Intelligent Automation, Inc. is committed to protecting the privacy of our users (“user”, “you” or “your”).
Who does this policy apply to?
This policy applies to:
- visitors to our Sites (“Site Visitors”);
- individuals who register to use Scraawl, mSmart, or any other IAI Sites or Services (the “Service(s)”);
- individuals who attend, or register to attend, sponsored events or other events sponsored by Intelligent Automation, Inc. (“Attendees”);
- individuals who take part in IAI’s online communities (available through our Sites);
- individuals who sign up to receive newsletters and other updates about Intelligent Automation, Inc. and about Scraawl;
- individuals who are third-party content authors of social media content (“Social Media Authors”),
For the purposes of this Policy, the term, “Site(s)”, shall refer collectively to www.scraawl.com, www.i-a-i.com and the other websites that IAI operates and that link to this Policy.
- your use of IAI’s Sites and/or Services;
- your interactions with IAI or its business partners, contractors and suppliers;
- the information IAI receives regarding Social Media Authors,
as well as to set out the rights you have to control the use of your information, and thereby assist you in making informed decisions when using its Site and Services.
This Policy (and where it relates to IAI’s Services; together with IAI’s Terms and Conditions and the Scraawl Terms of Service) sets out the basis on which any personal data that IAI collects from you, or that you provide to IAI, will be processed by IAI or its customers.
Important Note for European Users
Information submitted by you will be stored, processed, and used by IAI and our third party service providers who help IAI to deliver its Services and operate its business.
Intelligent Automation, Inc. is a US research and development company that provides a social media analytics platform as well as other products arising based on its research efforts. IAI’s data analytics platform and other tools help gain actionable insights from data.
IAI’s headquarters is located in Rockville, MD, in the United States. IAI contact information is listed below in the Contact Us section.
Information IAI May Collect about You
IAI may collect and process the following information about you:
- If you express interest in obtaining additional information about the Services, IAI may also collect contact information (such as your name, job title, email address, mailing address and home and/or business telephone number) as well as company information (such as company name, industry, location, annual revenue) that you provide by completing forms on the Site, including if you download content, register for an event or webinar, upload or submit any material via the Site, submit a request for a demo or ask IAI for more information;
- IAI may also collect data about how you interact with messages that IAI sends to you, for example; whether you opened an email and how you respond to periodic email and website campaigns;
- IAI collects information you provide to it through communications you send to IAI, for example; to report a problem or to submit queries, concerns or comments regarding the Site or its content;
- IAI may also collect other data directly from you, from time to time.
- Customer – In order to provide the Services, IAI requires its customers to provide it with certain contact information (such as company name, contact names, email addresses, mailing address, phone numbers, job titles and Authorized Users of the Services). IAI may also require financial/billing information (billing name, email address, mailing address, and credit card numbers) from its customers.
- Authorized Users –
- Additionally, IAI collects user and contact information (such as your name, email address, job profile, title, user permissions and password) about the individuals who are authorized to use its Services on behalf of its Customers (“Authorized Users”). If you are not an administrative user for your account, the same data about you may be provided by a colleague or other third party;
- IAI collects data about you when you use any part of the Services. For example, if you are logged in to your account, IAI will collect data as to how often you use the Services, which Services you use, what queries you created or amended, user permission settings and activities, API usage, and other data about how you interact with the Services;
- IAI may also collect data about how you interact with messages that IAI sends to you, for example; whether you opened an email or read an in-app message and how you respond to periodic surveys;
- IAI collects information you provide through communications you send to IAI, for example; to report a problem or to submit queries, concerns or comments regarding the Services; if you contact IAI’s support services, we will collect the data needed to categorize your question and respond to it. IAI also uses this data to track potential issues with the Services and customize support responses to better serve you;
- IAI may also require financial/billing information (billing name, email address, mailing address, and credit card numbers) from its customers, which may include Authorized Users’ information;
- IAI may also collect other data directly from you, from time to time.
- Social Media Authors – Finally, the Services themselves collect, process and store information, that may include personal information, from a variety of publicly available online sources, such as social networking sites, blogs, forums and news websites. This information is sourced only from content that has been made publicly available on the Internet and is used solely to provide the Services. The only parts of this Policy that are applicable to Third Party Content are contained in the Third Party Content and Social Media Authors section below.
It is always your choice whether or not to provide personal information. However, if you should choose to withhold requested information, you may not be able to use certain features of the Site or IAI may not be able to provide you with certain services.
Information we receive from other sources
Our Lawful Basis
IAI will only process personal data in a way that is compatible with and relevant to the purpose for which it has been collected. To the extent necessary for those purposes, IAI will take reasonable steps to ensure that the Information is accurate, complete, current and reliable for its intended use.
EU Users & Data Subjects: Our Lawful Basis for Using Personal Data
The data protection law in Europe only permits processing under certain prescribed lawful bases. For IAI’s EU users and data subjects, IAI has been careful to ensure it has a lawful basis for all the personal data that it processes. Its lawful bases include:
- Performing the contract that IAI has with you: In certain circumstances, IAI needs your personal data to comply with its contractual obligation to deliver its products or services to you. For example, if you want to use IAI’s products or subscribe to IAI’s Service, IAI needs your name and contact details so that it can communicate with you.
- Legitimate interests: This is a technical term in data protection law for IAI’s commercial interests where these have been weighed against the interests or rights and freedoms of the individual and it has been decided that IAI’s interests are not outweighed by those rights and freedoms. IAI sometimes requires your personal data to pursue its legitimate interests in a way which might be reasonably expected as part of running IAI’s business and which does not materially impact your interests or rights. For example, IAI analyzes how users interact with its Site and Services so that it can better understand which elements are working well and which are not working well.
- Consent: The legal basis for IAI’s processing of data may also be where IAI has your consent (for example where consent is required to send certain marketing communications).
- Compliance with a legal obligation: Sometimes the law says that IAI needs to collect and use your data. For example, IAI may pass on details of individuals involved in fraud or other criminal activity to law enforcement authorities. Tax laws require IAI to retain records of orders and payments for its Services, which can include contact details of individuals within its corporate customers.
IAI may communicate with you by phone, in writing, via email, or other means available on or through the Site and Services (for example, via pop-up messaging or push notifications). IAI may communicate transactional or service messages to you, such as welcoming you to IAI’s Services or informing you of scheduled downtime. IAI may also send you marketing communications as described below.
How Your Information May be Used
IAI uses information held about you for a wide range of purposes, including:
- to provide, operate, maintain, improve, and promote the Sites and Services; including any obligations arising from any contracts entered into between you and IAI and to provide you with the information, products and services that you request from IAI;
- to process and complete transactions, and send you related information, including purchase confirmations and invoices; as well as verify and carry out financial transactions in relation to payments you make to IAI;
- to send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
- to provide you with information about services, products or programs that IAI feel may interest you, such as new products and services, features, a/b testing opportunities, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about IAI and its partners. You can opt-out of receiving marketing communications from IAI by contacting IAI through the Contact Us options provided below or following the unsubscribe instructions included in marketing communications. In order to provide the Services to you, you cannot opt out of receiving transaction or service messages;
- to administer the Site and Services under IAI’s terms and for internal operations, including troubleshooting, account management, and, in IAI’s legitimate interests, data analysis, work prioritization, testing, research, tracking users’ movements, and gathering broad demographic information for aggregate use for the improvement of the Site and Services so that IAI can provide all of its users with a better experience;
- to ensure in IAI’s legitimate interests that content from the Site and Services is presented in the most effective manner for you and for your computer;
- as part of IAI’s legitimate efforts to keep the Site and Services safe and secure, including to investigate and prevent fraudulent transactions, unauthorized access to the Site and Services, and other illegal activities;
- to notify you about changes to the services or policies; and
- for other purposes for which IAI obtains your consent.
IAI may combine the information you give to IAI with the information that IAI collects about you. IAI will use this information and the combined information for the purposes set out above (depending on the types of information IAI receives). IAI may also use data to conduct research and development.
IAI does not sell or trade personally identifiable information about its Site visitors or its Customers or their Authorized Users.
IAI may share your personal data with:
- Trusted third parties, including business partners, sub-contractors, and suppliers who provide services to IAI (including handling and delivering email communications, newsletters, and website hosting services). These third parties assist IAI in operating its Site and Services, conducting its business, or servicing you and have agreed to keep this information confidential and use such information only for purposes relating to their services for IAI;
- Other Users on the Site: From time to time, we may post testimonials on the Site that may contain personal information. We will obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact IAI through the Contact Us options noted below;
- Social networking and other websites: the Site or Service may allow you to post information on social networking sites. IAI does not share your personal data to such websites unless you direct the Site or Service to share it. The use of the information by such social networking sites will be governed by their privacy policies and IAI does not control their use of shared data;
We may also share your personal data under the following circumstances:
- Merger, sale, or other asset transfers: As a result of the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, reorganization or liquidation of Intelligent Automation, Inc., Your personal data may be transferred as part of such a transaction (as one of the transferred assets) as permitted by law and/or contract;
- As required by law: If IAI is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements with you; or to protect the rights, property, or safety of Intelligent Automation, Inc., its customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and law enforcement purposes;
- With your consent: IAI may also disclose your information, including your personal information, where you have specifically provided your consent for the disclosure. You may withdraw consent at any time by clicking the unsubscribe link at the bottom of any communication that IAI sends to you, or by using one of the Contact Us options noted below.
Marketing Choices (Opt-Out/Discontinue)
Please keep in mind however, that regardless of these preferences regarding promotional contacts, IAI may contact you for other reasons connected to the service you request or receive, such as those related to:
- an order for a product or a service you placed;
- an inquiry you made;
- a newsletter you may have subscribed to;
- a legally required notice; and
- any other necessary administrative, service or maintenance notices relating to your subscription or account.
IAI may also retain a record of any stated objection by you to receiving updates from Intelligent Automation, Inc. regarding Scraawl or its other Sites or Services for the purpose of ensuring that it can continue to respect your wishes and not contact you further.
This Site may contain links to third-party websites. These links are provided solely as a convenience to you and not as an endorsement by Intelligent Automation, Inc. of the contents on such third-party websites. Intelligent Automation, Inc. is not responsible for the privacy practices or content of linked third-party sites and does not make any warranty or representation regarding the content or accuracy of materials on such sites. If you decide to access linked third-party websites, you do so at your own risk. Please review the privacy policies of these websites before submitting any personal data to these sites.
If you use a blog, bulletin board or chat room on IAI’s Sites (“Interactive Area”), you should be aware that any personal data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. IAI is not responsible for the personal data you choose to submit in these forums. To request removal of your personal information from an Interactive Area, you may contact IAI through the Contact Us options noted below. In some cases, IAI may not be able to remove your personal information, in which case it will let you know if it are unable to do so and why.
IAI places great importance on the security of all personal data associated with its users. IAI has security measures in place to attempt to protect against the loss, misuse, unauthorized access, disclosure, alteration, or destruction of personal data under IAI’s control. For example, its security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized personnel have access to personal data. While IAI cannot ensure or guarantee that loss, misuse, unauthorized access, disclosure, alteration, or destruction of information will never occur, IAI uses all reasonable efforts to prevent it.
You should bear in mind that submission of information over the Internet is never entirely secure. IAI cannot guarantee the security of information you submit via the Site or Services while it is in transit over the Internet. Any such submission is at your own risk.
You are responsible for maintaining the confidentiality of any user name or password that you use. It is advisable to log off of the Sites or Services and close your browser when you have finished your user session to help ensure that others do not access your personal data.
Storage and Transfers of Your Information
Your personal data which IAI collects is sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information. Personal data submitted may be transferred by IAI to its other offices and/or to the third parties mentioned in the circumstances described above (see Information Sharing), which may be situated outside the European Union (EU) and may be processed by staff operating outside the EU. Where IAI transfers your personal data, it will take reasonable steps to ensure that your privacy rights continue to be protected.
Retention and Deletion of Personal Data
IAI will only keep your personal data as long as necessary to fulfill the purposes that IAI collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements. IAI may need to retain certain personal data even once the purpose of using data under this Policy has been completed to enforce its terms, for fraud prevention, to identify, issue, or resolve legal claims, for proper record keeping purposes and/or as required for its business operations, or by applicable laws. IAI may retain certain information beyond this time for historical or statistical research purposes. IAI may also retain a record of any stated objection by you to receiving updates for the purpose of ensuring that IAI can continue to respect your wishes and not contact you further.
Your Rights (EU Users)
Under the General Data Protection Regulation (GDPR), individuals located in the EU have the right under certain circumstances:
- to be provided with a copy of their personal data held by IAI;
- to request the update, correction, or erasure of any of their personal data held by IAI;
- to object to any further processing of their personal data, including the right to object to marketing communications;
- to request that IAI restrict the processing of their personal data;
- to request that the data they have provided be transferred to a third party; and
- to withdraw consent: where the basis of processing their personal information is based on consent, they have the right to withdraw that consent at any time.
You can exercise the rights listed above at any time by contacting IAI at firstname.lastname@example.org or through the Contact Us options noted below.
You will not have to pay a fee to access your data or to exercise any other rights described above. IAI may, however, charge a fee if it believes that your request is unfounded or excessive.
IAI may need to request specific information from you to enable it to confirm your identity and to ensure that you have the right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. IAI may also contact you to ask you for further information in relation to your request, in order to process your request.
IAI aims to respond to all legitimate requests within 30 days. Occasionally, it may take longer than 30 days to process your request pending the extent and complexity of your request. In this case, IAI will notify you and keep you updated.
If your request or concern is not satisfactorily resolved, you may approach your local data protection authority (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) that can provide further information about your rights and IAI’s obligations in relation to your personal data. In the UK, this is the Information Commissioner (https://ico.org.uk/).
Third Party Content and Social Media Authors
Intelligent Automation, Inc. receives personal data from third parties, such as Facebook, Twitter, Instagram, and other online public blogs and forums. IAI is required to comply with its contract with those third parties or their public terms and conditions.
- IAI’s Services collect, use, process and store information that has been made publicly available on the Internet (“Third Party Content”). In general, the Third Party Content can be found using a standard Internet search engine or by visiting the applicable websites directly. IAI does not have any ownership interest or control over the Third Party Content or any direct relationship with those persons who post such Third Party Content. IAI obtains Third Party Content through agreements with certain data providers, who either have a direct relationship with Social Media Authors or who search and index publicly available information (including data) from the Internet. IAI does not attempt to gain unauthorized access to any information and does not circumvent any passwords or other technology protections. IAI only gathers Third Party Content that is made available to the public by the site or by the individual Social Media Author.
- IAI’s Services provide analytics that allow customers to aggregate and analyze the Third Party Content. The Services may also be used by customers to collect certain personal information about individual Social Media Authors and their online activities, such as interactions with a customer’s website and/or in relation to a customer’s products and services. IAI requires its customers to comply with all applicable legal requirements in using the Third Party Content, including any applicable privacy laws.
Information we collect about you
The data that IAI collects varies depending on the source of the data, what the source or platform chooses to make available, and what you choose to make publicly available. It could include the following:
- your name, username, handle, or other identifier;
- the content of the information you have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, etc.;
- your profile picture or other images or videos that you post or interact with;
- your job title or profession (including category of profession, for example “journalist”);
- your interests;
- your location;
- your gender; and
- any other information you publish on an Internet website that IAI searches or on a third party platform that provides IAI with data.
IAI may use the data you make available about yourself to infer other data about you in the context of a wider conversation. For example, based on your name, IAI may infer your gender and use it in an aggregated display as part of the Services. Equally, based on the content of one of your posts, IAI may infer some of your interests, your profession, your location, etc.
IAI may also analyze the content of the data you publish and provide that analysis to IAI’s customers. For example, if you publish a Tweet stating that you like a certain brand’s ice cream, IAI may mark that Tweet as having a positive sentiment toward that brand.
Uses of the Information We Collect about You
The legal basis for the data that IAI processes is pursuant to its legitimate interests. IAI’s legitimate interests are in providing the Services to IAI’s customers, which includes providing technology that is easy to access and use, and that empowers IAI’s customers to act with more certainty. .
Additionally, your information is used in the following ways:
- Allow IAI’s customers to learn more about their brand, their customers, their competitors, and other information available on the social web that is relevant to its customers;
- In ways related to, but ancillary, to the Services that IAI offers. For example, IAI may use the data to comply with its legal obligations or enforce its rights, including the legal obligations or enforcement of rights of third parties;
- IAI may also use the data to improve its Services.
Although it is the responsibility of IAI’s customers to use the Services properly, IAI do put in place safeguards to protect your data. IAI requires its customers to comply with applicable law, including data privacy law, when using the Services. IAI also prohibits its customers from using the Services, including your data, in a way that is outside of your reasonable expectations.
When IAI infers data about you, it does so automatically. The inferences are based on algorithms that analyze the data that you have posted. IAI does not make any decisions about you based on the data that it processes about you (inferred or not). In other words, IAI only make the data available to its customers. It is up to IAI’s customers what (if anything) to do with the data and any inferences about the data.
IAI will only process data about you which may be deemed sensitive or part of a special category under data protection law which has been made public and available to IAI by virtue of it being public.
Sharing your data
In addition to sharing your data with IAI’s Customers, IAI may share your data as described in the Information Sharing section (with the exclusion of Site testimonials and prospect or customer references) of this Policy.
IAI will store and transfer your data as described in Storage and Transfers of Your Information.
Retention of your data
In relation to IAI’s legitimate interests as it relates to historical and statistical research, IAI retains your data for as long as it is made publicly available.
Privacy practices of third parties
This Policy only addresses IAI’s collection, processing, and use (including disclosure) of your data. IAI’s customers and other third parties that may have access to your data can use it in other ways in accordance with their own privacy practices and applicable law. IAI encourages you to familiarize yourself with the privacy statements provided by any platform you use to publish any information.
As a Social Media Author, you are the source of the data. You have control over that data within the platform or forums that you choose to publish it on (e.g. Twitter, Facebook, Instagram and other blogs, forums, etc.), including through using the privacy settings made available to you by that platform or forum. In addition to whatever rights you have via your relationship with any publishing platform, you also have certain rights relating to your data that IAI processes, as set out in this Policy.
If you believe that IAI has information from you that you do not want it to have, please Contact Us as described below and contact the social media provider to whom you initially gave that information. IAI will delete your content upon your request, if it is able to do so.
If you reside in the European Union (EU) or other jurisdictions that provide access rights under law, you may access your information that IAI has collected or have it corrected or updated in accordance with applicable law by contacting IAI through the Contact Us options described in this Policy (See Your Rights (EU Users) above).
IAI is committed to protecting the online privacy of children. In accordance with the Children’s Online Privacy Protection Act in the United States and the GDPR in the EU, IAI will not knowingly collect or solicit any personally identifiable information from or provide any services to children under the age of 16. IAI’s Site and its content are not directed at children under the age of 16. If IAI learns that it has collected personal data from a child under the age of 16 without parental consent, it will delete that information as quickly as possible. If you believe that IAI might have any information from or about a child under 16, please contact IAI at email@example.com.
Special Notification for California Residents
Users who reside in California and have provided personal data to IAI have the right to receive: (a) information identifying any third party to whom Intelligent Automation, Inc. may have disclosed, within the past year, personal information pertaining to you and your family for that party’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to firstname.lastname@example.org. This request may be made no more than once per calendar year. IAI reserves its right not to respond to requests submitted other than to the address specified in this paragraph.
Email questions about IAI’s privacy and security practices to: email@example.com
Mail: Intelligent Automation, Inc., 15400 Calhoun Dr., Ste. 190, Rockville, MD 20855, Attn: General Counsel