Privacy Policy: Website


Last update: February 04, 2021

The purpose of this Privacy Policy is to demonstrate the commitment of Incognia US, Inc, a Delaware Corporation, located at 2479 East Bayshore Road, Suite 150 - Palo Alto, CA 94303, USA with the privacy and protection of personal data collected through its technology in accordance with the applicable privacy laws and regulations, ensuring transparency and best practices for the protection of personal data.

 

About

The Website Privacy Policy deals with the collection and processing of personal data of website visitors (the "data subjects"). The contact data that will be detailed here are provided voluntarily by the data subjects themselves through the contact means available on our page.

In addition to the contact data detailed in this Policy, this website also stores cookies in your browser to customize your experience, correct errors and improve usability. You can set your preferences regarding the storage of cookies. To learn more, read our Cookie Policy.

Personal data processing

Data source

Our website collects personal data by filling out forms, and via buttons enabling download of assets, such as requesting our SDK, among others.

The data collected in the "Request SDK" form is used for registration and communication with potential customers; providing requested products and services; and, if authorized by the data subject, targeting and marketing campaigns.

The data from the "Contact us" form is provided by subjects who want to contact us about a certain subject or with a certain sector of Incognia, either to clarify doubts about products, events, job opportunities, etc.; to establish partnerships; to produce journalistic articles; among other purposes. These data are not used for any purpose other than that intended by the subjects themselves at the time of contact.

The data on the download case study, ebooks and other content forms is provided by the holder who wishes to download any case study or other content available on our “resources” page or another page that contains some materials. These data are used to send this material and future content related to the topic.

Finally, the chat bot is available on our website for the data subject to ask general questions about Incognia or to direct the subject to a member of the Incognia team who can answer them. The bot collects contact information so that the communication continues in case of disconnection.

Categories of data and purposes of the processing

Incognia follows the principle of minimization established by the EU General Data Protection Regulation, which states that "personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed" (Art. 5, 1, (c), GDPR). For this reason, and because Incognia has the commitment of being transparent, we detail all the data that are collected through our website and for which purposes below.

Request Incognia SDK Form

Category

Description

Purposes

Contact

Name

Lead registration

Product communication

Targeting [1]

Marketing campaigns [1]

Last name

Corporate email

Job title

Company name

[1] Only if authorized by the data subject

“Contact us” Form

Category

Description

Purposes

Contact

Name

Contact with a specific area or team at Incognia for the purposes intended by the subjects themselves, including: answering questions; establishing partnerships; producing journalistic articles; obtaining information about job opportunities, etc.  

Last name

Work Email Address

Company name

Job title

 

Download Case Study, ebooks, analyst reports and whitepapers

Category

Description

Purposes

Contact

Name


Case study, ebooks, analyst reports or whitepaper submission

Sending future content related to the topic

Last name

Work Email Address

Company

Job title

 

Chatbot

Category

Description

Purposes

Contact

Name

Answer questions on general topics

Direct the data subject to a member of the Incognia team that can help them

Email

 

Sensitive data

We do not collect or treat sensitive data - information that reveals ethnicity, religion, political, religious, philosophical opinion or of union entities or data related to health, sexual life, genetics and biometry (Art. 5, II, Law No. 13.709/2018, Brazil).

Child data

As we do not collect data that allow us to know age information, it is not possible to detect whether the individual in contact with us is a child. However, we consider that our website is directed to the adult audience, especially with regard to the language used, which makes it unlikely that a child will have access to contact means and provide personal information.

Form and duration of the processing

Automated decision-making

There is no automated decision-making for any of the purposes of personal data processing detailed in this Privacy Policy. All the processing carried out with the data collected through the website contact means has human interference from members of our team.

Security measures

The data referred to in this Policy is collected directly from the data subject, who voluntarily provides it via form or chat, and is used only for the purposes intended and authorized by them. This data is stored in Hubspot and Google Drive cloud storage services, which apply physical, technical and organizational security measures, such as encryption in data transport and storage. In addition, such information is accessed by a restricted number of employees and is stored only for the time required for the purposes described in this Policy.

Data transfer

We only share data with processors, that is, agents who perform data processing on behalf of a controller (in this case Incognia) to facilitate the operation. These processes cannot use the information shared by Incognia for any purpose other than that intended by Incognia itself. They are: Hubspot, for lead registration, targeting, sending marketing campaigns, storage and communication with customers and partners; and Google Drive, for safe data storage.

Controller and processor responsibility

Incognia processes personal data as controller, which is the agent in charge of the decisions regarding the processing, in accordance with the Section 4 of the General Data Protection Regulation (GDPR). We use processors Hubspot and Google Drive, as detailed in the "Transfer" section, to facilitate our operation.

According to Chapter 4, Article 24 of the GDPR, the controller shall implement appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with the Regulation.

And also according to the GDPR, in Chapter 8, Article 82, any controller involved in processing shall be liable for the damage caused by processing which infringes the Regulation.

In addition, a processor shall be liable for the damage caused by processing only where it has not complied with obligations of the Regulation specifically directed to processors or where it has acted outside or contrary to lawful instructions of the controller.

Processing agents (controller and/or processor) shall be exempt from liability if it proves that it is not in any way responsible for the event giving rise to the damage.

Rights of the data subject

Incognia's mission is to respect your privacy and ensure the protection of your data. Therefore, we guarantee the exercise of the rights of the data subject as provided for in the General Data Protection Regulation of the European Union (GDPR) and the California Consumer Privacy Act (CCPA), which can be requested via email dpo@incognia.com.

Data processing confirmation

Data subjects (the “consumers”) have the right to know if any personal information about them is being processed. You may direct a request for the exercise of this right to the client with whom you have a direct relationship or by submitting a request to dpo@incognia.com.

Access your own personal information

Data subjects have the right to know which personal data of theirs is being collected by our technology, as well as to request a copy of any collected information. You may direct a request for the exercise of this right to the client with whom you have a direct relationship or by submitting us a request to dpo@incognia.com.

Information on data sharing

Data subjects have the right to know if their personal data is being shared, and with whom. This information can be observed in the previous section “Data sharing", in which we explain how and why we share data with our clients.

Opt-out

In order to have control over their own personal information, data subjects have the right to withdraw or refuse consent for certain actions to be carried out at any time. To exercise this right, you may submit a request by clicking here: Do Not Sell My Personal Information. Incognia only uses personal information - Mobile Advertising ID and current location - provided in the opt-out request to review and comply with it. Once you opt-out, Incognia will not only end your personal data sales, but also interrupt data collection from your device. You may change your mind and opt back in by sending us a new request to dpo@incognia.com.

Anti-discrimination clause

Data subjects have the right to equal service and price, even when they exercise privacy rights. Incognia encourages personal data subjects’ control over their data and users will not be harmed morally or financially for the exercise of rights, as detailed in the “Personal data collection” section.

Contact

If you have any questions, comments or suggestions, please contact our Data Protection Officer by sending an email to dpo@incognia.com.

 

Previous versions of the Website Privacy Policy