INGREDIENT SAFE™ PRIVACY STATEMENT
This Ingredient SAFE™ Privacy Statement (“Privacy Statement”) describes the various ways that Ithos Global, Inc., their subsidiaries, other affiliated and/or related companies, as applicable (“Ithos Global” or “we” or “us” or “our”) process information about you that is collected by Ithos Global in the context of sales and marketing activities through Channels (as defined below) and explains how Ithos Global uses such information for its own business purposes.
Ithos Global respects the privacy of our users (“user” or “you”) that use our website located at ingredientsafe.com, including other media forms, media channels, mobile application related or connected thereto (collectively, the “Website”).
As used in this Privacy Statement, “Personal Data” means any data collected through our Channels that can be used to directly or indirectly identify an individual. The “Channels” are the various Ithos Global online, digital, electronic sites and technologies, such as public-facing sales and marketing websites, software applications, social media pages, chat features and online conversations, tele-prospecting or HTML-formatted e-mail messages we use to pursue our sales and marketing activities. In this Privacy Statement, “goods and services” includes access to Ithos Global’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings, events, conferences, webinars and seminars.
LINKS TO OTHER WEBSITES
This website may contain links to foreign (meaning non- Ithos Global companies) websites. Ithos Global is not responsible for the privacy practices or the content of such foreign websites. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.
COOKIES
A cookie is a file that is downloaded onto your device when you access certain webpages. Cookies allow the webpage, among other things, to store and retrieve information about the number of times you visit it, the browser habits of a user or computer and, depending on the information that it contains and the way in which the computer is used, cookies can be used for user recognition. Some of the goods and services offered by Ithos Global require cookies to be enabled on your browser.
USE BY CHILDREN
Ithos Global’s Channels are not directed to users under the age of 13. If you are younger than 13, you may not use our Channels. If you are a parent or guardian and believe we may have collected information about a child, please contact us at: in************@it*********.com
INFORMATION WE COLLECT
We collect your Personal Data. We collect such Personal Data about you directly, indirectly and/or automatically as described below. To the extent permitted by applicable law, we may combine the information collected about you, as described below, including information about the organization for which you work, with other information in our possession or information that you provide to us, and we treat all this information about you as Personal Data.
HOW WE COLLECT INFORMATION
Direct Collection
When you access, use and/or interact with us through a Channel, we directly collect information you voluntarily provide us:
- information about you in the context of your professional activities, such as your name, professional email address, telephone number and country of residence
- information about your company such as the name, size and location of your company, your role within the company and its type of activity
- business information, such as your products, formulas, materials, suppliers, raw material details, etc. that you enter as required for the fulfilment of services (“Product Data”)
- billing and transactional information when purchasing goods and services on the Channels
- billing details are not stored; see below “Information Storage”
- information you may choose to provide us when completing any “free text” boxes on our forms (if any at all, for example in surveys or questionnaires)
Examples of direct interactions with you through the Channels where you provide us business information and Personal Data about you include the following:
- completion and submission of online and other forms for events, webinars, webinars recordings, or asset downloads, or to request information about our goods and services and/or as part as joint marketing activities with our business partners
- completion of lead cards at events or other forms, whether in paper or electronic format, providing your business card, badge attendance scanning and other information you provide when you attend an Ithos Global hosted event or visit an Ithos Global booth at a trade show or industry or association event
- sales inquiries which you initiate, such as through online chat, dedicated online “contact-us” link and “request a quote” forms
- phone sales (if permissible under applicable law) and information you provide during phone calls with sales representatives
- subscription to marketing communications and/or submission of marketing preference
- completion of questionnaires and surveys
- participation in sweepstakes and contests
- other conversation data triggered by the above direct interactions, such as follow-up calls and emails, thank-you emails, confirmation emails and the like
- contacting customer support as part of a contractual or informational request
- contact information gathering as part of implementation services for our products
Indirect Collection
We also obtain business information and Personal Data about you from third party sources, as permitted by applicable law, such as the following:
- information collected by our marketing service providers on our behalf, which are a variety of marketing lead generation service providers, marketing opt-in lists or data aggregators or professional event organizers
- information shared with us by Ithos Global business partners as part of their referral activities, such as third-party partners of Ithos Global
- public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms
- information shared with us by the other entities of Ithos Global
- information shared with us by a third party who recommended you, once you have confirmed your agreement for us to keep and process such data (for the purpose of providing you with updates about Ithos Global’s goods and services).
When the data protection laws applicable in the EEA apply to you, in the instances listed above, we shall provide you with the information required by law within the prescribed time frame (including the name, legal form and address of the source of your Personal Data).
Automatic Collection
When you access, use and/or interact with us through a digital Channel, you do so using a “Device,” which is either a personal computer, desktop or laptop, or a mobile device such as a smartphone or a tablet. A “Device Identifier” is the number that is automatically assigned to the Device you use to access the digital Channel, and we may identify your Device through its Device Identifier. The “Tracking Technologies” are the various technologies we use to automatically collect Device Identifiers and other information about you, more precisely the following information:
- your computer’s operating system, Internet Protocol (IP) address (including information derived from your IP address such as your geographic location), Device Identifier, access times, browser type, device type, domain name, duration of visit, referring URL, platform, new and repeat information, time stamp and language, and referring website addresses
- behavioral data about your usage and activity on the electronic Channels, such as webpages clicked, websites and content areas visited, content downloaded, date and time of activities
- information about your use of social media features such as the Facebook “Like” button, LinkedIn, Twitter and others
- past transactional behavior on the Channels based on your prior interactions with us
- information obtained from third parties on your interests
The information collected through Tracking Technologies may be considered Personal Data under applicable data protection laws. For additional information about our use of Tracking Technologies, please contact in************@it*********.com.
HOW WE USE, SHARE, PROCESS INFORMATION
LEGAL BASIS FOR PROCESSING
We collect and process your Personal Data with your consent or as permitted under applicable data protection laws to provide the goods and services you use on the Channels, fulfill your inquiry, operate our business, meet our contractual and legal obligations, ensure compliance, protect the security of our systems and our customers, or fulfil other legitimate interests.
GIVEN PERSONAL DATA OR CONSENT
As a general principle, granting your consent and providing business information and Personal Data about you is entirely voluntary and there are no adverse consequences to you if you do not grant a consent when required under applicable law or do not provide the required information. However, there are circumstances where Ithos Global cannot take action without certain Personal Data because such information is required, such as to process your orders or provide you with access to a web offering or newsletter. In these cases, without the relevant Personal Data, Ithos Global will not be able to provide you with what you requested.
SUBMITTED PRODUCT DATA
Product Data is required to complete most services offered by Ithos Global and the successful completion of your requested work may be dependent on Product Data. Your submitted Product Data is securely transmitted to the Ithos Information Network (IIN) for processing and a completed report is sent directly to your account’s registered email address. This communication is completed over the Salesforce.com secure network; we encourage you to review their documentation (Salesforce.com Security, Privacy and Architecture) to learn more. See the below section “Information Storage” for details regarding the storage of your Product Data.
INFORMATION SHARING
With your consent (when legally required), we may share your contact information with exhibitors and sponsors/co-sponsors of events hosted by Ithos Global for their own marketing and promotional purposes. These entities may contact you directly; this Privacy Statement does not apply in those situations. Refer to those individual privacy policies to learn how they use personal information.
Some of Ithos Global’s goods and services involve third-party business partners. If you purchase, or specifically express interest in a joint-offered product, service, or promotion, we may share relevant Personal Data with those partners (as permitted by law). Ithos Global does not control our business partners’ use of such Personal Data. Our partners are responsible for managing their own use of Personal Data collected in this manner and we recommend you review the Privacy Policy of any relevant partner(s) to learn more about how they handle Personal Data. These joint services may also require the sharing of Your Product Data. All Product Data shared with third-party recipients to carry out joint services is confidential and bound to the terms of Ithos Global’s non-disclosure and confidentiality agreement.
INFORMATION STORAGE
We store your Personal Data for as long as necessary to fulfill the purposes described in this statement, such as to provide goods and services requested by you, respond to inquiries, or for other essential purposes, or until you object to our use of your Personal Data. Some circumstances require us to retain your Personal Data longer, such as for tax and accounting purposes, or where we need your Personal Data to defend or support legal claims, we will retain your Personal Data until the end of the relevant period, or resolution of such claims.
Product Data is temporarily stored during order processing. When an order has completed as “successful”, the relevant Product Data is purged from the processing server. It is important to retain your report results as these are the master copy. We do not keep Product Data stored at this time.
Billing Data is not stored directly on Ingredient SAFE; any saved information is stored securely through our third-party payment processor Stripe. To learn more on how their data security and privacy practices, please review their Stripe Legal documentation.
MARKETING COMMUNICATION
Ithos Global may contact the email used to register your account for various purposes.
You can unsubscribe from promotional emails by:
- Following the unsubscribe instructions at the bottom of our emails
- Emailing in************@it*********.com
Please note that opting out of marketing communication will not prevent any contact from us regarding your transactional information to goods and services you have ordered or requested.
SECURITY AND DATA SAFETY
Our Website is hosted in the United States of America and is subject to U.S. State and Federal Law. Ithos Global has implemented a number of measures to ensure your information is secure and reduce the risk of unauthorized access, use, disclosure and destruction of your information. Ithos Global shall not be held liable by any third-party, including you, in any event of unauthorized access, use and/or disclosure of information, provided that such is not due to Gross Negligence, wilful misconduct, fraud or bad faith by Ithos Global. Ithos Global reviews its methods of information collection regularly and will update this Privacy Statement accordingly.
Our third-party data processors include:
- Hosting & data processing via Salesforce.com
- Refer to Salesforce.com Security, Privacy and Architecture for more about sales data processing.
- Refer to Salesforce.com Trust and Compliance to review the Salesforce Services Trust and Compliance Documentation.
- Payment Processing via Stripe
- Refer to Stripe Legal for more about payment processing
IMPORTANT NOTICES
Your confidential product information will never be shared outside the scope of our team. Occasionally our team will include third-parties who are obligated to adhere to the Ithos Global privacy methods and procedures described in this statement.
CHANGES TO THIS PRIVACY STATEMENT
Ithos Global will update this Privacy Statement from time to time without notice to you other than posting the revised Privacy Statement on the Channels or by providing such notice about or obtaining consent to changes as may be required by applicable law. When we update our Privacy Statement, we will post the most current version to this Privacy Statement and change the “last updated” at the end. We encourage you to regularly review this Privacy Statement for the latest information on our privacy practices.
QUESTIONS
If you have any questions about this Privacy Statement or would like to file a complaint, please contact us at the following:
Ithos Global, Inc.
ATTN: Team Ingredient SAFE
333 Broadway, Suite 440
Troy, NY 12180 USA
Telephone: +1 (518) 620-0320
Last updated July 2020