Privacy Statement

Communications

We are going to send you communications for different purposes.

By default, we send e-mails and push notifications through the mobile app because we really want to keep our users active, satisfied, and updated about new features and content in our products.

We will send you e-mails and push notifications through the mobile app for administrative purposes, for instance: we will send you a notification when an admin user uploads new content for your group; we will send you an e-mail to activate your account; etc. These communications are necessary for us to properly provide you with our services.

If you subscribe to our newsletter through our website or flag the consent to receive communications in the subscription panel of our web apps, we’ll send you communications regarding our products, events we’re going to participate to, and other informative and promotional content. 

If you don’t want to receive communications anymore, you can let us know at any time by clicking on the link present in every e-mail.

Feedbacks

In our web and mobile applications, we provide the possibility to the user to send feedbacks (either to comment a feature or report a bug). We keep your feedbacks in the highest consideration to resolve the possible issues you reported and to implement our services. For this reason, we could get in touch with you via e-mail or, if you specifically ask, via telephone. We will store your feedback only for the time necessary to process it and, anyway, no more than six months.

Other processing activities 

In addition to everything stated in this document, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3. Service providers and guarantees 

All our third-party service providers are committed to take appropriate security measures to protect your personal data in line with our policies. We only allow them to process your personal data for specified purposes and in accordance with our instructions. In case a third-party service provider requires to process personal data on our behalf outside the European Union, we will adopt in advance adequate guarantees to ensure the same level of protection to that data (the preferrable mean will be signing with the third-party service provider appropriate standard contractual clauses as issued by the European Commission on 04^th June 2021).

4. Your rights

You, as data subject, can at any time exercise the following rights:

• - Right to withdraw the consent: To the extent that the legal basis for the processing of your data is your consent, you have the right to withdraw that consent at any time;
  • - Right to access: You have the right to confirmation as to whether we process or not your personal data and, where we do, receive a copy of that data, together with additional information regarding the processing activities;
• - Right to rectification: You have the right to have any inaccurate data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed;
• - Right to erasure: You have the right to request the erasure of your data without undue delay;
• - Right to restriction of processing: You have the right to request the restriction of processing;
• - Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and the right to transmit those data to another controller;
• - Right to object: You have the right to object the prevalence of interests legitimating the processing over your interests, rights and freedoms.

Out of some circumstances in which you can autonomously honor your rights (for instance, unsubscribe to our newsletter; correct you data on your user profile, etc.), to exercise your right you can write at any time to privacy.security@incision.care; we will take care of your request.

Please note that:

• - We can honor your request if we are processing your data in the capacity of controller, otherwise we will forward your request to the controller;
• - We may ask you to verify your identity and/or to provide more information regarding your request;
• - We will answer you without undue delay and in any event within one month (we may require more time taking into consideration the complexity or the amount of the requests); 
• - Sometimes your rights are restricted, and, in some legitimate circumstances, we may decline your request (in these cases, we will always explain you why we did so).

If you consider that the processing of your data infringes data protection laws, you have the right to lodge a complaint to:

- The National Supervisory Authority, if you're based in the European Union;

- The Information Commissioner's Office (ICO), if you're based in the United Kingdom;

- The Swiss Federal Data Protection and Information Commissioner (FDPIC), if you're based in Switzerland.

Minors under age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16.

5. For individuals based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).

Collection, use and disclosure of personal information

In the last 12 months, we may have collected the following categories of personal information:

• - Identifiers, such as your name, email address, telephone number or other similar identifiers;
• - California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department;
• - Internet or network information, such as log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data;
• - Geolocation data, such as information about your location (at country and city level) collected from your IP address;
• - Feedbacks.

If you want to understand how we collect, use and disclose your data, please refer to the articles above.

California privacy rights

In addition to what is stated above, as a California resident you may be able to exercise the following rights under the CCPA in relation to the personal information about you that we have collected (subject to certain limitations at law):

• - The right to access/know all the information relating to the processing of your data that we have collected and disclosed in the last 12 months:
• - The right to request deletion of personal information we have collected from you, subject to certain exceptions.
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We do not sell your data.

You also have the right to be free of discrimination for exercising these rights.

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

6. For individuals based in Australia

This section is applicable to individuals whose personal information is collected, stored, used or disclosed under the Australian Privacy Principles (“APPs”) contained in the Privacy Act of 1988.

Providing anonymous and pseudonymous options

You have the option of anonymity or using a pseudonym when dealing with Incision. However, this option may not be made available to you in certain cases, including if it’s impractical for us to allow this option or when we are required or authorized to deal with an identified individual by or under the law.

Collection, use and disclosure of personal information

We collect personal information only by lawful and fair means.

If you want to understand how we collect, use and disclose your data, please refer to the articles above.

Your rights under the APPs

In addition to what is stated above, you have the following rights related to the collection, use and disclosure of your personal data:

• - Be informed about the collection and use of your personal data;
• - Access your personal information;
• - Correction of your personal information to ensure accuracy and completeness;
• - Request to not receive direct marketing communications from us or to not disclose your personal information to others for direct marketing purposes.

If you consider that the processing of your data infringes data protection laws, you have the right to lodge a complaint to the Office of the Australian Information Commissioner (OAIC).

7. Information Security

We are committed to protecting the security of your data by implementing appropriate technologies and procedures, to avoid unauthorised access or disclosure. We utilise a variety of security technologies and organizational procedures to help protect your data, such as access controls, firewalls and secure servers, encryption, secure connections, etc.