Innoflight CPRA Privacy Notice

This Privacy Policy describes how Innoflight and its affiliates ("Innoflight", "we", "us", "our") collects, processes, uses and discloses your personal information when you contact us, use our services or interact with our websites linking to this Privacy Policy ("Websites"). We respect your privacy and are committed to protecting your personal information.

The term "personal information" as used in this Policy shall mean any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you.

This Privacy Policy, together with the Terms and Conditions and Cookie Notice posted on our Websites, set forth the general rules and policies governing your use of our Websites.

This Privacy Policy does not apply to the websites, or any embedded content of our business partners or to any other third parties, even if their websites are linked to our website, or contain their embedded content. We recommend you review the privacy notices of the other parties with which you interact.

If you are visiting our Websites or accessing our products and services from outside the U.S., be aware that your personal information may be transferred to, stored, and processed in the United States. Where required by applicable law, personal information may be stored locally before onward transfer.

Information We Collect

We may collect the following personal information that you choose to provide voluntarily when you access our Websites, comment on blog posts, complete forms, make a call to us, correspond with us by e-mail or otherwise, and when you use our services:

• Identifiers, including name, title, alias, date of birth, marital status, postal address, email address, phone number, company name, username, password, blog post, and unique personal identifier;

• Commercial information, such as transaction history, products/services purchased, obtained or considered, your interests, preference, feedback and survey responses;

• Financial and transaction data, including bank account and payment card details and information about payments from you and other details of products and services you have purchased from us; and

If you apply for work with us, we may collect, store, and use categories of personal information including the following that you have provided to us in your curriculum vitae, a covering letter, on an application form or during an interview, or that we have received from a recruitment agency, reference, or background check provider:

• Identifiers, including name, title, alias, date of birth, marital status, postal address, email address, phone number, passport number, unique personal identifier and social security number;

• Professional or employment-related information, such as employment history, references, and qualifications;

• Non-public education information, such as academic qualifications and education records; and

• Protected classification information, such as race, national origin, gender, age, pregnancy, religion, ancestry, mental or physical disability, military and veteran status, sex, sexual orientation, gender identity, or any other basis protected by local, state, or federal law. Some of this information may be "sensitive personal information" as defined under applicable data protection law (as discussed below).

The amount and type of information that we gather depends on the nature of the interaction.

Like most website operators, we collect "internet or other similar network activity" indirectly from you when you access our Websites or otherwise correspond with us, including the sort of information that web browsers and servers typically make available, such as your IP address, browsing or search history, website interactions, the browser type and version, time zone setting, operating system and platform, page interaction information, language preference, referring site, and the date and time of each visitor request. We may also collect "general location information" through your IP address.

We collect internet or other similar network activity to better understand how visitors use our Websites. From time to time, we may release internet or other similar network activity in the aggregate (i.e. in a form that will not personally identify you), e.g., by publishing a report on trends in the usage of our Websites.

How We Use Your Information

We use your identifiers, commercial information, and financial and transaction data as is necessary so that we can provide services to you, and only where we have a legal ground for doing so under applicable data protection law. The legal ground will depend on the purpose for which we process your personal information. These purposes include:

Our website also uses cookies and similar technologies to collect technical information, which may include personal information. For further details on the types of technical information we collect, our use of cookies and how you can change the way your browser manages cookies, please see our Cookie Policy. 

How We Collect Information

We use different methods to collect your personal information including when you:

• fill in forms or use the functions and services on our website, including any interactive features such as an online forum on our website;
• enter into a contract with us (e.g., by means of our sales representatives, through service agreements, as a supplier, or a business partner, etc.);
• access our premises;
• use our IT resources and communication systems (e.g., email, network, Wi-Fi, etc.);
• register to use any of our online customer portals;
• correspond with us by phone, email, letters or otherwise;
• apply to work for us;
• purchase products from us, or send us products for repair; or
• provide it to third parties who may disclose your information to us, such as our business partners.

Retention of Information

We will retain your personal information for as long as is reasonably necessary for the purposes for which it was collected, in alignment with our business needs In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, and accounting requirements.

Sharing of Information

We work closely with a number of trusted third parties with whom we need to share personal information to help us provide our services. These include:

• Our affiliated companies (the information shared includes identifiers, commercial information, financial and transaction data, internet or other similar network activity, professional or employment-related information, non-public education information and protected classification information);

• Banks and payment providers, to authorize and complete payments (the information shared includes commercial information and financial and transaction data);

• Service providers who work with us to help provide our services; and

• Companies to whom we transfer or may transfer our rights and duties under our agreement with you.

We may also disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;

• If the company or substantially all of its assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets; or

• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any request from law enforcement or governmental organizations or public health authorities, or in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of us, our customers, or others.

We may also share your personal information (including identifiers, professional or employment-related information, non-public education information) for the purposes of processing your application for employment with search consultancies, background screening providers and our affiliated group companies.

Where we transfer UK and European Economic Area ("EEA") personal information to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the EU Commission or UK Government, to safeguard such personal information.

 Information Security

The security of your personal information is important to us. We use reasonable technical, administrative and physical measures to protect information contained in our system against unauthorized access, destruction, misuse, loss or alteration. We may use standard encryption technology to protect information being transferred to our site, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure and we cannot guarantee its absolute security.

Your Rights

You may have the right to request access to the personal information we hold about you and to have any inaccuracies corrected. If you wish to exercise this right where possible under applicable privacy or data protection laws, please contact us.

Information for individuals located in the EEA and/or the UK

Where EEA and/or UK data protection laws apply, you may have additional legal rights in relation to the information you give us, or which we collect about you, as follows:

• A right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
• A right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
• A right to ask us to transmit the information we hold about you to another person or company in a structured, commonly used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
• Where we use/store your information because it is necessary for our legitimate interests, you may have the right to object to us using/storing your information. Where this right applies, we will stop using/storing your information unless we can demonstrate why we believe we have a legitimate interest, which does not override your rights and freedoms.
• Where we use/store your information because you have given us your consent, you have the right to withdraw your consent at any time.
• A right to object to us using/storing your information, including for direct marketing purposes.

If you wish to exercise any of these rights where they apply, please contact us.  

We may need to request specific information from you to help us confirm your identity and to assess whether the legal right applies in the circumstances. We may also apply security measures to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to clarify the request and/or to speed up our response. We will respond to requests within the timeframes provided by applicable law.

You also have the right, at any time, to lodge a complaint with the competent data protection supervisory authority if you believe we are not complying with the laws and regulations relating to the use/storage of the information we collect about you.

Information for individuals located in California:

California Privacy Rights Act

If you are a California resident who interact with us, then the information in this section also applies to you. This section describes how we handle your personal information, the reasons we do so, and the rights you have as a California resident regarding your personal information. Capitalized terms used but not defined herein, shall have the meanings ascribed to them in California Civil Code § 1798.100, et seq. (together with the regulations thereunder, the “CCPA”), as applicable.    

During the 12-month period prior to the effective date of this Privacy Policy, we have:

(a) Collected the following categories of personal information:

• Identifiers, such as a real name, alias, postal address, email address, account name, and other similar identifiers;
• Online identifiers, such as a device identifier; cookies, beacons, pixel tags and similar technology, other forms of persistent or probabilistic identifiers, and Internet Protocol address;
• Internet and other electronic network activity information, such as the browsing history on our website;
• Approximate geolocation (e.g. country or region derived from your Internet Protocol address);
• Commercial information, such as products or services inquired about;
• Login credentials for our website portals (including your username, password, time and date of login to our website portals);<
• Professional or employment-related information (including job applications, resumes, background check forms and results, work history and prior employer, in connection with a job application);
• Sensitive personal information (as defined under California law), such as Social security, driver’s license, state identification card, passport number, and racial or ethnic origin, if you choose to provide such information in connection with a job application; and
• Other personal information or content that you submit to us when you contact us, including any document(s) or any audio, electronic, visual, or similar information that you choose to upload.

(b) Collected personal information from the following categories of sources:

• Directly from you. For example, when you inquire about a product or service, apply for or accept an employment position with us, etc.;
• Directly and indirectly from activity on our website and/or services; and
• Service providers who provide services on our behalf, such as those used to monitor activity on our services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, and provide consulting services.

(c) Collected personal information about you for one or more of the following business or commercial purposes:

• Providing customer service, including responding to your requests or inquiries.
• Processing and completing your orders and/or transactions including, as applicable, verifying customer information, processing payments, order confirmation/re-scheduling, billing and delivering products and/or services, providing storage and/or providing similar services.
• Personalizing your experience with our services with content tailored to you.
• Providing you with newsletters, articles, product or service alerts, new product or service announcements and other information.
• Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity or unauthorized access to or use of personal information, our website or data systems.
• Helping to ensure security and integrity on our website and platforms.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
• Enabling you to interact with content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment.
• Creating aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.
• Meeting legal obligations.
• Enforcing our Terms of Use and other agreements.

We do not collect or process sensitive personal information (as defined by California law) to infer characteristics about individuals.    

To the extent that we process de-identified information, we will maintain and use the information in de-identified form and will not attempt to re-identify the information unless permitted by applicable law.    

We do not sell or rent your personal information to third parties, nor do we share your personal information for cross-context behavioral advertising or targeted advertising purposes. Accordingly, we do not have actual knowledge that personal information of minors under the age of 16 are sold or shared for cross-context behavioral advertising or targeted advertising purposes.    

We also do not disclose to third parties the personal information we collect for their own direct marketing or other purposes. While we do not sell or rent personal information, we disclose personal information for business purposes as described below:

• Our affiliates: our affiliates or subsidiary entities may collect and share personal information described in this Privacy Policy for use in the ways described herein.
• Our service providers: We may disclose personal information to our service providers to do things like monitor activity on our services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, provide consulting services, and otherwise perform actions consistent with the uses described in this Privacy Policy.
• Legal process and emergency response: We may disclose personal information if we have a good-faith belief that it is necessary or authorized pursuant to applicable law to protect our customers, the public or our business.
• Business transfers: We may disclose personal information as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or in the event of insolvency, bankruptcy, or receivership. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Policy.

During the 12-month period prior to the effective date of this Privacy Policy, we have disclosed for a business or commercial purpose the following categories of personal information for the business purposes as described above:

• Identifiers, such as a real name, alias, postal address, email address, account name, and other similar identifiers;
• Online identifiers, such as a device identifier; cookies, beacons, pixel tags and similar technology; other forms of persistent or probabilistic identifiers, and Internet Protocol address;
• Internet and other electronic network activity information, such as the browsing history on our website;
• Approximate geolocation (e.g. country or region derived from your Internet Protocol address);
• Login credentials for our website portals (including your username, password, time and date of login to our website portals);
• Commercial information, such as products or services inquired about; and
• Professional or employment-related information;
• Other personal information or content that you submit to us when you contact us, including any document(s) or any audio, electronic, visual, or similar information that you choose to upload.

California law requires us to let you know how we respond to web browser 'Do Not Track' (DNT) signals. Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. 

If you are a California resident and depending on the circumstances, you may have additional legal rights in relation to the information you give us, or which we collect about you, as follows:

• The right to request that we disclose (i) the categories of personal information related to you that we have collected, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purpose for collecting or disclosing personal information, (iv) the categories of third parties to whom we disclose personal information and (v) specific pieces of personal information related to you that we have collected;
• The right to request that we delete certain personal information we have collected from you (subject to certain exceptions);
• The right to correct inaccurate personal information that we may have about you;
• The right to non-discrimination, meaning that you will not receive any discriminatory treatment when you exercise one or more of your privacy rights;
• The right to opt-out of the sale or sharing of your personal information (however, as stated in the section above, we do not sell or personal information, nor do we share personal information for cross-context behavioral advertising or targeted advertising purposes);
• The right to limit the use of your sensitive personal information (however, we do not process such personal information subject to this limitation); and
• The right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. Innoflight does not share personal information about its consumers with any third parties for their own marketing purposes. We are required to respond to a customer request only once during any calendar year.

To request any of the above rights, please contact us by email at: compliance@Innoflight.com  or by phone at: 858-332-0951 ext. 151.  

In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.    

To help protect your privacy and preserve the security of the information, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you request access to or deletion of your personal information and do not sign in to an account with us, we require you to provide the following information: name, email address, phone number, and postal address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we reserve the option to require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If we cannot verify your identity, we may not be able to respond to your request.    

If you designate an authorized agent to make a privacy request on your behalf, we may require you to provide the authorized agent written permission to do so (including proof of your consent and designation of the authorized agent for the purpose of making the request), and we may also require you to verify your own identity directly with us (as described above).    

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

Updates To Our Online Privacy Notice

This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on our Sites and indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at compliance@innoflight.com , by phone at 858-332-0951 ext. 151  or writing to us at:

Innoflight, LLC
5880 Oberlin Dr.
Suite 300 (Offices)
San Diego, CA USA 92121