•What data we collect, and why we collect it
•How we use that data
•How we protect that data
•How you can control your data, including accessing, updating and deleting what we store
•How we share data collected
Data We Collect & Share
IRI may collect or record basic personal data of its direct customers (e.g., name, e-mail address, mailing address, phone number) which you voluntarily provide through forms on our Site, through social media, subscription to our email alerts, electronic mail you send to us, or through other means of communication between you and IRI.
IRI only collects personal data of a more sensitive nature (e.g. social security or other governmental ID numbers, credit card details and account numbers) where it is appropriate or necessary for conducting business. This data will be collected, stored, accessed and processed in a secure manner. IRI may also collect general non-personal data pertaining to users of our sites, including IP addresses, source domain names, specific web pages, length of time spent, and pages accessed. This data is collected, among other things, to aggregate statistical data, facilitate system administration and improve the Site.
IRI also collects, uses, and discloses identifiable data about individual contacts for IRI’s customers (“Business Contact Data”) in the ordinary course of its business for managing and maintaining customer relationships. In particular, IRI may obtain the following types of Business Contact data: name, address, invoice data including bank account data, and order data. Unless otherwise specified or prohibited, IRI may share data with affiliates, business partners, service providers, subsidiaries or contractors who are required to provide you with services which you have requested from us.
IRI may also post links to third party websites as a service to you. These third-party websites are operated by companies that are outside of our control, and your activities at those third-party websites will be governed by the policies and practices of those third parties. We encourage you to review the privacy policies of these third parties which you contact directly before disclosing any data, as we are not responsible for the privacy policies of those websites.
Purpose of Data Collection:
INK ROUTER INC. (“IRI,” “we”, and ”our”) operates as a data processor for our business customers, also referred to as “Resellers”, located in the US, EU and other geographic locations worldwide. IRI’s business customers remain the data controllers with respect to any Customer data that they provide to IRI for our provision of goods and/or services. IRI therefore acts in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of Customer data, as well as other matters such as the provision of access to and rectification of this Customer data. IRI may obtain in the US the following types of EU and Swiss Business Contact Information: name, address, invoice information and order information. IRI uses EU and Swiss Business Contact Information for the following purposes: managing customer relationships, managing orders, tracking payments and ensuring payment, and otherwise maintaining the customer relationship.
How We Use data
IRI uses the data we collect to provide you with services which you request and to improve our existing services and the content of our Site. When you contact IRI, we may keep a record of your communication to help solve any issues that you might be facing. Depending on the country in which you live, work or access our Site(s), your data may be retained for a reasonable time for use in future contact with you, or for future improvements to IRI services.
IRI may also use or disclose your personal data when IRI believes, in good faith, that such use or disclosure is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements, or (iii) protect the rights, property or safety of IRI, IRI users, or others. IRI reserves the right to transfer and disclose your data if IRI becomes involved in a business divestiture, change of control, sale, merger, or acquisition of all or a part of its business.
Cookies are a technology that can be used to help personalize your use of a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it or decline at any time. To enable IRI to access the effectiveness and usefulness of this Site, and to give you the best user experience, we collect and store data on pages viewed by you, your domain names and similar data. Our Site makes use of anonymous cookies for the purposes of:
•Completion and support of Site activity;
•Site and system administration;
•Research and development;
•Anonymous user analysis, user profiling, and decision-making.
The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it.
IRI uses reasonable measures to safeguard personally identifiable data, which measures are appropriate to the type of data maintained and follows applicable laws regarding safeguarding any such data under our control. In addition, in some areas of our sites, IRI may use encryption technology to enhance data privacy and help prevent loss, misuse, or alteration of the data under IRI’s control. IRI also employs industry-standard measures and processes for detecting and responding to inappropriate attempts to breach our systems.
No method of transmission over the Internet, or method of electronic storage, can be 100% secure. Therefore, IRI cannot guarantee the absolute security of your data. The Internet by its nature is a public forum, and IRI encourages you to use caution when disclosing data online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third party access, and for selecting passwords that are secure.
Monitoring and Enforcement
Privacy Shield (European Union and Switzerland))
IRI may obtain in the US the following types of EU and Swiss information from its subscribing customers: name, address, invoice information including bank account information, and order information (“EU and Swiss Business Contact Information”). IRI uses EU and Swiss Business Contact Information for the following purposes: managing customer relationships, managing orders, tracking payments and ensuring payment, and otherwise maintaining the customer relationship. IRI may disclose EU and Swiss Business Contact Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above. IRI does not solicit information from its customer’s customers and only receives such information as an onward transfer from IRI’s customers for the purpose of order fulfillment as requested by its customers. IRI does not market or remarket to its customers’ customers and any personal information received is stored or onward transferred only for that purpose.
In situations where IRI discloses (i.e. onward transfers) EU and Swiss Business Contact Information to any third parties acting as service providers or “agents” on behalf of IRI, IRI will require the recipient to protect the disclosed EU and Swiss Business Contact Information in accordance with the relevant Privacy Shield Principles, or otherwise take steps to ensure that the EU and Swiss Business Contact Information is appropriately protected. With respect to any sharing of EU and Swiss Business Contact Information for the purposes of marketing IRI products and services, IRI obtains guarantees from its affiliates, subsidiaries and business partners that such entities will use and disclose such EU and Swiss Business Contact Information for purposes of marketing IRI products and services only. In cases of onward transfer of EU or Swiss Business Information to third parties pursuant to Privacy Shield, IRI is potentially liable in the event of an improper disclosure. In certain situations, individuals may seek to opt-out of disclosures of their EU and Swiss Business Contact Information by contacting IRI as specified in the “Contacting IRI” section below.
IRI takes appropriate technical and organizational measures to safeguard EU and Swiss personal data against unauthorized or unlawful processing of, or accidental loss, damage, misuse, unauthorized access, unauthorized disclosure, unauthorized alteration, or destruction, and maintains reasonable procedures to help ensure that such information is relevant for its intended use, accurate, complete, current and not excessive and that such information is not retained longer than is reasonably necessary.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, IRI is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, IRI may disclose EU and Swiss personal data as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where IRI believes that such disclosures are appropriate in connection with a law enforcement request or as otherwise permitted by the Privacy Shield Principles, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or in order to comply with, enforce or apply IRI agreements.
In compliance with the Privacy Shield Principles, IRI commits to resolve complaints about our collection or use of your personal data at no cost to the individual. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact INK ROUTER INC. Privacy Shield point of contact – DataPrivacyCompliance@INKROUTER.com. IRI will respond to your inquiry within 45 days.
In the event of a reported complaint that IRI does not resolve itself, INK ROUTER INC. has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Data Processor Activities
IRI operates as a data processor for our business customers located in the US, EU and other geographic locations worldwide. IRI’s business customers remain the data controllers with respect to any Customer data that they provide to IRI for our provision of services. IRI therefore acts in accordance with the instructions of such customers regarding the collection, processing, storage, deletion and transfer of Customer data, as well as other matters such as the provision of access to and rectification of this Customer data.
Children’s Online Privacy Protection – COPPA
IRI does not sell its services to children. As such, our Sites are designed for adult user interaction. We do not intentionally collect personally identifiable data from children under the age of 13.
Accessing and Updating Your Personal Data
If you have provided IRI with your personal data you have various rights:
•If you are a data subject based in the EU (and to the extent that Article 3(2) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applies to you) and where we control your data you have the right:
◦ (in certain circumstances) to erasure of personal data (and to therefore be forgotten);
◦ to data portability;
◦ to launch a complaint with the office of the Information Commissioner;
◦ to inspect the data stored by IRI for accuracy;
◦ to have the option to opt-out or opt-in for further communications from IRI
◦ via Subject Access Request, to know whether or not we are processing your personal data, the nature of that personal data and the purposes of the processing.
• Where the above does not apply to you, you may have the right to inspect the data stored by us for accuracy or may request that the data be removed from our files. IRI will make a reasonable effort to comply with such requests except where it would require a disproportionate effort (for example developing a new system or changing an existing practice). We may require that you verify your identity before we act on a request to edit or remove your data. Please direct any questions about your data to IRI by sending on inquiry to the appropriate contact in the “Contacting IRI” section below.
Paul Barnum, Data Privacy Compliance Officer
Brett Heap, CEO