INTELAEGIS SERVICE PRIVACY POLICY

Last revised: March, 2020

INTRODUCTION

Purpose.  The purpose of this Privacy Policy is to describe how IntelAegis, Inc. (“IntelAegis”) collects, uses and shares information, including personal information, in connection with the provision of its products and services, including the IntelAegis mobile app (collectively, the “Service”) to its customers.  Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

Our Privacy Policy explains:

Information We Collect Through the Service

How We Use and Share Your Information

Access to Your Information and Choices

Security of Your Information

Data Retention

California Privacy Rights

Consent to Processing of Personal Data in United States

Changes to Our Privacy Policy

Questions and How Contact Us

 

For the purpose of this Service Privacy Policy:

            “Customer” means the entity that purchases our Service.

            “Information” means the electronic information or data uploaded into the Service by, for or at the request of our Customer or Users.  Information includes general and personally identifiable information.

            “Mobile Application or Mobile App” means applications or credentials downloaded by any user of our hosted software applications to a mobile device. 

            “User” means any individual that is granted access and use of the Service.

 

Scope; Third Party Services.  This Privacy Policy applies only to Information we collect on behalf of our Customers or Users through the provision of our Service. See our website privacy policy for a description of our privacy practices for information collected at and through our website.  We are not responsible for the privacy practices of our customers or other third parties.

DATA WE COLLECT THROUGH THE SERVICE

Information Customers and Users Provide to Us

We collect Information that Customers and Users of the Service provide to us, for example when Customers provide Information to perform the Service, when Users create or modify an account, register to use our Service, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This Information may include, but is not limited to, name, address, mobile phone number, email address, driver’s license numbers, date of birth, photos provided for facial recognition, real time location, student information system data (i.e. class schedules, teacher affiliations, emergency contact information, other academic or administrative data, etc.), health or medical information, and other information Customers and Users choose to share with us.

Automated Data Collection

Our Service uses various devices to collect Information and other data, such as cameras; counters, door contacts, microphones; BLE beacons; tablet kiosks; smart phones, and other devices running our web app; mobile app; kiosks; and various other sensors necessary to operate and provide the Service to our customers.

No Information from Children Under Age 16

When it is provided to us from our Customers as described above or collected through devices used in providing our Service to our Customers, our Service may collect, store and use information about children.  Outside of the Services requested and purchased by our Customers, we do not knowingly collect personal information about children from children under the age of 16. If you are under the age of 16, please do not attempt to register with us at this Service or provide any personal information about yourself to us.  If we learn that we have collected personal information from a child under the age of 16, not provided by our Customers as described above, we will promptly delete that information.  If you believe we have collected personal information from a child under the age of 16, please Contact Us.

HOW WE USE AND SHARE YOUR INFORMATION

To Provide our Service.  We collect Information described above in order to provide and support our Service to our Customers.  We also use Information as outlined in our Customer agreements to provide Key Performance Indicators (KPIs) and other statistical and descriptive information to our Customers.  KPIs and other statistical and descriptive information are generated using Customer and User Data, proprietary workflows, and proprietary algorithms.  We use Customer and User Information to on-board Customers, register Users, communicate with Customers & Users, operate the Service, administer surveys, and also to respond to support or consulting requests from Customers and Users.

Sharing with Third Parties.  We may provide information to third party service providers that help us operate and manage our Service, host the Information we collect, process orders, provide advertising for us, and fulfill and deliver the Service to you. These service providers will have access to the information described in this policy in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Your Consent.  We require Customer and User consent to use any Information when required by applicable laws and regulations.  We require Customer and/or User consent to use facial recognition.  We require Customer and User consent to use any private medical information in compliance with Customer’s existing policies.  For any individuals under 18, we require appropriate consent from legal guardians.  In addition to the sharing described elsewhere in this Policy, we may share personal information with companies, organizations or individuals outside of IntelAegis when we have the User’s or applicable individual’s consent to do so.

Legal Proceedings.  We will share personal information with third party companies, organizations or individuals outside of IntelAegis if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
  • Enforce applicable Terms of Use, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security or technical issues.
  • Protect against harm to the rights, property or safety of IntelAegis, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control.  If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Service to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell and/or transfer your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

ACCESS TO YOUR INFORMATION AND CHOICES

Customers and Users have the right to access, correct, update and request deletion of personal information that we have collected or which has been provided to us. Customers can access and update certain information we have relating to their online account by signing into the customer account.  If you have questions about personal information we have about you or need to update information we have in our possession, custody or control, you can Contact Us here.

SECURITY OF INFORMATION AND BREACH NOTIFICATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of the information collected through our Service.  However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information provided to us or collected by our Service.  There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.  We host our Service in a third-party private cloud environment.  We have used all good-faith and commercially reasonable efforts to ensure the security of the cloud data centers; however, our cloud hosting partner is not an IntelAegis affiliate, and we do not control its operations.  We assume no liability for the actions of our cloud partner. It is the customer’s responsibility to protect the security of its login information.  Please note that emails and other communications customer’s send to us through our Service are not encrypted, and we strongly advise customers not to communicate any confidential information through these means.

We will promptly notify our Customers in the event of a security incident or breach impacting the applicable customers.

DATA RETENTION

Unless otherwise specified in a Customer or specific User agreement, our standard policy is to retain data in accordance with the following time periods:

User Data:  We may retain User Data for the period of up to 10 years

Student Data: Student data provided to us by our Customers in performance of our Service is stored for the period of 1 school year.

General video and photographic data: To the extent we store any general video or other photographic data, any captured video and other photographic Data may be stored for a period of 10 years.

Other general information: Other general information may be stored for a period of up to 10 years

Customers should feel free to contact us if they desire a different retention schedule for any of this data, and we will discuss alternative arrangements and any fees associated with a customized data retention policy.

CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities).

To obtain this information, please send an email message from www.intelaegis.com/contact/ with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

This Service and Services are not intended for and are not directed to residents of the European Union. By using and accessing our Service, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, email us from www.intelaegis.com/contact, or contact us by US postal mail at the following address:

IntelAegis, Inc.
840 N Old World 3rd St Suite 500
Milwaukee, WI 53203