Effective Date: May 25, 2018
IngageApp, Inc. (a.k.a. Xiaoshouyi) knows that you care about how the personal data we receive about you is used and shared, and we take your privacy seriously. This Privacy Notice describes IngageApp’s privacy practices in relation to information that we collect through websites operated by us from which you are accessing this Privacy Notice (collectively, the “Domains”), through the software applications made available by us for use on or through computers and mobile devices that link to this Privacy Notice (the “Apps”), through our social media pages (collectively, the “Social Media Pages”), and other services provided by us both online and offline; as well as through email messages that we send to you that link to this Privacy Notice (collectively, including the Domains, the Apps and the Social Media Pages, the “Sites”). “You” or “user” refers to any individual who visits or otherwise uses the Sites.
This Privacy Notice does not apply to the practices of third parties that IngageApp does not own or control, or to individuals that IngageApp does not employ or manage.
This Privacy Notice also does not apply to information that we receive or handle on behalf of our subscribers in our role as a service provider, such as information that we receive through IngageApp’s CRM software services or other IngageApp services, including any apps we make available for use by services subscribers (collectively, the “Subscription Services”). Such information is governed by the terms of the applicable subscription services agreement, rather than this Privacy Notice.
You can request a copy of this Privacy Notice by contacting us at email@example.com.
1. What Types of Information Does IngageApp Collect?
- Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, job function, expertise, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
- Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Sites and for other purposes described below.
2. How Does IngageApp Collect Information?
We and our service providers collect Personal Data and Other Information in a variety of ways, including:
- Through the Sites: We collect information through the Sites, e.g., when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. whitepapers), or register to use our Sites.
- Offline: We collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact an IngageApp representative.
- Through You: IngageApp collects information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Data, this information does not personally identify you or any other user of the Sites.
- Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
- Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Sites (such as the Apps) you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. IngageApp uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and for monitoring the regions from which you navigate to IngageApp’s Sites.
- Through Your Use of the Apps: When you download and use an App, we and our service providers track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Through Cookies and Other Similar Technologies: “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Sites. When you visit our Sites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse our Sites and enhance the level of services and functions provided. IngageApp recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions.
- By Aggregating Information: Aggregated Personal Data does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Data to calculate the percentage of our users who have a particular telephone area code).
3. How Does IngageApp Use Personal Data?
We use Personal Data:
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
- To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
- To send you marketing communications, including via email and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
- To personalize your experience on the Sites by presenting products and offers tailored to you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our Affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. We will collect and use your Personal Data where the processing is in our legitimate business interests, such as for direct marketing and sales of IngageApp’s CRM Platform and Applications to prospective Business-to-Business (B2B) customers. Our legal basis for processing Personal Data in certain circumstances will also be based on your consent to do so or where we need the Personal Data to perform a contract with you or in order to enter into a contract with you. In some cases, we may also have a legal obligation to collect Personal Data from you.
If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
4. How Will IngageApp Share Personal Data It Receives?
Subsidiaries and Affiliates:
We disclose Personal Data to our subsidiaries and Affiliates for the purposes described in this Privacy Notice. IngageApp, Inc. is the party responsible for the management of the jointly-used Personal Data.
Third-Party Business Partners:
IngageApp partners with a variety of businesses and works closely with them to market or sell products or services. In certain situations, these businesses operate within the Sites. We may disclose Personal Data to our partners for the purposes described above. Some of our third-party business partners co-sponsor events and other offerings with IngageApp. We may share Personal Data with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
Agents and Service Providers:
We contract with other companies and people to perform tasks on our behalf and share your Personal Data with some of them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, and performing analysis related to our products or services. We also provide your Personal Data to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Data.
IngageApp Blog and Social Media Pages:
Personal Data may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. This information can appear in public ways, such as through search engines or other publicly available platforms, and can be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
Profiling and Automated Decision-making:
IngageApp combines data obtained by the methods described in Section 2 to help us determine what products and services might be of interest to you and when you might be ready to make a purchase based on repeated interaction with IngageApp websites, emails, and content. IngageApp marketing and sales personnel are involved in this process and no automated decisions are made that would result in legal effects or similarly significantly affect an individual.
Protection of IngageApp and Others:
We release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organizations for the reasons given in the last bullet point under Section 3 above.
5. How Does IngageApp Use and Disclose Other Information?
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data.
In some instances, we may combine Other Information with Personal Data (such as combining your name with the name of your organization). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.
6. How Does IngageApp Secure Personal Data About Me?
We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Questions, Concerns and Complaints” section below.
7. How Can I Access, Correct, Amend or Remove Information About Me?
If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Data about you that has been collected and stored by IngageApp, or have it transferred to another organization, please notify us at firstname.lastname@example.org so that we may consider and respond to your request in accordance with applicable law. If you would like to object to the processing of your Personal Data for direct marketing purposes, please use the mechanisms outlined in Section 9 (“What Choices Do I Have?”).
For your protection, we only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we need to verify your identity before implementing your request. We will respond to your request within 30 days.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.
8. For How Long Will IngageApp Retain My Personal Data?
We will retain your Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business interests, comply with our legal obligations, resolve disputes and enforce applicable agreements.
9. What Choices Do I Have?
You can always opt not to disclose information. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.
You can opt-out of receiving marketing messages from IngageApp or our Affiliates by unsubscribing through the unsubscribe or opt-out link in an email, or by sending an email to email@example.com. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages.
10. Can Children Use IngageApp’s Sites?
The Sites are not intended for minors under the age of 18. IngageApp does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Data. If you believe that we have mistakenly or unintentionally collected such information, please notify us at firstname.lastname@example.org so that we can delete the information from our servers.
11. Third Party Sites
The Sites permit you to link to other websites on the Internet through direct links or through applications such as “share” or “like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Privacy Notice. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information is collected and used by them.
Similarly, please note that we are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Apple, Facebook, Google, LinkedIn, Microsoft, RIM, Twitter or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
12. Sensitive Information
We ask that you not send us or disclose any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Sites or via other means.
13. Changes to this Privacy Notice
IngageApp may amend this Privacy Notice from time to time. The “Effective Date” legend at the top of this page indicates when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Sites.
14. International Transfer of Data
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection, namely the European Commission Standard Contractual Clauses.
15. Questions, Concerns or Complaints
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information as a data Controller, please contact our Data Protection Officer (DPO) by email at email@example.com, or by mail at: IngageApp, Inc. 21th FL, Fosun Internationl Center, No.237 Chaoyang North Road, Beijing, P.R. China, 100022. ATTN: Privacy Officer, Legal.
Because email communications are not always secure, please do not include credit card information or other sensitive information in your emails to us.
IngageApp will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
You may have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.