InGo, Inc. (“InGo”, “we”, “our” or “us”) is a U.S.-based company which provides event organizers with a marketing solution that empowers event attendees to act as co-marketers. Our application (“Application”) is provided to organizers of trade shows and other events (“Event Organizers”) and allows event attendees to register for the event using their social media accounts, post about the event on their social media newsfeeds, invite their contacts to the event and see who else is attending the event (the “Services”).
We respect your privacy. We won’t use your personal information other than as described in this privacy statement (“Privacy Statement”).
This Privacy Statement applies to personal information that we receive directly from you, or through our Social Media Partners (as defined below) on your behalf, in connection with our Application. The Application is provided by InGo and may be provided by InGo on behalf of an Event Organizer. As such, when you use the InGo Application, your personal information will be provided to both InGo and to any Event Organizer using the Application in relation to such Event Organizer’s event or trade show. Accordingly, when you use the Application, you understand that your personal information will be provided to InGo and will be used in accordance with this Privacy Statement.
WHAT INFORMATION DOES INGO COLLECT?
We collect the following types of information from our users:
Information You Provide to Us or Authorize Us to Obtain
We may receive and store any information you submit directly to us via the Application, or otherwise authorize us to obtain through one of your social media accounts, such as Facebook, LinkedIn, Twitter or Xing (“Social Media Partners”) – though from time to time we may add or change the Social Media Partners with whom we work. Please note, when you use your social media account in connection with the Application, you and/or the Social Media Partner are in control of the personal information which is released to us. More information is provided on this point in the section of this Privacy Statement entitled “SOCIAL MEDIA PARTNERS” below.
The types of personal information collected either directly from you or through any applicable Social Media Partner may include your full name, email address, gender, username, demographic information, and any other information necessary for us to provide the Services. In addition to this information, we may collect certain information automatically when you use the Application which may also be considered personal information. Finally, we may also collect information about your contacts in connection with your use of a Social Media Partner, both of which are discussed in further detail below.
Information Collected Automatically
When you use the Application, we will automatically receive and store certain types of information, such as information regarding your computer’s IP address or your mobile device’s MAC address, browser information (such as what type of browser you use and what version of the software it uses which could impact your experience of using the Application), and Facebook Page fan status (or other similar types of information from other Social Media Partner sites as may be applicable).
Information About Your Social Media Contacts
HOW DOES INGO USE THE INFORMATION IT RECEIVES?
InGo uses the information it receives as described in this Privacy Statement, including for the following purposes:
(i) to assist you to sign up for an event where the Event Organizer is using the Services offered through the Application. Essentially, the InGo Application will (where you have authorized us to do so) use the information contained within your social media profile to pre-populate an event registration form to facilitate your registration for an event;
(ii) to prepare invitations and/or updates to be sent to your contacts/friends/connections in relation to your attendance at any particular event, and only where you consent and agree to send the relevant invitations and/or updates;
(iii) with respect to a particular event (a) what’s going on, (b) people with whom you might want to engage, and (c) other events you might find interesting;
(iv) to notify you about potential events and people you may want to connect with at such event;
(v) to determine, analyze, develop and improve our products and services;
(vi) to contact you regarding the Application, Services and/or to communicate with you in response to any questions or queries which you may have about your use of the Application and/or Services, as well as for other internal record keeping and management purpose;
(vii) for compliance with any regulatory or legal obligations; and
(viii) as set forth below in the section of this Privacy Statement entitled “Will InGo Share Any of the Personal Information it Receives?”.
Will InGo Share Any of the Personal Information it Receives?
Personal information about our users is an integral part of our business. We will not rent or sell your personal information to anyone, except as otherwise described in this Privacy Statement or as required by law. However, in order to provide the Application and/or the Services, as well as for the operation of our general business administration, we may share or disclose your personal information as described below.
Service Providers and Agents: We employ other companies and people (e.g., technical consultants, data center providers and marketing analysts) to perform tasks on our behalf (“Providers and Agents”) and we may share your information with them in order to provide the Application and/or Services to you, as well as to assist us in our everyday tasks. Unless we tell you differently, InGo’s Providers and Agents do not have any right to use the personal information we share with them for any reason other than assisting us in providing the Application and/or Services (where applicable) or otherwise assisting InGo in its daily business functions. All such Providers and Agents are instructed and appointed with appropriately worded contracts.
Business Transfers: In the event we are acquired by, or merge or consolidate into, another entity, or if there is a sale of our assets (in whole or in part), your personal information may be transferred to the entity acquiring us or our assets, or that survives the merger or consolidation. Moreover, in the unlikely event that InGo goes out of business or enters bankruptcy, personal information would be one of the assets that is transferred or acquired by a third party as part of such disclosure or bankruptcy.
Protection of InGo and Others: We may share or otherwise disclose personal information when we believe in good faith that release is necessary to comply with the law; enforce or apply our Terms of Service and/or other agreements; or protect the rights, property, or safety of InGo, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction where it is appropriate and lawful to do so.
Anonymous, Aggregated Data: Our Application gathers anonymous aggregated data like web statistics and demographics statistics on our users (among other things). This anonymous, aggregated data is not personal information and it cannot be used to re-identify any particular individual. We use the anonymous, aggregated data to help us run our business, attract advertisers/investors, and measure the effectiveness of our Application. We may choose to share, sell or publicize certain anonymous aggregated data about our Application and users. However, because this data is anonymous and in summary form (i.e., it is not personal information and will not include information such as your name, email address, home address, etc.), no advertisers or third parties could ever contact you using this aggregated, anonymized data.
With Your Consent: Except for transfers permitted by this Privacy Statement (or required by law), you will be notified when your personal information may be shared with third parties, and will be given the opportunity to object to the sharing of this information.
SOCIAL MEDIA PARTNERS
WILL MY PERSONAL INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
As stated above, InGo is a U.S.-based company. As such all personal information which is collected and used by InGo as set out in this Privacy Statement will be transferred to or accessed in the United States, and by your proceeding to use the Application and/or Services, you understand that your personal information will be transferred to and stored in the United States. Please note that InGo may from time to time also use third party contractors outside of the U.S. and the E.U. (e.g., Russia or Ukraine) to perform services on its behalf (for further information, see the section of this Privacy Statement entitled “Service Providers and Agents”). InGo will ensure that such third party contractors have entered into appropriate contracts relating to protection of personal information that they may access.
EU-U.S. PRIVACY SHIELD
InGo complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and/or Switzerland to the United States. InGo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
Enforcement Powers: InGo is subject to the investigatory and enforcement powers of the Federal Trade Commission. We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Responding to Complaints: In compliance with the Privacy Shield Principles, InGo commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact InGo at firstname.lastname@example.org.
If you do not receive a timeline response you can also contact our recourse provider here: https://www.jamsadr.com/eu-us-privacy-shield.
InGo 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 contact JAMS or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
If neither InGo nor JAMS resolves your complaint, you may pursue binding arbitration as described in Annex I to the Privacy Shield Principles.
Onward Transfer: InGo does not disclose personal information to any third parties except to fulfill the purposes for which the information was disclosed or for the purposes described in this Privacy Statement – for further information, see the section of this Privacy Statement entitled “Will InGo Share Any of the Personal Information it Receives?” InGo has responsibility for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. InGo remains liable under the Privacy Shield Principles if any of its agents process such personal information in a manner inconsistent with the Privacy Shield Principles, unless InGo can prove that it is not responsible for the event giving rise to the damage.
Choice: As stated above, except for transfers permitted by this Privacy Statement (or required by law), you will be notified when your personal information may be shared with third parties, and will be given the opportunity to object to the sharing of this information. In addition, you may always choose not to provide your personal information to InGo, although as a result you may be prevented from using the Services.
CONDITIONS OF USE
If you decide to use or otherwise access the Application, your use/access and any possible dispute over privacy is subject to this Privacy Statement and our Terms of Service, including limitations on damages, arbitration of disputes, and application of Delaware state law.
THIRD PARTY APPLICATIONS/WEBSITES
The Application may permit you to link to other applications or websites. Such third party applications/websites are not under InGo’s control, and such links do not constitute an endorsement by InGo of those other applications/websites or the services offered through them. The privacy and security practices of such third party application/websites are not covered by this Privacy Statement, and InGo is not responsible for the privacy or security practices or the content of such applications/websites.
WHAT PERSONAL INFORMATION CAN I ACCESS?
InGo allows you to access your personal information for the purpose of viewing and, in certain situations, updating that information. Below is a list of the personal information you can access. This list may change in the event the Application changes.
• Account and user profile information;
• User e-mail address, if applicable;
• Facebook profile information, if applicable;
• User preferences;
• Application specific data.
For individuals in the European Union, if you wish to exercise any of your data subject rights, such as your right of access, correction or erasure, please send an email to email@example.com as set out below.
USE OF THE APPLICATION BY MINORS
Our Application and the Services are not intended for persons under the age of 16. InGo does not knowingly or specifically collect information about children under the age of 16 and believes that children of any age should get their parents’ consent before giving out any personal information. We encourage you to participate in your child’s web experience.
CALIFORNIA DO NOT TRACK DISCLOSURE
At this time InGo does not respond to browser ‘Do Not Track’ signals.
CALIFORNIA SHINE THE LIGHT LAW
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. If you would like to make a request for information under the Shine The Light law, please send an email to firstname.lastname@example.org or mail your request to P.O. Box 2105, Manassas, VA 20108.
CHANGES TO THIS PRIVACY STATEMENT
InGo may amend this Privacy Statement from time to time. Use of personal information we collect is subject to the Privacy Statement in effect at the time such personal information is collected. If we make changes in the way we use personal information, we will notify you by posting an announcement on our website (www.ingo.me) or by sending you an email. You should review the Privacy Statement for changes each time you use the Application or visit our website.
QUESTIONS OR CONCERNS
If you have any questions or concerns regarding this Privacy Statement or our use of your personal information, please send us a detailed message at email@example.com. We will make every effort to resolve your concerns.v