Privacy Policy: Website

Last update: January 16, 2023

This Privacy Policy aims to reinforce our commitment to the processing of your personal data in accordance with applicable data protection legislation, specially General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”).

Through this Policy, you will understand, in a clear and transparent way, how we process your personal data collected through our Website and other media and marketing sources.

To understand how your data is processed by the Incognia Solution, see our Privacy Policy - Incognia Solution.

If you are from Brazil and want to know how we protect your privacy and personal data in accordance with the Brazilian General Data Protection Law (“LGPD”), see our Privacy Policy BR (in Portuguese).

1. How is your personal data collected?

We collect your personal data provided by you when you:

• Browse our Website;
• Agree to the collection of certain cookies;
• Fill in forms for downloading materials, for receiving the Newsletter and for contact requests; to apply for vacancies or when registering for our events;
• Participate in events promoted by us or our partners;
• Engage in social media with Incognia content;
• Are indicated as a potential customer by marketing companies that we hire for the purpose of offering our solution.

2. What data is collected and for what purposes?

The data we collect is always within a professional context and we process only minimal personal data that is necessary to achieve the specified processing purposes. In addition, we do not collect or process any personal data considered sensitive.

Thus, in order to reinforce our commitment to the principles of Purpose, Necessity and Transparency, we detail below the types of data collected through the aforementioned sources and consolidate the respective processing purposes.

Data collected via our Website:

• Website navigation: We collect the IP (Internet Protocol) addresses of all visitors to our website, as well as page requests, browser type, operating system, average time spent on our website and email address if you are logged into your browser using an email address that we have already registered in our systems. We use this information to help us understand your activity on the website and to monitor and improve our website. Some of the data described, as well as information related to audio, video, and browser settings, computer properties (available memory), text fonts, availability of sensors, available accessories, among other properties, may be used for internal research purposes for the development of new solutions and improvement of our technology.
• Cookies: We collect and store cookies on your browser to personalize your experience, correct errors and improve the usability of our Website. To learn more about this topic, as well as to configure your preferences regarding the storage of cookies, see our Cookies Policy.
• Material Download Forms: We collect your contact details such as name, surname, professional email address, company and title, provided by you when you sign up to receive our Newsletter or when you download case studies, ebooks or other materials available on our main web page or our blog. This data is used to send the requested material and also to send content related to the topic of the downloaded material or marketing communications that we believe may be of interest to you.
• Contact form: We collect your contact data such as name, surname, professional email address, company and title, which you provide us when you request our contact to talk about a certain subject or with a certain sector of Incognia, whether to clarify doubts about our solutions, events, available vacancies, or even to establish partnerships, produce journalistic material, among other purposes. We also use this data to send you content and marketing communications that may be of interest to you. By filling out our communication form in order to apply for a job position with Incognia, you will provide us with your personal data, which will be processed in accordance with the provisions of the Privacy Notice - Recruitment and Selection.
• Registration for events: We collect your identification and contact data such as first name, last name, professional email address, company and title, which you provide to us when you register for a lecture, webinar or any type of event promoted by Incognia. These data are used to register your participation and provide information about the event, as well as forwarding emails and marketing communications about our products and services of potential interest to you.

In addition to the personal data collected via the Website, we also collect some contact data about you through the following sources:

• Participation in events: We collect data such as your name, professional email address, company and title, when you participate in an event promoted by our partners and sponsored by Incognia, or when you provide us with data when visiting our stands at fairs and in-person events. We use these data to send you content and marketing communications that may be of your interest.
• Marketing companies: Through contracted marketing companies, we collect your professional contact data, such as first name, last name, professional email address, company and title, as a representative of companies that may be potential clients of Incognia, in order to establish contact for offering our products and services, as well as sending materials and communications that may be of interest and use to the company you work for.
• Social Media: When you engage with Incognia content on or through third party websites or social networks, plug-ins and applications, we may have access to certain information associated with your social media account (e.g. first name, last name, username, email address, profile picture). We may use this information to personalize your experience on the website, plug-ins and third-party applications, to provide you with other information you may request, or to communicate with you about matters of potential interest to you.

You can always opt out of receiving marketing communications or emails from us by following the unsubscribe instructions at the end of each communication/email or by contacting our Data Protection Officer/DPO (“Data Protection Officer” ) via email to dpo@incognia.com.

3. Does Incognia process data from children or adolescents?

As we do not collect data that allow us to know the age of the data subjects, it is not possible to detect whether the individual in contact with us is a child or adolescent. However, we understand that our Website is aimed at an adult audience, including with regard to the language used, which makes it unlikely for a child or adolescents to access our means of contact and provide personal information.

4. What role does Incognia play as a processing agent?  

We act as a Controller of personal data, as we define the purposes of processing and make all decisions related to the data collected. Because of that we implement appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with the Regulation.

5. With whom does Incognia share my personal data?

We share your data with processors, that is, agents who perform data processing on behalf of a Controller (in this case Incognia) to facilitate the operation. These agents may not use the information we share for any purpose other than those we determine for them. Currently hire, for example, the following Processors: Hubspot, for lead registration, segmentation, sending marketing campaigns, storage and communication with clients and partners; and Google Drive, for secure data storage. 

We may also share your data with marketing agencies for the purposes of building a base of contacts, audiences and other marketing-related actions.

We may also occasionally share your data obtained through registration or participation in an event promoted by Incognia, with sponsors and partners of the event. You will be informed in advance of this sharing.

To access information about with whom we share your personal data with, please contact our Data Protection Officer/DPO on dpo@incgnia.com.

6. How long is personal data stored?

Your personal data is stored in the company only for the time necessary to achieve the indicated processing purposes. After the processing purposes have been achieved, your data is securely and permanently deleted. Exceptionally, we may retain some of your personal data for longer for the purposes of audits, accountability, compliance with legal or regulatory obligations, compliance with court orders and the regular exercise of rights in judicial and administrative proceedings.

7. How and where is my personal data stored?

Your personal data is stored on Hubspot and Google Drive, both located in the United States, which apply physical, technical and organizational security measures such as encryption in the transport and storage of data. In addition, such information is accessed by a restricted number of employees and is only stored for the time necessary for the purposes described in this Policy.

8. Is there international data transfer?

Your personal data is stored on Google Drive and Hubspot, both located in the United States of America. We use secure protocol to protect data transfer to our servers in encrypted form. 

So, when there is a data collection from Users that is not in the United States, there will be an international transfer.

9. What security measures are in place to protect data?

We adopt technical and administrative measures capable of protecting your personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or dissemination. We apply techniques in encryption and access management security measures such as risk monitoring, systems and control application, environment and logical and physical access management, risk mitigation and assessment mechanisms and change management. Control reports from systems and organizations are evaluated by third parties to certify Incognia's compliance.

10. What are my rights with respect to my personal data?

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. Such as:

• Data processing confirmation
• Access your own personal information
• Information on data sharing
• 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, whether you have an account or not, please submit a request via dpo@incognia.com or if you are a California resident, you also have the right to opt out of our sales of some data related to the data subject via email or submitting a request by clicking here: Do Not Sell My Personal Information

In addition, to access your right to opt out of receiving marketing communications or emails from us, you can also follow the unsubscribe instructions at the end of each communication/email. 

Once you opt-out, Incognia will end your personal data sales. You may change your mind and opt back in by sending us a new request to dpo@incognia.com.

We also guarantee that the 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.

11. How to contact Incognia's DPO?

If you have any questions, comments or suggestions, you can contact our Personal Data Processing Officer/DPO directly by sending an email to dpo@incognia.com.

12. Privacy Policy Amendments

We may update and change the terms of this Privacy Policy from time to time. On our website, you will always find the latest version of the terms and, if you want,  you can access previous versions by registering a request by sending an email to dpo@incognia.com.

Incognia
251 Little Falls Drive, City of Wilmington
County of New Castle, Delaware 19808

Data Protection Officer- DPO: Dayana Caroline Costa (dpo@incognia.com)