Last updated January 1, 2020
Taking care, offering respect
As a digital marketing agency, Identyo (“we,” “us,” etc.) understands that ensuring you are getting the most out of your marketing initiatives is a key component of a successful business. We work with our business customers to do just that through the variety of services we offer. We also understand that in order to provide this insight, we must access personal information and that this information needs to be collected, protected, shared, and used appropriately.
This applies whether you are visiting our site, or when we are working for our business customers designing a website, optimizing search engine results, analyzing site traffic, providing marketing content, or working with one of our business partners to ensure delivery of these services to their customer. Because your personal information is valuable, we want you to be confident that we are handling it with care and respect. We also want to give you the necessary tools and options to manage and protect that information. This Privacy Notice is part of our effort to achieve those goals.
This Notice applies to our Websites (https://www.identyo.com, https://sherpath.com, https://localauthority.ai) and any sites or products that display these terms. It does not apply to any website, mobile app, service, or product that does not display or link to this Privacy Notice or that contains its own privacy notice. If you do not agree with our policies and practices, please do not use our services. By accessing the Website or using our services, you agree to this Notice.
How we collect personal information
We may collect personal information from you directly or indirectly. When you fill out a form on our Website, for example, you provide personal information directly to us.
Other times, personal information is collected automatically as you use our Website. And in some instances, third parties with whom we work provide personal information to us.
We collect personal information when you provide it
You may provide certain kinds of personal information directly by interacting with Identyo online and offline (via social media or Web forms, by phone, email, in person – or even through regular old postal mail).
When you register for an account with us, you will provide personal information that includes your name, email address, mailing address, and your phone number. You will create a username and password, information that on subsequent visits helps us confirm your identity and makes it easier to use our services.
We collect personal information from third-party sources
We may collect personal information about you from third parties, such as our business customers and trusted business partners, for purposes of research, targeting likely consumers, and fine-tuning marketing campaigns.
We work with third-party sources who provide non-identifying data based on personal email addresses. That data is used to expand and refine our clients’ marketing efforts. Other times, we provide that non-identifying data to our customers. We work with data analytics companies to gain insights and marketing strategies that focus our marketing efforts on people most likely to be interested in them.
We also use third-party payment processing services (Identyo does not process payment card information directly). The personal information those payment processors receive includes name, email address, mailing address, billing address, phone number, and payment card information. Your orders are deemed your consent to share this information.
We also may collect personal information from online social networks if you use them to connect with Identyo, or if you take part in a forum, for example, on Facebook. We may collect personal information when you click “Share This” or “Like” buttons or otherwise use social media buttons or plug-ins.
We use targeted advertising
We will not knowingly collect information from individuals under 16 years old
All products and services we offer are for individuals 16 or older. If we become aware that personal information of anyone younger than 16 has been provided to us, for any purpose and without parental consent, we will delete the information from our files.
Some browsers offer a “Do Not Track” privacy preference. Generally, when a user turns on the Do Not Track Signal, their browser sends a message to websites requesting that the user not be tracked. Our Website currently does not respond to “Do Not Track” signals.
How we use personal information
We know your personal information is important to you, so we want to be as transparent as possible while explaining how we use that information.
As mentioned above, those logging in through the internet will register by providing their names and email addresses to create profiles that include user IDs and passwords. Collecting this information allows easier, quicker access to our Website, products, and services on subsequent visits. As users navigate through the Website, their movements will be tracked and analyzed. Doing so allows us to make our products better and their experiences easier. We also use personal information:
● To send marketing communications, typically through email.
● To communicate with customers about their orders.
● To respond to support requests.
● To provide access to and maintain the security and integrity of the Website.
● To provide updates regarding the Website and marketing information, such as special promotions or surveys, etc.
● To comply with legal and regulatory requirements applicable to our business and internal policies for maintaining records.
● To protect all parties in the event of disputes.
● For any other legal, business, or marketing purposes that comply with the practices described in this Notice.
When we share personal information
We don’t share your personal information.
Our vendors help with analytics, too
We use Google Analytics, Facebook Insights, and other tools to study how users interact with our Websites and keep it up and running.
If you make a public post, other users may see it
If you make a post on a third-party social media site, such as on Facebook, or by identifying us in your social media feed by tagging us using a hashtag (#) or “at” (@), your personal information may be publicly available and is subject to the privacy policies of those third-party social media sites. As a reminder, this Notice describes how we will treat your personal information once it is in our possession.
We recommend you review the privacy policies of any third-party sites you visit to understand the data collection and use practices of that third party.
We may share feedback you provide to us
We want to hear how we’re doing. If you have suggestions for improving our services, we want those as well. Please be aware that any feedback relating to our services on our Website or successful operations with current clients may be publicly shared.
Eventual successors may access information
In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, any user information owned or controlled by us may be among the assets transferred to third parties as successors in interest. As part of this type of transaction, we reserve the right to transfer or assign your personal information to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Notice.
We need to comply with legal requirements
We may disclose your information to government authorities or other third parties if any lawful circumstances arise, including when:
● You have given us permission to share your information;
● We are required to do so by law, or in response to a subpoena or court order;
● We believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, or to protect our property or other rights or those of other users of the Website, third parties, or the public at large; or
How we secure personal information
We have implemented industry-accepted administrative, physical, and technology-based security measures to protect against loss, misuse, unauthorized access, and alteration of personal information in our systems. We ensure that any employee, contractor, corporation, organization, or vendor who has access to personal information in our systems is subject to legal and professional obligations to safeguard that personal information.
While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.
Questions or concerns about security or privacy protocols.
If you have received unwanted or unsolicited e-mail from us or by someone purporting to be sent by us, please forward a copy of that e-mail with your comments to firstname.lastname@example.org for our review. If you feel that any of our privacy practices or security standards detailed in this Privacy Notice have been violated, you may contact us (see Contact Us at the end of this Notice for additional detail).
We understand that you want to protect and control your personal information. This section details how you may review, update, correct, or delete your information.
Viewing or updating your personal information
You may update your name, contact information, email preferences, and physical address by accessing your account on the Website.
Deactivating your account
You may deactivate your account any time after you create it. To deactivate your account, please send an email to email@example.com with “Deactivate Account” in the subject line. Upon receiving your request, Identyo will deactivate your account and delete personal information where allowed or required by applicable law.
Opting out of promotional emails
If you do not wish to receive promotional e-mails from us, you may follow the unsubscribe process at the bottom of the promotional e-mail you received or by emailing us at firstname.lastname@example.org. Please keep in mind that you still may receive transactional e-mails from us (such as e-mails related to the completion of your registration or purchase, correction of user data, password reset requests, reminder e-mails you have requested, and other similar communications) that may be necessary for us to make the Website available to you or respond to your inquiries and support requests.
European Economic Area, Switzerland, or United Kingdom
Individuals from the European Union, including the United Kingdom and Switzerland, have certain rights associated with their personal information based on applicable law.
Identyo is headquartered in the United States. Your personal information, whether received by us through our Website, or provided to us by our business customer, will be transferred to, processed, and maintained on computer systems located in the United States.
The United States currently is not a country the European Union has deemed “adequate” under applicable data protection laws. Identyo collects, transfers, and processes personal information under terms required by applicable law, including: when you provide your consent, to perform a contract with you (such as to deliver products or services), or to fulfill a compelling legitimate interest of Identyo in a manner that does not outweigh your rights and freedoms. Identyo may enter into data protection agreements or other legally approved mechanisms with its vendors to support compliance with applicable law.
We have taken appropriate safeguards to require that the personal information we process will remain protected in accordance with this Notice when transferred internationally, including when processed internationally by third-party service providers and partners. The safeguards we have taken include implementing the European Commission’s Standard Contractual Clauses, relying on a third-party service provider’s EU-U.S. or EU-Swiss Privacy Shield certification or Binding Corporate Rules, for any transfer of personal information to non-EEA third-party service providers or business partners.
Your data protection rights
In addition to any of the general rights granted to you under this Privacy Notice, you have the following data protection rights:
● You can request access to, correction of, updates to, or request deletion of your personal information.
● You can object to the processing of your personal information, ask us to restrict the processing, or request portability of your personal information.
● You have the right to opt-out of marketing communications we send at any time. You can opt-out by clicking on the “unsubscribe” or “opt-out” link in any of the marketing emails we send you.
● When we have collected and processed your personal information based upon your consent, then you can withdraw your consent at any time.
● However, withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect processing of your personal information where we have relied on other legal grounds for the processing.
● You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
To make a request, please contact us at email@example.com with “Personal Information Request” in the subject line. Provide full details relating to your request, including your contact information and any other details you believe are relevant. We are committed to responding to requests to exercise data protection rights in accordance with applicable data protection laws.
California Consumer Rights
As of January 1, 2020, the California Consumer Privacy Act provides specific rights to those who live in the state of California. If you are a California-based consumer, as that term is defined under California law, this section shall apply in addition to all other applicable rights and information contained in this Notice:
● You have the right to request that we provide you with information about what personal information we collect, use, and disclose.
● You have the right to request that we delete personal information we, or our service providers, store about you.
● We will not discriminate or retaliate against you if you elect to exercise any rights under this section of our Privacy Notice.
● You may request that we not sell your personal information. We do not sell, rent, lease, or trade your personal information with third parties, except as described in this Notice.
● You have the right to designate an authorized agent to make a request on your behalf. Please see the Identity Verification Requirement below for information on our process for verifying we have received a legally valid request.
If you are a California consumer and have additional questions based on this section of our Privacy Notice, email us at firstname.lastname@example.org or call us toll-free at (877) 385-4798. Be sure to check this Notice for updates, as we will review it at least every 12 months and make necessary changes.
Identity verification requirement
The law requires us to verify that any request submitted was made by someone with the legal right to access the information. Therefore, before accessing or divulging any information pursuant to a data subject access request, we may request that you provide us with additional information so we can verify your identity and legal authority.
To make a request, please contact us at email@example.com with “Personal Information Request” in the subject line and provide full details about your request, including your contact information and anything you believe is relevant. We will provide a response to an access request within the timeframes required by law. If we cannot substantively respond in a timely manner, we will notify you and provide the reason for the delay.
Under certain circumstances, we may not fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, when we cannot verify your identity, if your request involves disproportionate cost or effort, or where the law allows us to retain that information. But we will respond to your request within a reasonable time, as required by law, and provide an explanation.
This Privacy Notice will be updated to reflect our personal information handling practices. We reserve the right to amend this Notice at any time, for any reason, without additional notice to you, other than through posting the updated Privacy Notice on our Website. We invite you to return to this page to ensure you are informed of any updates we make about how we collect, use, and protect customer information. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the beginning of this Notice.
If you have questions about the way we handle personal information, please contact us:
450 SW Powerhouse Drive, Suite 429
Bend, OR 97702