Last Updated/Effective Date: May, 2022
InRule Technology, Inc. and its subsidiary partners simMachines, Inc. and Barium AB (collectively, “InRule”) respect your privacy and are committed to protecting it through our compliance with this policy.
- Visit and use our websites located at inrule.com, barium.se, simmachines.com, and their associated webpages (collectively, the “Websites”).
- Purchase and use our products (“Products”) and services (“Services”).
- Correspond or otherwise communicate with us.
This Policy also addresses rights you may have under the California Consumer Privacy Act of 2018 (the “CCPA”), the European Union (EU) General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and other applicable data protection laws.
In this Policy, “we” and “us” means InRule, and “you” means any person who visits our Websites, uses our Products or Services, corresponds with us, or calls us on the phone. When we refer to “personal information” in this Policy, we mean information that directly identifies you (such as your name, postal address, or email address) or data that could be used to indirectly identify you.
What Information We Collect
We collect a variety of types of information, including:
- Contact information, such as your name, email address, job title, and company address and phone number;
- Purchase information, such as the Products and Services you purchase, credit card or other payment information, and billing and shipping address;
- Preference information, such as your contact and marketing preferences;
- Account information, which may include your account username and password, and other information about your account;
- User-generated information, such as the content you submit in comments to the blog posts or form fields on our Websites;
- Correspondence information, including information about your email or other written communications with us, and information that you share in your emails and other written communications with us;
- Call recordings and voicemail message transcripts including information about your call and information you share when you call us on the phone or leave us a voicemail; and
- Device and browsing information, including information about your phone, tablet, computer, or other device, and online browsing activity (collectively, “automatically collected information”). Automatically collected information may include IP addresses, countries of origin, unique device identifiers, cookie identifiers, device and browser settings and information, and Internet service provider information. Automatically collected information also may include information about when and how you access and use our Websites, such as the date and time of your visit or use, the websites you visit before coming to and after leaving our Websites, how you navigate and what you search for using our Website, and the website pages and items you view using our Websites.
Sources of Information We Collect
We collect and obtain personal information from the following sources:
- You provide, such as when you visit or use our Websites, purchase our Products or Services, contact or chat with us through our Websites, register for an online account, participate in a survey, fill out a form, or sign up for emails or marketing;
- From third parties, such as service providers that we use, analytics companies, advertising networks and cooperatives, third parties that provide us with information about you and the different devices you use online, and other third parties that we choose to collaborate or work with;
- From social media platforms and networks that you use in connection with our Websites, or that share or allow you to share information with us, such as LinkedIn and Twitter. For example, if you use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Websites (for example, to share content from our Websites with your friends and followers on social media), we will collect the information that you share with us, or that those social media platforms or networks share with us;
- Using cookies and other automatic collection methods. For example, we and third parties we work with may collect information from the computer, tablet, phone, or other device that you use to access our Websites, or that you use to open an email or click on an advertisement from us. This collection includes automatically collected information, and generally does not include personal information that directly identifies you unless you provide it through our Websites or you choose to share it with us. Automatic collection methods we use include:
- Web beacons or tags, which are small images embedded into websites or emails that send information about your computer, tablet, phone, or other device when you visit our Websites, or open an email we send to you;
- Website log files, which we or our service providers tend to create automatically in connection with access to and use of our Websites; and
- Other technologies, which may be similar to or different than the methods noted above.
How We Use Information
We use the information that we collect and obtain to conduct our business and to provide you with our Products and Services, and experiences that you request or that we think may be of interest to you. We also may combine any or all of the information that we collect or obtain with other information that we collect or obtain, including but not limited to information obtained from third parties with which we choose to work. We use information:
- To provide you with Products and Services, to process, maintain, and service your account, and to provide you with our Products and Services that you request or that we think may be of interest to you;
- To respond to you, when you contact us through our Websites, correspond with us by email, or otherwise communicate with us, complete a form or survey, make a request or inquiry, or share a comment or concern;
- For personalization of your experiences with us, including to remember your interests and preferences, to personalize Website content, to customize the Products and Services, to track and categorize your activity and interests on our Websites (including by identifying the different devices you use), and to enrich your experience and on our Websites;
- For marketing and advertising, including to provide social media features, to send you marketing and advertising communications, to segment and build audiences and engage in interest-based advertising, and to personalize the marketing and advertising that we show you (for choices about marketing and advertising, see the “Your Choice and Access Requests” Section below);
- For analytics, including to understand how you use our Websites, to analyze our Websites’ traffic, to determine the methods and devices used to access our Websites, and to improve our Websites and Products and Services;
- For our business purposes, including to operate and improve upon our business and lawful business activities, to maintain our accounts and records, for research, to determine your satisfaction with our Products and Services, to deliver the agreed service level of our Products, to perform necessary processing activities to maintain our Products’ performance and to protect the integrity of the Services, e.g. to detect and prevent fraud or misuse of our Services; to enforce, apply, or comply with any of our terms or policies, including but not limited to this Policy, and for any other business purpose that is permitted by law;
- For legal, contractual and safety purposes, including to defend or protect us, our customers, you, or third parties from harm or in legal proceedings, to protect our rights, to protect our security and the security of our customers, employees, and property, to respond to court orders, lawsuits, subpoenas, and government requests, to address legal and regulatory compliance, to verify your identity or communications from you, to comply with contracts and other agreements to which we are a party, and to notify you of changes to our terms, policies, or practices.
How We Share Information
We do not sell the personal data of our customers, prospects or partners. We share personal information with:
- Affiliates. We may share personal data with our affiliates for their internal and business purposes.
- Third parties and service providers that provide products or services to us (e.g. payment processors), that help us market or advertise to you (including co-branded/reseller marketing and advertising), including our advertising and analytics partners (see “Online Advertising, Analytics, and Other Partners We Work With” section below for more information). We may use third parties or service providers to perform any of the actions or activities allowed under this Policy;
- Parties to business transactions, such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party; and
- Additional third parties, such as law enforcement, government entities, courts, our legal advisors, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How We Use Information” Section above, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your consent, although we may not be able to accommodate all requests.
- Other. We may share personal data with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Online Advertising, Analytics and Other Third Parties We Work With
We work with third-party companies for measurement, analytics, and advertising purposes, including to measure website activity, track conversions, target and serve advertisements across the Internet, track and categorize your activity and interests over time on our Websites and on third party websites and mobile applications, build a profile of your apparent interests and show you ads on other websites that may be relevant to your apparent interests, and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information, including automatically collected information, when you use our Websites through the methods described in the “How We Collect Information” Section above (see “Using cookies and automatic collection methods”). These third-party companies also may possess or obtain information about you from your interactions directly with the third-party companies, with other websites, mobile applications, or other companies that the third-party companies work with, or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you.
We may share personal information with the third-party companies we work with for our purposes, though in general we do not share personal information that directly identifies you with third parties for those third-parties’ marketing or advertising purposes unless you request or consent to such sharing and use, or as otherwise described in this Policy. We may also share other information in our discretion, including automatically collected information, which may be used by third parties for third-party marketing, advertising, and other purposes. For information about the choices you have about the online advertising practices described in this section, please see the “Your Choices ” Section below.
We offer you choices about how certain personal information is used and shared. Your choices include:
- Online Advertising. In addition to using the management tools linked-to in the “Online Advertising, Analytics, and Other Third Parties We Work With” Section above, you can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices. For mobile users, you also have numerous controls in your Operating System that enable you to choose whether to allow cookies, or share your advertising ID with third parties. For some information on controlling your mobile choices, click here. To help control or block certain ads in mobile applications, you may choose to download and utilize the Digital Advertising Alliance’s mobile app by clicking here. We do not guarantee that all of the third parties we work with will honor the elections you make using those options.
- Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
- Email Choices. You can opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails you receive from us. Please note that opting out of receiving marketing or advertising emails from us will not apply to transactional communications or legal notices, for example, emails about your orders or about changes to our terms, policies, or business practices.
- Managing Cookies. You can activate settings on your Internet browser to refuse the setting of some or all cookies. Please keep in mind, however, that if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Websites and services. For further information about managing cookies, please visit allaboutcookies.org. Please note that disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you have previously set, in which case you would have to revisit the applicable pages and renew your opt-out after clearing cookies.
- Mobile Devices. Your mobile device may offer settings relating to cookies, pixel tags, and other similar technologies. We encourage to you to visit your device’s help menu to learn about your options to limit tracking when using your device.
Use And Disclosure Of De-Identified Or Aggregated Information
InRule may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. InRule is the sole and exclusive owner of such de-identified and aggregated information, including if InRule de-identifies personal data so that it no longer considered personal data under applicable laws.
Security and Retention
Although we take steps to help protect the security of personal information you share with us, information transmitted through the Internet may not be perfectly secure. We do not guarantee the security of your personal information. We will keep your personal information only for as long as necessary for the purposes for which it was collected, to provide you with Products or Services, to carry out legitimate business interests, and where otherwise required or permitted by law.
Links to Other Websites and Services
Our Websites may provide links to other Internet sites, content, or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos accessed via the links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of those third parties.
Browsers Do Not Track Signals
Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating that you do not wish to be tracked. There is not yet a common understanding of how to interpret the DNT signal. We currently do not respond to web browser DNT signals. For information about the choices you have about limiting how you are tracked online (for example, for advertising practices described in this Policy), please see the “Your Choices” section above.
Individuals Located in the European Union, European Economic Area, and the United Kingdom
The purpose of this section is to provide information and additional provisions that apply regarding InRule’s processing of personal data of persons located in the European Union (“EU”), European Economic Area (“EEA”), and United Kingdom (“UK”) in accordance with the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation (collectively referred to herein as the “GDPR”). THIS SECTION ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU, EEA, OR UK. In the event of a conflict between this section and the remainder of the Policy, this section shall control for those persons located in the EU, EEA, or UK. The terms “personal data”, “processing”, and “automated decision” have the same meanings set forth under the GDPR.
Legal Basis for Processing. When InRule processes your personal data, it has a legal basis for doing so as required under GDPR. InRule will only process your personal data if: (i) it has received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which InRule is subject, (iv) the processing is necessary to protect the vital interests of the data subject, (v) the processing is necessary for a task carried out in the public interest, or (vi) if InRule or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the data subject.
Marketing. InRule does not process personal data for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of personal data for marketing purposes at any time by contacting us at [email protected]
Special Category Personal Data. “Special Category Data” is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. The data InRule collects and processes does not qualify as Special Category Data, and InRule does not intend to collect any Special Category Data from you. Please refrain from sending us any Special Category Data.
Automated Decision Making. InRule does not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of personal data via automated decision making at any time by contacting us at [email protected]
Transfer to Third Parties and Countries. Personal data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU, EEA, or UK, some of which EU, EEA and UK authorities may not consider to have an adequate level of protection for personal data. InRule will only transfer data subject’s personal data to third-parties located outside of the EU, EEA, and UK when it has ensured appropriate safeguards for such personal data through use of the standard contractual clauses or other approved methods by the EU, EEA, and UK.
You may request a copy (which may be provided as a summary) of any such appropriate safeguards or seek inquiries regarding such safeguards by contacting us at [email protected] We will respond to your request or inquiry within a reasonable period of time.
This section provides additional provisions that apply to residents of California. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).
The Collection, Source, Purpose and Sharing of Your Personal Information
Categories of Personal Information. We collect the categories of personal information described in the above section titled “What Information We Collect.”
Categories of Sources From Which Personal Information is Collected. The categories of sources from which your personal information is collected is described in the above section titled “Sources of Information We Collect.”
Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in the above section titled “How We Use Information.”
Categories of Third Parties / Services Providers With Whom Personal Information is Shared. The categories of third parties and / or service providers with whom we share your Personal Information are described in the above section titled “How We Share Information.”
We Do Not Sell Personal Information. In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information. “Sold” / “Sell” has the definition set forth in the CCPA.
Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your personal information within the past year for direct marketing purposes, and (b) a description of the categories of personal information disclosed, by contacting us per the “Additional Information and Contacting Us” section below.
Your Data Protection Rights
The GDPR, CCPA, and other applicable data protection laws provide certain rights to individuals in relation to their personal data. Accordingly, you may have some or all of the rights set forth below, although some exceptions apply, and we will comply with any requests made relating to the following rights to the extent required by applicable law:
- Right of Access – The right to be informed of and request access to the personal data we process about you, including, in certain circumstances, a right to know what personal information the we collected, or disclosed about you, including the specific pieces of personal information held
- Right to Erasure (Deletion) – The right to request deletion of your personal data
- Right to Withdraw Consent – The right to withdraw your consent InRule processing your personal data
- Right to Rectification – The right to request that we amend or update inaccurate or incomplete personal data
- Right to Restrict Processing – The right to request that we temporarily or permanently stop processing all or some of your personal data.
- Right to Object – The right to object to InRule processing your personal data, such as for direct marketing purposes or when automated decision making is used.
- Right to Data Portability – The right to request a copy of your personal data in electronic format and request that we send such personal data to another party
- Communication Preferences and Opt-Outs – The right to stop receiving communications from us at any time
- Non-Discrimination – The right to not receive discriminatory treatment for exercising any of their rights.
- Right to Lodge a Complaint – The right to lodge a complaint with the applicable supervisory authority
To exercise any of your rights as described in this section, you may submit your request to us by contacting us at [email protected] or +1 312-648.1800. If you have any questions about your privacy, your rights and choices, or how to exercise them, please contact us with your request at [email protected]
Verification of Your Requests. In order to verify your requests, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your request to exercise your rights: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use personal information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.
When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your personal information to you. We may charge a fee to process or respond to your request if it is excessive or repetitive.
Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with InRule, and (c) directly confirm with InRule that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.
Our Products, Services, and Websites are not directed to or intended to be used by individuals under the age of 16. We do not knowingly request or collect personal information from any person under 16 years of age without prior verifiable parental consent. If you believe that your child under the age of 16 has submitted personal information to us, and without prior verifiable parental consent, please email us at [email protected] so that we can take steps to delete the personal information that she or he provided as required in accordance with applicable law.
If you have questions about this Policy or our privacy practices, please contact us by email at [email protected] or write to us at:
InRule Technology, Inc.
651 W. Washington Blvd, Suite 500
Chicago, IL 60661
Updates to this Policy
We may make changes to this Policy, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Policy, we will notify you by e-mail and/or by posting the updated Policy on our Websites, and we will update the effective date at the top of this Policy.
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