Last Updated: July 21, 2020
WE ARE NOT HEALTH CARE PROVIDERS. WE DO NOT COLLECT HEALTH CARE NOR MEDICAL INFORMATION. PLEASE CONSULT YOUR HEALTH CARE PROVIDER BEFORE MAKING ANY HEALTHCARE DECISIONS OR FOR GUIDANCE ABOUT A SPECIFIC MEDICAL CONDITION. BY ACCESSING OR USING OUR WEB BROWSER, YOU AGREE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE POLICIES AND TERMS. IF YOU DO NOT AGREE, YOU MAY NOT USE OUR SERVICES.
CMIA Compliance. CMIA establishes standards to protect Medical Information of the individuals that use the Service. We do not collect Medical Information.
HIPAA Compliance. The HIPAA Privacy Rule establishes standards to protect users of the Service individuals’ medical records and other personal health information. We do not collect information regarding the personal health of individuals. Users however may provide Mental Health providers with protected health information or “PHI,” as defined by the Health Insurance Portability and Accountability Act (HIPAA). This is any individually identifiable health information that a healthcare provider or another “business associate” to your healthcare provider receives about you. Any Medical information entered into InnerPal Services is not collected.
Changes. We may amend this privacy notice at any time by posting the amended version on this site including the effective date of the amended version.
Information We Collect & How We Process Data
We are a data Processor and Collector. We process data received from our services and take proportionate precaution in storing such information for short periods on our secure servers until permanently destroyed. Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. Our service collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Platform has collected the following categories of personal information from its consumers within the last twelve (12) months:
- Category A: Identifiers
- Examples: A real name Information, Internet Protocol address, email address, or other similar identifiers, device information.
- Collected: YES
- Category B: Personal information categories.
- Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Collected: YES
- Category C: Protected classification characteristics under applicable laws.
- Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Collected: YES
We obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our Platform.
- Indirectly from you. For example, from observing your actions on our Platform or interactions with our advertisers.
Categories of Personal Information We Collect
Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Company Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively, “Identification Activities”), we will ask you to provide certain information about yourself. We also collect the following:
- Identity Data
- Contact Data
- Technical Data
- Usage Data
- Transaction Data
- Financial Data
- Assessment Data
- Profile Data
- Marketing and Communications Data
Non-Personally Identifiable Information
Personal information collected from Third Parties. We supplement the personal information we collect directly with information collected from third parties and add it to your account information. For example, we collect and use demographic and other information that is publically available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws
- We allow you to share information with social media sites, or use social media sites to create your account or to connect your account with the respective social media site. Those social media sites may give us automatic access to certain personal information retained by them about you (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). If you provide us with access to any site with video content, then you agree that we can share your video viewing with, or obtain information about your video viewing from, third-party social media sites for at least two years or until you withdraw authorization or connection to the social media site.
- You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to the personal information retained by the respective social media site about you. By associating an account managed by a social media site with your account and authorizing us to have access to this information, you agree that we can collect, use and retain the information provided by these social media sites in accordance with this privacy notice. We may also use plug-ins or other technologies from various social media sites. If you click on a link provided via a social media plug in, you are voluntarily establishing a connection with that respective social media site.
- If you give us personal information about someone else, you must do so only with that person’s authorization. You agree to inform them how we collect, use, disclose, and retain their personal information according to our privacy notice.
Information Collected From All Users. Information you provide to us: For all Users we collect Personal Data when you voluntarily provide such information to the Services, such as when you register for access to the Services, contact us with inquiries, respond to one of our surveys or browse or use certain parts of the Services. The Personal Data we may collect includes without limitation your name, address, email address and any other information that you choose to provide and/or that enables Users to be personally identified.
- When you register for the Services or otherwise submit Personal Data to us, we may associate other Non-Personal Data (including Non-Personal Data we collect from third parties) with your Personal Data. At such instance, we will treat any such combined data as your Personal Data until such time as it can no longer be associated with you or used to identify you.
User Profiles. User may create a profile, with certain or all information publicly available. Clients and Agencies may also create organization profiles. You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, hourly pay rates and earnings information, feedback information and other information, including your username (“Profile”). You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. Clients and Agencies of associated individual users or companies may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us.
How We Use Your Personal Data
Specific Reason. If you provide Personal Data for a certain purpose, we may use the Personal Data in connection with the purpose for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem and will respond to the email address from which the contact came.
- We use your personal information to provide and improve our Services, provide you with a personalized experience on our sites, contact you about your account and our Services, provide you customer service, provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities.
- We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing.
Access and Use. If you provide Personal Data in order to obtain access to or use of the Services or any functionality thereof, we will use your Personal Data to provide you with access to or use of the Services or functionality and to analyze your use of such Services or functionality. For instance, if you supply Personal Data relating to your identity or qualifications to use certain portions of the Services, we will use that information to make a decision as to granting you access to use such Services and to assess your ongoing qualification to use such Services.
Internal Business Purposes. We may use your Personal Data for internal business purposes, including without limitation, to help us improve the content and functionality of the Services, to better understand our Users, to improve the Services, to protect against, identify or address wrongdoing, to enforce our Terms of Service, to manage your account and provide you with customer service, and to generally manage the Services and our business.
Marketing. We may use your Personal Data for our marketing and advertising purposes, including (without limitation) by email, display media, and targeting other devices (such as tablets, mobile devices and televisions). We do this in order to inform you about services or events we believe might be of interest to you, develop promotional or marketing materials and display InnerPal or event-related content and advertising on or off the Services that we believe might be of interest to you. We may also do this on behalf of a Servicer, for example where your prior interactions with a Servicer suggest you may be interested in a particular type of service.
Use of Interest-Based Data. We sometimes make inferences about the type of services you may be interested in. We may use these inferences to help target advertising or customize recommendations to you, including on behalf of Servicers. We may do this on an aggregated or generalized basis.
Staying Signed in. When you sign in to your account on our Services, we give you the option to stay signed in to your account for certain amount of time. If you are using a public or shared cellular device, we encourage you not to choose to stay signed in. You or any other user of the cellular device/browser you signed in on will be able to view and access most parts of your account and take certain specific actions during this signed in period without any further authorization. If you are using a public or shared cellular device, you should sign out and/or clear your cookies when you are done using our Services to protect your account and your personal information.
Legal Requirements. We may disclose your Personal Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Services, (d) act in urgent circumstances to protect the personal safety of Users of the Services or the public, or (e) protect against legal liability.
Security. We take commercially reasonable steps to help protect and secure the information it collects and stores about InnerPal Users. All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection for our InnerPal Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, InnerPal cannot ensure and does not warrant the security of any information you transmit to us.
Your Rights & Data Retention
We retain your Personal Data for as long as necessary to provide you with our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you have an account with us, we will typically retain your Personal Data for a period not less than thirty (30) days after you have requested that your account is closed. Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, object to profiling and unsubscribe from marketing communications. Registered InnerPal Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. You may opt-out of receiving text messages by replying “STOP” to any text message received. Registered InnerPal Users who access the Service by using an InnerPal Website may, with permission, receive push notifications. Similarly, registered InnerPal Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the Website or the applicable browser. All Users may request access to or correction of any Personal Information we have about them or close their account and/or request deletion of all Personal Information we have about them. In certain jurisdictions, Users may have certain rights with regard to their Personal Information. We will honor User requests to the extent we can reasonably do so and as required by law, but some information will remain on the Services, such as information you posted publicly. Upon request InnerPal will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting InnerPal through your online account. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so through the InnerPal Service (once you have logged in, visit settings / user settings, and then click on the close my account link). We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including information in your messages you posted to the Service. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor InnerPal can delete all copies of information that has been previously shared with others on the Service.
Limit the Personal Data You Provide. You can browse the Services without providing any Personal Data (other than Automatic Data to the extent it is considered Personal Data under applicable laws) or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.
Third Party Privacy Practices. This privacy notice addresses only our use and handling of personal information we collect from you in connection with providing you our Services. If you disclose your information to a third party, or visit a third party Website via a link from our Services, their privacy notices and practices will apply to any personal information you provide to them or they collect from you. We cannot guarantee the privacy or security of your personal information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your personal information. This is true even where the third parties to whom you disclose personal information are bidders, buyers or sellers on our site.
Dispute Resolution. If you have a complaint about InnerPal's privacy practices you should contact us. We will take reasonable steps to work with you to attempt to resolve your complaint in accordance with the “Terms” incorporated with these policies.
The EU General Data Protection Regulation (GDPR) for EEA, SWITZERLAND AND UK ONLY. The GDPR requires InnerPal. and Servicers using the Service to provide Users with more information about the processing of their Personal Data. The GDPR requires us to tell you about the legal ground we're relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data for the purposes set out above will typically be because:
- You provided your consent; it is necessary for our contractual relationship;
- The processing is necessary for us to comply with our legal or regulatory obligations;
- And/or the processing is in our legitimate interest as a service platform.
Nevada & California Residents. Certain residents may opt out of the sale of “personally identifiable information”. “Personally identifiable information” includes first and last name, address, email address, phone number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada or California resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under law by emailing us. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Transfers of Personal Data. As InnerPal. is a global company, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the EEA, Switzerland and the UK which have no data protection laws or laws that are less strict compared with those in Europe. Whenever we transfer Personal Data outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data.
Change of Ownership. If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your personal information. If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.
Contact Us. If you have a question or a complaint about this privacy notice, our global privacy standards, or our information handling practices, you can reach us at:
Email - Support@InnerPal.com