anyone. It is your responsibility to keep your password protected. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. Remember to sign out of your account, close your browser window, and delete your temporary Internet files when you have finished your session. This helps ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place where others may have access to it.

4.3 Whenever you voluntarily disclose personal information online — for example, on message boards or blogs, through email, or in chat areas — that information can be collected and used by others. No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure; therefore, we cannot guarantee its absolute security.

5. International transfers of your personal data

5.1 Our headquarters is located in the United States. Information we collect will be stored and processed in the United States in accordance with this Privacy Policy. To facilitate our global operations, we may transfer and access personal information from around the world, including to the United States. This Privacy Policy shall apply even if we transfer personal information to other countries. By accessing the taginsepctor.com website or providing us with any personal information, you consent to this transfer, processing, and storage of your information in the United States, which is a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside. Note that your personal information may be available to the United States government or its agencies under legal process in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our services for you and for the purposes set out in this Privacy Policy. If you are located in the EU, we have implemented standard data protections clauses to secure the transfer of your personal data to the United States and other jurisdictions. Personal information from EU residents will be treated in accordance with applicable law.

6. Children under 16

6.1 Our Website and application are not directed to children and we will not request personally-identifiable information from anyone who we know to be under the age of 18, unless we have obtained verifiable parental consent from a parent or legal guardian.

6.2 We have no way of distinguishing the age of individuals who access our website, and so we carry out the same Privacy Policy for individuals of all ages. If a child has provided us with personally-identifying information without parental or guardian consent, the parent or guardian should contact us to remove the information and opt out of promotional opportunities or other applicable services.

6.3 If we become aware that a user under the age of 13 has registered with our Website, application, or services and Tag Inspector has not obtained prior verifiable consent from a parent or legal guardian, we will immediately remove the user’s personal information from our files.

7. California Residents – Your California Privacy Rights

7.1 California Civil Code Section 1798.83 permits California residents to request from us certain information regarding the disclosure of certain categories of personal information to third parties for their direct marketing purposes within the immediately preceding calendar year. A company may also comply with the law by disclosing in its privacy notice that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes (as we do), and information on how to exercise that choice. If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to us via the email address or the mailing address set forth below. Please put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address, and include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

7.2 California Consumer Privacy Act (CCPA)

This Section applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
The CCPA gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:
1. What specific pieces of information a business has about the consumer;
2. Categories of personal information it has collected about the consumer;
3. Categories of sources from which the personal information is collected;
4. Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
5. Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or selling personal information.
In addition, California consumers can request that the personal information a business has collected about them be deleted from the business’s systems and records.
- - InfoTrust LLC is a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers.
  - InfoTrust LLC and it’s subsidiary Tag Inspector do not presently sell personal information to third parties for any purpose.
  - To make a “request to know” or request to delete your personal information, send us an email as set forth below. Please indicate if this is a “request to know” or “request to delete” in the subject line of your email. You may also submit these requests by mailing your request to our address in the United States:
            Data Protection Officer
            InfoTrust, LLC
            4340 Glendale Milford Rd. Suite 200
            Blue Ash, OH 45242 USA
We may honor these requests for US individuals whether or not you would qualify as a California consumer under the CCPA.
- We will confirm receipt of your request within 10 days along with a description of the steps to verify and execute your request. We must provide the requested action within 45 days of receipt of your request but can use an additional 45 days, provided we let you know the additional time is needed.
- We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  - Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  - Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  - Debug products to identify and repair errors that impair existing intended functionality.
  - Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  - Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  - Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  - Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  - Comply with a legal obligation.
  - Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- When contacting us, we may request for you to provide certain limited personal information to verify your request and to match with our records and systems. This is to protect against fraud. We will not retain or use this personal information for any other purpose. We need to search our records and systems for only the preceding 12 months worth of information.

7.3 Residents of other states may have similar rights to request or delete their personal information. To inquire about these rights, please contact us at the email set forth below.

8 European Union GDPR Rights

8.1 This Section applies solely to all visitors, users, and others who reside in an area subject to the European Union General Data Protection Regulation 2016/679 (“GDPR”). In this Section, we have summarized certain rights that you may have under the European Union General Data Protection Regulation 2016/679 (“GDPR”). Some aspects of GDPR are complex and not all of the details have been provided below. Therefore, you should read the GDPR and relevant guidance from the applicable regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under GDPR are as follows:

the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

8.4 Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.5 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.6 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of GDPR; The processing is for direct marketing purposes; and The personal data have been unlawfully processed. There are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

8.7 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.8 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.

8.9 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.10 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.11 To the extent that the legal basis for our processing of your personal data is (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.12 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

8.13 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.14 You may exercise any of your rights in relation to your personal data by written notice to us via any of the contact information described below.

9. Retaining and deleting personal data

9.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

10. Acting as a data processor

10.1 In respect of data controlled and collected by the clients we represent, we do not act as a data controller; instead, we act as a data processor.

10.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

11. Our use of cookies

11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2 Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date. A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

11. 4 We use cookies for the following purposes:

Authentication – we use cookies to identify you when you visit our website or leverage any of our applications. Cookies for this purpose are used to enable account log-in and navigation in-app.
Status – we use cookies to indicate if you are logged in or a subscriber to our website.
Personalization – we use cookies to store information about your preferences and to personalize website content for you.
Advertising – we use cookies to help us display advertisements that will be of interest to you, cookies used for this purpose are for Google, LinkedIn, and other paid marketing initiatives.
Analysis – we use cookies to help us analyze the use and performance of our website and applications. Cookies used for this purpose include Google Analytics.
Cookie consent – we use cookies to indicate your consent preferences in relation to broader cookie use.

11.5 Our service providers use cookies and those cookies may be stored on your browser when you visit our website. These cookies include:

Google Analytics – we use Google Analytics to analyze the use and performance of our website and marketing initiatives. The information gathered relating to our website is used to create reports about the use of our website.
HubSpot – we use HubSpot to manage the content and contact submissions on our website. Cookies are used to associate content consumption and preferences with the user. This service uses cookies to track web visitor behavior and assist with our sales and marketing activities.

11.6 Most browsers allow you to refuse to accept and delete cookies. You can obtain up-to-date information about blocking and deleting cookies via these links:

https://support.google.com/chrome/answer/95647?hl=en (Chrome);
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
https://support.apple.com/kb/PH21411 (Safari); and
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12. Questions or Complaints

12.1 You can direct any questions or complaints about the use or disclosure of your personal data to us at the contact information below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 45 days of receiving your complaint. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

13. Changes to our policy

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure that you agree with any changes to this policy.

13.3 We may notify you of changes to this policy by email or through adjusting the last modified date at the top of the Privacy Policy.

14. Contact Information

14.1 If you have any questions about this Policy or would like to request access to your personal data, please contact us as follows:
        Email: dpo@infotrust.com
        Phone: 1-513-322-2236
        Mailing Address: Office of the DPO
        4340 Glendale Milford Rd. Suite 200
        Blue Ash, OH 45242 USA

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