Privacy Policy
Version 1.1
This policy effective as of: June 12th, 2023
This Privacy Policy describes how Indr, Inc. (“Indr,” “we“, “us” or “our“) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). Indr may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
Indr is a human-centered digital transformation platform to allow organizations to listen and engage with their employees and customers. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing Indr services to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer.
Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.
Table of Contents
Personal Information We Collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
- Demographic data, such as your city, state, country of residence, and postal code.
- Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as data providers and data licensors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate and improve the Service and our business;
- personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data as further described in ‘To create aggregated, de-identified and/or anonymized data’ below.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Policy.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
How We Share Your Personal Information
We may share your personal information with the following third parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:
Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services).
Advertising Partners. We may sometimes share your personal information with partners or enable partners to collect information directly via our Service.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transfers. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Indr, financing of Indr, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). We may also disclose some or all of your personal information to an acquirer, successor or assignee of Indr as part of any business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, sale of assets, or similar transaction, and/or in the event of bankruptcy, dissolution, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your Choices
In this section, we describe the rights and choices available to all users. Users who are located in California, and Europe can find additional information about their rights below.
Other Sites and Services
The Service may contain links to other websites, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites, or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use
Security Practices
The security of your personal information is important to us. We employ organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. Email, in particular, is an insecure way to transmit personal information. Please take special care regarding what information you send to us via email.
We take all reasonable steps to protect the information we receive from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, but no security measures are perfect; the risk of a data breach is possible.
- Personal data is encrypted during transmission.
- Personal information is encrypted at rest at our data centers.
- Employees are given access to users’ personal information only on a “need to know” basis.
- All employees are required to receive training on information security.
- All employees with access to personal information are subject to background checks.
- Before sharing personal information with our vendors, we make sure they have implemented security procedures to protect your data. Our vendors and partners are not permitted to use or share your information for any purpose other than to provide the services for which they have been contracted.
Users of the Service can raise security related issues at security@indr.com
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information
International Data Transfers
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the information provided below in the section Notice to European Users regarding transfer of personal information outside of Europe.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law, will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
How to Contact Us
If you would like to exercise your rights under this Policy, please submit your request via the form at http://indr.com/dsar
Please direct any questions or comments about this Policy or privacy practices to privacy@indr.com
Our US postal address is:
Indr, Inc.
4445 Eastgate Mall Suite #200
San Diego, CA 92121
Our UK postal address is:
Indr Ltd.
Oak House, Tanshire Park, Shackleford Road,
Elstead, Surrey, United Kingdom, GU8 6LB
GDPR – Notice to European Users
Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals subject to this Privacy Policy located in the European Economic Area or United Kingdom (i.e., “Europe” as defined at the top of this Privacy Policy).
Controller. Indr is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the so-called ‘UK GDPR’).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
EU Representative
Osano International Compliance Services Limited
ATTN: IKVT
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0
UK Representative
Osano UK Compliance LTD
ATTN: IKVT
42-46 Fountain Street
Belfast
Antrim
BT1 – 5EF
Legal Basis for Processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
- Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Retention
| Purpose | Category of Data | Legal Basis |
| Service delivery and operations | Contact data Demographic data Communications data Communication interaction data | Contractual Necessity. |
| Research and development To create aggregated, de-identified and/or anonymized data | Any and all data types relevant in the circumstances | Legitimate interest. We have a legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers. |
| Direct Marketing | Contact data Demographic data Communications data Marketing data Communication interaction data | Legitimate Interest. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications. |
| Interest-based advertising | Demographic data Device data Online activity data | Consent. |
| Service improvement and analytics | Contact data Demographic data Device data Online activity data | Legitimate Interest. We have a legitimate interest in offering you a good service, including by improving our Service based on how you use our Service. Consent. In respect of any optional cookies used for this purpose. |
| Compliance and protections | Any and all data types relevant in the circumstances | Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety. |
| Further uses | Any and all data types relevant in the circumstances | The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent. If the relevant further use is not compatible with the initial purpose for which the personal information was collected. |
Other Info
Your Rights
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the UK – the contact information for the UK data protection regulator is below:
Data Processing outside Europe
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
- However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
- However, in these cases:
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
Sub-processors
|
Sub-processor |
Purpose |
Data Location |
| Amazon Web Services | Hosting & Infrastructure | United States |
| Neo4j Aura | Cloud-based Graph Database | United States |
| Google, Inc | Cloud-based Email Service Provider, Analytics | United States |
| HubSpot, Inc. | CRM & Marketing Platform | United States |
| Intercom, Inc. | Cloud-based Customer Support Services | United States |
| Slack Technologies | Cloud-based Team Chat Services | United States |
| Atlassian | Feedback Mgmt & Processing | United States |
| Databricks | Data Analytics | United States |
| Osano, Inc. | Cookie Consent Management | United States |