EU-U.S. Privacy Shield Notice

Effective June 9, 2017

Ineo, LLC (“Ineo”, “we”, “us”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred to the U.S. from European Union Member States and Switzerland, respectively. Ineo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Information Management Practices

Ineo collects personal data from a variety of sources, including through our website. This personal data may include names, postal addresses, email addresses, financial information, and other details relevant to the services we provide. We may obtain personal data directly from customers, or indirectly from business partners or other third parties. In addition, certain information that incorporates personal data may be developed as a function of providing a product or service to a customer.

We limit the collection and use of personal data about our customers to that which is necessary to administer our business and provide superior service. We may disclose personal data to our service providers, business partners, and others who assist us in providing our services. Ineo may be liable with respect to the onward transfer to third parties of EU and Swiss data subjects’ personal data received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

Please note that in certain situations Ineo may be required to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Security

We are committed to the security of our customers’ personal data and financial information. Our operational and data processing systems are maintained in a secure environment, with appropriate administrative, technical, and physical safeguards to protect the personal data we maintain from unauthorized access.

Your Access and Limitation Rights

EU and Swiss data subjects have the right to access personal data maintained about them and to impose certain limits on the use and disclosure of such personal data. Ineo has committed to uphold these Privacy Shield Principles, but our ability to access certain personal data of individuals directly may be restricted depending on our services. We do not share personal data with unaffiliated third parties. If we were to share personal data in this manner, we would provide EU and Swiss data subjects with appropriate means to opt out of such sharing as required by law, and will request opt-in consent prior to using EU or Swiss personal data for a purpose other than the purpose for which it was originally collected.

If you wish to access your personal data or make a request regarding the use or disclosure of your personal data, please contact us using the contact information below.

Questions, Complaints, Recourse, and Contact Information

EU-U.S. or Swiss-U.S. Privacy Shield Complaints

In compliance with the Privacy Shield Principles, Ineo is committed to resolving your privacy complaints regarding our collection or use of your personal data. European Union or Swiss data subjects with inquiries or complaints regarding this Privacy Notice should first contact Ineo at: Privacy@ineomobility.com, by phone at +1 203-529-3020, or by postal mail sent to:

Ineo
Attn: PRIVACY SHIELD INQUIRY
372 Danbury Road
P.O. Box 428
Wilton, CT 06897
USA

Ineo has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint filed with Ineo as described above, or if your complaint is not satisfactorily addressed by Ineo, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Ineo is subject to the investigatory and enforcement authority of the Federal Trade Commission.