Last update: October 25th, 2024

Privacy Policy

We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web page with a hyperlink thereto. We will also send you an email describing such changes. Please regularly review this Privacy Policy. Notwithstanding, if you continue to use our services, you are bound by any changes that we make to this Privacy Policy.

1. Introduction

Intentwise Inc. (“Intentwise,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Intentwise Platform (the “Platform”) through Intentwise’s website at https://www.intentwise.com (the “website”).

Intentwise is committed to protecting the privacy of its Users whose information is collected and stored while using Intentwise’s Platform through our website or App. This Privacy Policy is applicable to our website, Platform, and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms and Conditions as applicable, unless otherwise noted here.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our website and Platform, you agree to accept all the terms contained in this Privacy Policy and acknowledge and agree with the practices described herein. If you do not agree with the terms of this Privacy Policy, please do not access and use our website and Platform.

If you have any questions regarding this Privacy Policy, please send us an email at privacy@intentwise.com.

We do not sell your personal information, nor do we intend to do so. We do not give access to your personal information to third parties except to subprocessors to assist us in the provision of our services to you.

2. What Information Do We Collect?

When you register to use our website or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username, and other personal information. The information so collected will be stored on our servers. You can change your personal information by contacting us at privacy@intentwise.com or through your profile or account settings on our website or Platform.

• Geolocation and Equipment Information: We may collect non-identifiable information such as (i) your geolocation and (ii) details about your internet connection, equipment, and usage of our website or Platform.
• Financial Information: Currently, we do not collect or store any credit card or bank information, as we use a third-party payment processor. We will update this Privacy Policy and notify you if we begin collecting such information.

3. How Do We Collect Information?

We collect personal information from you in the following ways:

• At registration on our website or Platform.
• In email and other electronic messages between you and our website or Platform.
• When you subscribe to a newsletter.
• From your responses to a survey.
• From forms filled out by you.
• From records or copies of correspondence (including email addresses) if you contact us.
• From search queries on our website or Platform.
• When you post information to be published or displayed on our website or Platform.

We also collect information automatically as you navigate through our website or Platform, including:

• Usage details.
• IP addresses.
• Information obtained through browser cookies.

4. How Do We Use Your Information?

We use the information that you provide to:

• Personalize your experience in using our Platform.
• Provide you with information, products, or services requested from us.
• Present our website and Platform and their contents to you.
• Provide you with notices about account and/or subscription, including expiration and renewal notices.
• Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection.
• Notify you about changes to our website and Platform and any products or services.
• Improve the website and Platform.
• Improve our customer service.
• Process transactions.
• Contact you for other purposes with your consent.
• Contact you about our products and services that may be of interest.
• Contact you about third parties’ goods and services.
• Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 13, via the email address provided by you to:
  • Send information, respond to inquiries, and/or other requests or questions;
  • Process orders and send information and updates pertaining to such orders;
  • Send additional information related to your product and/or service;
  • Market to our mailing list or continue to send email to you after the original transaction has occurred.

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to our legal obligations and legitimate business interests. Once the data is no longer needed, we will securely delete or anonymize it. If you wish to request the deletion of your data, please contact us at privacy@intentwise.com.

5. Our Cookie Policy

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”

We use Cookies on our website to:

• Help remember and process items in the shopping cart.
• Understand and save your preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
• Allow trusted third-party services that track this information on our behalf.

You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.

We allow third-party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our website or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our website and Platform and welcome any feedback about these sites. Please contact us at privacy@intentwise.com.

6. How Do We Protect the Information We Collect?

Our website is reasonably scanned to meet or exceed PCI Compliance. Our website receives regular security scans and penetration tests, along with regular malware scans. Additionally, our website uses an SSL certificate as an added security measure.

We require usernames and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. We actively prevent third parties from accessing your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third-party credit card processor on our behalf. Reasonable security measures are implemented every time you:

• Place an order.
• Enter, submit, or access your information.
• Register or access our Platform on our website.

Our Platform may contain links to third-party websites, products, or services that are not owned or controlled by Intentwise Inc. We are not responsible for the privacy practices or the content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

7. Data Security Measures

We implement a variety of security measures to protect your personal information from unauthorized access, use, or disclosure. These measures include encryption, firewalls, and secure server facilities. However, please be aware that no method of transmission over the Internet or electronic storage is completely secure. We strive to use commercially acceptable means to protect your personal information but cannot guarantee its absolute security.

a. Security Measures

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website or Platform.

b. Fair Information Practice Principles

In the event of a personal data breach, we will notify you within three (3) days via (i) email and/or (ii) our Platform notification system on our website. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

c. Open-Source Software

We use the following open-source software in the provision of our Services, which can be found here:

• Adopt OpenJDK 8, 11
• Spring Boot, Spring Web
• Hibernate
• Postgres
• Python 3

8. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us with others to enable us to provide you with our Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Intentwise may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describes how and with whom we may share your Personal Information:

Disclosure of Personal Information

1. We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
2. We may disclose personal information to our subsidiaries and affiliates.
3. We may disclose personal information to contractors, service providers, and other third parties.
4. We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
5. We may disclose personal information in the event of a merger, sale of business, etc.
6. We may disclose personal information to third parties to market their products and services if you have either consented or not opted out of these disclosures.
7. We require all other Partners to whom we disclose your personal information to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
8. We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
9. We may disclose personal information for any other purpose for which you have provided it.
10. We may only disclose personal information as described in this Privacy Policy or with your consent.

Other Disclosure of Personal Information

1. We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Intentwise, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Intentwise, our customers, or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third Party Disclosure

1. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our website or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
2. We do not provide non-personally identifiable visitor information for marketing purposes.

Choices Users Have About How Intentwise Uses and Discloses Information

1. Tracking Technologies and Advertising: You can set your browser to refuse some or all browser cookies, but if you disable or refuse cookies, some parts of our website may not be accessible or function properly.
2. Disclosure of Users’ Information for Third-Party Advertising: Users can opt-out by (i) checking the relevant form when we collect the data; (ii) logging into the website or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at privacy [at] intentwise [dot] com. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Intentwise for product purchases, warranty registration, or other transactions.
3. Disclosure of User’s Information for Targeted Advertising: Users can opt-out by (i) checking the relevant form when we collect the data, (ii) logging into the website or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at privacy [at] intentwise [dot] com.

9. Google AdSense and Google Analytics

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our website and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt-out, please visit Google Partners.

We have implemented advertising features on our website and Platform including:

• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Google Demographics and Interests Reporting
• Google’s DoubleClick platform integration

We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our website or App.

10. For Our European Customers and Visitors

We may transfer your personal information to countries outside of your jurisdiction for processing and storage. By using our Platform, you consent to such transfer of information. We ensure that adequate protection is provided for personal information that is transferred internationally, in accordance with applicable privacy and data protection laws.

We are headquartered in the USA. Most of the operations are located in the USA. Your Personal Information, which you give to us during registration or use of our website or Platform, may be accessed by or transferred to us in the United States. If you are visiting our website or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

• If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).
• In some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.
• We will still respond to let you know of our decision.

As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

a. EU Standard Contractual Clauses

On June 4, 2021, the EU promulgated a new set of SCCs (the “New SCCs”), which replaced the old SCCs which had been in place for over a decade. We now comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US and other countries for Processing, as defined in the GDPR. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and conditions in the new SCCs will govern.

b. The New SCCs

• The New SCCs took effect on June 27, 2021.
• The Old SCCs may still be used for new data transfers in new contracts during a three-month transition period that ended on September 27, 2021.
• Existing data transfers contracts that rely on the Old SCCs can be used until December 27, 2022, by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs.
• As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries including the US for processing by us.

c. Our GDPR Compliance Commitment

• We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect to the transfer of your Personal Data for Processing outside the EU.
• A User may contact us regarding their Personal Data stored and processed in the US, Canada, and Turkey for Services provision.
• Upon request, we will provide you with a list of your Personal Data that we will process and a copy of the New SCCs under which we transport your Personal Data for processing.
• Personal Data will only be transferred to a third country with your documented instructions.
• Your Personal Data will be transferred and stored in an encrypted format, with access limited to employees who need it for contractual and legal obligations.

d. Rights of Data Subjects

To make any of the following requests, with respect to this Privacy Policy, our Terms of Use, and/or Personal Data, please contact us via email at privacy@intentwise.com.

• Access: You can request more information about the Personal Information we hold about you.
• Rectification: You can request correction or supplementing of incorrect or incomplete data.
• Objection: You can object to the collection or use of your Personal Information for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Information from our systems.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
• Portability: You can request a copy of your Personal Information in a machine-readable format.
• Withdrawal of Consent: You have the right to withdraw your consent at any time.
• Right to File Complaint: You have the right to lodge a complaint with your Data Protection Authority. For more information, visit Data Protection Authorities.

We will respond to your inquiry within thirty (30) days of receipt.

11. YOUR CALIFORNIA PRIVACY RIGHTS

Intentwise does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits users of our website or Platform that are California residents to request information regarding our disclosure of their Personal Information to third parties for direct marketing purposes. To make such a request, or for identification and/or deletion of Personal Information stored on you, email us at privacy@intentwise.com.

Note that (i) if we delete your Personal Information as requested, we may no longer be able to provide services to you, and (ii) we may need to retain such information during the shutdown and billing process. For inquiries about our data storage practices, please email privacy@intentwise.com.

We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning here.

a. Right to Request Personal Information

Upon request, we will provide you with: (i) a list of all Personal Information collected on you, (ii) its source, (iii) the reason for collection, and (iv) any parties with whom we have shared it. If we sell or disclose your Personal Information, upon request, we will provide a list of collected information, disclosed information, and recipients. Requests can be made twice within a 12-month period. Personal Information is collected only as necessary to provide Services.

b. Disclosure of Personal Information

We only share your Personal Information with service providers (e.g., billing agents) as required for Services. We do not sell or transfer your data for unrelated purposes.

c. Right to have Personal Information Deleted

Upon request, we will delete your Personal Information and instruct Service Providers to do the same. Note that deletion will prevent further use of our Services.

d. Non-Discrimination Right

We will not discriminate against you for exercising your CCPA rights. We will not:

• Deny you goods or services.
• Charge different prices, offer discounts, or impose penalties.
• Provide different levels of goods or services.
• Suggest that you may receive different prices or levels of goods or services.

e. Financial Incentives

We may offer CCPA-permitted financial incentives related to your personal information, with terms provided for participation. You can opt-in to or revoke participation at any time.

f. Contact Information

You may contact us at privacy@intentwise.com, or by mail at Privacy Officer, Intentwise Inc, 11440 W. Bernardo Court, Suite 300 | San Diego, CA | 92127, to (i) make a Personal Information request, (ii) lodge a complaint, (iii) request deletion, or (iv) discuss our Privacy Policy.

g. Under 16

We will not share your Personal Information if you are under 16 without parental consent. We will also honor opt-out requests.

h. Personal Information We Store

We may store/collect the following on you:

• Name
• Business Address
• Business Email Address
• Business Telephone Number
• IP Address
• Business Title
• Employer

12. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)

The Children’s Online Privacy Protection Act (“COPPA”) applies to entities that collect information from children under 13. Our website and Platform are not intended for children under 13. If you wish to know more, please email privacy@intentwise.com.

13. CAN-SPAM ACT OF 2003

The CAN-SPAM Act regulates commercial messages. Per the Act, we will:

• Not use false or misleading subjects or addresses.
• Identify the message as an advertisement.
• Include Intentwise’s address.
• Honor opt-out/unsubscribe requests quickly.
• Provide an unsubscribe option.

To unsubscribe, follow the instructions at the bottom of emails or email privacy@intentwise.com.

14. MODIFICATIONS TO OUR PRIVACY POLICY

We will post any Privacy Policy changes and email notifications. Continued use of our services signifies acceptance of changes.

15. LIST OF THIRD-PARTY SERVICE PROVIDERS

Intentwise uses the following providers:

• Amazon Web Services Inc. (North Virginia, US) - Contact
• Stripe, Inc. - info@stripe.com
• Google Cloud - support@google.com (855) 817-0841

16. COPYRIGHT INFRINGEMENT/DMCA NOTICE

To request content removal under the DMCA, send a written notification including:

• Your signature (physical or electronic).
• Identification of copyrighted work(s) and infringing material.
• Your contact information.
• A statement of good faith regarding use of the material.

Send to Raghu Kashyap at privacy@intentwise.com, Intentwise, Attn: DMCA Notice, 11440 W. Bernardo Court, Suite 300 | San Diego, CA | 92127.

17. ANTI-BRIBERY COMPLIANCE

Intentwise complies with anti-bribery laws, including the U.S. Foreign Corrupt Practices Act and U.K. Anti-Bribery Act, ensuring no improper payments are made to influence any official decision.

18. CONTACT US

For questions about this Privacy Policy, email privacy@intentwise.com or write to Privacy Officer, Intentwise Inc, 11440 W. Bernardo Court, Suite 300 | San Diego, CA | 92127.

PLEASE NOTE: By using our website or Platform, you agree to this Privacy Policy and the Terms and Conditions. If you do not agree, please do not use our website or Platform.