Privacy Policy

What information do we collect?

In Short: We collect personal information that you provide to us such as name, address, contact information, location, passwords and security data, and payment information. We collect personal information that you voluntarily provide to us when registering at the Sites, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Location. Depending on your use of the Sites, we may collect your approximate location and geographic information as determined through data such as GPS, IP address and WiFi.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. For further information on cookies please visit http://www.aboutcookies.org.

Information collected through our Sites

In Short: We may collect information regarding your mobile device, when you use our apps. If you use our Apps, we may also collect the following information:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).

How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:
To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed ” HOW DO WE HANDLE YOUR SOCIAL LOGINS ” for further information.

To send administrative information to you for Business Purposes, Legal Reasons and/or possibly for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

Will your information be shared with anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

Administrative Purposes. We may use your Personal Information in order to provide you with the Services, to contact you in connection with the Services, or respond to any questions or comments you have in connection with the Site or the Services.

Relevant Advertising. We may disclose Personal Information to affiliates and nonaffiliated third parties to provide you with relevant advertisements, products or services related to the Services.

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Outside Vendors. We sometimes engage with other persons/companies to provide services on our behalf, such as sending newsletters, providing customer services, payment processing, and performing statistical analysis of our Services. We will generally only provide as much Personal Information as is necessary to provide their respective services to us, and we will prohibit such persons/companies from using such Personal Information for any other purposes.

With your Consent. We may disclose your personal information for any other purpose with your consent.

Global Data Processing and Safe Harbor Principles

The information that we collect from you may be transferred to, stored at and processed at a destination outside of the U.S. By submitting your personal information, you agree to this transfer, storage and processing. Where the privacy laws of these countries are not as comprehensive as those in the US, we will take steps to ensure that your privacy rights are respected.

In order to bridge the different privacy approaches between the U.S. and the European Union, the U.S. Department of Commerce, in consultation with the European Commission, developed a “Safe Harbor” framework. We adhere to the Safe Harbor framework, which includes the privacy principles of Notice, Choice, Onward Transfer, Access and Accuracy, Security, and Oversight/Enforcement.

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

Cookies are small text files that are placed on your computer or device by a web server when you access the Site or use the Services.

We may place and access cookies and similar technologies on your computer or device, which are known as “first party cookies”. Cookies may also be placed and accessed by third parties, which are known as “third party cookies” and are described below.

We use cookies to monitor aggregate usage and web traffic of the Sites and Apps, customize and improve the Sites and Apps, help you navigate the Sites and Apps, deliver content specific to your interests, and deliver relevant advertisements to you.

We may use “web beacons” (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Site and in connection with the Services. For example, such web beacons can be used to deliver or communicate with cookies, to track and measure the performance of our Site, to monitor how many visitors view our Site, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user’s hard drive or device, web beacons are typically embedded invisibly on web pages (or in an email).

Types of Cookies

We may use the following types of cookies:

Strictly Necessary Cookies: These are cookies that are essential to enable you to use the Sites and Apps, for example moving around our website and using its features (e.g. cookies that enable you to log onto the Site).

Performance Cookies: These are cookies which collect information about how and when you and other visitors interact with our Sites and Apps (e.g. pages viewed most often) and the information collected by these cookies is used to improve the efficacy and efficiency of the Site.

Functionality Cookies: These are cookies that allow our Sites and Apps to remember choices you have made (such as your login information) and provide you with content and features which are customized to you. For example, providing you with relevant content (or in your local language) by using a cookie to remember which region you are in.

Advertising Cookies: These are cookies which are used to deliver advertisements to you which are more relevant to you and your interests. We may also share this type of information with third parties for these purposes.

The types of cookies described above may be “session cookies” or “persistent cookies”. Session cookies are only stored on your device while you are using the Sites and Apps, and are deleted when you log off from the Sites and Apps or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Site or close your browser.

Third Party Cookies

Some cookies may be placed by third parties when you use the Sites and Apps as some third party services providers that we engage (including third party advertisers) may place their own cookies on your hard drive or device. These cookies may provide information to those third parties about your browsing habits. Some also help to serve you with advertisements which are more relevant to you.
By using the Sites and Apps, you consent to the processing of data about you in the manner and for the purposes set out above.

Cookies Settings

Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Sites and Apps.

If you continue to use the Sites and Apps, you consent to our use of cookies as described in this Privacy Policy.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from its unauthorized use or disclosure, the purposes for which we process such information and whether we can achieve those purposes through other means, and the applicable legal requirement.

In some circumstances you can ask us to delete your data: see “What Are Your Privacy Rights” below for further information.

In some circumstances we may anonymize such Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at
1-888-845-4983 or sales@iclsystems.com.

What are your privacy rights?

In Short: You may review, change, or terminate your account at any time.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Note your preferences when you register an account with the site.

Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information as stated below.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites.. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

Additionally, California residents are entitled to additional protections under the California Consumer Privacy Act of 2018 (“CCPA”). Capitalized terms that are not defined herein shall have the meanings set forth in the CCPA.

Categories of Personal Information we have collected from or about our users in the preceding 12 months:

• Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number)
• Characteristics of protected classifications (e.g. gender, age)
• Commercial information (e.g. products or services purchased, purchase history)
• Internet or other electronic network activity (e.g. browse or search history)
• Geolocation data (e.g. latitude or longitude)
• Audio, electronic, visual, or similar information (e.g. recording of guest service calls)
• Inferences drawn from any of the above (e.g. preferences or characteristics)

Categories of Sources from which we have collected Personal Information about users (for more information, see the Information We Collect section of this privacy policy).

• Sites
• 3rd Party Websites
• Data Brokers
• Social Media

Business or Commercial purposes for which we have collected or sold Personal Information about users in the preceding 12 months (for more information, see the Use of Information section of this privacy policy).

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by us.

Categories of Personal Information we have sold about users in the preceding 12 months

• Internet or other electronic network activity (e.g. “cookies” or other tracking tags)

Categories of Personal Information we have disclosed for a business purpose in the preceding 12 months

• Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number)
• Characteristics of protected classifications (e.g. gender, age)
• Internet or other electronic network activity (e.g. browse or search history)

Non-Discrimination
We will not discriminate against you because you exercise your rights. For example, we will not deny you services or charge you a different price or rate for services if you make an access, deletion, or do not sell request.

You have the following rights under the CCPA –

The right to make requests as follows:

Access Request (can make a request no more than twice in a 12-month period) – Request that we disclose the following information:

• Categories of PI we collected about you during the preceding 12 months
• Categories of sources from which PI is collected
• Business or commercial purpose for collecting or selling PI
• Specific pieces of PI we collected about you
• Categories of PI we have sold about you
• Categories of third parties to whom the PI was sold
• Categories of PI disclosed about you for a business purpose
• Categories of third parties to whom PI was disclosed for a business purpose

Deletion Request

• Request we delete PI that we collected from you
• Request we opt you out of the sale of your PI

Access and Deletion Requests

Contact us at www.iclsystems.com or
sales@iclsystem.com

Do we make updates to this policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How can you contact us about this policy?

If you have questions or comments about this policy, you may email us at sales@iclsystems.com or by writing to:

ICL Inc.
1100 Crescent Green Dr., Suite 105
Cary, North Carolina 27518

How can you review, update, or delete the data we collect from you?

How to Access or Modify Your Information

We strive to keep all personal information accurate and complete. You are always fully in control of the information that we maintain to service you. You can change your personal information at any time and as often as necessary. You can also request that information be deleted. Information may be withheld or exempted from deletion if this is required by law or is part of a fraud investigation, or as otherwise as described above in the Use of Information section.

If you have questions or comments about this policy, you may email us at sales@iclsystems.com or by writing to:

ICL Inc.
1100 Crescent Green Dr., Suite 105
Cary, North Carolina 27518

Complaints

Privacy Complaints
If you believe that we have not complied with this Privacy Policy, please contact us at:

ICL Inc.
1100 Crescent Green Dr., Suite 105
Cary, North Carolina 27518

You may also email us at www.iclsystems.com or sales@iclsystems.com and explain thoroughly where Privacy Policy lacked compliance. We will investigate your complaint promptly.