What this policy covers
informed360 offers online tools and other related services for managing ethics and compliance programs. We also own and operate a website and offer other ethics and compliance related information and services such as webinars and informational white papers. We refer to all of these products, together with our other services and websites as “Services” in this policy.
When we refer to “informed360,” “we,” or “us” in this policy, we mean informed360 LLC, which controls the information informed360 collects when you use the Services.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you access our Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when we activate your account or you are invited to create or modify your account, set preferences, and sign-up for the Services. For example, you provide your email address and contact information when you register as an authorized user of the Services. You also have the option of adding a profile photo, job title, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
Content you provide through our products: The Services include the informed360 platform you access, where we collect and store content that you create, post, send, receive and share. This content includes any information about you that you may choose to include. Content also includes the files and links you upload to the Services. Examples of content we collect and store include: risk assessment survey results, conflict of interest disclosure information, details and content in any external record or action plan, members of a compliance committee or committee agendas, or comments you enter into a risk assessment survey, disclosure, action plan or otherinformed360 module.
Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which generally includes name, email address, company affiliation and phone number. For example, you may provide us with your name and email address in order to download a white paper from our website or to contact us for more information on our Services.
Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with our Services. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you subscribe and license certain paid Services. For example, we ask you to designate a billing representative and system administrator, including name and contact information, upon registration. You might also provide payment information, such as purchase order or payment record details.
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use in risk assessments, disclosures, action plans, compliance committees, external records; and other modules; the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services. We also collect information about the teams and people you create and work with and how you interact with them, like who you collaborate with and communicate with most frequently. As a benefit to our customers, many of our Services contain “comment” and “audit trail” capabilities which allow users to communicate with each other and to view activity and changes within a record. For example, a user can post comments to a disclosure or action plan. A user may also view updates to an action plan status or when certain information has been changed or deleted.
Device and Connection Information: We may collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We may use your IP address and/or country preference in order to determine your time zone or approximate your location to provide you with a better Service experience. How much of this information we collect depends on the Services you have purchased, the type of authorized user you are, and the settings of the device you use to access the Services.
Information we receive from other sources
We receive information about you from other authorized users, from third party providers, and from our business and channel partners.
Authorized users of the Services: Other authorized users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by someone else on a disclosure or an action plan. We also receive your email address from other Service users and system administrators when they provide it in order to invite you to the Services. Similarly, an authorized user may provide your contact information when they designate you as an owner of an action plan or mention you on a disclosure.
informed360 partners: We work with a global network of partners who provide software development services, hosting, and other services around our products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as sales leads, billing information, billing and technical contact information, company name, what products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.
Other partners: We may receive information about you and your activities on and off the Services from third-party partners, such as conference and event organizers, and advertising and market research partners who provide us with information about your interest in, and engagement with, our Services and online advertisements.
How we use information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any information you or your system administrator have authorized us to collect on your behalf. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the name and picture you provide in your account to identify you to other Service users. Our Services also include tailored features that personalize your experience, enhance your productivity, and improve your ability to collaborate effectively with others by automatically analyzing the activities of your team to provide search results, activity feeds, notifications, connections and recommendations that are most relevant for you and your team.
For research and development: We are always looking for ways to make our Services smarter, faster, more secure, more integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. For example, we use information collected about how users approve disclosures to design a better, more user-friendly disclosure tool. In some cases, we apply these learnings across theinformed360 Services to improve and develop similar features or to better integrate the services you use. We also test and analyze certain new features with some Customers before rolling the feature out to all Customers.
To communicate with you about the Services: We use your contact information to send transactional communications via email within and outside of the Services, including confirming your use of the Services, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. Depending on your settings, we send you email notifications when you or others interact on the Services, for example, when you are @mentioned on a disclosure or action plan or when you are added to a compliance committee.
To market, promote, and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offerings and promotions. You can control whether you receive these communications as described below under “Opt-out of communications.”
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you or your system administrator give us permission to do so, we share your information with our third-party software development vendor for the purpose of responding to support-related requests. Please be aware the software development vendor and cloud provider are not employees of or directly affiliated with informed360.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you or your system administrator have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where:
- we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- it satisfies a contractual requirement (which is not overridden by your data protection interests) between your employer and informed360.
- it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- you or your system administrator give us consent to do so for a specific purpose; or
- we need to process your data to comply with a legal obligation.
If you or your system administrator have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we, your employer or other third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
How we share information we collect
We make information tracking and collaboration tools for ethics and compliance programs, and we want them to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discuss below, including in connection with possible business transfers, but we do not sell information about you to advertisers or other third parties.
Sharing with other Service users
When you use the Services, we share certain information about you with other authorized users.
For collaboration: You can create content, which may contain information about you or your employer, and grant permission to others to see, share, edit, copy and download that content based on settings you or your system administrator (if applicable) select. Some of the collaboration features of the Services display some or all of your profile information to other authorized users when you share or interact with specific content. For example, when you comment on a disclosure or an action plan, we display your profile picture and name next to your comments so that other users with access to the record understand who made the comment. Similarly, when you join a compliance committee, your name, profile picture and contact information and will be displayed in a list for other team members so they can find and interact with you.
Managed accounts and system administrators: If you register or access the Services using an email address with a domain that is owned by your employer, certain information about you including your name, profile picture, contact info, content, and account use may become accessible to your employer’s system administrator and other authorized users, as permitted by your system administrator. If you are the system administrator of an enterprise or business account within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
Community Forums: Not currently applicable.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
Service providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
Informed360 partners: We work with third parties who provide consulting, sales, support and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with contract negotiations, billing and collections, or to provide localized support. We may also share information with these third parties where you or your system administrator have agreed to that sharing, like when you agree to us sharing your information with our third-party software development team for support-related questions.
Links to Third-Party sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
With your consent: We share information about you with third parties when you or your system administrator give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforceour agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Informed360, our Customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Sharing with affiliated companies
Software Development Partners: We share information we have about you with our third-party software development partner in order to operate and improve products and services and to offer other services to you.
How we store and secure information we collect
Information storage and security
We use data hosting service providers in the European Union to host the information we collect, and we use reasonable technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How long we keep information
How long we keep information we collect about you depends on the terms and conditions of the agreement in place between your employer and informed360. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information until you or your employer delete your account or terminate the subscription to our Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to aggregate, anonymize and/or eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other authorized users to make full use of the Services. For example, we continue to display comments and content you provided in any disclosure or action plan.
Managed accounts: If the Services are made available to you through your employer, we retain your information as long as required by the system administrator of your account or the agreement between us and your employer.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. Where the Services are administered for you by your employer (see “Notice to End Users” below), you will need to contact your system administrator to assist with your requests. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: For example, if fulfilling your request would reveal information about another person, or if you ask us to delete information which we or your system administrator are permitted by law or have a contractual or compelling legitimate interest to keep. Where you or your system administrator have asked us to share data with third parties, for example, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted.
Access and update your information: Our Services and related documentation give you or your system administrator the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate your access to informed360: Only your system administrator can deactivate your access to informed360 or to an informed360 module. If you would like to deactivate your own access, please contact your system administrator. If you are a system administrator and are unable to deactivate an account through your system settings, please contact informed360 for support. Please be aware that deactivating access to a module does not necessarily delete your information from that module; your information remains visible to other authorized users based on your past participation within the Services and your employer’s requirements.
Delete your information: Our Services and related documentation give you or your system administrator the ability to delete certain information about you from within the Service. For example, you can remove content that contains information about you using the key word search and editing tools associated with that content and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal or contractual obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you or your system administrator gave us consent to use your information for a limited purpose, you can contact your system administrator or us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request with your system administrator. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your system administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your system administrator to do so.
Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us or your system administrator as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
Send “Do Not Track” Signals: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you or your system administrator with an electronic file of your basic account information and the information you create on the spaces under your sole control.
How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in the European Union. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.
International transfers: To facilitate our global operations, we transfer information to the European Union and allow access to that information from countries in which informed360 and has operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area and Switzerland. Please see our Privacy Shield notice below for more information or contact us as provided below.
Privacy Shield Notice
Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
To learn more about the Privacy Shield Program, and to view our certification, please visit our public Privacy Shield listing.
We encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS (www.jamsadr.com), our U.S.-based third-party dispute resolution provider (free of charge).
Under certain conditions, more fully described on the Privacy Shield website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Other important privacy information
Notice to End Users
Our products are intended for use by licensed subscribers and authorized users only. Where the Services are made available to you through your employer, your employer is the system administrator of the Services and is responsible for the end-users and/or Service modules over which it has control. If this is the case, please direct your data privacy questions to your system administrator, as your use of the Services is subject to your employer’s policies. We are not responsible for the privacy or security practices of your employer, which may be different than this policy.
System administrators are able to restrict your access to and privileges within the platform. In some cases, system administrators can also:
require you to reset your account password;
restrict, suspend or terminate your access to the Services or your account;
control your ability to edit, restrict, modify or delete account information;
change your account information, including profile information or the email address
associated with your account;
access information in and about your account;
access or retain information stored as part of your account; and
enable or disable third-party apps or other integrations.
Please contact your organization or refer to your system administrator’s organizational policies for more information.
Our policy towards children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
Your information is controlled by informed360 LLC. If you have questions or concerns about how your information is handled, please direct your inquiry first to your system administrator then to informed360 LLC, as set forth below or, if you are a resident of the European Economic Area, please contact our EU Representative directly:
2413 E. Shorewood Boulevard
Milwaukee, Wisconsin 53211