Privacy Policy


Assure ID Inc. (“Assure ID”, the “Company”, or “we/us”) is committed to respecting and protecting your privacy and that of your Users. This Privacy Policy explains our practices
 regarding the use of personal data collected and processed through our Assure ID Services (the “Services” or “Assure ID Services”) and integrates our conditions of use of our Services.This Privacy Policy explains our practices regarding the use of personal data obtained and/or processed through our Assure ID Services. It is part of our Assure ID Terms of Services.

Summary


Assure ID processes two types of personal data in relation to the Services: (1) your account and contact data; and (2) your User Data, collected from your devices associated to your User Accounts (“Associated Devices”)

  • Your account and contact data are used for managing our relationship with you, including activation and support.
  • Your User and Associated Devices information is processed on your behalf, for providing the services through the family management panel.

WeComply With The Children’s Online Privacy Protection Act of 1998 (COPPA) COPPAand its rules require us to inform parents and legal guardians (“parents”) about our
 practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent, or confirm that the child’s teacher has obtained verifiable consent from such child’s parent, for certain collection, use, and disclosure of the child’s personal information.
Read more about COPPA at the FTC’s COPPA page. This regulation is designed to protect the privacy of your children. In order for a child under the age of 13 located in the United States to use the Assure ID Services, his/her parent or teacher must approve the registration.
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The Assure ID Services is designed for use in a household environment by parents and not by children, and we do not knowingly collect personal information directly from children under the age of 13. You warrant that (a) you have informed any Users that are 14 years old or more that the associated devices used by them include a web browser add-on and have obtained authorization from such Users for this kind of activity or (b) there are rules in your country that exempt you from the aforementioned obligation of information and consent, or provides for a different age limit, in which case that age limit will apply. Both Assure ID and you agree to fully comply with this Privacy Policy
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1. Data collection by the Company through the Services:
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  • Registration Data. On registering for Services, we will collect the following personal data about you: email address, nickname(s) of minors under your legal guardianship, state of residency, and date of birth of minors under your legal guardianship. This data is mandatory and if it is not provided, your account cannot be created.
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  • UserData: When using the Assure ID Services, we start collecting data from the Devices associated to the Account, which may include personal data relating to you, to the Users of the Devices or to third parties (“User Data”, including information about your
    Devices, user activity including websites that your Users visit, etc.). Furthermore, in the  event of any promotional or other campaign, Assure ID may process the contact information ( email address) of a potential new client or user of our Services you provide us with.
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  • Information about your computer. Due to the communications standards on the internet, when you visit our website we automatically receive the URL of the site from which you came and the site to which you are going when you leave the site. We also receive the internet protocol (“IP”) address of your computer and the type of web browser you are using. We use this information to analyze overall trends and to help improve the Services. This information is not shared with third parties without your permission.

 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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You warrant that you have the appropriate authority to collect and process the User Data and any other data you provide us and you will not submit to the Services any personal data relating to any individual over 13 that has not authorized such processing. Through the Services, you may also access a copy of the User Data collected by us on your behalf. You will protect the confidentiality of any accessible User Data and prevent access by or disclosure to any unauthorized third person
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 Information We Collect
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To comply with the CCPA, a business must describe the categories of personal information it has collected about consumers during the past twelve (12) months. Accordingly, this section applies to visitors, users, and others accessing the Assure ID Services who reside in the State of California.
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We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not
 include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

 
We obtain the categories of personal information listed in the previous section from the following categories of sources:

  • Directly from you. For example, from forms you complete or features of the Assure ID Services you interact with.
  • ndirectly from you. For example, from observing your actions within the Assure ID Services.

 Purposes for Processing
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 The personal data we collect about you are used for performing our contract and communications with you, for managing your Assure ID Account and for providing our Services to you (as described in the Terms of Service). The data we collect are also used to measure and improve the Services and its functionality and to provide customer service, send email notifications and (if you gave your consent) newsletters, or communications, in general, about the Services, products and novelties. We will use your data also for granting compliance with the Terms, the applicable laws, and other legal obligations we are subject to.
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 Legal Basis for processing. Below are the lawful bases that we rely on to process your data:

  • Preparation and performance of Contract: Processing your data is necessary for the performance of our contract with you, or to take steps at your request before entering into such a contract.
  • Legitimate Interest: we have a legitimate interest to process your Registration Data for our business, in conducting and managing our business to give you the best
     service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest and we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Comply with alegal or regulatory obligation: We may process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your Account Data other than in relation to sending own marketing communications to you via email. However, for transparency and clarity, we ask you to provide this consent, which is given by you on registering your account. You have the right to withdraw consent at any time by contacting us at support@assureid.io. This will not affect the processing of your Registration Data for service provision until you cancel your account.
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 Service Optimization. We may process data on an aggregated non-identifiable basis for establishing user general attributes and profiles and share such anonymous information with third-party service providers to improve or promote our Services. We also use your data in a non-identifying and aggregated manner (i.e., dissociated data) to better design our website, software, and services.
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Disclosure. We treat your personal data with strict confidentiality by applicable law. However, we disclose any information about you or your use of our Services: (i) in order to comply with the legal obligations we are subject to, (ii) in order to correctly deliver our Services or perform other obligations in accordance to the Terms, (iii) in the event of a sale or change of control of the Company for the purpose of appropriate due diligence actions; or (iv) to our service providers that provide us a service in relation to the data.
Werequire all third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it data for specific purposes and in accordance with our instructions.
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Data Retention. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including (a) the performance of the contract with registered users and (b) for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally speaking, we will retain your personal data for the period of your subscription (in active format) and 5 years thereafter (blocked), for legal and/or administrative purposes.
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Anonymised Data for Statistical Purposes. For the purpose of improving our Services and providing sector/segment reports, we may anonymize your Registration Data and certain User Data and store and process this data on an anonymous basis, even after your Account has been closed, indefinitely. The principal purpose is to analyze on an aggregated non-identifiable basis how our Services are used, measuring their effectiveness, and providing general customer service. We may also provide this data (or parts of it) on a fully anonymous aggregate basis to third-party business partners, including for conducting academic research and surveys or commercial analytics, and to publish periodic sector or segmented information and reports about behavior patterns and tendencies.

2. Data Security
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We have adopted technical and organizational measures to preserve and protect your personal information from unauthorized use or access and from being altered, lost, or misused, taking into account the technological state of art, the features of the information stored, and the risks to which the information is exposed. In case of a security breach, we will take the appropriate measures and will notify you electronically in a timely manner.

3. Data Subject’s Rights
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 In accordance with the applicable data protection law, you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may
     need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information
     which override your rights.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want
    us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer
    require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party (known as “data portability”). We will provide to you, or a third party you have chosen, your personal data
    in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or
    where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out
    before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will notify you if this is the case.

 
To exercise your rights, please contact us at support@assureid.io. If you contact us to exercise your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 speed up our response.


Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please submit a request by emailing us at support@assureid.io. You may also make a request to know or delete on behalf of your child by emailing us at support@assureid.io.


You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which
    may include but is not limited to:

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    • (a) contact information associated with the account;
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    • (b) the user profile name;
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    • (c) the name of one or more Monitored Devices;
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    • (d) technical information (e.g., model ID, serial number, IMEI code, operating system, etc.); or
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    • (e) any other piece of personal information we determine in our sole discretion to be sufficient for verifying your identity to a reasonable degree of certainty.
  • Describe your request with sufficient detail that allows us to properly understand,
     evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
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7. Response Timing and Format

 We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. Wedonot charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 
8. Non-Discrimination


We will not discriminate against you for exercising any of the rights described above, and we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


 9. Commercial Communications.

 As a user of Assure ID’s Services, you will receive electronic commercial communications in accordance with applicable law, including alerts, notices, newsletters, offers, and promotions, related to Assure ID’s Services. If you do not wish to receive such information you can expressly opt out of our commercial communications by clicking “unsubscribe” in one of our emails or by sending a notification to support@assureid.io

 
10. Warranty and Indemnity.


You, as the person responsible for User Data that we process on your behalf as data processor for the provision of the Services, represent and warrant to us that you have all the appropriate informed consents or other legal basis for processing from each and every data subject whose personal data are submitted to us in the course of the provision of the Services or collected and transmitted to us by the Assure ID Software. You agree to indemnify and keep us harmless from all claims, damages, and losses we may suffer relating to or arising out of the processing of User Data and other third-party personal data submitted to our systems during the course of use and provision of the Services.

 
11. General.

We mayamend this Privacy Policy as required to adapt it to future legislative or case law developments. We will notify you by posting a clear notice of these changes on our website, platform, and in this Privacy Policy and update the notice’s effective date. Your continued use of the Assure ID Services following the posting of changes constitutes your acceptance of such changes.

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