Privacy Policy Imfuna, Inc. and Imfuna Limited Effective Date: 22 April 2019

About us

Welcome to imfuna.com which is operated by Imfuna Inc of 2125 Ygnacio Valley Road, Suite 200, Walnut Creek CA 94598, ([support@imfuna.com]), (“Imfuna Inc”) and Imfuna Limited of 114a Cromwell Road, 3rd Floor, London, United Kingdom, SW7 4AG, ([support@imfuna.com)] (“Imfuna Limited”).

When we refer to “Imfuna”, “we”, “us” or “our” in this Privacy Policy, we’re talking about [the relevant data controller] (Imfuna Limited for EU-based individuals or Imfuna Inc for non-EU-based individuals, as applicable).

Imfuna values the privacy of those who use our website, products and services. This Privacy Policy covers the collection, use and disclosure of personal data that may be collected any time you interact with Imfuna, such as when you visit our website, use or purchase our products and services, or communicate with Imfuna. Please read this Privacy Policy to learn more about what personal data we collect, what we use that personal data for, and what your rights are in relation to your personal information.

Registered Imfuna users can view, change and update their personal data at any time by visiting the Imfuna account information page by signing in at www.imfuna.com. If you cancel your account, or delete any inspection or inspection content, it will no longer be accessible to you or others who may access the service, and your personal data will be removed from our system.

Imfuna as a data processor

Imfuna is a data processor in relation to, and does not control, the content uploaded by users of our services/applications. If a user uploads your personal information in such a way, we shall keep such personal information for as long as determined by the relevant data controller customer. Should you wish to remove your personal information from within customer content, you should contact the relevant customer, who is responsible for giving effect to your rights in relation to personal information, including the right of access and erasure.

What information do we use and why?

The Imfuna web site allows you to create an “Imfuna Username” based on your personal data. This is required in order to take full advantage of the Imfuna services. It also allows Imfuna to provide more personalised and secure services and saves time when you want to use the Imfuna services, update your software or settings, or share Imfuna-created products.

In addition, we collect, process and store the following personal data:

• Contact information
• Order history

Most of the information comes directly from you, but we may obtain information from third parties, e.g. Integrated Business Partners such as Qube, Fixflo, Arthur Online.

We collect and use your personal data for the purpose of legitimate interests being pursued by us in relation to our website, products and services that we provide. For example, we use your personal data to:

• provide the best possible level of customer service to you. It enables us to provide convenient and personalised user access (for example when you create an ‘Imfuna Username’) and improve the features and usability of our products;
• use and take other actions with respect to such data in order to provide Imfuna’s services as described in the Terms of Use;
• contact you occasionally to inform you about software and service updates, and system maintenance;
• contact you to respond to queries you have raised; and
• aggregate with information from multiple users without personally identifying you or those other individuals, such as broad geographic region. You are not identifiable from this information, it simply enables us to improve our understanding of customer needs and provide relevant services to our customers generally.

We may also collect and use your personal data:

• where this is necessary for the performance of the contract with you for products or services, or to take steps at your request prior to entering into a contract; and
• in order to comply with any legal obligation that we have, in connection with any legal proceedings, in order to establish, exercise or defend our legal rights.

We may also provide marketing information (for example in relation to new produces or services) to you in relation to our business activities where you have given your consent, or we are otherwise legally entitled to do so and it is in our legitimate interests to provide such information to you. If you do not wish to be contacted in this way, you can tell us by contacting us using the details set out at the end of the Privacy Policy or using the “unsubscribe” option in communications sent to you.

With your consent, we may collect demographic information, such as where you use your computer and mobile devices to enable Imfuna to improve our understanding of our customers’ location and provide better support.

We also use ‘cookies’ and similar technologies – see below for further information.

Where we rely on your consent to process your personal information, you may withdraw that consent at any time by contacting us using our contact details below.

Where we have relied on our legitimate interests to process your personal data, you may contact us to obtain more information, including in relation to our assessment of the impact on you.

Where is your information stored?

Your personal data will be stored locally by your Controller, but may also be stored, backed up or accessed from outside of the European Economic Area– specifically in the US. We ensure that your data is protected in these countries by requiring the recipient of your personal information to have either:

• certified under the so called ‘Privacy Shield’ framework – a framework that is available to US recipients of your personal data to provide adequate safeguards in relation to the processing of your personal information; or
• entered into standard contractual clauses that have been approved by the European Commission as providing adequate safeguards in relation to the processing of personal information.

If you would like further information on these safeguards, you can contact us using the details set out at the end of this Privacy Policy or click on the following link to find our about the Privacy Shield, or this link for information on the standard contractual clauses.

Who do we share your information with?

We do not share, sell, rent or otherwise distribute your personal data to others, except as disclosed in this Privacy Policy.

Imfuna may need to share your information with others outside of Imfuna from time to time, including:

• our service providers who support Imfuna’s business or process personal data on our behalf, to fulfill your product or service request;
• our group companies for the purposes of supporting our provision of products and services to us;
• our professional advisers, such as our accounting and legal advisers where they require that information in order to provide advice to us;
• Imfuna business partners, to fulfill your requests for information from Imfuna business partners; and
• in the event that we sell (or may sell) any business or assets, to the buyer (or potential buyer) of such business or assets.

We will also disclose your personal information if we are required to do so by law or to a law enforcement agency.

Cookies

Cookies are small data files that a website you visit may save on your computer or other device that usually include an anonymous unique identifier.

Our website uses cookies for user authentication, keeping track of your preferences, promotional campaigns that require user identification, keeping track of our audience size and traffic patterns, providing you with a good experience when you browse our website and improving our website.

Our website uses both persistent and session cookies. Persistent cookies are cookies that stay on your device permanently until you manually delete them. Session cookies delete themselves automatically when you leave the website and go to another one or shut down your browser. The persistent and session cookies used on our website are as follows:

• Strictly Necessary Cookies – these are essential for you to move around our website and use its features, such as accessing secure areas of our website;
• Performance Cookies – these collect information about how you use the website, such as the pages you visit and any errors that you encounter;
• Functionality Cookies – these are used to provide you with services or to remember your preferences in order to improve your experience of our web site;
• Targeting Cookies – these are used to deliver adverts that are relevant to you and to also provide advertisers with information on your visit so they can in the future provide you with other adverts you may be interested in.

You can configure your browser to accept cookies, reject cookies or notify you when a cookie is being used. However, if you configure your browser to reject cookies (especially Strictly Necessary Cookies, Performance Cookies and Functionality Cookies), you may not be able to use Imfuna products or services that require you to sign in or to otherwise take advantage of all the features of the our website. Please note however that this will not remove cookies that have already been placed on your device or prevent them from being read. To delete existing cookies you will need to delete them manually from your computer.

How long will we keep your information?

We only keep your personal data for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations.
In summary, however, we keep:
Properties/Projects: A user deletion action ‘Marks as deleted’. All associated inspections are also ‘Marked as deleted’. They are retained 180 days and then permanently deleted.
Inspections related to a Property/ Projects: A user deletion action ‘Marks as deleted’. They are retained 180 days and then permanently deleted.

• Immediate Deletion: A user can immediately delete any given property/project or inspection. An email will be sent to the requestor with a 6-digit code to authenticate the immediate and permanent deletion. The double-authentication email will be sent to all users at the Administrator Level if a Corporate Structure has been established. These are the same recipients who receive automated Inspection completion notifications.

We will securely erase your information in advance of these deadlines if we decide that we no longer need it.

Your rights

If you are located in the EEA, you have the following rights regarding your personal data:

1. Right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.
2. Right of access You have the right to obtain access to your personal data (if we are processing it), and other certain other information (similar to that provided in this Privacy Policy).
3. Right to rectification You are entitled to have your personal data corrected if it is inaccurate or incomplete.
4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. Right to restrict processing You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. Right to data portability You have the right to obtain and reuse your personal data in a structured, commonly used and machine readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such personal data transferred directly to a third party.
7. Right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
8. Rights in relation to automated decision making and profiling
   Not applicable

Right to object to processing In addition to the above rights, you also have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your personal data based on our legitimate interests grounds (including processing for direct marketing).

To exercise any of these rights, at any time, you can contact your data controller using the details set out at the end of this Privacy Policy. If you are not sure who is your data controller, contact Imfuna using the contact details below and they will help you.

Third party links

The Imfuna website and services may contain links to other sites. Imfuna is not responsible for the privacy policy or other practices employed by websites linked to, or from, our web site nor the information or content contained therein. This Privacy Policy applies solely to personal data collected by the Imfuna website and its associated data collection services. Imfuna encourages you to read the privacy policy and terms of use of such linked sites.

Data security

Imfuna is committed to protecting the security of your personal data and takes precautions to protect it when we are processing it:

• your Imfuna password is protected by encryption and only you have access to it;
• your personal data stored in our systems is protected by various physical, electronic and procedural safeguards. It is housed in a secure facility and Imfuna restricts physical and network access to this facility to selected trained staff and regularly evaluates its technologies, facilities, procedures and potential risks to maintain the security and privacy of our users’ data.
• as a rule, Imfuna employees do not monitor or view your personal data or content stored in the Imfuna service, but it may be viewed if we learn that our Terms of Service may have been violated and confirmation is required, or we otherwise determine that we have an obligation to review it; and
• certain Imfuna services support the use of standard SSL encryption to protect data transmissions. However, this is not a guarantee that such data transmissions cannot be accessed, altered or deleted due to firewall or other security software failures.

Children

Our web site, products and services are not currently directed to children. We will not knowingly collect personal information relating to children under 13 years of age, and if we learn that we have inadvertently done so, we will promptly delete it wherever possible.

Changes and updates

As this Privacy Policy may be updated from time to time, we will revise and display the effective date at the top of the web page. You should periodically review it to keep abreast of our plans and procedures to protect the personal data that we collect.

Contacting us and making a complaint

Contact details for Imfuna Inc and Imfuna Limited are set out below. Imfuna welcomes your feedback regarding this Privacy Policy and how we handle your personal data, so if you have questions, comments or concerns please do get in touch.

If you are not satisfied with our response or you believe our use of your personal data does not comply with data protection law, you can make a complaint to a privacy authority, for example, the authority responsible for regulating data protection law in the territory in which you are located. In the UK, that is the Information Commissioner – see www.ico.org.uk for more information.

Imfuna Inc and Imfuna Limited contact GDPR@imfuna.com