Effective Date: October 24, 2018
This website is not intended for children and we do not knowingly collect data relating to children via the website.
This website, io-tahoe.com, (the “Website”) is owned and operated by Io-Tahoe. Io-Tahoe, LLC’s principal place of business is in the United States at 111 Broadway, Suite 601 New York, NY 10006. Io-Tahoe UK Limited’s principal place of business is in the United Kingdom at 71-91 Aldwych, London, WC2B 4HN, UK.
For the purposes of data protection under the General Data Protection Regulation and any applicable national implementing laws, regulations, secondary or other legislation (collectively, the GDPR), the legal entities overseeing the processing of your personal data are Io-Tahoe LLC and Io-Tahoe Limited. To clarify the essence of the arrangement by which Io-Tahoe collects and processes personal data, both legal entities are considered data controllers in their own right. On occasion, for certain processing activities, one of the entities may act as a data processor for the other. There may also be processing activities for which we would be considered joint data controllers in that we may jointly determine the purposes and means by which your personal data is processed by us.
If you have any questions or concerns about Io-Tahoe’s data policies or practices, you may get in touch with us at the above address or at the following e-mail address: firstname.lastname@example.org.
Collection of Personal Data
Most of the services provided by www.io-tahoe.com can be used without the need for collection of personal data of any kind. However, we may collect personal data (such as name, address, e-mail address and IP address for example) for purposes described in this Policy. As a visitor to our website, prospective customer or customer of ours, we collect contact information about you when you provide it to use, for example, when you fill out our online forms, respond to our promotions, or inquire about our products and services. Other organisations that provide products and services to you may also share information with us. For example, if you attend a conference and agree to allow the conference organization to share your contact information, the conference organizer may share your personal data with us. We may combine this information with information we collect in accordance with this Policy. We may also process personal data with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
In addition to collecting contact information, as a visitor to our website, we collect analytics relating to your time spent on the website. We collect the following information: your internet protocol (IP) address; your login data, browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform; and other technology on the devices you use to access the website.
Why We Collect Personal Data and Legal Basis for Processing
When processing your personal data, the objectives pursued are:
The personal data we collect concerning you are processed in full compliance with European laws and regulations.
Where the processing of your personal data is based on your consent only, you have the right to withdraw this consent at any time. We will then erase your personal data and stop processing it.
You may receive marketing communications from us if you are an existing client or if you provided us with your consent or where we are pursuing a legitimate interest and have a lawful right to do so and, in each case, you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting email@example.com at any time.
Any personal data that we have collected or stored about you or that you have provided to us, may be transferred to a future purchaser of our company and/or its assets or as part of current or future legal proceedings or as required by law enforcement.
Protection of Information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Storage and Retention
We store your personal data on Io-Tahoe’s servers located in the United States and on the servers of the cloud-based database management service that Io-Tahoe engages, located in the United States. The data collected from our website is stored in a secure server with our ISP who will take periodic backups of such data but will not give or sell it to anyone else.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see “Your Rights” below for further information.
Where the processing of your personal data is based on your consent only, you have the right to withdraw this consent at any time. In that case, we will then erase your personal data and stop processing it. For more information on where and how long your personal data is stored, and for more information on your rights to erase your personal data, please contact us by email at firstname.lastname@example.org.
We also use tools like Google Analytics to measure traffic to our Site and how users interact with our Site. Google Analytics utilizes cookies to gather information regarding use of our Site, which Google uses to generate reports for us regarding our Site. To find out more about how Google uses data when you use our Site and your options for controlling the information collected by Google from this Site, please click here. You may opt-out of having your activity on the Site made available to Google Analytics by installing the Google Analytics browser add-on, available here.
Please refer to our Cookies Policy for more information about the cookies we use and why. You can also find out more about how to control them.
How We Share Personal Data with Others
We may engage vendors, subcontractors, agents and other service providers to perform functions on our behalf or to assist us in providing services to you (“Processors”). We may share your personal data with Processors as required for them to perform their functions on our behalf or to permit us to perform our functions. Examples include creating and maintaining our Website, providing analytics and Website usage information, processing transactions and payments, and other services related to the operation of our business. We carefully select these Processors and require them to keep your personal data secure.
We reserve the right to disclose any information in our possession if we are required to do so by law or we believe, in good faith, that such a disclosure is necessary to comply with the law, court order or other government or law enforcement agency, defend our rights or property, or to respond to an emergency situation or protect the rights, property or safety of website users.
We reserve the right to transfer personal data to a purchaser or successor entity in the event of a sale or other corporate transaction involving some or all of the business.
We may share your personal data with your consent or at your direction.
International Transfer of your Personal Data
Our website is hosted in the United States. Io-Tahoe, LLC (based in the United States) and Io-Tahoe UK Limited (based in the UK) share infrastructure, personnel and providers of services in connection with the services we provide and marketing activities that we undertake. Io-Tahoe, LLC (based in the United States) also provides client and support services to Io-Tahoe (based in the UK). As a result, Io-Tahoe and its offices in the United States will receive and have access to your personal data. This is required to provide you with services and effectively run our business. We store your personal data on Io-Tahoe’s servers located in the United States and on the servers of the cloud-based database management service that Io-Tahoe engages, located in the United States.
Transfer of personal data may occur internally between Io-Tahoe offices, to our providers as necessary to provide our services, or to public and regulatory bodies in the event we are required to do so. These transfers will involve international transfer of your personal data to our Io-Tahoe offices (including our offices located outside the European Economic Area (EEA)) and data centers or those of our providers or public and regulatory bodies.
The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR. However, we only transfer your information where there are appropriate measures and controls in place. If accessing the Website from outside the United States, you acknowledge that personal data that you submit through our Website will be processed in the United States.
Under certain conditions, you have the right to request from us, among other:
For more information on the full extent of your rights or to exercise your rights, please contact us by e-mail at email@example.com with a brief explanation of your situation. Please attach to your request a copy of an official identity document. 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 for further information in relation to your request to speed up our response.
If you would like to unsubscribe from any email publication you can also click on the ‘unsubscribe’ button at the bottom of the relevant email publication. It may take up to 10 days for this to take place.
Consequences of not providing your personal data
For customers or prospective customers of Io-Tahoe, it is in your discretion to provide personal data to us. However, for us to enter into a contract with you, or other professional, employment or business relationship with you, we will need to obtain certain information, including personal data that may be necessary or legally required. If you do not provide us with all or some of the personal data we request, we may be prevented from entering into a contract with you, providing you with services, or sending you marketing information or other communications that you have requested. For users of the website, providing your personal data is purely voluntarily. Not providing such data may only prevent you from receiving information from Io-Tahoe.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at firstname.lastname@example.org in the first instance.
Managing “Do Not Track” Signals
Some browsers have an optional Do Not Track (“DNT”) feature that allows you to express your preference regarding tracking of your online activity by websites. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies. Our Site does not currently respond to DNT browser signals or mechanisms.
Your Rights Under California Law
If you are a California resident under 18 years old and have an online account with us, you can request that we remove content or information that you have posted to our website or other online services. Note that fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please email or call us using the contact information below.
If you are a California resident, you have a right to request from companies conducting business in California a list of all third parties to which the company has disclosed Personal Information, as defined under California Civil Code Section 1798.83(e), during the preceding year for third party direct marketing purposes. We will respond to one request per California resident per calendar year, according to California Civil Code Section 1798.83. You may request this information in writing by contacting us by email at email@example.com. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please allow up to thirty (30) days for a response.
Changes to Our Policy
Io-Tahoe LLC may from time to time make changes to this Policy to reflect changes in legal or regulatory obligations or changes in the manner in which we collect and use personal data. We will post any revised version of this Policy on our website and update the version number.
Version No. 1 of October 2018