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Legal documents governing your use of iboss services and our commitment to data protection
Last Updated: June, 2024
This Regional Privacy Policy Supplement ("Regional Supplement") is provided as a supplement to the iboss Privacy Policy to provide additional information to individuals who are residents of California or are located in the European Union, United Kingdom, and Switzerland ("Relevant Regions") as required under applicable data protection laws in those regions ("Regional Laws"). This Regional Supplement includes information such as our purposes for personal information processing, the categories and sources of personal information, third parties with whom we may share personal information, and the rights available to individuals under Regional Laws.
Certain Relevant Laws provide individuals in Relevant Regions rights regarding their Personal Information, as set forth below. If a Relevant Law applies to you, you may submit a request to exercise your right(s) in relation to your Personal Information as set forth in the Privacy Policy.
Know/Access: You may request access to the specific pieces of Personal Information we have collected about you, which may, in accordance with Relevant Laws, be limited to the information collected in the prior 12 months. You may also request additional details about our information practices, including the categories of Personal Information we have collected about you, the sources of such collection, the categories of Personal Information we share for a business or commercial purpose, the categories of third parties with whom we share Personal Information, and our purposes for collecting or selling Personal Information.
Correct/Rectify: You may request that we correct or rectify the Personal Information we have collected about you. Please note that we may decline to correct certain information as required or permitted by applicable law, and we may deny your correction request if retaining the Personal Information in its current state is necessary for us or our service providers under any permitted exceptions. We are required by law to verify your identity prior to correcting your information in order to protect your security and privacy.
Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive Personal Information, as defined in Relevant Laws, to certain purposes as set forth in the Relevant Laws.
Delete/Erase: You may request that we delete the Personal Information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the Personal Information is necessary for us or our service providers under any permitted exceptions. If you request to delete your Personal Information, certain features of our Website or Platforms may no longer be available to you.
Restrict or Object: You may request that we limit the way we use your Personal Information or object to certain forms of processing.
Data Portability: You may request for your Personal Information to be transferred directly to another organization.
Automated Decision Making and Profiling: You have the right not to be subject to automated decision-making if it produces a legal effect that significantly affects you, with certain exceptions. Please note that we do not generally engage in this activity and do not as a matter of course control or process Personal Information for this purpose, and if we do, we comply with Relevant Laws in connection with such data processing.
Not to Receive Direct Marketing Communications: In some Relevant Regions, you may request to not receive our direct marketing messages, as more fully set forth below.
Certain other details regarding the processing of Personal Information that individuals located in Relevant Regions may be entitled to receive are contained in other provisions of the Regional Supplement.
You may be able to access, correct, or delete your Personal Information using your account settings and tools that we offer, but if you aren't able to do that, or you don't have an account, or you would like to contact us about one of the other rights, our contact information is set forth in "How May I Contact iboss?" below. Individuals in the European Economic Area, Switzerland, and United Kingdom (collectively, "Europe") also have the right to make a complaint to a government supervisory authority.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. Under some Relevant Laws, you may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We may not be able to provide all of the information you request, but we will tell you if we cannot provide certain information and why.
Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your Personal Information.
If you are a California resident, the CPRA requires us to disclose the following information with respect to our collection, use, and disclosure of Personal Information.
Categories and Specific Pieces of Personal Information Collected: In the preceding 12 months, we have collected the following categories of Personal Information: certain identifiers, certain of the Personal Information categories listed in the California Customer Records statutes, commercial information, internet or other similar network activity, professional or employment-related information, and geolocation data. For more detail regarding the Personal Information we collect, please see "What Information Do We Collect And From What Sources" in our Privacy Policy.
Business or Commercial Purpose for Collecting and Using Personal Information: We collect Personal Information for the business purposes described in "How Do We Use Personal Information" in our Privacy Policy.
Categories of Sources of Personal Information: We collect Personal Information directly from you, automatically, and from other sources, each of which is more particularly described in "What Information Do We Collect And From What Sources" in our Privacy Policy.
Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of Personal Information for business or commercial purposes as set forth in "What Information Do We Collect And From What Sources" in our Privacy Policy.
Categories of Third Parties with whom We Share Personal Information: We may share your Personal Information with the third parties as described in "What Personal Information Do We Disclose to Third Parties" in our Privacy Policy.
"Sale" or "Sharing" of Personal Information: iboss does not as a matter of course "sell" or "share" (as those terms are specifically defined in the CPRA) your Personal Information.
Retention of Data. Please see "What Is Our Personal Information Retention Policy" in our Privacy Policy for details regarding the time period for which we retain Personal Information or the criteria we use to determine how long we retain Personal Information.
We will not discriminate or retaliate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; and/or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California residents may request certain information regarding our disclosure (if any) of Personal Information to third parties for their direct marketing purposes, pursuant to California Civil Code Section 1798.83 (the California "Shine the Light" law). To make such a request, please contact us, identify yourself as a California resident and provide sufficient information so we can take appropriate action, such as your name, email address or any additional information required.
If you are located in Europe (as defined above), the legal bases for using your Personal Information as set out in our Privacy Policy are as follows:
Necessary for Performance of a Contract: If we or our affiliates have entered into a contract with customers, partners, suppliers or other third parties, we may need to process your Personal Information or we may need to process your Personal Information to enter into a contract with you for employment purposes if you have applied for a job with iboss.
Consent: Where you have provided your consent for us to engage in marketing activities with you, we may need to process your Personal Information or where you have provided us with explicit consent to process your sensitive or special categories of Personal Information in connection with our recruiting activities.
Legitimate Interest: We may need to process your Personal Information where we have a legitimate interest in doing so, such as (1) to communicate with you in response to your requests, questions, inquiries, and submissions; (2) to conduct advertising, marketing and promotional activities in connection with operating our business; (3) for research and development, operation, security and optimization of our Websites, Platforms, and business; (4) to process a job application, conduct recruitment activities, and respond to applications; (5) for certain administrative purposes such as network security, fraud prevention, and incident management; (6) to monitor and improve our services; and (7) to maintain records of our activities, such as for audit and compliance purposes.
Comply with Legal Obligations: Where we are required to comply with laws or legal obligations.
We may transfer to, process, and store the data we collect about you in countries other than the country in which the data was originally collected, including the USA, Canada, or other destinations outside Europe. Those countries may not have the same data protection laws as the country from which you provided the data. When we transfer your data to other countries, we will protect the data as described in our Privacy Policy and comply with Relevant Laws providing adequate protection for the data.
We transfer your Personal Information outside Europe with appropriate organizational safeguards in place. Specifically, we transfer your Personal Information in accordance with the Standard Contractual Clauses ("SCCs"). The SCCs are part of our Data Processing Addendum. By utilizing our Website and Platforms, you agree to the transfer of your Personal Information in accordance with our Data Processing Addendum.
You may request more information about the safeguards that we have put in place in respect of transfers of Personal Information by contacting us as described below.
Data protection laws in the Europe differentiate between the "data controller" and "data processor" of Personal Information.
Data Controller. iboss is the data controller for the processing of your Personal Information relating to customer accounts, marketing, and Personal Information collected through our Website and the Platforms when we engage in the foregoing activities. You can find our contact information, and the contact information of our EU-based representative, below.
Data Processor. iboss is the data processor for the processing of Employee Personal Information (as defined in our Privacy Policy). If you are an employee or end user of one of our customers, please contact the appropriate customer of iboss to exercise the rights described above.
iboss may review and update this Regional Supplement periodically without any prior notice. We will indicate in this Regional Supplement when it was most recently updated. In the case of material changes to the Supplement, we may notify you of such changes.
To contact iboss about any of the foregoing matters, please contact us as set forth in the Privacy Policy.