Privacy Policy

 

Last Updated: December 20, 2019

Ioterra, Inc. (“Ioterra”) is committed to protecting the privacy of individuals who visit the Ioterra web sites and individuals who use the Services as defined below (“Members/Partners”). This Privacy Policy describes Ioterra’s privacy practices in relation to the use of the Ioterra web sites and the related applications and services offered by Ioterra (collectively, the “Services”).

Our principle guidelines are simple. We will be clear about the data we collect and why. We do not and will not sell your data to third parties. The primary purpose of collecting your data is to assist you in the planning, prototyping, and development of technology products. Whether we are providing access to our proprietary tools and information, matching members with partners, providing easy access to partner services, or facilitating your participation in the product lifecycle, our aim is for you to develop, produce, launch, and maintain smart products as effortlessly as possible.

This Privacy Policy (the ‘Policy’) explains the personal information we collect from you, either directly or indirectly, and how we use it. As used in this Policy, “Personal Information” has the meaning provided in the EU General Data Protection Regulation of 2018 (the “GDPR”), and includes any information which, either alone or when combined with other information we hold, identifies an individual, such as name, mailing address, email address, IP address, and telephone number. For legal residents of California, who are covered by the California Consumer Privacy Act (“CCPA”), Personal Information includes any additional elements defined as such by the CCPA. By contrast, “Anonymous Data” means any data that, alone or combined with other information available to us or a third party, does not permit identification of an individual. We collect both Personal Data and Anonymous Data as described below.. It typically includes such information as your name, e-mail address, or mailing address. This Policy also covers the choices you can make about the data we collect, and how you can control these decisions. Please read this Policy carefully to understand how Ioterra may collect, use, and share your personal information. The terms ‘we’, ‘us’, or ‘Ioterra’ are each intended as reference to Ioterra.

Change

We will update this Policy when necessary to reflect legal changes, customer feedback, and changes in our Services. When we post changes to this Policy, we will revise the Last Updated date at the top of the Policy and may describe the changes in a change history. If there are material changes to the Policy or in how Ioterra will use your personal information, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Policy to learn how Ioterra is protecting your information.

IMPORTANT INFORMATION (EU AND CALIFORNIA USERS)

EU Users

Who We Are

For the purpose of the GDPR, the data controller of your Personal Information is Ioterra, a division of Breadware, Inc. of 200 S Virginia St #100, Reno, NV 89501, USA. You may contact our data protection officer at [email protected].

California Users

Sale of Personal Data

You may opt out of all sales of your Personal Information. We never exchange Personal Information for money or any other consideration (e.g., trade it for free services). However, the CCPA’s definition of “sale” is very broad, and may include situations where, for example, browsing data is sent to referral advertisers. We, along with millions of other sites, use these services. While we limit the information sent to what is needed to properly record the referral, the fact that you clicked on the link and visited Ioterra may be added to your profile by the ad publisher. This is all done with cookies, the use of which can be controlled as described below in the “How to control cookie settings” section.

 

The Type of Personal Information We Collect

Information you provide to us

We collect information you voluntarily provide to us, such as your name, phone number and email address; for instance, when you register for an account, apply to be a partner, or when you contact our customer care department for assistance.

Information we collect automatically

We automatically collect information about you, such as data about your use of the Ioterra Service. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites, and whether and how you interact with content available on our websites.

Information obtained from other sources

We may receive information about you from other sources, including third parties, such as Ioterra partners and partners with whom we offer co-branded services or engage in joint marketing activities. We may also receive information about you from Ioterra partner websites, for instance, when you interact with us on those sites. We protect data obtained from third parties according to the practices described in this Policy and we also apply any additional restrictions imposed by the source of data.

Information of children

Ioterra does not target and is not intended to attract children under thirteen. Although visitors of all ages may navigate through our websites or potentially use our web service, we do not knowingly collect or request personal information from those under the age of thirteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under the age of thirteen has improperly accessed or used our Services by using false information, we will delete the child’s personal information from our records.

Member/Partner Interactions with Ioterra

To make the information in this Policy easy to understand, we have highlighted different occasions when Ioterra could potentially collect personal information from Members/Partners. The Members/ Partners interactions with Ioterra are broken down into the following segments:

Learning about Ioterra

As you gather more information about Ioterra, you may virtually physically visit or interact with a site that we own or operate. Examples include browsing our website, calling our in-house representatives, or attending Ioterra-sponsored events. To learn more about Ioterra Services, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online when you visit our websites.

We collect: name, email address, and IP address.

Why: We use this information to share news about events, products, and services offered by Ioterra, and to provide Service and event access and authentication services. Additionally, the IP address helps us to understand geographic information about our websites’ visitors better so that we can improve our websites for everyone. It is our legitimate interest to process your personal data for these purposes.

Processing your personal data for these purposes is necessary for the performance of the agreement we have with you.

Getting Help from Ioterra and Ioterra Partners From time to time, you may decide to contact our customer care department for assistance with the product development and manufacturing process. To be able to offer you the best service possible, we may collect certain data from you.

We collect: This may include contact information, such as your name, email address, phone number, and the content of your chats and other communications with Ioterra customer care or Ioterra partners.

Why: We collect this information to give you the best and most efficient customer support possible. For instance, for Customer inquiries and technical questions, we use contact information to respond to the Customer in their preferred channel (e.g., phone or email). Processing your personal data for this purpose is necessary for the performance of the agreement we have with you.

 

How We Use Personal Information

Ioterra uses the data we collect to provide you with the Services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about the status of a request for proposal or contract submission, new Services available, security, and other types of updates.
Ioterra uses the data for the following purposes:

To Identify You and Provide Requested Services

We use data to provide, operate, support and improve the Services we offer to ensure our Members/Partners can communicate and work together as effortlessly as possible. This processing is necessary for the performance of our agreement we have with you.

Customer Support

We use data to respond to Members/Professionals inquiries, diagnose problems using the Services, address document submission and document execution issues, and provide other Customer Care and support services. This processing is necessary for the performance of our agreement we have with you, as well as to serve our legitimate interest.

Service Improvement

We continually use data to develop and improve the Services, including maintaining and improving the performance of our Services, developing and adding new features or capabilities, such as using verification to improve security, and using usage data to determine what new features to prioritize. This processing is necessary to serve our legitimate interest.

Security, Safety and Dispute Resolution

We use data to protect the security and safety of the Services and our Members/Professionals, to detect and prevent fraud, to resolve disputes, and enforce our agreements. This processing is necessary to serve our legitimate interest.

Business Operations

We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.

Communication and Marketing

We use the data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means of electronic communication to inform you about new Ioterra Services, to update you on a support issue or to invite you to take part in a survey. This processing is necessary to serve our legitimate interest.

 

How We May Share Personal Information

Ioterra will never sell your Personal Information (as “sell” is normally defined – see Sections above for information about “sales” as defined In California) or use it except as stated in this Policy. We share your Personal Information in the following circumstances:

Matched Members/Partners

When directed by a Member or Professional, Ioterra Services use matching algorithms and professional knowledge to match Member to Professionals based on Members’ requests for proposals and applicable Professional attributes. We only share your personal data as necessary, or to provide a Service you have requested or authorized. In this case, your personal information will be shared with these Members or Partners but only for the purpose of performing services on behalf and under instructions of Ioterra and in accordance with this Policy. This processing is necessary for the performance of our agreement we have with you.

Ioterra Partners

We may share information with Ioterra Partners to the extent you have authorized us to do so.

Compelled Disclosure

When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organizations, our affiliates or in legal proceedings.

Sale or Merger

We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights.

The Legal Bases for Using Personal Information

There are different legal bases that we rely on to use your personal information, namely:

Performance of a contract

The use of your personal information may be necessary to perform the agreement you have with us. For example, to process your submission of a request for proposal, to process your submission of a quote or proposal, to initiate contract execution, to help with Service issues, and to respond to your requests.

Legitimate interests

We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyze and improve Ioterra Services, to send you notifications about Ioterra Services, or to use your personal information for administrative, fraud detection or legal purposes. Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you on our website, you may exercise your right to object by sending an email to [email protected].

 

Security, Storage and Retention of Personal Information We Collect

Security

Ioterra is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.

We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. We ensure that our data center has adequate security measures. Additionally, your data is protected with encryption, such as Transport Layer Security (TLS), during transmission over the Internet. Moreover, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including Ioterra (it can only be reset).

You can only access your product, proposal, and quote information and our Service through the use of an individual user login and password. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person. Please alert us immediately if you believe your password has been misused. Additionally, always log out and close your browser when you finish reviewing or updating your Service submissions Please note, we will never ask you to disclose your password. If you have any questions about the security of your personal information, you can contact us at [email protected].

Storage

Personal data collected by Ioterra may be stored and processed in your region, in the United States (for instance in our data centers), or in any other country where Ioterra or Ioterra partners are located or maintain facilities. Ioterra has put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission.

Retention

Ioterra will retain your personal information for as long as we deem it necessary to enable you to use the website and your Ioterra Services, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Policy and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to [email protected].

 

Your Rights and Choices

Your Rights

We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:

• you can ask us for a copy of the personal information we hold about you;
• you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
• in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
• in certain situations, you can also ask us to send the personal information you have given us to a third party.

Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.

We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting [email protected].

We will respond to your request as soon as possible but certainly within 30 days.

We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to lodge a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.

Rights for EU and California Users Only

The GDPR and CCPA grant EU and California residents certain rights regarding their Personal Information, including the right to access and modify Personal Information held by providers (like us), and to have providers “forget” Personal Information that is no longer relevant. You may always contact us for assistance in exercising these rights. Please include information about which rights you are seeking to exercise if you contact us. We may need to verify your identity before fulfilling your request. It should not need to be said, but we will never provide worse services to, or in any way punish anyone who chooses to exercise these rights.

You have the following rights with respect to your Personal Information that we process. Except where indicated, these rights apply equally to EU and California users:

• Withdraw Consent: You may withdraw your consent to our processing of your Personal Information, in whole or in part (i.e., for marketing purposes). Certain Services may be ineffective upon opt out.
• Access / Request Information: You may access the Personal Information we hold about you at any time by contacting us directly.
• Modification: You may modify the Personal Information we hold about you at any time via by contacting us directly.
• Erase and Forget. In certain situations, for example when the Personal Information we hold about you is no longer relevant or accurate, you can request that we erase your Personal Information. If you delete your account, all Personal Information will be erased within thirty days of the date of deletion.
• Portability: you may request a copy of your Personal Information and may always move it to other entities as you desire.
• No Sale of Personal Data (California Users only): Go to the Do Not Sell My Personal Information page to stop all “sale” of your Personal Data. See Section 2(b) above for more information about how this works.

If you wish to exercise any of these rights, please contact us at [email protected], or write us at the address below. In your request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only fulfil requests with respect to the Personal Information associated with the email address you send your request from, and we will need to verify your identity before doing so (which is typically done by having you make the request from within the Services). We will comply with your request promptly, but in any event within thirty (30) days of your request (forty-five (45) days for requests under the CCPA). We may need to retain certain information for recordkeeping purposes or to complete transactions that you began prior to requesting such change or deletion.

 

Your Choices

Service Data Submissions

If you wish to add, access, edit, or remove product requirement documents, requests for proposal, proposals, quotes, or contracts, change your password, or request deletion of your personal data, you can do it by sending an email to [email protected]. We will respond to any request to access or delete your personal data as soon as possible but certainly within 30 days. Note that some data requests will require authorization from the company that provisioned your account, as it is typically the case they have an ownership interest in the data.

Your Communication, Marketing and Advertising Preferences

You can opt out of receiving direct marketing communications from Ioterra by following the instructions included in every email sent to you via the “Unsubscribe” link. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.

Please note we will continue to communicate with you regarding changes to terms and conditions, policy updates, Ioterra Service updates, routine customer service messages such as information about current or past reports, shipping activity, service interruptions, data breaches, or other significant information about a Service submission.

Our Use of Cookies and Other Similar Technologies

We use cookies and similar technologies to help us personalize our websites for you, remember your preferences, understand how users are using our websites or app, and help customize our marketing offerings.

Cookies

A ‘cookie’ is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Ioterra uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website.

• Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like shopping baskets cannot be provided.
• Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate.
• Functional cookies. These cookies allow our websites to remember choices you make and personalize your experience. We may store your geographic location in a cookie, for instance, to ensure that we show you the websites relevant to your area.
• Third Party cookies. Third-party cookies are those placed by websites and/or parties other than Ioterra. These cookies may be used on our websites to improve our products or services or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies for these external services.
• Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our websites, what pages they find most useful and how they arrived at Ioterra.com. To learn more about Google Analytics and your data, visit this Google webpage.

How to control cookie settings

Most web browsers allow you to control cookies through their settings preferences. However if you limit the ability of websites to set cookies, you may impact your overall user experience. Some browsers offer a “Do Not Track” (“DNT”) signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognizes DNT signals, we will only process your personal data in accordance with this Policy. Below you can learn about how to control cookie settings on popular web browsers:

• Google Chrome
• Internet explorer
• Safari
• Firefox

Advertising and Modern Marketing Tools

Ioterra may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about Ioterra products and services on our websites and across the internet. To provide this ‘interest-based advertising’, the parties combine non-personal data about your online activities acquired over time, which help cater advertising that we deliver to you. Examples of this may include a Ioterra advertisement on a Facebook page, or a Google-owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your personal information as part of this process. Where necessary we obtain your consent to this process. At all times, you can opt out of these personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI websites and DAA websites. Opting out may make the ads you see across the internet less relevant to you.

If you have opted out of receiving communications from us, we will not use your email for interest-based advertising.

 

How to Contact Us

If you have any questions about the use of your personal information, please send an email to [email protected].

When accessing Ioterra services via www.Ioterra.com, Ioterra, Inc. is a data controller for personal data we collect subject to this Policy.

In many cases, the Ioterra customer provisioning your account may be a data controller subjecting you to different privacy policies. You can contact the provisioning Rebellion customer or Rebellion directly for more information.

Our address is:

Ioterra (a division of Breadware, Inc.)

200 S Virginia, Suite 100

Reno, NV 89501

 

FAQ

The following are basic questions you may have about our Privacy Policy. We encourage you to read the detailed statement above for additional details.

Why is Ioterra updating its Privacy Policy?

We now meet the high standard required by the European Union’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act of 2018 (CCPA) have updated our Privacy Policy to reflect that. We also continue to simplify language and remove jargon, to make our Privacy Policy easier to understand and read.

What is the GDPR?

The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). And because we believe that all our customers can benefit from its mandates, we’re implementing it globally. The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data.

What is the CCPA?

The CCPA was created to protect the privacy and data of consumers. The CCPA initiative states that the act is intended to “give Californians the ‘who, what, where, and when’ of how businesses handle consumers’ personal information.” The act requires businesses tell consumers what data its collecting and gives consumers the right to say no to the sale of their personal information.

How often do you anticipate updating your Privacy Policy?

We will update our Privacy Policy as necessary to ensure that our policies are in line with international regulations, our product and business practices.

What information does Ioterra collect about me?

Ioterra collects your first name, last name, street address, city, state, postal code, country, phone number, email address, delivery/shipping address, payment information, and the content of your chats and other communications with Ioterra customer care or Ioterra partners.

Why does Ioterra need my information?

Ioterra uses the data we collect to provide you the best experience within the services we offer, which includes using data to improve your experiences. We also use the data to communicate with you, for example, informing you about your Service submission status, new services available, security, and other types of updates.

How is my information used?

Ioterra uses the data we collect for the following purposes:

• Service Improvement
• Future Service Development
• Customer Support
• Security, Safety, and Dispute Resolution
• Business Operations
• Communications and Marketing

How does collecting my information help Ioterra improve its services?

We use the information to make sure that we are efficiently expediting the development, production, launch, and maintenance of smart products. We also collect service error information, so we can make improvements to eliminate potential bugs and problems. And finally, understanding how and when our customers collectively use our service helps us design new ways to improve the Service.

Does Ioterra sell information to third parties?

No. We never have.

Can I opt out of sharing my information with Ioterra?

Yes, you can opt out of submitting certain types of personal information to Ioterra, but because Ioterra only collects data related to facilitating product development and production processes, the decision not to submit this information may impact Ioterra’s ability to provide efficient and effective services.

How do I delete my personal data from Ioterra and what are the consequences?

You can always send us an email to [email protected] or contact our customer care team and request that your data be deleted. Please note, however, that by deleting your personal data, in-process product requirement documents, requests for proposals, proposals, quotes, and contracts will be deleted.

How long does Ioterra keep my information?

Ioterra retains personal data for as long as necessary to provide the Services, and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly.

How is information stored and secured on Ioterra servers?

Ioterra is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption.

Is Ioterra using cookies or pixels to gather information?

Yes. We use cookies or similar tracking such as pixels, tags, web beacons, or other identifiers.

Does Ioterra use interest-based advertising?

No. We do not deliver internet-based advertising.

What safeguards are in place for children who have access to Ioterra services?

Ioterra does not target and is not intended to attract children. Ioterra does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our website, we do not intentionally collect personal information from persons under the age of thirteen. If following a notification by a parent or guardian, or discovery by other means, that a child under thirteen has improperly accessed or used the site, we will delete the child’s personal information from our records.

How can I contact Ioterra if I have questions regarding Ioterra’s Privacy Policy?

If you have any questions about the use of your personal information, please send us an email to [email protected].