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PRIVACY POLICY

v. 2 from 12/06/2021

 

Welcome to iPNOTE!

IPNOTE Inc. (or “we”, “iPNOTE”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.

iPNOTE is the controller and responsible for your personal data.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

By accessing our Site or our Service, you accept our Privacy Policy, and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

If you have any questions, concerns or claims in relation to this Privacy Policy you can contact us at [email protected].

TABLE OF CONTENTS
  1. Definitions used in this Privacy Policy
  2. What information do we collect?
  3. How is your personal data collected?
  4. How do we use information?
  5. How do we share information?
  6. Your legal rights
  7. How long do we keep information?
  8. How do we protect your personal information?
  9. California and Nevada Residents Privacy Rights
  10. Supplemental Privacy notice for Californian Residents
  11. Contact information
  12. Miscellaneous

 

1. DEFINITIONS USED IN THIS PRIVACY POLICY

The following terms are used throughout these Terms of Use and have specific meanings:

The “User”, “You” and “Your” refer to the person, company, or organization that has visited or is using the Website and/or the Service.

The “Account” is a collection of settings and information associated with a User on the Website.

The “Company” is legal body, individual entrepreneur or a physical person that is added by User to their Account for Service usage. A Company may be a Client, a Consultant, both, or neither.

The “Task” refers to the Service request made by a Client to other Users (potential Consultants) describing Client’s needs related to intellectual property or other legal issues. After acceptance of a particular Consultant’s Offer by the Client, the Task becomes a part of a legally binding Agreement between the Consultant and the Client.

The “Offer” refers to a commercial proposal for a Task made by a Consultant to a Client. Offer normally contains information about service charge, governmental fee, delivery time etc.

The “Agreement” refers to the legally binding Agreement between a Consultant and a Client concluded when the Client accepts a Consultant’s Offer to a Task.

The “Consultant” refers to Companies in the intellectual property or legal field who may communicate with and provide contracting or consulting work to Clients for a fee. Consultants are not the employees or agents of iPNOTE.

The “Client” refers to Companies who set Tasks and enter into Agreements with Consultants to receive services connected with intellectual property for a fee.

The “Content” refers to content featured or displayed through the Website, including without limitation text, documents, information, data, articles, opinions, images, photographs, graphics, software, applications, video recordings, audio recordings, sounds, designs, features, and other materials that are available on the Website. Content includes, without limitation, User-Generated Content, which may be submitted by any iPNOTE User (Client, Consultant).

The “IP Sowtware” a software integrated in the Service and designated for effective intellectual property management, including but not limited to document management and storage.

The “IP Marketplace” is a part of the Service designated for collaboration and communication between legal professionals, patent attorneys and those seeking assistance in the sphere of intellectual property. Marketplace provides access to iPNOTE’s virtual community of professional Consultants; easy collaboration through iPNOTE’s communication management tools; conclusion of Agreements between Companies, secure payment, invoicing, dispute resolution and arbitration tools.

2. WHAT INFORMATION DO WE COLLECT?

2.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Registration information, such as name, last name, password and email.

Profile information (Identity information), such as profile photo, company name, your country, description of your business, type of your business, information about active employees in your company. Please note, that entering information about employees into your personal account you confirm that you obtained a proper consent to process and transfer their personal data.

Contact Data includes information, such as billing address, delivery address, email address and telephone numbers.

IP Rights, including documents, information and data about intellectual property such as: results of intellectual activity, applications for intellectual property assets registration, authors and other persons data, commercially valuable information, know-how and other materials that you upload to your Account.

Agreements: we collect details about Tasks and Agreements you carry out using the Service including but not limited to information about your counterparties, the scope and subject-matter of your Agreements, price and status of their performance.

Financial: we collect payment and billing information in your profile upon your registration and/or receipt of our services or your contractual performance including but not limited to banking details, information about your financial operations in the Service, receipts, current balance, available funds etc.

Professional Information – to confirm your professional experience and skills we can require your graduation or attorney certificates, state Bar number, your profession, your business or industry, etc.

Content, documents, and other information you voluntarily submit to other Users through the Service as well as your chats between Companies of the Service, discussions and messages concerning any of your Tasks, Transactions or other requests via the Service.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Technical Data includes 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 this website.

We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

3.1. Direct interactions. You may give us your Personal Information by filling in forms on the Site. This includes personal data you provide when:

  • apply for our products or services;
  • create an Account on our Site;
  • use the Service, including but not limited to upload your IP documents and information, make up Tasks, enter into Agreements, send messages via chat, make payments etc.;
  • subscribe to our publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.

3.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.

iPNOTE and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, the desktop app, and the mobile app, and to gather demographic information about our user base as a whole. The technology used to collect information automatically from our visitors may include the following: Cookies, Web Beacons. To learn more about Cookies and Web Beacons, please visit Cookie policy.

You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Service.

We may also receive Technical Data about you if you visit other websites employing our cookies.

3.3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    (a) analytics providers (such as Google, Yandex etc.);
    (b) advertising networks (such as AdWords, Baidu etc.); and
    (c) search information providers (such as Google Search, Yandex Search, Yahoo etc).
  • Contact, Financial and Transaction Data from providers of technical and payment services (such as Stripe Connect, Paypal etc.).
  • Identity, Professional Information and Contact Data from publicly available sources such as Company’s Website, Social media.
4. HOW DO WE USE INFORMATION?

4.1. Lawful basis for processing your Personal information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.2. Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register your Account(a) Identity
(b) Contact
Performance of a contract with you
To provide the Services you request including:
(a) allowing User effectively store data about their intellectual property and manage it;
(b) allowing Clients to select right Consultants for the Tasks and Agreements;
(c) facilitating communication between Clients and Consultants;
(d) providing contractual performance between Consultant and Client;
(e) simplifying invoicing and billing for Transactions.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) IP Rights
(g) Professional Information
(h) Content, documents, and other information you voluntarily submit to other Companies
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests.
To manage our relationship with you which will include:
(a) notifying you about changes to our terms or privacy policy
(b) asking you to leave a review or feedback, as well as to take a survey
(c) sending you information regarding our services, such as promotions or events;
(d) collect and recover money owed to us.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)

 

4.3. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.4. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

4.5. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

4.6. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. HOW DO WE SHARE INFORMATION?

iPNOTE may share User Personal Information with your consent to perform services you have requested in the following ways:

5.1. Account management:

5.1.1. When you create your Account and agree upon personal account management service, we share your User Personal Information with our employees designated to personal account management (IP Manager).

5.1.2. If Сonsultant or Client have any disagreements in contractual performance, IP Managers might analyse your discussion (chat) within a Task and/or an Agreement, documents and other information to arbitrate contractual disputes in a right way.

5.1.3. iPNOTE discloses User Personal Information only to those of its employees that need to know this information in order to process it on our behalf or to provide or improve our services. In addition, our employees have agreed not to disclose this information to others, in accordance with terms and conditions at least as restrictive as this Privacy Policy.

5.2. Task creation and discussion

5.2.1. When Client creates a Task, we can share their profile information with potential Consultants to the extent necessary to consider this Task and make an offer.

5.2.2. We can share Consultant’s profile information with a Client to the extent necessary to consider suitability of this Consultant for aTask.

5.2.3. Client and Consultant may launch Task discussion in the Service, where they voluntarily exchange information and documents about the Task before they enter into Agreement. This data exchange presumes explicit User’s consent to share User Personal Information with other User in the discussion.

5.2.4. The User which receives your information is not allowed to use it for purposes unrelated to the transaction.

5.3. Performance of an Agreement

5.3.1. When Client and Consultant enter into an Agreement, they may continue their discussion started according to the Section 4.2.3. hereof and voluntarily exchange information and documents necessary to perform the Agreement. This data exchange presumes explicit User’s consent to share User Personal Information with other User in the discussion.

5.3.2. The User which receives your information is not allowed to use it for purposes unrelated to the transaction.

5.3.3. To fulfill contractual payment, we can share your banking details with respective banking and/or payment organizations. These banking and payment organizations have agreed not to disclose this information to others, in accordance with terms and conditions at least as restrictive as this Privacy Policy.

5.4. Internal third parties

We can share your personal information with iPNOTE’s subsidiaries and affiliated organizations that need to know this information to process it on our behalf or to provide or improve our Service (IT and system administration services, leadership reporting). These subsidiaries and affiliates have agreed not to disclose this information to others, in accordance with terms and conditions at least as restrictive as this Privacy Statement.

5.5. Third party service providers

iPNOTE discloses User Personal Information only to those of our third party contractors (e.g., cloud storage providers, email service providers and payment processors) that need to know this information in order to process it on our behalf or to provide or improve our Service.

  • Service providers (acting as processors) based in Russian Federation, the USA who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in EU, the USA, Russian Federation who provide consultancy, banking, financial, investment, legal, and accounting services.
  • Banking and/or Payment organizations according to the Section 5.3.3. hereof.

5.6. In a merger

iPNOTE may share User Personal Information if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will seek to continue to ensure the confidentiality of User Personal Information, and we will notify you on our Website before any transfer of User Personal Information.

5.7. Advertising

Third-party tracking, re-targeting or analysis: iPNOTE may from time to time share, sell, rent, or trade User Personal and/or Non-Personal Information with third parties or permit third-party tracking, re-targeting or data analysis across our Website or Service for their or our promotional purposes (e.g., to serve you more relevant advertisements or promotional offers). These third parties may collect more information than iPNOTE collects.

5.8. Legal and Investigative Purposes:

iPNOTE will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to:

  • protect the property and rights of iPNOTE or a third party,
  • protect the safety of the public or any person, or
  • prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.

In complying with court orders and similar legal processes, iPNOTE strives for transparency. When permitted, we will make a reasonable effort to notify Users of such disclosure.

5.9. International transfer

Some of our employees, contractors, subsidiaries and affiliated organizations may be located outside of your home country; by using our Site and Service, you consent to the transfer of such information to them.

Please contact us via email [email protected]. if you want further information on the specific mechanism used by us when transferring your personal data abroad.

6. YOUR LEGAL RIGHTS

You have the right to:

6.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

6.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

6.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

6.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

6.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

6.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

6.8. The processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection by ensuring at least one of the following safeguards is implemented:

6.8.1. we may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

6.8.2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

6.8.3. If you reside in the ЕЕА, we may transfer your personal data when the transfer is necessary for the performance of Terms of use. Such transfer is not repetitive, concerns only a limited number of data subjects, is necessary for the purposes of compelling legitimate interests pursued by the controller which are not overridden by the interests or rights and freedoms of the data subject, and the IPNOTE Inc. has assessed all the circumstances surrounding the data transfer and has on the basis of that assessment provided suitable safeguards with regard to the protection of personal data (article 49 of the GDPR).

6.9. In case of deletion of personal data in accordance with the article 5.3. herein we will not be able to provide you with products and services.

6.10. To exercise any right listed in the clauses 6.1. – 6.7. you may contact us at [email protected].

6.11. 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 could refuse to comply with your request in these circumstances.

6.12. 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.

6.13. We try to respond to all legitimate requests within one month. Occasionally it could 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.

7. HOW LONG DO WE KEEP INFORMATION?

7.1. 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.

7.2. 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.

7.3. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at [email protected].

7.4. In some circumstances you can ask us to delete your data: see your legal rights above for further information.

8. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

8.1. User Personal Information includes confidential information of the User.

8.2. We undertake to ensure the safety and non-disclosure of this information and use it exclusively for the purposes you gave your explicit consent for. Thus, we are obliged to:

8.2.1. Provide storage and use of User Personal Information exclusively to perform and provide the services you request in the Service.

8.2.2. Keep User Personal Information in secret and not disclose it to any other parties, except as in cases provided by this Privacy Policy and applicable law.

8.2.3. Perform reasonable technical and legal measures to protect the confidentiality of User Personal Information.

8.2.4.. Protect User Personal Information from unauthorized access, alteration, theft, misuse and destruction.

8.2.5. Perform regular backups of User Personal Information on a schedule.

8.2.6. Maintain an adequate level of User Personal Information security control.

8.2.7. Constantly improve and test our systems for security vulnerabilities in order to prevent attempts of illegal access to the Service’s data.

8.2.8. Notify Users of any unauthorized access by third parties to their data.

8.3. iPNOTE is not obliged to provide separate technical support service for each User.

8.4. Users are obliged to immediately inform iPNOTE about potential misuse of User Personal Information.

8.5. Industry standards in data security

iPNOTE takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information. We follow generally accepted industry standards to protect the User Personal Information submitted to us, both during transmission and once we receive it. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

8.6. No responsibility for third party service providers’ security

In addition, while we take measures reasonably necessary to ensure that our third party service providers, such as our payment processing and data tracking, re-targeting or data analysis services, keep your information secure, these organizations’ practices are ultimately beyond our control. By using our Service, you acknowledge that you understand and agree to assume these risks.

8.7. OAuth, in general

iPNOTE makes use of the industry standard OAuth authentication protocol. OAuth is a simple, secure process that allows you to grant UpCounsel access to your accounts on third party networks without sharing the passwords to those accounts. Using OAuth, the data you choose to share is securely transferred without revealing your login information. OAuth also allows you to verify that an application acting on your behalf is doing so only with the permissions you have granted it. Most social networks, such as LinkedIn, Twitter, Facebook, and Google, allow applications to access user accounts via the OAuth process. OAuth functions using authentication tokens, which will expire after a period of time and may be revoked.

8.8. Documents, in general

iPNOTE uses third party service providers to transmit, store, encrypt, process and display uploaded documents on our behalf. iPNOTE has taken measures reasonably necessary to ensure that these services keep uploaded documents private and secure, but these organizations’ practices are ultimately beyond our control. By using the documents feature, you acknowledge that you understand and agree to assume the risks.

9. CALIFORNIA AND NEVADA RESIDENTS – YOUR PRIVACY RIGHTS

Please see the Supplemental Notice for California Residents in the Section 11 below in the for additional details on rights available to California residents, and how to exercise such rights.

NOTICE FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing [email protected]. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

10. SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

10.1. This Supplemental Privacy Notice for California Residents supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Site and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees or job applicants in their capacity as employees and job applicants. It also does not apply to information we collect about businesses that use our Site – including any employees, owners, directors, officers, or contractors of those businesses – in the course of our provision or receipt of business-related services.

10.2. California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers (as that term is defined in the California Consumer Privacy Act (“CCPA”)), the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

Examples of these types of uses are identified below. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

CategoryExamplesCollectedCategories of Third Parties With Which We May Share That Information
Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YESThird parties, such as Consultants, Clients (e.g. where an Agreement or Task is made), payment services, and government agencies, our subsidiaries and affiliates
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
YESThird parties, such as Consultants,Clients (e.g. where an Agreement or Task is made), payment services, and government agencies, our subsidiaries and affiliates
Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).NONONE
Commercial information.Records of IP rights, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YESThird parties, such as Consultants, Clients (e.g. where an Agreement or Task is made), payment services, and government agencies, our subsidiaries and affiliates
Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NONONE
Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YESThird parties, such as analytics providers, advertising networks, our subsidiaries and affiliates
Geolocation data.Physical location or movements.NONONE
Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NONONE
Professional or employment-related information.Current or past job history.YESThird parties, such as Consultants, Clients (e.g. where an Agreement or Task is made), payment services, and government agencies, our subsidiaries and affiliates
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.YESThird parties, such as our subsidiaries and affiliates
Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NONONE

 

Our Website obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete on the Site or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Website.

We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    (a) analytics providers (such as Google, Yandex etc.);
    (b) advertising networks (such as AdWords, Baidu etc.); and
    (c) search information providers (such as Google Search, Yandex Search, Yahoo etc).
  • Contact, Financial and Transaction Data from providers of technical and payment services (such as Stripe Connect, Paypal etc.).
  • Identity, Professional Information and Contact Data from publicly available sources such as Company’s Website, Social media.

10.4. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To register your Account;
  • To provide the Services you request including:
    (a) to allow User effectively store data about their intellectual property and mange it;
    (b) to allow Clients to select the best Consultant for Tasks and Agreements;
    (c) to facilitate communication between Clients and Consultant;
    (d) to provide contractual performance between Consultants and Clients;
    (e) to simplify invoicing and billing for Transaction;
  • To manage our relationship with you which will include:
    (a) Notifying you about changes to our terms or privacy policy;
    (b) Asking you to leave a review or feedback, as well as to take a survey;
    (c) Sending you information regarding our services, such as promotions or events;
    (d) Collect and recover money owed to us.
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
  • To make suggestions and recommendations to you about services that may be of interest to you;

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

10.5. Reselling Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months.

10.6. Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.
  • You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

10.7. Exercising Your Rights

If you would like to exercise any of these rights, please submit a request through the Data Request Form available in our Privacy Center or email us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

10.8. Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us again via [email protected] or call us +1 302 467-19-88.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

10.9. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

10.10. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

10.11. Accessibility

This Privacy Policy uses industry-standard technologies and was developed in connection with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

11. CONTACT INFORMATION

11.1. If you have any questions or comments about this notice, the ways in which iPNOTE collects and uses your information described in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 302 467-19-88
Website: https://ipnote.pro/
Email: [email protected]
Postal Address:
IPNOTE Inc.
251 Little Falls Drive, Wilmington,
New Castle County, Delaware 19808

11.2. If you would like to exercise any of these rights stated herein, please submit a request through the Data Request Form available in our Privacy Center or email us at [email protected].

11.3. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

11.4. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

11.5. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

11.6. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

11.7. You do not need to create an account with us to submit a request to know or delete.

11.8. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

11.9. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

12. MISCELLANEOUS

12.1. Our Service is not directed to children who are under the age of 18. We do not knowingly collect personal data from children under the age of 18. If you have reason to believe that a child under the age of 13 has provided personal data to us through the Services, please contact us at [email protected] and we will endeavor to delete that information from our databases.

12.2. If you know or suspect that your personal data have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your Personal Account, please immediately contact us by email at: [email protected].

12.3. We keep our privacy policy under regular review. This version was last updated on 12/06/2021. Historic versions are archived here.

12.4. iPNOTE may change its Privacy Policy from time to time, and at iPNOTE’s sole discretion. We will provide notification to Users of material changes to this Privacy Policy:

  • by sending a notice to the primary email address specified in your account, which will take effect immediately upon our sending of this email, and/or
  • through our Website by posting a notice on our home page, which will take effect no sooner than 30 days from the date of the posting. Non-material changes to this Privacy Statement will take effect immediately.

We encourage visitors to frequently check this page for any changes to our Privacy Policy. Your continued use of the Service after the effective date of a revised version of this Privacy Statement constitutes your acceptance of its terms.

12.5. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

12.6. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.