This privacy policy applies to information collected online from users of this website. In this policy, you can learn what kind of information we collect, when and how we might use that information, how we protect the information, and the choices you have with respect to your personal information.
What personal information is collected through this website and how is it used?
We collect information about our users in three ways: directly from the user, from our Web server logs and through cookies. We use the information primarily to provide you with a personalized Internet experience that delivers the information, resources, and services that are most relevant and helpful to you. We don’t share any of the information you provide with others, unless we say so in this Privacy Policy, or when we believe in good faith that the law requires it.
User-supplied information
If you fill out the “contact” form on this website, we will ask you to provide some personal information (such as e-mail address, name, phone number and state). We only require that you provide an e-mail address on the contact form. Further, if chat is available through this site, you may be asked to provide information if you participate in an online chat. Please do not submit any confidential, proprietary or sensitive personally identifiable information (e.g. Social Security Number; date of birth; drivers license number; or credit card, bank account or other financial information) (collectively, “Sensitive Information”). If you submit any Sensitive Information, you do so at your own risk and we will not be liable to you or responsible for consequences of your submission.
Information that you provide to us through the contact form or an online chat will be used so that we may respond to your inquiry. We may also use information you provide to us to communicate with you in the future. If you do not wish to receive such communications, you may opt out (unsubscribe) as described below.
Web server logs
When you visit our website, we may track information about your visit and store that information in web server logs, which are records of the activities on our sites. The servers automatically capture and save the information electronically. Examples of the information we may collect include: your unique Internet protocol address; the name of your unique Internet service provider; the town/city, county/state and country from which you access our website; the kind of browser or computer you use; the number of links you click within the site; the date and time of your visit; the web page from which you arrived to our site; the pages you viewed on the site; and certain searches/queries that you conducted via our website(s).
The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use and improve the user’s experience.
Cookies
In order to offer and provide a customized and personal service, our websites and applications may use cookies and similar technologies to store and help track information about you. Cookies are simply small pieces of data that are sent to your browser from a Web server and stored on your computer’s hard drive. We use cookies to help remind us who you are and to help you navigate our sites during your visits. Cookies also can tell us where visitors go on a website and allow us to save preferences for you so you won’t have to re-enter them each time you visit. The use of cookies is relatively standard. Most Internet browsers are initially set up to accept cookies, but you can use your browser to either notify you when you receive a cookie or to disable cookies.
If you wish to disable cookies from this site, you can do so using your browser. You should understand that some features of many sites may not function properly if you don’t accept cookies. For more information about using browsers to manage cookies, please see All About Cookies. You can also refuse to accept Flash cookies from this website using Adobe’s Flash management tools. You can opt out of Google’s use of cookies by visiting Google’s Ad Settings.
By visiting this website, you consent to the use of cookies and similar technologies in accordance with this Privacy Statement.
Third-party Services
We may use services hosted by third parties, including Adobe Site Catalyst, to assist in providing our services and to help us understand the use of our site by our visitors. These services may collect information sent by your browser as part of a web page request, including your IP address or cookies. If these third-party services collect information, they do so anonymously and in the aggregate to provide information helpful to us such as website trends, without identifying individual visitors.
In addition, we may use services provided by third parties to display relevant content, products, services and advertising to you. These third parties may use cookies, web beacons and similar technologies to collect or receive information from this website and elsewhere on the internet. They may then use that information to provide measurement services so we can understand your interests and retarget advertisements based on your previous visits to this website. Please keep in mind that we do not share your personal information with any third-party advertiser, ad server or ad network.
You may be able to opt-out of the collection and use of information for ad targeting by some third parties by visiting www.aboutads.info/choices. You can opt out of Google’s use of cookies by visiting Google’s Ad Settings. You can visit this page to opt out of AdRoll’s and their partners’ targeted advertising. Please see “Cookies” in the section above for more information on how you can control the use of cookies on your computer.
California Do Not Track
Our web services do not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described in more detail above, we track user activity using web server logs, cookies and similar technologies. Information collected in web server logs helps us analyze website usage and improve the user’s experience. Cookies allow us to offer you a customized experience and present relevant advertising to you.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
We may use third-party services that identify business visitors to our website based on IP address and other technical information. These services may provide us with information about the organization associated with a visitor, such as company name, industry, and contact details where available. This information is used for sales, marketing, and business development purposes.
How is personal information protected?
We take certain appropriate security measures to help protect your personal information from accidental loss and from unauthorized access, use or disclosure. However, we cannot guarantee that unauthorized persons will always be unable to defeat our security measures.
Who has access to the information?
We will not sell, rent, or lease mailing lists or other user data to others, and we will not make your personal information available to any unaffiliated parties, except as follows: to agents, website vendors and/or contractors who may use it on our behalf or in connection with their relationship with us; if we are unable to assist with your matter, but know an unaffiliated attorney or firm that may be able to help you, we may refer you and share information you provided us with that party; and as required by law, in a matter of public safety or policy, as needed in connection with the transfer of our business assets (for example, if we are acquired by another firm or if we are liquidated during bankruptcy proceedings), or if we believe in good faith that sharing the data is necessary to protect our rights or property.
How can I correct, amend or delete my personal information and/or opt out of future communications?
You may opt out of any future contacts from us at any time. Contact us via the phone number, contact form or mailing address on our website at any time to: see what data we have about you, if any; change/correct any data we have about you; ask us to delete any data we have about you; and/or opt out of future communications from us.
If you have any additional questions or concerns about this privacy policy, please contact us via the phone number, contact form or mailing address listed on this website. If our information practices change in a significant way, we will post the policy changes here.
Privacy Notice
Last updated: May 2026
This Privacy Notice provides you with information about what personal data we collect about you, how and why we use it, with whom we share it, how we store it, and your rights with respect to your data. This Privacy Notice is meant to be read together with our Terms of Service, which you can find at https://innova.co/terms-conditions/.
We at Ephoca Inc. (“us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our website visitors. This Privacy Notice describes the types of information we collect from you when you visit our site and/or use our services thereon (such services, together with the site, the “services”). “You” means an individual using the services, and “personal data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which personal data we collect when we provide the services to you.
This Privacy Notice applies to residents of the United States and Canada. If you are located outside of these jurisdictions, please note that your use of the services is governed by applicable laws in your jurisdiction, and you should review those laws to understand your rights. If you are a resident of the State of California, please note that, in addition to this Privacy Notice, the Supplemental Privacy Notice for California Residents set forth in Exhibit A hereto may also apply to you.
1. Personal Data We Collect
1.1. Communications
When you send us a message through the contact form on our site or other means, request information from us, sign up for our email list, complete online forms, or contact us for any other reason, we collect any data you provide, such as your name, phone number, email, and the content of your message.
1.2. Sensitive Information
Please do not submit any confidential, proprietary, or sensitive personally identifiable information (such as Social Security Number, date of birth, driver’s license number, or credit card, bank account, or other financial information) (collectively, “Sensitive Information”) through our contact forms or online chat features. If you submit any Sensitive Information, you do so at your own risk and we will not be liable to you or responsible for consequences of your submission.
1.3. Online Chat
If chat is available through this site, you may be asked to provide information if you participate in an online chat. Information that you provide to us through an online chat will be used so that we may respond to your inquiry.
1.4. Activity and System Data (including Cookies)
In addition, when you use the site, we may track information about your visit and store that information in web server logs, which are records of the activities on our sites. Our servers automatically capture and save the information electronically. Examples of the information we may collect include: your unique Internet protocol (IP) address; the name of your unique Internet service provider; the city, state/province, and country from which you access our website; the kind of browser or computer you use; the number of links you click within the site; the date and time of your visit; the web page from which you arrived to our site; the pages you viewed on the site; device ID; your browsing history (e.g., other sites you have visited before ours); and certain searches/queries that you conducted via our website(s). The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve the user’s experience. This data is also collected via cookies (for more information, see the Cookies Section below).
2. How We Use Your Personal Data
2.1. General
We and any of our trusted third-party subcontractors and service providers use the personal data we collect from and about you for any of the following purposes: (1) to provide you with the services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and services; (4) to review the usage and operations of our site and services; (5) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); and (6) to prevent fraud, protect the security of our site and services, and address any problems with the site and/or services.
2.2. Legal Bases for Processing (Canada)
Where required by Canadian privacy law, we process your personal data based on your consent, as necessary to perform a contract with you, or as otherwise permitted or required by law. You may withdraw your consent at any time by contacting us at privacy@innova.co, but this may affect our ability to provide certain services to you.
2.3. Statistical Information and Analytics
We and/or our service providers use analytics tools to collect and analyze information about the use of the services, such as how often users visit the site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users. This helps us improve our services by allowing us to identify new trends and customer needs, which in turn allows us to consider new products and services or tailor existing products and services accordingly. As part of our use of analytic tools, we may use Google Analytics. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.
2.4. Third-Party Analytics Services
We may use additional services hosted by third parties, including Vector, to assist in providing our services and to help us understand the use of our site by our visitors. These services may collect information sent by your browser as part of a web page request, including your IP address or cookies. If these third-party services collect information, they do so anonymously and in the aggregate to provide information helpful to us such as website trends, without identifying individual visitors.
2.5. Microsoft Clarity
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement at https://www.microsoft.com/privacy/privacystatement.
2.6. Business Visitor Identification
We may use third-party services that identify business visitors to our website based on IP address and other technical information. These services may provide us with information about the organization associated with a visitor, such as company name, industry, and contact details where available. This information is used for sales, marketing, and business development purposes.
3. Sharing the Personal Data We Collect
We share your information, including personal data, as follows:
3.1. Access-Holders
Access-holders who have access to personal data are personnel who have a need to know and process personal data in accordance with this Privacy Notice, and who are bound by confidentiality obligations towards us. It is hereby clarified that the identity and/or type of access-holders may change from time to time in accordance with our business needs. In case there is a material change in the types of access-holders, we will use commercially reasonable efforts to update you about such change.
3.2. Service Providers and Subcontractors
We disclose information, including personal data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: (1) help us provide you with the services, and (2) aid in their understanding of how users are using our services.
3.3. Affiliates
We share information, including your personal data, with our parent company, Innova SRL (located in Via 1° Maggio, 8 – 38089 Storo (TN) Italy), where this is necessary to provide you with our products and services, and for business management purposes.
3.4. Referrals to Third Parties
If we are unable to assist with your matter, but know an unaffiliated party that may be able to help you, we may refer you and share information you provided us with that party.
| Type of Service | Description | Personal Data Shared |
|---|---|---|
| Cloud Computing | We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data. | All personal data that we collect from you is stored on third party servers. |
| Customer Relationship Management (CRM) | We use an external CRM tool to help us keep track of our customers and information related to them, including their personal data. | Your name, email address, and phone number. |
| Analytics Providers | We use service providers to assist us with analytics services. | Data collected automatically through our site, including IP addresses, cookie information, and user interactions. |
| Online Advertising | External service providers assist us in placement of online advertisements. | Data collected automatically through our site, including IP addresses and cookie information. |
| Contact Form Service | We use a service provider to assist us in displaying and managing our site’s contact forms. | Your name, email address, phone number, and the content of your message. |
| Payment Processors | When you make a payment through our services, the transaction is processed by an independent vendor. | The details of your credit card. |
3.5. International Transfers
Your personal data may be transferred to, stored, and processed in countries outside of your country of residence, including the United States. By accepting this Privacy Notice, you acknowledge and agree that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including personal data). When we transfer personal data from Canada, we take appropriate steps to ensure that your information receives an adequate level of protection.
3.6. Business Transfers
Your personal data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your personal data shall continue being subject to the provisions of this Privacy Notice.
3.7. Law Enforcement Related Disclosure
We may share your personal data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms of Service and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.
3.8. Legal Uses
We may use your personal data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
3.9. Advertisers
When you click on one of our ads on a third-party site, the relevant advertiser will be alerted that someone has visited the page on which the relevant advertisement was displayed, and may be able to identify that it was you by using certain mechanisms, like cookies. We share personal data with such advertisers as follows: (i) with your consent or (ii) hashed IDs and/or device identifiers. Advertisers are able to combine the personal data they collect independently with the personal data we share.
3.10. Sale and Sharing of Personal Data
We may “sell” or “share” your personal data (as those terms are defined under applicable state privacy laws) with third parties for purposes of cross-context behavioral advertising or targeted advertising. We do not share your personal information with any third-party advertiser, ad server, or ad network except as described in this Privacy Notice. You have the right to opt out of such sale or sharing by contacting us at privacy@innova.co or by clicking the “Do Not Sell or Share My Personal Information” link on our website. You may also be able to opt out of the collection and use of information for ad targeting by some third parties by visiting www.aboutads.info/choices. You can opt out of Google’s use of cookies by visiting Google’s Ad Settings. You can visit https://app.adroll.com/optout/personalized to opt out of AdRoll’s and their partners’ targeted advertising. We do not knowingly sell or share the personal data of consumers under 16 years of age.
4. Security
We make efforts to follow generally accepted industry standards to protect the personal data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
5. Your Rights
Subject to applicable law, you may have certain rights regarding your personal data. Depending on your jurisdiction, these may include the right to: (1) access any personal data we hold about you; (2) request correction or update of inaccurate personal data; (3) request deletion of your personal data; (4) request that we restrict or limit the processing of your personal data; (5) object to certain processing activities; (6) request portability of your personal data; and (7) opt out of the “sale” or “sharing” of your personal data (as those terms are defined under applicable law), or the processing of your personal data for targeted advertising. You may exercise such rights by emailing us at privacy@innova.co. We will not discriminate against you for exercising any of these rights.
5.1. California Residents
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These include the right to: (i) know what personal information we collect, use, disclose, and sell or share; (ii) request deletion of your personal information; (iii) correct inaccurate personal information; (iv) opt out of the sale or sharing of your personal information; (v) limit the use of your sensitive personal information; and (vi) not be discriminated against for exercising your privacy rights. To exercise these rights, please contact us at privacy@innova.co or visit Do Not Sell or Share My Personal Information. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf. For more information, please see Exhibit A hereto.
5.2. Ohio Residents
If you are a resident of Ohio, you may have rights under the Ohio Personal Privacy Act (OPA), effective January 1, 2026. These rights include the right to: (i) confirm whether we are processing your personal data; (ii) access and obtain a copy of your personal data; (iii) request deletion of your personal data; (iv) correct inaccurate personal data; (v) opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise these rights, please contact us at privacy@innova.co. If we decline to take action on your request, you may appeal our decision by contacting us at the same address within a reasonable period. We will respond to your appeal within sixty (60) days.
5.3. Other US State Residents
Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights, including the right to access, correct, delete, and obtain a copy of personal data, as well as the right to opt out of targeted advertising, sales of personal data, and profiling. To exercise these rights, please contact us at privacy@innova.co. If we deny your request, you may have the right to appeal our decision by contacting us at the same address.
5.4. Canadian Residents
If you are a resident of Canada, you have certain rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. These include the right to access your personal information, to request correction of inaccurate information, and to withdraw your consent to the collection, use, or disclosure of your personal information. You may also file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner if you believe your privacy rights have been violated. To exercise your rights, please contact us at privacy@innova.co.
6. Data Retention
Subject to applicable law, we retain personal data as necessary for the purposes set forth above and then delete the personal data once we deem it is no longer necessary for these purposes. In some circumstances, however, we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
7. Cookies and Similar Technologies
We use cookies and similar technologies for a number of reasons, including to help personalize your experience. Third parties through which we provide the services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting our site, you shall be notified of the use and placement of cookies and other similar technologies on your device as specified herein.
7.1. What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.
7.1.1. A “session cookie” is temporary and will remain on your device until you leave the site.
7.1.2. A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
7.1.3. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
7.1.4. We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
7.2. How We Use Cookies
We use cookies and similar technologies for a number of reasons, as specified below. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
| Type of Cookie | Why We Use These Cookies |
|---|---|
| Necessary | These cookies are necessary in order to allow the site to work correctly. They enable you to access the site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled. |
| Functionality | These cookies remember your settings and preferences and the choices you make in order to help us personalize your experience and offer you enhanced functionality and content. |
| Security | These cookies can help us identify and prevent security risks. |
| Performance/Analytics | These cookies can help us collect information to help us understand how you use our site, for example whether you have viewed specific pages and how long you spent on each page. This helps us improve the performance of our site. |
| Advertising | These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own services and for other websites. Such cookies may track your browsing habits and activity when visiting our site and those of third parties. |
7.3. How to Adjust Your Preferences
Most web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your site preferences, you will be required to input these each time you visit.
8. Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.
9. Communications
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. If you have opted in to receive marketing or promotional communications from us, you may opt out at any time by following the unsubscribe instructions in the communication or by contacting us at privacy@innova.co. Please note that even if you opt out of marketing communications, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.
10. Children
We do not knowingly collect personal data from children under the age of thirteen (13) in the United States, or under the age of majority in Canada where applicable. In the event that you become aware that an individual under these ages is using the services without parental permission, please advise us immediately. If we learn that we have collected personal data from a child under the applicable age without parental consent, we will take steps to delete that information as soon as possible.
11. Do Not Track Signals
Some web browsers may transmit “Do Not Track” (“DNT”) signals to websites. We currently do not take action in response to these signals. However, if a uniform standard for responding to such signals is adopted, we may revisit our policy on responding to these signals.
12. Changes to the Privacy Notice
We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our site or via email.
13. Comments and Questions
If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at privacy@innova.co.
Exhibit A
Supplemental Privacy Notice for California Residents
This Supplemental Privacy Notice for California Residents (“CA Supplement”) supplements and forms an integral part of our general Privacy Notice available above. This CA Supplement describes how we collect, share, and store personal information about California residents who use our Site and/or Services, as well as the rights they have with respect to that information. If not otherwise defined herein, capitalized terms have the meaning given to them in our Privacy Notice. Please read the Privacy Notice for additional terms that may apply to you.
“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise may be defined by applicable law.
Depending on your usage, we collect different types of information and we and any of our third-party sub-contractors and service providers use the information we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Information, but if you refuse to provide such Personal Information, we may not be able to register you and/or provide you with the Services or part thereof.
This CA Supplement will cover the following topics:
1. Categories of Personal Information We Collect
2. How We Share Your Personal Information
3. Your Rights – How to Access and Limit Our Use of Certain Personal Information
4. How to Contact Us
1. Categories of Personal Information We Collect
In the past twelve months, we have collected the following Personal Information from users of our Site and/or Services who are using the Site as visitors and potential customers. This Personal Data is used for the purposes described in the Privacy Notice:
1.1. Contact Information
If you contact us, we collect certain identifiers directly from you, such as your name, phone number, email address, and the content of your message.
1.2. Device/Network Information
When you use the Site or Services, we will collect information about your device automatically, including non-Personal Information such as your operating system and browser type, identifiers such as your IP address or device ID, and internet and other electronic network activity such as your browsing history and usage data.
2. How We Share Your Personal Information
2.1. Sharing for Business Purposes
In the past 12 months, we have disclosed the following categories of Personal Information for the following business or purpose in the preceding 12 months: we have shared your personal identifiers and internet or other electronic network activity with data analytics providers, operating systems, and other third parties that assist us in providing you with the Services, including providing us with IT and system administration services, data backup, security, and storage services, and providing data analytics services, and to help us serve advertisements and provide other marketing services, as well as with our affiliates as necessary to provide you with services.
2.2. Additional Sharing Activities
2.2.1. Affiliates. We share information, including your Personal Information, with our parent company, Innova SRL (located in Via 1° Maggio, 8 – 38089 Storo (TN) Italy), where this is necessary to provide you with the Site and Services, and for the purpose of management of our business.
2.2.2. Business Transfers: Your Personal Information may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such a case, your Personal Information shall continue being subject to the provisions of this CA Supplement.
2.2.3. Law Enforcement Related Disclosure: We may share your Personal Information with third parties: (i) if we believe in good faith that such disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms of Service, the Privacy Notice, and this CA Supplement); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
3. Your Rights – How to Access and Limit Our Use of Certain Personal Information
Subject to certain exemptions, you have certain rights in relation to the Personal Information that we have collected about you, as detailed below. In accordance with applicable law, we may ask for reasonable evidence to verify your identity before we comply with certain of your requests, as detailed below.
3.1. Your Rights
3.1.1. Right to Know and Access. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:
- The specific Personal Information we have collected about you.
- The categories of Personal Information we have collected about you.
- The categories of sources from which we collected the Personal Information about you.
- The categories of third parties to whom we disclosed Personal Information about you.
- The categories of Personal Information about you we have sold and the categories of third parties to whom we have sold such Personal Information.
- The categories of Personal Information about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such Personal Information.
- Our business or commercial purpose(s) for collecting or selling your Personal Information.
3.1.2. Right to Delete. Subject to certain exceptions, you have the right to request that we and any of our service providers delete your Personal Information.
3.1.3. Right to Correct. If you find that any of the Personal Information we’ve collected about you is inaccurate, you have the right to correct such information.
3.1.4. Right to Opt-Out of the Sale of Personal Information. If you are 16 years of age or older or have opted in to the sale of your Personal Information, you have the right to direct us not to sell your Personal Information at any time. You may change your mind and opt back into the sale of your Personal Information at any time by contacting us at the address above. We may deny any request to opt out of the sale of Personal Information that we deem in our good-faith, reasonable and documented belief is fraudulent.
3.1.5. Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as not being denied any goods or services or charged different prices or rates.
3.1.6. Right to Limit our Use of Your Personal Information. To the extent we collect any sensitive Personal Information about you, you have the right to instruct us to limit our use of such Personal Information only for the purpose of providing you with our services and certain business operation purposes.
3.2. How to Exercise your California Privacy Rights
3.2.1. Contact Information. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at privacy@innova.co. You may only request to exercise your right of access twice within a 12-month period.
3.2.2. Submitting a Verifiable Request: In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Information or an authorized agent of such person, which may include details relating to your account. Any requests made through your password-protected account will be verified through our existing authentication procedures for such account.
3.2.3. Submitting Requests through an Authorized Agent: An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your Personal Information through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law.
4. Retention
4.1. We retain your Personal Information as long as necessary to fulfill each of the purposes we described above. Once we are done with your data, we delete it.
4.2. When deciding how long to store Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized access, the purposes for which the Personal Information was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy.
5. Children
We do not knowingly sell the Personal Information of California residents under 16 years of age.
6. How to Contact Us
If you have any comments or questions about this CA Supplement or our privacy practices, or if you wish to exercise any of your legal rights as set out herein, please contact us at privacy@innova.co.
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