Privacy Policy Last updated: April 13th, 2022
This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.
Welcome
We provide incident management infrastructure for the internet. Businesses of all sizes use our software and services to manage their businesses resilience online. Initsys cares about the security and privacy of the personal data that is entrusted to us.
This Policy refers to Initsys Merlin (all derivatives), Initsys Responder Application, Initsys Protect Duty Application, Initsys Crisis Application and Protector Application.
General Notice :: We use personal data to provide protection and response services to Incidents and for only that purpose. We do not hold nor acquire any financial information, (such as credit/debit cards) to process your data and if asked for such information from a site purporting be an Initsys affiliate or subsidiary you should immediately inform Initsys at fraud@initsys.net.
The information we acquire and use is restricted to your name, contact details and incident type as well as responder informatics collected by the Initsys system such as location, time etc. This information is only collected while you are using the applications and specific authority should have been given.
We use some cookies and analytics data but this is anonymised and you should refer to the privacy policy shown on each of our sites for more information.
This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us.
“Initsys”, “we”, “our” or “us” means the Initsys entity responsible for the collection and use of personal data under this Privacy Policy. It differs depending on your country.
“Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP address).
“Services” means the products and services that Initsys indicates are covered by this Policy, which may include Initsys provided devices and apps. Our “Business Services” are Services provided by Initsys to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities.
Our “End User Services” are those Services which Initsys directs to individuals (rather than entities) so that those individuals do business directly with Initsys.
“Sites” means Initsys.net and the other websites that Initsys indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.
Depending on the context, “you” means End Customer, End User, Representative or Visitor:
When you directly use an End User Service (such as when you sign up, or make a payment to Initsys in your personal capacity), for your personal use, we refer to you as an “End User.”When you do business with, or otherwise transact with, a Business User (typically a company or entity using our systems and services) but are not directly doing business with Initsys, we refer to you as an “End Customer.”When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for someone who is a Business User), we refer to you as a “Representative".
”When you visit a Site without being logged into a Initsys account or otherwise communicate with Initsys, we refer to you as a “Visitor.” (e.g. you send Initsys a message asking for more information because you are considering being a user of our products).
Depending on the activity, Initsys acts as a “data controller” or “data processor” and for more information about this and on the Initsys entity that is responsible under this Policy.
Personal data that we collect and how we use and share it.
End Users
We provide End User Services where we do not act as a service provider to Businesses but instead provide the Services directly to you for your personal use (e.g. Protector user). See here for further information on the legal bases which we rely on for using (processing) your Personal Data.
Personal data that we collect about End Users
Using our Services.
Initsys offers you the opportunity to store some personal data with Initsys so that you can conveniently use it across services. When you opt in to Link, you agree to let us store your details so that you can more readily link with Business Users of our Resilience services (e.g. name, nickname, telephone numbers etc). When you use our services, we will also collect your Incident Transaction Data.
If you choose to share information with us, Initsys will periodically collect and process your location information (e.g. account owner information, incidents (either instigated by you or responded to by you) until you ask us to disconnect. We will hold this data for no more than 90 days, unless a business partner, or first responder (such as Police) has asked us to retain it.
Other Services.
We may offer other End User Services directly to you from time to time.
How we use and share personal data of End Users
Services.
We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to use. The use of this Personal Data is subject to the Business Users’ privacy policies.
Our Business Users.
When you choose to connect with Initsys, you may also choose to share account information with certain Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.
Transactions.
End User Personal Data is shared with others to enable the service. For example, when you choose to use any application for the transaction of incidents with Initsys or link with an SOC (Security Operations Centre), that method will receive transaction information that includes your Personal Data.
Please review your SOC privacy policy to learn more. When you use our applications, the SOC you choose to do business with will also receive Transaction Data that includes your Personal Data and with your permission, your location and status.
The SOC may share that Personal Data with others, such as responders and Police (see below regarding End Customers). Please review your SOC's privacy policy for further information.
Fraud Detection Services.
We use your Personal Data collected across our Services (e.g. Initsys Threat Manager) to detect and prevent fraud against us, our Business Users and partners, including to detect unauthorized log-ins using your online activity.
We may provide Business Users (including SOC and others involved in incident processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted incident transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction by contacting
admin@initsys.net
End Customers
Initsys offers Business Services to our Business Users. When we are acting as a Business User’s service provider (or data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. For example, we process incident transactions for a Business User because you are employed by them or subcontract to them. Business Users are responsible for making sure that their End Customer’s privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their services. If you are an End Customer (e.g., a purchaser of a product at an online Business User site), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly. For further information on the legal bases which we rely on for using (processing) your Personal Data please contact admin@initsys.net
Personal data that we collect about End Customers
Transaction Data.
If you are an End Customer, when you make incidents, respond to incidents from or otherwise transact with a Business User that uses us to provide Resilience Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, email address, location, sex, access card image (selected by you), and your phone number. We may also receive your transaction history with the Business User.
We may collect information typed into a form, even if you choose not to complete the form or subscribe with the Business User.
Identity/Verification Information.
Initsys provides a verification and fraud Service that allows a Business User to verify Personal Data about you, such as your status or your authorization. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input. We may compare this information with information about you we collect from Business Users, business partners, identity verification services, publicly available sources, and third party service providers.
How we use and share personal data of End Customers.
We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Initsys’s own purposes to secure, improve and provide our Business Services, as described below.
Identity/Verification Services.
We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Initsys or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified.
Fraud Detection Services.
We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners (e.g. Initsys Radar), including to detect unauthorized log-ins using your online activity. We may provide Business Users that have requested our fraud Business Services with Personal Data about you (including your incident transactions) so that they can assess the associated fraud risk with a potential user. You can learn more about how we may use technology to assess the fraud risk associated with an attempted incident and what information we may share with Business Users about such risks by emailing admin@initsys.net
Our Business Users (their Authorized Third Parties).
We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third party application provider to access its Initsys account using Initsys NEON. For example, when the Business User uses Identity Services to verify an End Customer’s identity, Initsys shares with the Business User the information, documents or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data to third parties they authorize. Please review your SOC privacy policy to learn more.
We do not sell the data of any Customers.
Please see below for information about additional ways in which we may use your Personal Data.
Representative Personal Data.
Please see below for information about additional ways in which we may use and share your Personal Data.
Visitors (e.g. visitors to Initsys sites who are not an End User, End Customer or Representative)
Visitor personal data that we collect
When you visit our Sites, we generally receive your Personal Data either from you providing it to us or through our use of cookies and similar technologies. See our Cookie Policy.
Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form, usually your contact information and other information about your question related to our Services.
Please see below for information about additional types of Personal Data that we may collect, including about online activity.
How we use and share visitor personal data
Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience and to tailor content about Initsys and our Services to you.
Personal Data Collection
Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),Usage data associated with those devices and browsers, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, and the pages that led or referred you to Sites and Third-Party Sites.
For example, activity indicators, like mouse activity indicators, help us detect fraud.
Please also see our Cookie Policy.
We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Initsys emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Initsys, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Initsys events and other interaction with Initsys personnel.Forums and Discussion Groups. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.
Personal Data Usage. In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways:
Improving and Developing our Services. We use analytics on our Sites to help us analyse your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our Cookie Policy. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you.
Communications.
We will use the contact information we have about you to perform the Services, which may include sending codes via SMS/email to authenticate you. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements.
For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.
Social Media and Promotions.
If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. Based on your permission or opt-out, we will also use that Personal Data and Personal Data you make available on social media to market to you.
Fraud Prevention and Security.
We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, and information. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Initsys and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised.
This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.
Compliance with Legal Obligations.
We use Personal Data to meet our contractual and legal obligations related to Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas, and other legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of incident transactions and other online signals and use those insights to reduce the risk of fraud, and other activity that is harmful to Initsys, our End Users and their End Customers.
Minors.
The Services are not directed to minors, including children under the age of 13, and we request that they do not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of End Customers, Representatives, Visitors or End Users, including those aged between 13 to 16.
Personal Data Sharing.
In addition to the ways described above, we share Personal Data in the following ways:
Initsys Affiliates.
We share Personal Data with other Initsys affiliated entities. When we share with these entities, it is for purposes identified in this Policy.
Service Providers or Processors.
In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers (provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data of our Users that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the UK, European Union, the United States of America and India.
Financial Partners.
“Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data of our Users with certain Financial Partners to provide the Services to the associated Business Users.
Others with Consent.
In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with to deliver some services). In these cases, we will disclose the identity of the third party and the information that will be shared with them, and seek your consent to share the information.
Corporate Transactions.
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.
Compliance and Harm Prevention.
We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by first responders (Police, etc); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Initsys, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Legal bases for processing data
For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. For more information contact
admin@initsys.net
Contractual and Pre-Contractual Business Relationships.
We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include:
Creation and management of Initsys accounts and Initsys account credentials, including the evaluation of applications to commence or expand the use of our Services;Creation and management of Initsys accounts; Accounting, auditing, and billing activities; and Processing of payments, including fraud detection and prevention, optimizing valid transactions, communications regarding such payments, and related customer service.
Legal Compliance.
We process Personal Data to verify the identity of our Users in order to comply laws associated with the identification and reporting of illegal and illicit activity, such as Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity. These obligations are imposed on us by the operation of law, industry standards, and by first responders (Police, etc) and may require us to report our compliance to third parties, and to submit to third party verification audits.
Legitimate Business Interests.
Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:
Detect, monitor and process incident transactions;
Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Initsys;
Determine eligibility for and offer new Initsys products and services;
Respond to enquiries, send Service notices and provide customer support;
Promote, analyse, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
Analyse and advertise our Services;
Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business Learn More;
Enable network and information security throughout Initsys and our Services; and Share Personal Data among our affiliates.
Consent.
We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services like Protector, Responder and Crisis Applications. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.
Your rights and choices.
You may have choices regarding our collection, use and disclosure of your Personal Data:
Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described here. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.
Your data protection rights
Depending on your location and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you:
The right to request confirmation of whether Initsys processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
The right to request that Initsys rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
The right to request that Initsys erase your Personal Data in certain circumstances provided by law.The right to request that Initsys restrict the use of your Personal Data in certain circumstances, such as while Initsys considers another request that you have submitted (including a request that Initsys make an update to your Personal Data);The right to request that we export your Personal Data that we hold to another company, where technically feasible;Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/orWhere we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Process for exercising your data protection rights
To exercise your data protection rights please also see the Initsys Privacy Center or contact us as described below.
Security and retention
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately at admin@initsys.net
We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Initsys account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
International data transfers
We are a global business. Personal Data may be stored and processed in any country where we do business, where our service providers do business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities). End User data will always reside in the region in which it is applicable, unless there is no acceptable hosting service there.
If you are located in the European Economic Area (“EEA”), the "United Kingdom ("UK")" or Switzerland, please contact Initsys for more information.
Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law. For transfers to third countries we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA. You can obtain a copy of the relevant Standard Contractual Clauses.
Updates and notifications
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Initsys Dashboard, email address and/or the physical address listed in your Initsys account.
If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.
Jurisdiction-specific provisions
Australia. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner.
EEA and UK. To exercise your rights, you may contact our DPO. If you are a resident of the EEA or we have identified Initsys Limited as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission.
If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office.
Indonesia. As used in this Policy, “applicable law” includes Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions, and Minister of Communication and Informatics Regulation No. 20 of 2016 on Personal Data Protection in Electronic Systems and “Personal Data” includes “personal data” as defined under such laws.
Malaysia. If you have any questions or complaints about this Policy, please contact our DPO.
Thailand. Thailand residents may have additional rights under applicable laws. If we process your Personal Data due to a legal obligation or contractual right, and you do not provide us with personal Information, we may not be able to lawfully provide you services.
United States - California. If you are a consumer located in California, we process your personal information in accordance with the California Consumer Privacy Act ("CCPA"). You have a right to receive notice of our practices at or before collection of personal information. This section provides additional details about the personal information we collect and use for purposes of CCPA.
How We Collect, Use, and Disclose your Personal Information.
The Personal Data We Collect section further describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the How We Use Personal Data section. We share this information as described in the How We Disclose Personal Data section.
Initsys uses cookies, including advertising cookies, as described in our Cookie Policy.
Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information (learn more):Exercising the right to know: you may request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about categories of their personal information collected, sold, or disclosed; purposes for which this personal information was collected or sold; categories of sources of personal information; and categories of third parties with whom we disclosed this personal information.Exercising the right to delete: you may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
Exercising the right to opt-out from a sale: We do not sell Personal Data as defined by the CCPA and have not done so in the past 12 months.
Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights.To submit a request to exercise any of the rights described above, please contact us using the methods described in the Contact Us section below. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.An authorized agent may submit a request on your behalf by contacting us using the methods described in the Contact Us section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.
Contact us
If you have any questions or complaints about this Policy, please contact us at admin@initsys.net
If you are an End Customer (i.e. an individual doing business or transacting with a Business User), please refer to the privacy policy or notice of the Business User for information regarding the Business User’s privacy practices, choices and controls, or contact the Business User directly.