Privacy

Integra, Inc.(“Integra, Inc.” “Integra Ledger,” “Integra”,“we,” “our,” or “us”) is committed to protecting your privacy.  This Privacy Policy explains how your personal information is collected, used, and disclosed by Integra.  ThisPrivacy Policy applies to our website, Integra, Inc. (our “Service”)and the use of the Integra Ledger.  By accessing or using our Service and participating in Integra, you signify that you have read, understood, and agree to  our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy.

WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

The categories of information we collect can include:*

Information you provide to us directly.  We may collect personal information, such as your name, email address, phone number, and any other information you provide to us when you sign up for our mailing list, participate in Integra’s BlockchainIntegration Wizard use the Integra Ledger, or otherwise communicate with us.  We may also collect any communications between you and Integra and any other information you provide to Integra.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, run and administer the Integra, and communicate directly with you, such as to send you email messages.  We may also send youService-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices).  For more information about your communication preferences, see “Control Over YourInformation” below.

HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION.

We, and our third-party partners, automatically collect certain types of usage information when you visit or use our Service, read our emails, or otherwise engage with us.  We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology(collectively, “tracking technologies”).  For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to uniquely identify your browser, mobile device, or your account), and other such information.  We also collect information about the way you use ourService, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.  When you access ourService from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows AdvertisingID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g.,latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.  We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users.  You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.  We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.  Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through tracking technologies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

We and our third-party partners may also use cookies and tracking technologies for advertising purposes.  For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

SHARING OF YOUR INFORMATION

We may share your personal information in the instances described below.  For further information on your choices regarding your information, see the “Control OverYour Information” section below.

We may share your personal information with:*

  • Other companies and brands owned or controlled by Integra and other companies owned by or under common ownership as Integra, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy;*

  • Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfilment, web hosting, or providing analytic services;*

  • The public when you provide feedback or user content on our Service. For example, if you post user content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our Service or on our social media pages;*

  • Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and*

  • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or(c) to exercise or protect the rights, property, or personal safety of Integra, our visitors, or others.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

CONTROL OVER YOUR INFORMATION

How to control your communications preferences:  You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications.  We make every effort to promptly process all unsubscribe requests.  You may not opt out of service-related communications (e.g.,account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Modifying or deleting your information:  If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at info@integraledger.com.  We may not be able to modify or delete your information in all circumstances.

THIRD-PARTY TRACKING AND ONLINE ADVERTISING

Interest-BasedAdvertising.  We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history.  We may share or we may permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information.  We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Social MediaWidgets and Advertising. Our Service may include social media features, such as the Facebook Like button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter, or other widgets.  These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employ other tracking technologies.  Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others.  These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics.  These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-DeviceLinking.  We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device.  We do this by collecting information about each device you use when you are logged in to our Service.  We may also work with third-party partners who employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household.  We may share a common account identifier(such as an email address or user ID) with third-party advertising partners to help recognize you across devices.  We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

Your Choices:*

  • Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the NetworkAdvertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices.  You may also manage certain advertising cookies by visiting the EU-based Your Online Choices atwww.youronlinechoices.eu.*

  • Cross-device linking.  Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices.  You must perform the opt-out on each browser or device you use.*

  • Mobile advertising.  You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking”(iOS) or “opt-out of interest based ads” (Android).  You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.*

  • Some of these opt-outs may not be effective unless your browser is set to accept cookies.  If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Google Analytics and Advertising.  We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us.  We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service.  Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you.  For information on how GoogleAnalytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/.  You can learn about GoogleAnalytics’ currently available opt-outs, including the Google Analytics BrowserAd-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, GoogleDisplay Network Impression Reporting, the DoubleClick Campaign ManagerIntegration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service .  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer:  Your information collected through our website may be stored and processed in the United States or any other country in which Integra or its affiliates or service providers maintain facilities.  If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Integra or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Keeping your information safe:  We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through ourService.  However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

CHILDREN’SPRIVACY

Integra does not knowingly collect or solicit any information from anyone under the age of 13 on this Service.  In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have any information from a child under 13, please contact us at info@integraledger.com.

LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at info@integraledger.com.

CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically.  When we change the policy in a material manner, we will let you know and update the ‘last modified’ date at the bottom of this page.  If you object to any changes, you may close your account. Continuing to use our Service after we publish changes to this Privacy Policy means that you are consenting to the changes. 

EU Data Subjects

Scope. This section applies if you are an individual located in the European Union orEuropean Economic Area (collectively, “EU”) (“EU Data Subject”). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland.

DataController. INTEGRA is the data controller for the processing of your PersonalData.Your Rights. Subject to applicable law, you have the following rights in relation to your Personal Data (“Personal Data” means information that, alone or in combination with other information, could be used to identify you);*

Right of access: If you ask us, we will confirm whether we are processing yourPersonal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.*

Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your PersonalData so that you can contact them directly.*

Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.*

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your PersonalData with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.*

Right to data portability: Effective 25 May 2018, you have the right to obtain yourPersonal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it else where.*

Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:* If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or* If we are processing your Personal Data for direct marketing.* Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that affect you, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing.*

Right to withdraw consent: If we rely on your consent to process your PersonalData, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.*

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your PersonalData, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.

Legitimate Interest. “Legitimate interests” means the interests of INTEGRA in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the Websites, Apps and our services are being used by you, and to ensure network and information security, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, un less we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “YourRights” section above.