Privacy Policy

Last updated: June 24, 2024

This is the Privacy Policy of IGMR Research Ltd including its affiliates, subsidiaries, and related entities (collectively, “Intelligo,” “we,” “us” or “our”) and applies to our website and its subdomains (the “Website” or “Site”), as well as our software applications, and all portals, products, goods, services, events, and interactive features, or other services controlled by us that post a link to this Privacy Policy (collectively, the “Platform”).

All references to “you,” “your” or “User” in this Privacy Policy means the person who registers for, access, or uses the Site or our Services. If you use or access our Site or Services on behalf of an entity or an individual, you represent and warrant that you have the authority to bind that entity or individual, and “you” and “your” refers to that entity or individual as well.

Your privacy is important to us, and in this Policy, we tell you what personal information we collect, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and what choices you may make about that information.

This Privacy Policy is expressly incorporated into our Terms and Conditions (“Terms”) and governs information that we collect from you on the Platform, as well as through other online and offline communications with our personnel. We refer to all of the above as our “Services.” If you have questions about this Privacy Policy, contact us at compliance@intelligo.ai

1. Who We Are

Intelligo is a background check provider for our clients (our “Clients”) and collects and processes personal information in the course of providing its Services.

2. What Information Does This Policy Apply To?

This Policy reflects how Intelligo processes personal information through our Platform and our Services. It does not apply to our Clients’ uses of your data, or the use of your data by any third party (for example, when you visit a third-party website or interact with third-party services). You should review those third parties’ privacy policies before you use any of their services (“Third Party Services”). In some instances, Intelligo only acts as a “processor” of your information and may not be the “controller” of the information (which may be our Client or our vendor). Our use of your information is usually in the context of providing a service to our Clients, and you may be required to reach out to the Client directly to remove your information from their databases as well as Intelligo’s.

3. What Information We Collect

As a preliminary matter, we handle all information provided to us with the utmost care, whether provided by our Clients or vendors, or provided by you directly. Please note that if you voluntarily provide your information in the course of interfacing with the Platform or using our Services, we will take that as your agreement to our collection, use, and disclosure of your information as set forth in this Privacy Policy. Your use of our Platform indicates your consent to the practices described in this Policy and in our Terms of Use. 

Internally, your personal information will only be shared with members of our company who need to know this information in order for us to provide our Services. At times, we may need to disclose your personal information to third parties outside the company who may be assisting us with providing Services to you, as set forth in this Policy, or to our Clients.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will and consent. If you do not wish to provide us with your personal data, or to have it processed by us, please avoid any interaction with us or any use of our Service.

a. Information You Provide to Us

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The categories of Personal Information we collect may include:

• First and last name, email address, home or business address, telephone numbers, mobile numbers, credit card or debit card number, bank account and other financial information, payment and/or service history, signature, or other information used to identify an individual;

• Passport ID or driver’s license or other government-issued identification card information;

• Current or past employment and/or educational information;

• Information about an individual’s gender or gender identification, racial or ethnic origin, political opinions, religious or philosophical believes, or trade union membership, biometric data, or information relating to sex life or sexual orientation;

• Information that you may share via a message, free text field, chat function, or other unstructured format on the Platform (please note that we do not collect consumer information via our Contact Us function unless you provide it);

• Documents, photos, and/or videos that you upload through the Platform or our Services, including record made via customer service calls;

• Social media or communications platform information, such as usernames or social media handles, User Content (as defined in Terms of Use) and other data shared with us through our Platform (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, LinkedIn, and Twitter) or posted on social media pages (such as our social media page or other pages accessible to us); and/or

• Other information that could reasonably be used to identify you personally or identify your household or device.

We may also obtain Personal Information from you where you expressly provide us with the information. Examples of sources from which we collect information include telephone calls with you, letters, e-mails or other communications from you, information provided via online chat or support services, web forms or inputs/uploads into our Platform, documents you have provided to us, or references and referrals provided to us in connection with your employment application.

Your decision to provide us with the Personal Information above is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Platform or our Services.

b. Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Platform (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Platform. Usage Information may include:

• Your IP address, MAC address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;

• Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);

• Referring and exit web pages and URLs;

• The areas within the Platform, Site and Apps that you visit and your activities there, including remembering you and your preferences;

• Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Platform or the Services;

• Your Device characteristics; and

• Certain other Device data, including the time of day you visit our Platform or other information used to provide analytics or other usage information.

For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you.

If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access the Platform, or certain features, Services, content, promotions, or products may be limited or disabled.

c. Information from Third Parties

As stated above, Intelligo is a service provider to our Clients. We are not a direct-to-consumer provider. The Platform and Services may include functionality that allows certain kinds of interactions between us and our Client. The use of this functionality may involve the Client or a third-party providing your Personal Information to us. Our receipt of this information is always controlled by an agreement with the Client that contains specific provisions about our ability to use your Personal Information. We cannot use your Personal Information for any purpose other than fulfilling the business relationship with the Client. We may also collect information about you from other sources, including consumer credit reporting agencies, background check vendors, court and other public records, and state, federal or international agencies.

The Site and Platform may also include functionality that allows certain kinds of interactions between the Site or Platform and your account on a third-party website or application, like YouTube, BuzzSprout, or LinkedIn. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Platform to facilitate sending a communication from the Site (e.g., “Contact Us”) or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.

The Client or these third parties may retain any information used or provided in any such communications or activities and their privacy practices may be subject to different Terms or Privacy Policies. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using these third-party tools on our Site. 

4. How We Use Your Information

We may use Personal Information for various purposes, including the following:

• Responding to your requests for information;

• Providing the Platform, products or Services to you and to our Clients;

• Verifying your identity and for fraud prevention;

• Providing you with updates and information about products and Services we provide;

• Sending you marketing information about Intelligo;

• Sending you email communications such as electronic newsletters about our Services, events and promotions, as well as periodic customer satisfaction, market research or quality assurance surveys that may be of interest to you;

• Improving the effectiveness of our Platform, our marketing endeavors, and our product and service offerings;

• Customizing your experience on the Platform;

• Identifying your product and service preferences, providing personalized content and informing you of new or additional information, products and services that may be of interest to you;

• Helping us address problems with and improve our Platform and our products and Services, including testing and creating new products, features, and services;

• Protecting the security and integrity of the Platform, including understanding and resolving any technical and security issues reported on our Platform;

• Engaging in analysis, research, and reports regarding the use of our Platform and Services;

• For internal business purposes (including but not limited to HR-related functions for applicants and employees, such as evaluating your employment application or administering employee benefits, such as medical, dental, commuter and retirement benefits, including recording and processing eligibility of dependents, absence and leave monitoring, insurance and accident management, rewards or discount programs offered to employees);

• Complying with the law and protecting the safety, rights, property or security of Intelligo, the Services, and the general public; and

• For other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

5. Disclosure of Your Information

We may be required under our agreement(s) with our Clients to share Personal Information and preferences that we have collected with them. We also may share your information, including your Personal Information, with our affiliates, service providers, business associates, and other third parties that perform essential services for us; for example, a payment processor, a cloud-service or internet service provider, an email marketing vendor, a customer service provider, or entities that handle other business functions for us.

As permitted by law, we insist that these partners follow the same rules and standards with respect to your personal information as we do, and we typically have a contractual agreement in place with the other party which prohibits them from disclosing or using the information other than for the business purposes for which it was disclosed.

We do not “sell” your information to any third parties, as that term is defined under California law. If you are a California resident, you may have additional rights with respect to the transmission of your information. Please see the section entitled “Your California Privacy Rights” below for more information.)

We may share the information we have collected about you, including your Personal Information, in ways other than as described in this Privacy Policy if they are disclosed at or before the time you provide your information.

We may aggregate, de-identify, and/or anonymize any information collected through the Platform or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (which is no longer considered Personal Information) for any purpose, including without limitation, for research and marketing purposes, analytics, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

Certain Personal Information about you may also be disclosed in the following situations:

• To comply with a validly issued and enforceable subpoena or summons;

• As necessary to properly comply with or respond to an inquiry or complaint from a federal or state agency;

• In conjunction with a prospective purchase, sale, or merger of all or part of our company, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review; and

• As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.

6. Cookies and Other Tracking Technologies

We may use various methods and technologies to store or collect information about you (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site or Apps, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

• Cookies. Cookies are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data.

• Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.

• ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.

• Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

• Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (g., that a user of multiple devices is the same user).

We may use Tracking Technologies for a variety of purposes, including:

• To allow you to use and access the Site or Apps, including for the prevention of fraudulent activity and improved security functionality;

• To facilitate navigation, display data more effectively, collect statistical data, personalize your experience while using the Online Services and recognize your computer to assist your use of the Online Services;

• To assess the performance of the Site or Apps, including as part of our analytic practices or otherwise to improve the design and functionality, content, products or services offered through the Site or Apps;

• To offer you enhanced functionality when accessing the Site or Apps, including identifying you when you sign into our Site or Apps or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and

• To deliver content relevant to your interests on our Site, Apps and third-party sites based on how you interact with our content.

You can choose whether to accept cookies by changing the settings on your browser. If you choose not to enable cookies, you will still be able to browse our Site, but doing so will restrict some of the functionality of our Site and what you can do. To learn more, please see our Cookie Policy 

7. Do Not Track Signals

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed-upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

8. Your Choices About the Information We Collect

You have choices when it comes to how we use your information, and we want to ensure you have the information to make the choices that are right for you.

If you no longer want to receive marketing-related emails or newsletters, you may opt out by following the instructions in any such email you receive from us, or contacting us at compliance@Intelligo.ai. 

Please note that Intelligo’s Clients, as the controllers of the data, remain wholly responsible for obtaining any necessary consent for an applicable consent and giving effect to users’ choices with respect to that consent. If you wish to revoke your consent for us to conduct a background check, you must contact the Client to whom you provided your prior consent in order to revoke it.

9. Children’s Privacy

The Platform and our Services are not intended for use by children under the age of 16. We do not request, or knowingly collect, any Personal Information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us at compliance@intelligo.ai to request the deletion of that information.

10. Security

We use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your information has been compromised), please immediately notify us via compliance@intelligo.ai.

11. Links to Other Web Sites

For your convenience, the Platform and this Privacy Policy may contain links to other websites. Intelligo is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Platform should be deemed to imply that Intelligo endorses or has any affiliation with the links. Please see our Terms for more information.

12. Updating Personal Information

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at compliance@intelligo.ai.  We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

13. International Data Transfers

We operate in and use service providers located in the United States and throughout the world. Because Intelligo works with global companies and technologies, we may transfer your personal information outside of the country in which it was originally provided. When we transfer Personal Information outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your personal information. As a result, if you are located outside the U.S., we are notifying you that your Personal Information may be transferred to the U.S. pursuant to the Standard Contractual Clauses or other adequacy mechanisms, or pursuant to exemptions provided under European Union laws. Note that U.S. data protection laws may not offer the same level of protection as those in the European Union, and your information may be subject to access requests from governments, courts, or law enforcement in the United States. By using the Site or the Platform or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Privacy Policy.

14. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

This section of the Privacy Policy applies solely to visitors, users, and others who reside or are located in the United Kingdom and/or the European Economic Area (“EEA”). We adopted this Policy to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”) and the UK GDPR. Any terms defined in the GDPR have the same meaning when used in this Section.

Under applicable law, we are considered a “processor” of Personal Information we handle for our Clients. For our employees and job applicants, we are considered the “data controller.”  If you are a resident of or located within the UK or EEA, you have certain data protection rights. These rights include:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Information.

• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where Intelligo relied on your consent to process your Personal Information.

a. Legal Basis for Processing Personal Information Under GDPR

In most instances, Intelligo is a processor of Personal Information; however, in some instances Intelligo may be a controller of Personal Information. Intelligo’s legal basis for collecting and using the Personal Information described in this section depends on the Personal Information we collect and the specific context in which we collect it.

Intelligo may collect or process your Personal Information because:

• We need it to provide a service to you;

• You have given us your consent to do so;

• The processing is in our legitimate interests, and it is not overridden by your rights; or

• To comply with the law.

More specifically, we rely on the following legal bases for processing your Personal Information:

• Processing of your Personal Information that you provide to us when you interact with our Services is necessary to respond to or implement your request prior to entering into a contract with us.

• When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

• We use account-related data to set up accounts for users in our Platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and us.

• We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt in to receive those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

• Our use of data relating to your use of the Site and/or the Services, described above, is necessary for our legitimate interests in understanding how the Site and the Services are being used by you, to improve your experience on it and our Services offerings. We also have a legitimate interest in aggregating and/or anonymizing the information that we collect through our Site and/or the Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

b. Retention of Information

Intelligo will retain your Personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Intelligo will also retain Personal information, including Usage Data, for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

c. Disclosure of Personal Information

Under certain circumstances, Intelligo may be required to disclose your Personal Information if required to do so by law or by contract, or in response to valid requests by public authorities (e.g., a court or government agency).

Intelligo may disclose your Personal Information in the good faith belief that such action is necessary to:

• To comply with a legal obligation;

• To protect and defend the rights or property of Intelligo;

• To prevent or investigate possible wrongdoing in connection with the Service;

• To protect the personal safety of users of the Service or the public; and/or

• To protect against legal liability.

d. Exercising Your Rights Under GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the UK or the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the UK or EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us at compliance@intelligo.ai. 

For more information about the GDPR, please contact your local data protection authority in the EEA.

15. Your Data Protection Rights Under the UK GDPR

If you are a resident or citizen of the United Kingdom, the following provisions also apply:

“UK GDPR” means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

If we share your personal data within the Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

16. Your Additional Data Protection Rights Under the Lei Geral de Proteção de Dados (LGPD)

If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados (“LGPD”). These rights include:

• The right to confirmation of the existence of the processing;

• The right to access the data;

• The right to correct incomplete, inaccurate or out-of-date data;

• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;

• The right to the portability of data to another service or product provider, by means of an express request;

• The right to delete personal data processed with the consent of the data subject;

• The right to information about public and private entities with which the controller has shared data;

• The right to information about the possibility of denying consent and the consequences of such denial; and

• The right to revoke consent.

a. Legal Basis for Processing Data Under the LGPD

Intelligo’s legal bases for collecting or processing your Personal Information are as follows:

• We need to provide a service to you;

• You have given us your consent to do so;

• The processing is in our legitimate interests, and it is not overridden by your rights; or

• To comply with the law.

b. Duration of Processing

Intelligo will process and retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Intelligo will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

c. Exercising Your Rights Under the LGPD

If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days or let you know if we need additional time.

17. Your California Privacy Rights

This section of the Privacy Policy applies solely to California residents. We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”).  Any terms defined in the CCPA have the same meaning when used in this Section.

California residents have the following rights:

• The right to know what personal information is being collected about you;

• The right to know whether your personal information is sold or disclosed and to whom;

• The right to access your personal information;

• The right to request correction of any inaccurate Personal Information that we maintain about you;

• The right, in certain circumstances, to delete the information you have provided to us;

• The right to opt out of the sale of personal information;

• The right to limit the use of your Sensitive Personal Information, except for such information that is collected or processed without the purpose of inferring characteristics about you; and

• The right not to be discriminated against, even if you exercise your privacy rights.

a. Request for Information, Correction, or Deletion

California consumers have the right to request, under certain circumstances, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months:

• The categories of Personal Information collected about you;

• The categories of sources from which we collected your Personal Information;

• The business or commercial purpose we have for collecting or selling that Personal Information;

• The categories of Personal Information that we have sold or disclosed about you for a business purpose;

• The categories of third parties with whom we share your Personal Information;

• The categories of Personal Information that we have disclosed about you for a business purpose, or if we have not disclosed that information for a business purpose;

• The categories of Personal Information that we have sold, or if we have not sold consumers’ Personal Information;

• The categories of sensitive personal information to be collected, and the purposes for which sensitive personal information is collected or used, and whether such information is sold or shared, except for such information that is collected or processed without the purpose of inferring characteristics about you; and

• The specific pieces of Personal Information we have collected about you.

Intelligo collects certain types of personal information about you during your relationship with us, as explained above. In particular, due to the nature of our business, our Site and our Services have collected and sold or shared the following categories of Personal Information from consumers within the last twelve (12) months:

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You have the right to request that we correct any inaccurate information that we maintain about you.

You can also request that we delete your personal information. As permitted by the CCPA/CPRA, if you request deletion of Personal Information that we have collected about you, we, our services providers, and our contractors may be unable to comply with such a request if certain exceptions apply, such as if your Personal Information is necessary to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you or our Clients, or otherwise perform a contract between us and you or us and our Clients;

• Prevent, detect, and investigate security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with a legal obligation; or

• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

b. Right to Opt Out/Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information. At this time, we do not sell our consumers’ personal information to third parties. We will, however, honor your request to opt out of any marketing emails or correspondence.

c. Right to Limit the Use of Sensitive Personal Information

We may collect your sensitive personal information (e.g., social security number, driver’s license, state identification card, passport, or racial or ethnic origin) if it is necessary to perform our Services, as reasonably expected by you when using a due diligence and background check organization. We do not collect or process your Sensitive Personal Information for the purpose of inferring consumer characteristics about you.

d. Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

e. Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. As stated above, we are usually required to provide your Personal Information to our Clients, as they are the ultimate controllers of the information. We do not currently disclose personal information protected under this section to other third parties for their own direct marketing purposes.

f. Exercising Your Rights Under the CCPA

You or your authorized agent may make a request to access, correct, delete or opt-out of the sale of your information by contacting us as follows:

• Email Address: compliance@intelligo.ai 

• Telephone: (888) 247-1921

If you use an authorized agent to submit your CCPA request, we may require proof of the written authorization you have given to the agent. We also may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

18. Your Nevada Privacy Rights

If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. At this time, we do not sell consumer’s personal information to third parties.

19. Your Virginia Privacy Rights

If you are a resident of Virginia, you have the right under the Virginia Consumer Data Protection Act, upon a verified request, to:

• To confirm whether or not a controller is processing your personal data and to access such personal data;

• To correct inaccuracies in your personal data;

• To delete your personal data;

• To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;

• To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below:

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Virginia Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Virginia resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

If we decline to take action on your request, residents of Virginia can appeal our decision by submitting an email to compliance@intelligo.ai entitled “Virginia Privacy Rights Appeal” and we will review your request and respond with a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

20. Changes in Privacy Policy

We may elect to change or amend our Privacy Policy; in such event, we will post the policy changes in our Privacy Policy on the Platform, and they will become effective on the date posted. If you are concerned about how your personal information is used, please visit this Site often for this and other important announcements and updates.

21. Contact Us

If you have any questions about this Privacy Policy, please contact us as follows:

• Email Address: compliance@intelligo.ai 

• Telephone Number: (888) 247-1921

• Website: https://www.intelligo.ai/