Innate®

Privacy Notice

Last updated April 18, 2022

Introduction

Innate Guidance Systems, LLC, and its affiliates (“IGS,” “we,” “us”), provider of INNATE®, an online assessment platform (the “Service”), provides products and services to help you become more aware of how you’re innately wired and how it impacts some of the life’s biggest decisions.

When you visit our website (innate.com) or use our mobile browser version of INNATE (app.innate.com) (innate.com and app.innate.com collectively referred to as the “Website”), you share your personal information with us in various ways. We also may collect personal information directly from you via email, in person or by phone. Sometimes we collect it directly from you, and other times, we use technology to automatically collect personal information or receive your personal information from third parties.

We believe in being transparent about our practices regarding collection, use and disclosure of your personal information and the choices you have regarding your personal information.  This Notice is intended to provide you with information on how you benefit from sharing personal information with IGS, who we share it with and when, and how we keep it safe – along with providing you information on the tools and options available to you to manage that information.

This Privacy Notice applies to our Website and Services (collectively the “Platform”) and any sites or products that display these terms. It does not apply to any website, mobile app, service, or product that does not display or link to this Privacy Notice or that contains its own privacy policy. If you do not agree with our policies and practices, including our Terms of Service, please do not use our Platform. By accessing or using our Platform, you agree to this Notice.

 

What personal information we collect

When you use our Platform, we collect certain personal information from you.  When you register for an account with us, you must provide contact information including your name and email address (your email address will be your username).  You will also share certain demographic information including education level with an option to share year of birth, gender, and similar demographic information.  We also require career interests so we can provide our Service. Your username (your email address) will be used on subsequent visits helps us confirm your identity and makes it easier for you to use our Platform.

Our Platform is for individuals who are over 16 years old

Our services are offered for individuals 16 or older.  We will never knowingly collect personal information from anyone younger than 16 years. If we become aware that personal information of anyone younger than 16 has been provided to us, for any purpose, we will delete the information from our files.

 

How we collect personal information

We may collect personal information from you directly or indirectly. When you click on an advertisement displayed by one of our partners and are either directed to the Website or complete our assessment quiz on a partner website, your personal information is provided directly to us. We also use technologies that collect data (including personal information) automatically as you use them. We may also collect personal information from third parties such as social media platforms.

We collect personal information when you provide it

When using our Platform, you may provide certain personal information directly when you interact with us online and offline, including through social media or when you register an account with us, or complete forms or assessments on the Website.  You may also provide personal information when you interact with us  by phone, email, in person – or even through postal mail.

We collect personal information from third-party sources

We may receive your personal information from online social networks if you take part in a forum, for example, or follow IGS on Facebook or Instagram. We may collect personal information when you click “Share This” or “Like” buttons or otherwise use social media buttons, plug-ins or refer to us using hashtags like #innate or #innateguidance. Note that any personal information collected by a third party, such as a social networking site, is handled based on their privacy practices rather than this Notice.

We collect personal information using automated technologies

We may also collect personal information through automated technologies when Website visitors and Platform users navigate through our Platform. We log your IP address and may track your browsing actions (for example pages visited, links you clicked on, etc.).

Automated collection technologies, including cookies, beacons, tags, and scripts – are used by us to analyze trends, administer the Platform, and track users’ movements around the Platform. We, and our third-party partners, also use these technologies to gather demographic information about our user base as individuals and in the aggregate.

A “cookie” is a small text file that is stored on an individual’s computer and downloaded to the computer or mobile device when he or she visits a website. Cookies then send information back to the originating website on each subsequent visit, or to another website that recognizes that same cookie. We use different types of cookies:

Essential and Required Cookies.  These are cookies that are required to make our Website function properly and cannot be turned off in our systems.  If you block these cookies, portions of our Website may not function properly.

Performance and Functional Cookies.  Performance and functional cookies allow us to count visits and sources of traffic on our Website so we can measure and improve their performance and functionality. They help us know which pages of our Website are most and least popular, which features are used most, and how visitors move around the Website.

Targeted Advertising Cookies.  Advertising cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

Social Media Cookies.  These cookies allow you to share information using social media sharing buttons (such as the Facebook “Like”) on social networks like Facebook, LinkedIn, Instagram, or Twitter.  This information may then be used by the social media network to deliver targeted advertising to you depending upon the social media’s own privacy practices.

We may use cookies to aggregate personal information collected automatically with data (including personal information) previously stored from other interactions with our Website and third-party sites. We examine metrics, such as which pages you visit or features you use, which links you click on and resources you view, the performance of our marketing efforts, and your response to those marketing efforts. This allows us to offer relevant and useful information to our users.

If you opt out of allowing certain cookies, you may do so by changing your browser settings so that cookies from our Website cannot be set. Please note that if you delete, block, or otherwise restrict cookies and use a different computer or Internet browser, you will need to renew your cookie management choices.

Do-not-track requests

Some browsers offer a “Do Not Track” privacy preference. Generally, when a user turns on the Do Not Track Signal, their browser sends a message to websites requesting that the user not be tracked. The Website currently does not respond to “Do Not Track” signals.

 

How we use personal information

We use personal information to give you insights into how you are innately wired so you can make more informed choices, and to improve our services. We know your personal information is important to you, so we want to provide you with information on how we use that information. Here are the ways IGS uses your personal information:

• To provide access to the Website, including maintaining the security and integrity of both.
• To analyze aggregated data across our users that provides us with the ability to improve our insights.
• To provide you with opportunities to connect with IGS third-party partners to support your decision making—such as receiving email communications from education institutions, training/coaching services, job boards, job alert services, resume services or prospective employers.
• To share questions, feedback, or other content our users provide.
• To provide marketing information regarding Platform updates, special promotions, and relevant information.
• To comply with legal and regulatory requirements applicable to our business and internal policies for maintaining records.
• To protect all parties (IGS, users, and other related third parties) in the event of disputes.
• To conduct reviews of our Website. Understanding our users allows us to improve product offerings and users’ experiences and more efficiently market promotions to make their experience more efficient.
• To comply with court orders and legal processes, and to enforce our Terms of Service and this Privacy Notice.
• For any other legal, business, or marketing purposes that comply with the practices described in this Notice.

 

When we share personal information

Once your personal information is collected, as detailed above, we sometimes share it with third parties for various reasons. Note that when we share your personal information with a third party, we require that third party to protect the information consistent with this Notice and limit its use of that information in compliance with applicable law.

IGS sells certain personal information to education institutions, training/coaching services, job boards, job alert services, resume services or prospective employers.  This is limited to contact information, including, name, email address, and zip code, and demographic information including level of education, and year of birth and gender assuming you provide us with that information.   We will also share, as you indicate, your job interests.  This helps our third-party business partners find students and potential employees that are best suited to the structure, environment and goals of the employer. In addition, since Innate.com provides email job alert services, we will share your personal information with third parties to provide you with such services. Please see our Business Partner Page for information on the businesses we share your personal information with. Please see “Your Options” below on how to opt-out of the sale or sharing of your personal information.

If you purchase products or services on our Platform, you may provide your credit card number, expiration date and billing address, but this data is sent directly to our payment processors and is never stored or otherwise retained by IGS—we only store confirmation of your purchase.

We use interest-based advertising

We use some third-party service providers to help us operate our Platform or promote our services, including to serve ads on our behalf through the Internet. These third parties may use cookies to collect information about your Platform visits, as described in the automated technologies section of this Notice. They also may use information about your visits to our Platform to serve advertisements on other sites that you visit.

Our vendors help with Platform analytics, too

IGS uses Squarespace tools and Google Analytics to study how users interact with our Platform.

If you make a public post, others may see it

If you make a post on a third-party social media site, such as on Facebook, or by identifying us in your social media feed by tagging us using a hashtag (#) or “at” (@), your personal information may be publicly available and is subject to the privacy policies of those third-party social media sites. As a reminder, this Notice describes how we will treat your personal information once it is in our possession.

We recommend you review the privacy policies of any third-party site you visit to understand the data collection and practices of that third party.

We may share feedback you provide to us

We want to hear how we’re doing. If you have suggestions for improving our products and services, we want those as well. We would be delighted to receive video testimonials from our users, that we can share, so that others can learn about your road to achieving your dreams. Please be aware that any feedback relating to our services on our Website, App, or on social media channels may be publicly shared and used by us.

Eventual successors may access information

In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, any user information owned or controlled by us may be among the assets transferred to third parties as successors in interest. As part of this type of transaction, we reserve the right to transfer or assign your personal information to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Notice.

We need to comply with legal requirements

We may disclose your information to government authorities or other third parties if any lawful circumstances arise, including when:

• You have given us permission to share your information;
• We are required to do so by law, or in response to a subpoena or court order;
• We believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, or to protect our property or other rights or those of other users of the Website, App, third parties, or the public at large; or
• We believe that you have misused the Website or App by using it to attack or gain unauthorized access to a system or to engage in spamming or other conduct that violates applicable laws or our Terms of Use.

 

How we secure personal information

We have implemented industry accepted administrative, physical, and technology-based security measures to protect against loss, misuse, and alteration of personal information in our systems. We ensure that any employee, contractor, or vendor who has access to personal information in our systems is subject to appropriate legal obligations to safeguard that personal information.

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or form of electronic storage is 100 percent secure. Therefore, we cannot guarantee its absolute security.

Questions or Concerns about Security or Privacy as detailed in this Notice

If you have received unwanted, unsolicited e-mail from us or purporting to be sent by us, please forward a copy of that e-mail with your comments to privacy@innate.com for our review. If you feel that any of our privacy practices or security standards detailed in this Privacy Notice have been violated, you may contact us (see Contact Us section below).

 

Your Choices

We understand that you want to protect and control your personal information.  This section details the choices you have in managing your personal information.

Deleting your account

You may delete your account, personal information and any assessments associated with your account any time after you create it. To delete your personal information and/or assessments, please go here and provide your email address.  We will then email you a link to access your account’s history page where you can delete any assessments and the personal information associated with each.  If you delete all assessments, your account will be deleted too.  Information will be deleted from IGS systems within a reasonable period of time following your deletion request.

Opting out of Promotional Emails

If you do not wish to receive promotional e-mails from us, you may follow the unsubscribe process in the promotional e-mail you received. Please keep in mind that you may still receive transactional and service-related e-mails from us that may be necessary for us to make the Platform available to you or respond to your inquiries.  These e-mails may be related to completion of your registration, updates to your data, password reset requests, reminder e-mails you have requested, and other similar communications essential to your transactions on the Platform.

Opting out of Interest-Based Advertising

To manage third-party advertising preferences for some of the third parties we work with that serve interest-based advertising across the Internet, use the choices available from the Network Advertising Initiative and the Digital Advertising Alliance. We do not guarantee that the third parties we work with will honor the elections you make using these options, but we strive to work with third parties that do.

Identity Verification Requirement

We are required by law to verify that any request submitted was made by someone with the legal right to access the information. Therefore, before accessing or divulging any information pursuant to a data subject access request, you will be required to validate your identity through email.

European Economic Area, Switzerland or United Kingdom Citizen Rights

Individuals residing in the European Economic Area (EEA), including Switzerland and the United Kingdom (UK) have additional rights reserved under local laws (the General Data Protection Regulation, the UK Data Protection Act, the Swiss Federal Act on Data Protection and/or ePrivacy Directive, as applicable).  IGS currently does not market to or intend for our Platform to be accessed outside the United States. In the event we make our Platform available to individuals in those geographic areas, we will update these terms to ensure we reflect any additional rights granted under those laws. Those updates will be made available within this Privacy Notice, in accordance with those regulations.

California Consumer Rights

The California Consumer Privacy Act provides specific rights to those who live in the state of California. If you are a California-based consumer, as that term is defined under California law, this section shall apply in addition to all other applicable rights and information contained in this Notice:

• You have the right to request, no more than once during any 12-month period, that we provide you with information on the third parties we have shared your personal information with for their own direct marketing purposes.
• You have the right to request that we delete personal information we, or our service providers, store about you.
• You have the right to request, no more than twice during any 12-month period, that we provide you with the following information for the 12-month period prior to your request:
• • • The categories of personal information and the specific pieces of personal information we have collected and store about you.
    • The categories of sources from which we collected your personal information.
    • The purpose(s) for which we collected or sold your personal information.
    • The categories of your personal information we sold and the categories of third parties to whom we sold your personal information.
    • The categories of personal information we disclosed for any business purpose.
• We will not discriminate or retaliate against you if you elect to exercise any rights under this section of our Privacy Notice.
• You have the right to designate an authorized agent to make a request on your behalf.
• Please see the “Identity Verification Requirement” section above for more information on our process for verifying we have received a legally valid request.

You may request that we not sell your personal information.  To make a request, please go here and provide your email address.  We will then email you a link to access your account, click on the ‘Setting’ button and then you can opt-out of company selling your information.

If you are a California consumer and have additional questions based on this section of our Privacy Notice, email us at privacy@innate.com with “Exercise my Rights Under CCPA” in the subject line.

Be sure to check this Notice for updates, as we will review it at least every 12 months and make necessary changes.

 

Updates

This Privacy Notice will be updated to reflect our personal information handling practices and notices as may be required by law.  We reserve the right to amend this Notice at any time, for any reason, without additional notice to you, other than through posting the updated Privacy Notice on the Platform. We invite you to periodically return to this page to ensure you are informed of any updates we make about how we collect, use, and protect customer information. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the beginning of this Notice.

 

Contact Us

If you have questions about the way we handle personal information, please contact us:

Innate Guidance Systems, LLC

6663 SW Beaverton-
Hillsdale Hwy, Suite 230
Portland, OR 97225