Privacy policy

Updated: 7 July 2021

Introduction

Innovative Systems, Inc., its affiliates and subsidiaries (including, but not limited to, Fin-Scan GmbH, ISI Latin America S. DE R.L. C.V. and Innovative Systems, Incorporated) (for the purposes of this privacy notice, collectively, “Innovative”) value individual privacy and hold all personal information with which we are entrusted in strict compliance with the provisions of this Privacy Policy. Innovative is further committed to complying with applicable data protection and e-marketing laws, including, but not limited to, the European Union’s General Data Protection Regulation (“GDPR”) and Brazil’s Lei Geral de Proteção de Dados/The General Personal Data Protection Law 13709/2018 (“LGPD”).

For the purposes of this Privacy Policy, “Site” shall refer to www.finscan.com and related websites.

1. Contact information

For inquiries concerning what personal data we collect or how your personal data is used, please contact: info@innovativesystems.com

For inquiries concern exercising your legal rights with respect to your personal data, please contact: dataprotection@innovativesystems.com

2. Privacy statement

This Privacy Policy applies to information Innovative collects from all sources, including, but not limited to, events, webinars, websites, newsletters, applications, our website, and/or other communications.  The following is our disclosure of how we collect and use personal information; any third parties to which we may disclose that information; how you can access your information and restrict our use of it; how to contact us with any questions or complaints about how we use your information; and how we protect your personal information.

We use personal data only for lawful purposes. If you have any questions, please inquire using the e-mail address above for more information about Innovative’s lawful purposes and legitimate business interests for processing your personal data.

For information on how we use Cookies on this Site, please see our Cookie Policy.

3. Types of personal information collected

We may collect personal information such as name, title, firm, address, e-mail address, phone number, and survey results from individuals who have requested information from us or expressed interest in our products and services. You may provide this information to us electronically, over the Internet, physically, through a third party, by requesting information through our website, or by attending a presentation, conference, event, or webinar.

Other personal information gathered through this Site, such as web pages visited, enables us not only to improve and upgrade our website but also to refine our product lines and marketing.

Further information gathered through this Site is purely statistical. This statistical information is useful to Innovative and enables us to improve and upgrade our website. This information is anonymous in nature.

We do not collect sensitive information (e.g., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual).

Questions or complaints on personal information collected and manner of collection may be sent to: info@innovativesystems.com.

4. Use and lawful basis for processing your personal information

We use your personal information only as authorized by law. Our lawful use of your personal information is based upon: (1) your consent (for example: your request of information from us), (2) a contract that we have with you or the organization you represent, (3) a legitimate business interest; or (4) compliance with a regulatory or legal obligation.

If you are an EU resident in the European Economic Area (collectively, the “EEA”), our lawful basis for storing and processing your personal information is on a lawful basis available under the GDPR.  In particular, we usually rely on (1) your consent (for example: your request of information from us), (2) a contract that we have with you or the organization you represent, (3) a legitimate business interest that is not outweighed by risks to your personal information; or (4) compliance with a regulatory or legal obligation.

If you are a Brazilian resident, our lawful basis for storing and processing your personal information is based on a lawful basis available under the LGPD.  In particular, we usually rely on (1) your consent (for example: your request of information from us), (2) a contract that we have with you or the organization you represent, (3) legitimate business interest where we have determined our use of your personal data does outweigh your fundamental rights and freedoms; or (4) compliance with a regulatory or legal obligation.

5. Purposes for which we will use your personal information

Your personal information may be used by Innovative for marketing purposes, including providing and improving service to you, or informing you of additional products and services which we think will be of interest to you. We may also use your personal data to notify you of events and presentations or to improve our website.   If we have your personal information as a result of a contract we have with you or your organization your personal information is used consistent with the marketing purposes in this paragraph and also consistent with the terms of that contract.

In addition to the information in this Privacy Policy, any personal information gathered through this Site is subject to our Cookie Policy.  Personal information gathered through this Site, such as web pages visited, enables us to improve and upgrade our website and also to refine our product lines and marketing of those product lines.  In addition, statistical information gathered through this Site is also used to improve and upgrade our website, improve website performance and user experience.  

Any personal information sent to us by our clients pursuant to a contract with an Innovative group company is used exclusively for the purposes and services for which we contracted and is subject to applicable terms in that contract.

6. Choice to opt-out, and revoke consent to use

If you are an EU resident located in the EEA, a Brazilian resident, or a Canadian resident, you will be given the choice to opt-in to receive future marketing communications from us on information, products, or services that may be of interest to you.

If you request information from us or if you have provided us with your personal information in the past, and you do not wish to receive further communications of information, events, presentations, products, or services from us or object to our use of your personal data, you can opt out by going to our preferences page by clicking here.

If you provide personal information to us as part of a service we provide to you or your organization, we do not share, transmit, rent or sell that information to any third parties, except to certain third parties as detailed in the onward transfer section below and then only where necessary for the provision of services to you or your organization.

If our reason for using your personal data is that you gave us consent to use it, you may revoke that consent at any time and we will stop using your personal data. You can opt out by going to our preferences page by clicking here.

If you have any questions or need additional information on your right to opt out or revoke consent of use of your personal data, please contact us at dataprotection@innovativesystems.com.

7. Your rights with respect to your personal information

If you desire to exercise any of your legal rights to your personal data under this section, please contact us at: dataprotection@innovativesystems.com.

General rights with respect to your personal data:
You are welcome to contact Innovative at any time to review the personal information about you that we hold.

You may ask us to correct, amend, or delete that information where it is inaccurate.

If at any time you wish to have your personal data erased, we will erase personal information at your request. If Innovative believes it has a superseding interest or legal interest to retain all or part of the information, we will provide a full explanation with our response at that time.

Further, if you desire to restrict processing and/or object to processing of your personal information, we will restrict or stop processing of your personal information at your request. If Innovative believes it has a superseding interest or legal interest to continue processing all or part of the personal information, we will provide a full explanation with our response at that time.

EU residents in the EEA – exercising specific rights to your personal data under GDPR:

If you are an EU resident in the EEA, you have additional rights under GDPR that you may exercise related to your personal data: (a) right of access (subject access requests), (b) right of rectification, (c) right of erasure (right to be forgotten), (d) right to restrict processing, (e) right to object to processing, (f) rights relating to automated decision making, and (g) right to data portability.

Brazilian residents – exercising specific rights to your personal data under LGPD:

If you are a Brazilian resident, you have additional rights under LGPD that you may exercise related to your personal data: (a) right to confirm the existence of the processing, (b) right of access (subject access requests), (c) right to correct incomplete, inaccurate, or out-of-date data, (d) right to erasure (right to be forgotten), (e) right to restrict processing in certain circumstances, (f) right to data portability, (g) right to revoke consent and object to processing, (h) right to information about the possibility of denying consent and the consequences of such denial, and (i) right to information about public and private entities with which we have shared data, and (j) rights relating to automated decision making.

8. Onward transfer to third parties

Your personal information is never rented or sold to any third parties under any condition. Other than as described in this section, personal information provided to us as part of our business is not disclosed, transmitted, or shared with any third parties.

If you provide us with personal information in order to receive information from us, we do not disclose, transmit or share that information with any third parties, except as provided to affiliates/subsidiaries, partners, or to contracted third parties we have retained to assist us in our business and who are working under our instructions, and then only for the purpose of alerting you to information, products, events, presentations, and services that may be of interest to you. Any third party with whom we may share personal information for these purposes must demonstrate that they agree to provide at least the same level of privacy protection as is required in this Privacy Policy.

Innovative may share your personal data with a partner of Innovative if your personal data was obtained as part of an event, webinar, or presentation with such partner.

9. International transfer

Innovative Systems, Inc. is a United States corporation with headquarters as indicated on the Site and may store and access your personal data from the United States.  Innovative may transfer your personal data, as necessary, to affiliates and/or subsidiaries in the Innovative group of companies. If we do so, Innovative will ensure that any transfer is in compliance with applicable law, including laws related to international transfers of personal information. Locations where personal data may be accessed from include, but are not limited to, affiliates and subsidiaries in the United States, United Kingdom, European Union, Mexico, UAE, Saudi Arabia, and/or Brazil and to a partner in Pakistan. 

10. Security

Innovative employs reasonable technical and organizational measures within our company — including physical, electronic, and procedural safeguards — designed to help secure the privacy of all personal information we retain and protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. As a result of the foregoing, while we undertake commercially reasonable efforts to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which your information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Site. You provide all such information entirely at your own risk.

11. Data retention

Generally, Innovative will store personal information only as long as is necessary to complete the original purpose for which it was being used. We comply with applicable law in retaining and destroying your personal data.   If your data is subject to GDPR, LGPD, or similar data protection law, we will retain the personal data for as long as we have a legal basis for doing so.

Our retention rights are subject always to your right to erasure if provided in applicable law and any obligations we may have under law or regulation to maintain the personal data. 

12. Enforcement

Innovative’s Information Security Office (“ISO”) is responsible for verifying that our Privacy Policy is accurate, comprehensive, prominently displayed, completely implemented, and accessible. The ISO is also responsible for employee training related to the Privacy Policy and periodic review to make sure the proper procedures and protections are in place.

Any questions or complaints regarding Innovative’s handling of personal information can be addressed to the Information Security Office at dataprotection@innovativesystems.com.

Any complaints or disputes that are not satisfactorily resolved by the Information Security Office can be referred to the relevant supervisory authorities for investigation and resolution. 

Innovative reserves the right to update and revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of our Site constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

Our Site may contain links to other websites. Please be aware that we are not and cannot be responsible for the privacy practices of such other websites and that this Privacy Policy applies solely to the information that we collect through this Site. We encourage you to ensure that you read the privacy statements of all the destination websites that you visit.

We value your opinion as to this Privacy Policy. Please feel free to contact us with your privacy concerns.

13. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.