Last Updated/Effective Date: November 5, 2024
Intelener Srl. (“Intelener,” “we,” “our,” or “us”) is committed to safeguarding your privacy and the security of any information that can identify you or that we can associate with you (“Personal Data”). This Privacy Notice (“Notice”) outlines our practices regarding the collection, storage, use, sharing, transfer, deletion, and overall processing of your Personal Data.
We encourage you to read this Notice thoroughly. By providing us with your Personal Data or engaging with our Services, you acknowledge your acceptance of this Notice, to the extent permitted by law. If you do not agree with our policies and practices, you are free to refrain from using our Services or engaging with us.
Purpose of this Privacy Notice
This Notice details the categories of Personal Data that Intelener may collect or process, the purposes for which we may use and disclose that Personal Data, your rights regarding your Personal Data, and the contact information should you wish to exercise those rights or have any inquiries or concerns.
This Notice applies to Personal Data we collect or process (1) through our websites, including www.intelener.com, www.trakkempro.com, www.temptag.it, and all associated sub-sites and micro-sites under our control, including any related mobile applications; and (2) in any other scenarios where we provide this Notice to you (collectively referred to as the “Services”). This Notice does not extend to other information collected by Intelener through different means, such as offline data. In certain situations, Intelener may provide a separate privacy notice that applies specifically to the Personal Data collected in that context, superseding this one.
In some cases, we may collect or process Personal Data as a service provider at the direction of our business-to-business clients, such as your employer. In these instances, you should consult the applicable privacy notice from that client or contact them for information regarding their processing of your Personal Data.
If you provide us with Personal Data regarding individuals other than yourself, you must ensure compliance with all relevant privacy and data protection laws prior to disclosing such information to Intelener, including obtaining necessary consents.
Personal Data Collected, Purposes, and Recipients
We may collect or process your Personal Data when you interact with the Services, including but not limited to creating an online account or utilizing Intelener tracking devices and related applications. Below, we outline the types of Personal Data we may collect or process, the methods by which we obtain your Personal Data, the purposes for which we process it, the legal bases for such processing, and the categories of third parties who may receive your Personal Data.
Examples of the types of Personal Data we may collect or process (Personal Data that may be classified as sensitive under certain data protection laws is marked with a “*”):
– Identity and Contact Information:
– Username and password*
– First and last name or unique pseudonym
– Titles and preferred form of address
– Employer/company
– Personal/business email address
– Personal/business postal address
– Personal/business phone number
– Video, Audio, and Recorded Information:
– Still images*
– Video*
– Recordings of your interactions with our Services
– Commercial Information:
– Payment details, including credit card number, expiration date, and CVV*
– Purchasing and transaction history
– Geolocation Information:
– General location based on your Internet Protocol (IP) address
– Technical or Electronic Network Activity Information:
– Internet Protocol (IP) addresses (which may reveal your general geographic location or organization)
– Browser type and language
– Device identifiers
– Device type
– Date and time of your use of our Services
– URLs visited prior to and after accessing our Services
– Activity and online behavior while using our Services and referring websites or applications, including form submissions, videos watched, and clicks on our site pages
– Data collected from cookies or similar technologies
Where do we obtain your Personal Data?
– Directly from you
– From Intelener devices, including real-time trackers and passive loggers
– From authorized individuals acting on your behalf
– From your devices (e.g., computers, smartphones, tablets)
– From business partners and other third parties that assist us in providing and enhancing our Services
Why do we process your Personal Data?
– To provide you with our Services
– To communicate with you
– To manage our relationship with your organization
– To verify your identity and authenticate you
– To detect security incidents
– To protect against malicious, fraudulent, or illegal activities
– To ensure appropriate use of our Services
– To improve our Services
– For short-term, transient uses
– For administrative purposes
– For marketing, internal research, and development
– For quality assurance
– To comply with legal and regulatory obligations
What are the Legal Bases for Processing your Personal Data?
– For our legitimate interests
– To prepare for or perform a contract with you
– To comply with legal and regulatory obligations and to establish, exercise, or defend our legal rights
– In instances where we have obtained your consent for processing and for other legally permissible purposes
Who may receive your Personal Data?
– Intelener and our affiliates
– Your employer or organization
– Individuals or entities you designate or instruct us to share your Personal Data with
– Authorized representatives
– Third parties assisting in fraud prevention, detection, and mitigation
– Third parties supporting our IT and security programs as well as loss prevention efforts
– Intelener’s legal, audit, and consulting professionals
– Partners who assist us in enhancing our Services or improving our marketing or administration
The legal bases utilized by Intelener include those specified in Articles 6 and 9 of the European Union’s General Data Protection Regulation (GDPR). Where required and permissible, we will seek your consent or authorization to process your Personal Data and will only proceed with processing upon receipt of such consent. Refusal to provide consent or authorization will not adversely impact you; however, in cases where consent is necessary, it may hinder Intelener’s ability to maintain its relationship with you or provide you with Services.
In limited circumstances, recipients may include (1) in the event of a sale, assignment, merger, consolidation, corporate reorganization, or transfer, to the buyer, assignee, or transferee; and (2) government or regulatory officials, law enforcement, courts, public authorities, or others as permitted by this Notice or mandated by law.
Personal Data of Children
Intelener does not knowingly collect, maintain, disclose, or process Personal Data from individuals under the age of 18 without the consent of their parents or legal guardians.
Marketing, Cookies, and Analytics
To the extent allowed by law, including with your consent where necessary, we may engage in the following activities:
– We may use your contact information to reach out to you to discuss the initiation of a business relationship or to send you marketing communications. If you prefer not to receive such marketing emails, you may opt-out by declining during registration, following the opt-out instructions in subsequent communications, contacting us as described below, or at other points of information collection while using our Services.
– We may collect Personal Data automatically through cookies and similar technologies to enable functionality of our Services, recognize you across devices, and achieve legitimate business purposes or obtain consent as required. These purposes may include evaluating usage information, identifying trends, enhancing our Services, tailoring user experiences, implementing security measures, and selecting advertisements and offers that may interest you. For additional information regarding our use of cookies and similar technologies, please refer to our Cookie Notice.
– We do not engage in profiling that uses Personal Data subject to privacy laws. We do not process sensitive Personal Data to infer characteristics about you.
– We do not sell your Personal Data or share it with third parties for cross-context behavioral (i.e., “targeted”) advertising or third-party marketing purposes.
– If you enroll in any mobile text messaging or SMS service with us, we will not share your mobile number obtained during enrollment with third parties or affiliates for marketing or promotional uses. Additionally, we will not share text messaging originator opt-in data and consent with any third parties.
However, we may utilize Personal Data from cookies and similar tracking technologies for statistical analyses of our Services users to enhance functionality, content, design, and navigation.
Do-Not-Track Signals
Certain web browsers and other applications may transmit Do-Not-Track (“DNT”) signals to automatically opt users out of targeted advertising, sales of Personal Data, or other website tracking. Please note that we currently do not have the capability to recognize or comply with DNT signals. Nonetheless, Intelener does not participate in targeted advertising or sell Personal Data.
Service Providers and Third Parties
Service Providers
Third-party service providers, vendors, and processors acting on our behalf are required to sign agreements that mandate confidentiality and restrict processing of Personal Data to services provided to us, in alignment with this Notice and applicable privacy notices, as permitted or required by law.
Links to Other Websites
Our Services may contain links to other websites, applications, or services not owned or operated by Intelener. Such links do not imply endorsement by us of any third party, website, or products or services provided. We recommend that you review the privacy policies and practices of such third-party websites, applications, and services, as we cannot control and are not responsible for their privacy practices.
Your Rights Regarding Your Personal Data
Depending on your location, you may have the following rights regarding your Personal Data:
– To request information regarding whether and how we process your Personal Data
– To request access to and a copy of your Personal Data, including the right to provide your Personal Data to another organization (known as the right to
data portability in some jurisdictions)
– To request corrections or updates to your Personal Data
– To request the deletion of your Personal Data
– To request limitations, restrictions, suspension, blocking, or opting out of processing your Personal Data, including sensitive Personal Data
– To appeal a request denial
– To withdraw your consent when we process your Personal Data based on your explicit consent
– To file a complaint with the data protection authority in your jurisdiction
To submit a request, file a complaint regarding our processing of your Personal Data, or to appeal a denied request, please contact us using the information at the end of this Notice. Your authorized agent or representative may submit a request on your behalf, subject to verification of their relationship with you.
We will not discriminate against you for exercising any of the aforementioned rights, but fulfilling a request may impede our ability to provide certain Services or alter how we can engage with you.
We will strive to respond promptly to your requests and may require additional information from you to honor your request and verify your identity. Please note that we may not be able to grant these rights under specific circumstances if legally restricted from doing so.
Safeguarding Personal Data
In compliance with applicable laws and requirements, Intelener has implemented physical, technical, and administrative safeguards designed to protect Personal Data against loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure. However, as with all websites, applications, products, and services, we cannot guarantee complete security for data collected through our Services. It is also your responsibility to secure any passwords, identification numbers, or similar information associated with your use of the Services.
Retention of Personal Data
We generally retain Personal Data only as long as necessary for the purposes for which it was collected or obtained, as described in this Notice. In some instances, we may be obligated to retain Personal Data for an extended period due to legal requirements or other essential purposes. Whenever feasible, we aim to de-identify or anonymize your Personal Data or remove identifiable information from records retained beyond the specified retention period. Our criteria for determining retention periods include: (i) the duration of our ongoing relationship with you; (ii) any legal obligations affecting retention periods; and (iii) whether retention is necessary for Intelener due to litigation, limitations, or other legal or regulatory requirements. Intelener takes reasonable measures to securely dispose of Personal Data once the retention period expires, considering legal, regulatory, or litigation obligations.
International Transfers of Personal Data
We operate globally, and as such, the Personal Data we collect and process may be transferred and maintained outside your state, province, country, or jurisdiction where privacy laws may not offer the same level of protection as those in your location. Intelener has established lawful transfer mechanisms and appropriate safeguards to protect your Personal Data in compliance with legal requirements.
Changes to this Privacy Notice
We reserve the right to amend this Notice periodically. We will notify you of changes by indicating the date this Notice was last updated or as otherwise required by law. We recommend that you periodically review this Notice to remain informed of any modifications.
Contact Us
For any questions regarding our practices or this Privacy Notice, please contact us at https://www.intelener.com/home/#sendusamessage.