Privacy Policy

Effective October 13, 2021

Your Privacy is Our Priority

This is the privacy policy (“Privacy Policy”) that governs how we, Innventural, Inc. (“Company”,” "Us", "We", or "Our"), use Personal Information  (as defined below) that we collect, receive, process and store about our website visitors and candidate employees in connection with the use of the website www.innventural.com and any other website that we operate (each, together with its sub-domains, content and services, a “Site”). 

We have implemented this Privacy Policy because privacy is important to us. This Privacy Policy explains our online information practices and the choices our website visitors and candidate employees can make about the way personal information is collected and used in connection with the use of the Site.

By browsing, accessing, or using the Site, you agree to the terms of this Privacy Policy and the accompanying Terms of Service. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Information We Collect

While using our Site, we may ask you to provide us with certain Personal Information that can be used to contact or identify you. Personal Information may include, but is not limited to, your email address, name, birthdate, phone number, postal address, and for the candidate employees, background and professional experience information. Because we value your privacy, we treat this data carefully and safeguard it from unintended disclosure or access.

Log Data

We collect information that your browser sends whenever you use our Services ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor, and analyze this type of information in order to increase the functionality of our Services and to improve your user experience. These third-party service providers have their own privacy policies addressing how they use such information. By accessing and using the Service, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site.

When you access the Services by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, your location information, and other statistics.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information in order to improve the Site.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “do not track” feature on most browsers provides information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our website and we recommend that you leave them turned on.

Behavioral Remarketing

Company uses remarketing services to advertise on third party websites to you after you visit our website. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Site. The following lists the remarketing services we use:

1. Google

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page.

Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at https://policies.google.com/terms.

How We Use and Share Your Information

You authorize us to use Personal Information, Log Data, and information collected from Cookies and Behavioral Remarketing (collectively, the “Information”) for the purpose of providing the Site, identifying and communicating with you, responding to your requests/inquiries/job applications.

You also authorize us to use and/or share Information as described below.

Service Providers

We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform services related to the Site and/or to assist us in analyzing how our Services are used.

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Communications

We may use your Personal Information to contact you with the newsletter sending activity, recruitment, marketing, or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

To limit the use and disclosure of your personal information, please submit a written request to support@innventural.com

Data That Does Not Identify You

In an ongoing effort to better understand our website visitors, we may analyze information in aggregate form in order to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. 

When you use our Site, we collect statistical information about the usage of a group and/or an event in an anonymized form. This information does not identify you personally. We may share this information with you as well as with our affiliates, agents, customers, and business partners.

Compliance With Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Site.

Merger, Sale or Bankruptcy

In the event that we are acquired by or merged with a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we may have collected from you. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail and not send us by unsecure email.

Information for California Residents and California Notice at Collection

This section applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act (“CCPA”), and it supplements the information in the rest of our Privacy Policy. Data about individuals who are not residents of California may be handled differently and is not subject to the same California rights described below. In addition, this section does not apply to personal information we collect in the following circumstances:

  • From employees or job applicants in their capacity as employees or job applicants;
  • Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and
  • Information that we process as a service provider on behalf of other businesses, such as our Clients. Where we are acting as a service provider to a Client, if you wish to exercise any rights that may be available to you, you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests.

Your California Privacy Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information;
  • Provide access to and/or a copy of certain personal information we hold about you; and
  • Delete certain personal information we have collected from you. If you choose to exercise this right, please note that we may retain your personal information as permitted under applicable law, including but not limited to the following purposes: to provide goods or services within the context of our relationship with you; to detect security incidents or other fraudulent or illegal activity; and to comply with our legal and regulatory obligations.

If you choose to exercise any of these rights, you will not be discriminated against or receive discriminatory treatment. You also may have the right to receive information about the financial incentives that we offer to you (if any).

When you seek to exercise your rights, we will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum and depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, phone number, email address, and other information. If we are unable to verify your request, we will notify you and request additional information. If we do not receive this information, we will close your request due to our inability to verify your identity.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. Authorized agents will be required to provide proof of their authority to act on your behalf.  If an authorized representative submits a request on your behalf, we will contact you to confirm their representation. If we are unable to verify your identity, or confirm that you have authorized the request, we may not be able to respond to your request in full.

Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased products from us, you may submit a request to opt out of any potential future sales under Nevada law by email to support@innventural.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Information for International Users 

We are based in the United States and, regardless of where you use our Site, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Site, you consent to this collection, transfer, storage, and processing of information to and in the United States.

International Transfer

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you choose to provide information to us, please note that we may transfer the information, including Personal Information, to another country for processing. Generally, this will be either to the United States or to Turkey.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

EU-US and Swiss-US Privacy Shield Frameworks

Company complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Company has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern.

Company is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

As part of our Privacy Shield certification, and our overall commitment to privacy, we are responsible for onward transfers of personal data (as that term is defined under applicable law) provided to us by our website visitors and candidate employees, but particularly from those who are EU and Swiss residents. We are liable to ensure that any such onward transfer to third parties are appropriate, safeguarded, and that we are not a party to any such actions that result in injury to the individual(s) who is the data subject.

As such, we acknowledge the right of individuals who are EU and Swiss residents to access their personal data.  Such individuals who wish to access their data to review, edit, or erase it may do so by contacting us at support@innventural.com.

In compliance with the Privacy Shield Principles, Company commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact the Company at info@innventural.com.

Company has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit  BBB EU Privacy Shield - For Consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
Note that we may be required to release EU and/or Swiss personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

Links to Other Sites

Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy

Our Site is only intended for persons age 18 or older and only persons at least 18 years of age have permission to access our Site. Our Site is not directed to anyone under the age of 16 (“Child” or "Children").

We do not knowingly collect information from individuals under the age of 16. If you are a parent or guardian and you learn that your Child has provided us with Personal Information, please contact us at info@innventural.com. If we become aware that we have collected Personal Information from a Child without verification of parental consent, we will promptly take steps to remove that information from our servers.

Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top.

By using the Site, you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Site. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy of the Site, and your continued use of the Site thereafter means that you accept those changes.

Commitment

We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Site to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at info@innventural.com.