Effective date: October 9th 2019
Indicado web platform is owned and operated by, or on behalf of Indicado LLC. We are the data controller in respect of Personal Data of our users based in the European Union.
If you happen to be left with even more questions after reading our policy – or already have some – do not hesitate to contact us at the following email address: email@example.com.
“Applicable laws” means all the laws and regulations relevant to the collection, processing and storage of data, especially all the data protection laws and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
“Indicado” or “we” or “us” or „our” means Indicado LLC with a registered office at 228 East 45th Street Suite 9E, New York 10017, USA.
“Cookies” means small text files that are created when you use your browser to visit the Website and stored on your computer’s browser directory. Cookies allow the Website to remember your preferences as well as they allow to recognize websites visited and/or web browsers used from one visit to another.
“Legal Grounds” means the legal basis for the collection, processing and storage of your Personal Data as indicated in the article 6 (1) of the GDPR.
“Personal Data” or “Data” or “Personal Information” any information that could be used to identify you or other persons as individuals based in the European Union.
“Data Processor” means Indicado when you provide us with Personal Data that you are in possession of as its controller (someone who determines the purposes and means of the processing of Personal Data) on the basis of a separate agreement called Data Processing Agreement.
“Website” means https://www.indicado.com.
“Services” means services provided by Indicado via Website in accordance with the Terms and Conditions.
“You” means an individual that uses our Services via the Website or/and an individual who uses the Website but has no access to the areas of the Website and Services.
We try to collect only as much of your Personal Information as we need to. We collect this information directly from you when you sign up for Indicado web platform or contact us for support. We can divide your Personal Information into the one that is provided by you to us on through the Website and the one that we collect automatically when you use our Website or Services. We do obtain information about you from other sources and as a result we do combine it with information we collect through our Services for purposes of advertising and user authentication.
We collect and process information you provide us with by using the Website or Services. Personal Data submitted through the Website or Services includes the details you provide when:
In the newsletter form on the Website you can provide us with your basic Data such as: your name, surname, email address and work position.
You can also use our chat box to contact with us with regard to the Services we provide. In order to do this, you may provide us with your email address as well. You can also send us your other Personal Data both concerning you or other persons.
For these providers, we recommend that you read their privacy policies, so that you can understand the manner in which your Personal Data will be handled by them.
III. Data we collect automatically when you use the Website or Services
When you access or use the Website or Services we automatically collect information about you, including the one collected by Cookies and other tracking technologies.
We gather certain information about your use of the Website or Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Website.
Below you can find out for which reasons we use your Personal Data (purposes of Data Processing) and what is the legal basis of it (Legal Grounds of Data processing):
Apart of that, your Personal Data may be processed on the basis of your explicit consent – article 6 (1) (a) of the GDPR. In this case you may withdraw your consent at any time by contacting us at the following email address: firstname.lastname@example.org. Your Personal Data will be processed until you withdraw the consent. The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.
Therefore regarding our use or disclosure of their Personal Data, you may contact Indicado LLC as indicated in section below – XI. Contact details. We will provide you with reasonable methods to exercise your choices.
Please see the description of your rights in connection with Data processing as determined in point VI. Your rights.
Your Personal Data will be retained by Indicado for the duration of your account and may be retained for a period after this time according to our terms of agreement with you or as necessary and relevant to our legitimate interests (i.e. creating statistics and improving and changing our systems, pursuing claims or defending against claims, handling your complaints and chargebacks, sending marketing communications) or in accordance with applicable legal obligations in order to meet the tax and accounting law requirements.
This means that for example with respect to payment details: while we do not process details like your card number, we will be required by law to retain information about the payment in our systems for accounting purposes, such as the bank account number associated with it.
However, with regard to the Data processing for marketing purposes we are obliged to process your Data for that purposes only as long as you do not object it. When you send us your request in that matter, we will cease to process your Data for marketing purposes. Moreover you may unsubscribe from newsletter at any time by clicking the unsubscribe link in the sent email. In these circumstances, your Personal Data will not be processed after cancellation of your subscription.
If information about you are processed on the basis of your explicit consent, you may withdraw your consent at any time by contacting us. Your Personal Data will be processed until your withdrawn of the consent.
Data is stored using generally accepted security standards and in compliance with Applicable laws. If you need more detailed information about the retention of your Personal Data, please contact us at the following email address: email@example.com.
The following rights may apply to you in connection with the processing of Personal Data with regard to using our Website and Services if relevant conditions of the GDPR are fulfilled:
You may exercise the abovementioned rights by contacting us at the following email address: firstname.lastname@example.org. Please include information that will enable to verify your identity within your request. 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. Without verifying your identity, especially if you do not provide us with additional information if needed, we will not be able to handle your request therefore it will not be processed.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You are also entitled to submit a complaint to the competent supervisory authority in your country at any time in the event of a breach of your rights regarding the processing of Personal Data.
If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. Indicado agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.
VII. Disclosure of the Data
Indicado shares your Data only with qualified and authorized employees as well as trusted third parties, including:
VIII. Transfer of Data to the U.S. and other countries
Indicado is based in the United States. By accessing or using the Services or otherwise providing information to us, you understand that your information will be subject to processing, transfer and storage in and to the U.S. where you may not have the same rights and protections as you do under local law.
Moreover your Personal Data may be transferred to other third country i.e. outside the European Economic Area, however, only in accordance with Applicable laws and with appropriate safeguards in place, to (i) entities covered by decision of the European Commission stating appropriate level of the personal data (Article 45 of the GDPR), including decision regarding the Privacy Shield (EU Commission Decision 2016/1250), (ii) using appropriate safeguards stated in the Article 46 of the GDPR such as standard contractual clauses adopted by the European Commission (EU Commission Decision on standard contractual clauses for the transfer of Personal Data to processors established in third countries under Directive 95/46/EC) or binding corporate rules in accordance with Article 47 of the GDPR.
Indicado uses various security technologies and organisational procedures that help protect your Personal Data from unauthorized access, use, disclosure, alteration or destruction.
We want you to feel confident using our Website to conduct business. However, you should also take care of how you handle and disclose your Data and avoid sending Personal Data through insecure channels or networks. It is important for you to protect yourself against unauthorized access to your password and to your computer. Be sure to sign off when you finish using a shared computer and under no circumstances share your password with anyone, even with us – we will NEVER ask for it. If we notify you about suspicious logging or traffic on your account, please be sure to change your password immediately also to accounts in other systems for which you use the same password.
Indicado provides services regarding processing of Personal Data on your behalf. This means that we process End-users’ data in the range of provided Services.
Therefore we process Personal Data submitted to us by you according to the terms determined in our Data Processing Agreement (DPA).
As the Data Processor, we may process the following data of Data Subjects, provided by you:
The Data Processing Agreement is available on the Website and it is accepted by you when you conclude an agreement with Indicado (i.e. by accepting the Terms and Conditions). We will process Personal Data submitted to us by you according to the terms determined in our Data Processing Agreement. In the range of that Data Processing Agreement we shall not process those Data except on your instructions, unless required to do so by Applicable laws.
Please note that if you use Services in such a way that your employees or workers have their own accounts in the organizational structure created by you on your master account, you entrust Indicado with their Data according to the provisions of Data Processing Agreement.
registered office at 228 East 45th Street Suite 9E,
New York 10017, USA.
Contact email: email@example.com