Intelli Returns Privacy Notice
1. Introduction.
Intelli Returns cares about privacy and wants you to be familiar with how it collects, uses, and shares (“Processes”) information that identifies you, relates to you, describes you, or could be linked, directly or indirectly, to you as an individual or, if you are a California resident, your household (“Personal Information”). This privacy notice (“Privacy Notice”) describes Intelli Returns’ practices concerning information it collects through its website (the “Website”), the social media pages it controls (“Social Media Pages”), and the software applications it makes available (“Apps”) when they are used by employees or contractors of our customers in their capacity as such (collectively, the “Services”).
This Privacy Notice does not apply to the extent that Intelli Returns Processes Personal Information on behalf of its customers. When a customer runs a website or application on Intelli Returns’ platform, the customer is the controller of the Personal Information that is Processed through such website or application and is responsible to you for protecting its privacy. Under such circumstances, the customer's privacy notice, not Intelli Returns’, applies.
Please note that Intelli Returns' practices are subject to applicable law, which may differ across jurisdictions. For purposes of this Privacy Notice, terms such as "we," "our," and "us" refer to Intelli Returns.
2. Personal Information Categories.
Intelli Returns collects Personal Information from a variety of sources and uses and discloses it for multiple purposes. This Personal Information falls into several broad categories, including contact information, user-generated content and social media account information, financial information, unique personal identifiers, geolocation data, and newsletter subscription data. The information below provides examples of the data types in each category and explains how Intelli Returns Processes such data.
2.1 Contact Information
2.1.1 Examples. Sample data elements include, without limitation, your name, postal address, email address, and telephone number.
2.1.2 Sources. Intelli Returns primarily collects this data directly from you when you fill out the "contact us" form on the Website or otherwise use the Services. Other sources may include, without limitation, public databases and any social media accounts you choose to connect to your Website account.
2.1.3 Uses. Intelli Returns may use this information to, among other things, enter into or perform a contract with you, respond to your inquiries, and enable you to send messages through the Services and submit reviews and other user-generated content.
2.1.4 Disclosure. Intelli Returns may share this information with service providers or as permitted by laws as described in Section 3 below.
User-Generated Content and Social Media Account Information
2.2.1 Examples. Sample data elements include, without limitation, reviews, testimonials, posts, or social media account information (such as profile data).
2.2.2 Sources. Intelli Returns collects this data from you when you use the Services. Other sources may include, without limitation, public databases, joint marketing partners, data firms, social media platforms, your social media connections, any social media account you choose to connect to your Website account, and other third parties.
2.2.3 Uses. Intelli Returns may use this information to facilitate social sharing functionalities of your social media account(s); enable you to send messages through the Services; send you newsletters or marketing communications that may be of interest to you; enable you to provide a testimonial or story or submit a review or comment; enable you to “like,” “follow,” or otherwise connect with or post to Social Media Pages.
2.2.4 Disclosure. Intelli Returns may share this information with service providers or as permitted by law as described in Section 3 below.
2.3 Financial Information
2.3.1 Examples. Sample data elements include, without limitation, credit or debit card numbers and bank account information.
2.3.2 Sources. Intelli Returns collects this data from you when you interact with Intelli Returns and use the Services. Other sources may include, without limitation, public databases, data firms, or other third parties.
2.3.3 Uses. Intelli Returns may use this data to enter into or perform a contract with you, allow you to make a payment for a product or service, and complete and fulfill any purchases or requests for services.
2.3.4 Disclosure. Intelli Returns may share this information with service providers or as permitted by law as described in Section 3 below.
2.4 Unique Personal Identifiers
2.4.1 Examples. Sample data elements include, without limitation, online identifiers, device identifiers, Internet protocol ("IP") addresses, accounts, membership names, and identification numbers.
2.4.2 Sources. Intelli Returns collects this data from you when you use the Services. Other sources may include, without limitation, public databases, joint marketing partners, data firms, or other third parties.
2.4.3 Uses. Intelli Returns may use this information to analyze usage of the Services, understand how you use the Services across the various devices you use, and recognize you across devices you use.
2.4.4 Disclosure. Intelli Returns may share this information with service providers or as permitted by law as described in Section 3 below.
2.5 Geolocation Data
2.5.1 Examples. Sample data elements include, without limitation, your postal address and precise geographic location information about a particular individual or device.
2.5.2 Sources. Intelli Returns collects this data when you use the Services.
2.5.3 Uses. Intelli Returns may use this information to analyze usage of the Services or ensure we are compliant in our presentation of content.
2.5.4 Disclosure. Intelli Returns may share this information with service providers or as permitted by law as described in Section 3 below.
2.6 Newsletter Subscription Data
2.6.1 Examples. Sample data elements include, without limitation, your email address, the IP address of the computer you use to subscribe, and the data and time of subscription.
2.6.2 Sources. Intelli Returns collects this data when you subscribe to the newsletter.
2.6.3 Uses. Intelli Returns will use subscription data only for the purpose of sending the newsletter.
2.6.4 Disclosure. Intelli Returns will not share subscription information with third parties.
2.7 Cookies. Intelli Returns uses cookies that install a small amount of information on your computer or other device to permit us to, for example, recognize future visits to the Website using the same computer or device. When you first access the website, you will receive a message advising you that cookies are in use. By continuing to browse the website, you agree to our use of cookies as described in this Privacy Notice. You do not have to accept cookies and can block them by activating the setting on your browser that allows you to refuse all or some cookies. You may also delete them after they have been placed on your hard drive. If you do not accept, or delete, cookies, some areas of the Website may take more time to work, or may not function properly. For more information about cookies, visit: http://www.allaboutcookies.org. We use strictly necessary cookies, analytical/performance cookies; functionality cookies; targeting cookies; and third-party cookies.
Cookies Used by Us
Google Analytics. We use Google Analytics to help us get a better understanding of how visitors use this Website. The information generated by the Google Analytics cookie about your use of this Website is transmitted to and stored by Google. If you do not want your activity on this Website to be tracked by Google Analytics, you may opt out by using this link: http://tools.google.com/dlpage/gaoptout?hl=en.
2.8 Pixels. The newsletter contains tracking pixels (miniature graphics) that enable us to see if and when you open the newsletter and which links in the newsletter you click on. We analyze this data to gauge the success of marketing campaigns and optimize the newsletter service, including adapting the newsletters to your interests. We will not share this data with third parties. You may withdraw your consent to our use of the tracking pixels at any time by contacting TeamIntelli@intellireturns.com
2.9 All Categories. Intelli Returns may also use data from any of the categories above in connection with data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing the Services, compliance with legal requirements or process, enforcement of terms and conditions related to the Services, protection of the Services, assessment of the effectiveness of promotional campaigns, and operating and expanding Intelli Returns business activities. Intelli Returns may share or disclose data from any category in response to requests from public and government authorities globally; to protect the rights, privacy, safety, or property of Intelli Returns; and to pursue available remedies or limit damages Intelli Returns may sustain.
3. Information Disclosure.
Intelli Returns may disclose your Personal Information to the entities and under the circumstances described below.
3.1 Service Providers: Intelli Returns may disclose your Personal Information to its service providers, including, but not limited to, those who provide information technology services and payment or credit card processing.
3.2 User-Generated Content: Intelli Returns may facilitate your submission of content to the Services. If content includes Personal Information, third parties over whom Intelli Returns has no control and for whom Intelli Returns has no responsibility may access it and use it in ways that are inconsistent with Intelli Returns' privacy practices.
3.3 Merger or Acquisition: Intelli Returns may disclose your Personal Information to a third party who acquires any part of its business or the business of any of its Affiliates, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of Intelli Returns' assets.
3.4 Disclosure Permitted by Law: Intelli Returns may disclose your Personal Information to entities with appropriate legal authority or justification for receipt of your data if required or permitted to do so by law or legal process; to respond to claims; or to protect its rights, interests, privacy, property, or safety and that of you or third parties.
4. Information Safeguards.
Intelli Returns has implemented reasonable and appropriate physical, technical, and administrative steps to help protect your personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is one hundred percent secure, thus Intelli Returns cannot ensure the security of all information you provide to us via the Services.
5. Other Important Information.
5.1 Website Links. The Services may link to sites Intelli Returns does not operate. Intelli Returns has no control over how sites operated by other entities collect your data or liability for their practices, policies, and security measures. You should read privacy notices on other sites before providing any data to them.
5.2 Privacy Notice Changes. Intelli Returns may update this Privacy Notice from time to time. Intelli Returns will make updated and date stamped versions of the Privacy Notice available on the Services. The revised notice will take effect upon posting, but any new provisions will only apply to data collected after the posting is effective. Should Intelli Returns need to materially change the way it Processes information it previously collected about you, it will only do so after notifying you and obtaining your express consent.
5.3 Minors. Intelli Returns does not knowingly process the information of children under sixteen years of age unless it verifies through reasonable efforts (based on available technology) that the minor's parent or guardian consents to such processing.
5.4 Data Transfers. Intelli Returns is an international company and may transfer your data to selected third parties outside your country where information protection standards may differ (e.g., your information may be stored on servers in other jurisdictions). Intelli Returns will use appropriate safeguards governing the transfer and usage of your Personal Information, such as an adequacy decision by the European Commission, Model Clauses, or other applicable mechanism.
5.5 Retention Period. Intelli Returns will retain your Personal Information for the period necessary to fulfill the purposes outlined herein unless a longer period is required or permitted by law, or required by legal process, such as a pending claim or litigation requiring preservation of relevant records.
5.6 Third-Party Links and Social Networking Services. The Services may include links to third-party websites, plug-ins, or applications (collectively, "Third-Party Websites"). Clicking on those links may enable third parties to collect data about you. We do not control Third-Party Websites and are not responsible for their privacy practices. We encourage you to read the privacy notice of every Third-Party Website you visit. Similarly, the Services may integrate with third-party social networking services. We do not control such services and are not liable for the manner in which they operate, including their privacy practices. Others may view and use information that you voluntarily post online to a publicly-accessible blog, social network, or other service. We are not responsible for such viewing or use.
5.7 Aggregated Data. Aggregated information is information that relates to a group or category of consumers from which individual consumer identities have been removed and that is not linked or reasonably linkable to any individual, including by device. It may be derived from Personal Information. We may aggregate information or obtain aggregated information from our customers and use it to develop and improve the Services. Subject to applicable laws and our contractual obligations, we may provide or sell aggregate information to third parties.
6. Rights Under the General Data Protection Regulation (GDPR).
Data subjects in theEuropean Union and the United Kingdom have the following rights:
6.1 Withdrawing Consent. If you have provided consent for Intelli Returns to Process your Personal Information, you may withdraw it at any time.
6.2 Access/Right to Know. You may access the Personal Information about you that Intelli Returns Processes. Any request to access or obtain copies of your Personal Information must be made in writing by contacting Intelli Returns as set forth below. Intelli Returns may, in certain jurisdictions, be entitled to charge a nominal fee to cover the administrative costs related to your request. Intelli Returns may also ask you to verify your identity and to provide further details relating to your request.
6.4 Correction. Intelli Returns will take reasonable steps to ensure the accuracy of Personal Information it retains about you. You are responsible for submitting accurate and complete information to Intelli Returns and timely updating Intelli Returns if it changes. You may contact Intelli Returns to request correction of any inaccurate or incomplete data.
6.5 Erasure/Deletion. You may contact Intelli Returns to request that deletion of your Personal Information. Intelli Returns will assess your request and determine whether it may delete the information if no exemption under law applies, or it is not otherwise subject to a longer legal requirement or as part of information required to be preserved due to a pending claim or litigation.
6.6 Objecting to or Restricting Processing. You may contact Intelli Returns to object to any Processing of your Personal Information or to request a restriction of Processing. Intelli Returns will assess your request and determine whether it has any legal or other justification for continued Processing.
6.7 Data Transfers. You may request to receive your Personal Information in a format that allows you to send it to another company or to direct Intelli Returns to transfer it directly to another company.
7. Exercising Your Rights.
We will respond to your request regarding the rights outlined in Section 6 without unnecessary delay, but in any event within one month of receiving the request. If your request is complex or we are responding to many requests, we may have two additional months to respond to your request. If we need the extended time, we will notify you within one month of receiving your request and inform you of the reason for the delay. If we cannot grant your request for some reason, we will let you know within one month and provide the reason why we cannot grant your request, along with information regarding your right to lodge a complaint with a supervisory authority and seeking a judicial remedy. Please note that we must process certain Personal Information in order to provide the Services, and if you do not allow us to process such Personal Information, we will not be able to provide the Services to you.
8. Contact Intelli Returns.
If you have a complaint or concern about how Intelli Returns Processes your Personal Information, Intelli Returns will work to address it. If you have any privacy-related questions or concerns, or would like to make any requests in relation to your Personal Information, please contact Intelli Returns by email (Intelli Returns at TeamIntelli@intellireturns.com).
California Supplemental Privacy Notice
If you are a California resident, Intelli Returns will process your Personal Information in accordance with the California Consumer Privacy Act ("CCPA").
Your Rights
Under the CCPA, you have the right to request disclosure of the categories of Personal Information Intelli Returns collects; the sources of the Personal Information Intelli Returns collects; the manner in which Intelli Returns uses the Personal Information it collects; the categories of Personal Information Intelli Returns shares with third parties for business purposes; the categories of Personal Information Intelli Returns sells to third parties; and the categories of third parties to whom your Personal Information is sold or disclosed. Disclosure of Personal Information to a third party for business purposes occurs when a business, such as Intelli Returns, discloses Personal Information to providers of auditing, security, payment processing, technology, and development services, among others. The sale of Personal Information occurs when a business provides access to or discloses Personal Information to a third party for monetary or other valuable consideration.
Under the CCPA, you also have the right to have Personal Information deleted (with exceptions) by us and our service providers; request that your information not be sold to third parties; not be discriminated against by, for example, being charged a higher rate for the Services, because you exercised any of the foregoing rights; and request a copy of the specific personal information we have collected about you in the twelve (12) months preceding your request up to two (2) times within a twelve (12)-month period.
Please note that we must Process certain Personal Information in order to provide the Services, and if you do not allow us to Process such Personal Information, we will not be able to provide the Services to you.
Categories of Personal Information
The CCPA identifies eleven (11) categories of Personal Information. These are: (1) identifiers (such as contact information, government identification numbers, cookies, etc.); (2) information protected against security breaches (such as financial account information, driver's license, social security number, username and password, and health/medical information); (3)
protected classification information (like race, gender, ethnicity, etc.); (4) commercial information (records of personal property or products or services purchased, obtained, or considered); (5) internet/electronic activity (such as browsing history, search history, or interaction with an internet website or application); (6) geolocation (precise geographic location information about a particular individual or device); (7) audio/video data (e.g., audio recordings, closed circuit television images, photographs, and thermal or olfactory information); (8) professional or employment-related information; (9) education information (information about education history or background that is not publicly-available, personally-identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99); (10) biometrics (physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity); and (11) inferences from the foregoing categories (inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
All data comes to us directly from your participating organization. This data can change from time to time. Please reach out to TeamIntelli@intellireturns.com for more information.
Notice Requirements
The CCPA requires that Intelli Returns tell you: which categories of Personal Information we collected in the twelve (12) months preceding the date of the Privacy Notice (in any format and from any source); the sources for each category of Personal Information we collected; all of our reasons for processing each category of Personal Information; the categories of Personal Information we sold in the twelve (12) months preceding the date of the Privacy Notice; and the categories of Personal Information we disclosed for a business purpose in the twelve (12) months preceding the date of the Privacy Notice.
The following table provides the required information:
Submitting Requests
You may submit requests by emailing TeamIntelli@intellireturns.com. Please provide your email address, first and last name, California residential address, and phone number. If this information does not match what Intelli Returns currently has on file, or if Intelli Returns is otherwise unable to verify your identity, Intelli Returns may request that you provide additional information for verification purposes. Intelli Returns will respond to verifiable requests received from California consumers within forty-five (45) days from receipt as required by law. Please note that we must process certain Personal Information in order to provide the Services, and if you do not allow us to process such Personal Information, we will not be able to provide the Services to you.
Opting Out
You may opt out of having your Personal Information sold to a third party by emailing TeamIntelli@intellireturns.com. If you ask that Intelli Returns does not sell your Personal Information, we will comply, but we will still share your Personal Information as needed for business purposes, such as completing your order.
Authorized Agent
Under the CCPA, you may designate an authorized agent (e.g., an attorney or family member) to make requests on your behalf. If you choose to designate an authorized agent, you must provide Intelli Returns with a written and signed authorization letter from you that includes your first and last name, California residential address, email, and phone number, as well as the full name, address information, and relationship to you of the agent you wish to authorize. Please send the agent authorization letter TeamIntelli@intellireturns.com. Intelli Returns will review all requests made by authorized agents, but may require additional details for verification purposes. Please note that for fraud prevention purposes, even when requests are made on your behalf by an authorized agent, Intelli Returns will send its response to the request to you, not the authorized agent.