Privacy Policy

Who is IVM?

International Vending Management, Inc. (“IVM”) offers smart vending and locker solutions (“services”) for internal distribution of products to our clients and their employees. Our corporate office is located at 5155 Technology Way Indianapolis, IN 46268, USA.

This Privacy Notice describes our privacy practices in relation to your use of our website (www.ivminc.com) and our services. This Notice also describes your choices regarding use, access, and sharing of your personal data by IVM.

GDPR Readiness

What is the GDPR?

The European Union has taken a monumental step in protecting the fundamental right to privacy for every EU resident with the General Data Protection Regulation (GDPR) which will be effective from May 25, 2018. Simply put, EU residents will now have greater say over what, how, why, where, and when their personal data is used, processed, or disposed. This rule clarifies how the EU personal data laws apply even beyond the borders of the EU. Any organization that works with EU residents’ personal data in any manner, irrespective of location, has obligations to protect the data.

Statement of Commitment

At IVM, we take the trust placed in us to secure and protect our customer’s data very seriously. We are also aware of our role in providing the right tools and processes to support our customer’s need to meet their GDPR mandates. IVM is fully committed to the GDPR and we have recently published some important updates to our Privacy Policy at https://ivminc.com/privacy , effective May 25, 2018. These updates are just enhancements which clarify and provide additional information about:

• Privacy rights and how to exercise them.
• Child privacy protection
• GDPR compliance and requirements
• The right to Erasure and how to exercise that
• How we collect, use, share and protect personal data.
• The legal basis we rely on to process personal data.
• How we operate in our capacity as a data processor acting on behalf of our customers.

Standard Contractual Clauses

Standard Contractual Clauses for the transfer of Personal Data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and the Council approved by European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, as currently set at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en requirement for the transfer of personal data outside of the EU under the EU Data Protection Directive and outside of Switzerland under the Swiss Federal Act on Data Protection.

IVM agrees that it shall abide by the terms of the Standard Contractual Clauses (as applicable) as set out in Module Two (Controller to Processor). The Standard Contractual Clauses shall apply to IVM, Inc in its role as the “data importer.” IVM, Inc has agreed that, as provided in the Standard Contractual Clauses, Data Subjects shall be third party beneficiaries to the Standard Contractual Clause.

What about personal data that is provided to IVM by one of our Customers?

For information that a customer provides to IVM about their employees to use our services, we do not own this data. Our services are used by our customers for internal distribution of products to their employees. Those customers are the owners (controllers) of the data that is provided to them. If personal data is provided to one of our customers, their employees should contact that customer to access, correct or delete their personal data.
For personal data provided to us by our customers, we consider that information to be private and owned by the customer. We allow access to the customer account and any reports therein to the person with the authorized username and password login information for that account.

Data Protection Addendum

IVM has updated its Data Processing agreements to add the GDPR specific clauses as required by GDRP Article 28. Below is a summary of what was added to meet compliance:

• • The processor agrees to process personal data only on written instructions of the controller. Everyone who comes into contact with the data is sworn to confidentiality.
  • All appropriate technical and organizational measures are used to protect the security of the data.
  • The processor will not subcontract to another processor without notifying the controller in writing the, in which case the new subproccessor will need to be added to the DPA (pursuant to Sections 2 and 4 of Article 28).
  • The processor will help the controller uphold their obligations under the GDPR, particularly concerning data subjects’ rights.
  • The processor will help the controller maintain GDPR compliance with regard to Article 32 (security of processing) and Article 36 (consulting with the data protection authority before undertaking high-risk processing).
  • The processor must allow the controller to conduct an audit and will provide whatever information necessary to prove compliance.

Who can I contact if I have more questions about IVM and GDPR?

IVM
Attn: Privacy Officer
5155 Technology Way
Indianapolis, IN 46268 317.899.6787
privacy@ivminc.com

What kind of personal data does IVM collect and how is it used?

Direct Collection and Use

We collect your personal information directly from you when you contract to use IVM’s services, when you contact us via our website contact form, or when you submit an online support ticket. We may collect the following personal information from you:

• • • Contact data, such as name, email, phone number
  • • Business data, such as company name, business type, department, title, business email, business phone number.

The personal information that we collect from you is used to:

• • • Provide you with IVM’s services
    • Log you into your account
    • Respond to your requests and questions
    • Communicate upcoming IVM events of interest or updates to our services
    • Improve our services
    • Detect, prevent, and resolve security and technical issues

Third-Party Collection and Use

We may collect personal information about you from business partners, our clients, or other third-parties. This information may include:

• • • Contact data, such as name, email, phone number
    • Business data, such as company name, business type, department, title, business email, business phone number

This information is used to:

• • • Identify new customers
    • Provide you information on our services that may be of interest to you
    • Provide us information on the usability of our website
    • Provide you and/or your employer the services that they have contracted with us

If you would like to know if we have your personal data via third-party collection, please contact us at Privacy@IVMinc.com.

Passive Collection and Use

Like most companies, we collect limited personal information from visitors to our website and users of our products and services. This information may include:

• • • IP Address
    • Browser Type
    • Internet Service Provider Address
    • Referring pages
    • HTML pages, graphics, or other files viewed on our site
    • Operating systems
    • Date/time stamp

We may use cookies, web analytics and other means to do so.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org .

Google Analytics

IVM uses Google Analytics to help us understand how you engage with our website and applications. To learn more about how Google Analytics collects and processes data, please see https://www.google.com/policies/privacy/partners/ .

Web Server Logs

For statistical purpose, IVM may collect information and store it in log files. These logs files will contain standard information collected by web servers, such as client IP address, browser type, internet service provider, operating system and the like. This information is used internally to administer our website and to gather demographic information about our user base.

Passively collected information is used to:

• • • Provide us information about website usability, user interaction and number of users
    • Track and analyze trends and patterns to improve our website and online ads
    • Help us identify you as a repeat visitor
    • Provide you information on our products and services that may be of interest to you
    • Manage and track the effectiveness of our marketing efforts.

We do not use passively collected information to determine your identity.

Will IVM use my personal data to communicate with me?

IVM may send you information, such as announcements about new services, promotional materials, survey inquiries, newsletters, and other marketing materials. You may discontinue receiving this marketing information by using the “Unsubscribe” link found in the email communication, or by contacting us at Privacy@IVMinc.com .

As a user of our services, IVM may also send you information about your account or our services, such as an email when you register for a trial account or new account, an email to confirm account changes, updates on our website, and our products and services. We consider these communications to be part of your IVM account. You may discontinue receiving this information by using the “Unsubscribe” link found in the email communication, or by contacting us at Privacy@IVMinc.com . Please note that your choice to unsubscribe to account or service information may affect our ability to provide you with our products or services.

Does IVM collect personal data from children?

We do not knowingly collect personal data from children under the age of 16. IVM does not target our website, our products or our services toward children under the age of 16.

What are IVM’s Policies on Transferring EU Employee Data to the US?

IVM does not have employees or offices in the EU or Switzerland.

Does IVM share my personal data with third parties?

IVM may share or disclose personal data under certain circumstances. We may disclose or share your personal information when:

• • • We need to share personal information with third parties to provide you with the IVM products and services that you request;
    • You request that we share your personal information with a third party;
    • We need to share your personal data with other companies to prevent fraud or to reduce risk; or
    • We are required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We consider information, including your personal information, to be an asset to our business. This business asset may be included in an acquisition of IVM, in whole or in part; a sale of some or all of IVM’s assets; a merger or merger involvement; during a bankruptcy; or other transition of our business.

Onward Transfer

IVM complies with the Privacy Shield Principles for onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Integration and Links to Other Websites

Our website and our products may contain links and provide integrations to other websites and products of other organizations. We provide these links and integrations as a convenience to you; we do not operate, control or endorse these websites or products. It is your choice whether to utilize these links and integrations or not. These external websites and products are subject to their own privacy policies.

Can I access my personal data collected by IVM?

You have the right under Privacy Shield, GDPR, and CCPA to access, correct, or delete your personal data

For personal data that we have collected about you, you may contact us at Privacy@IVMinc.com or toll-free at (866) 271-9680 to exercise these rights.

Do I have a choice in providing my personal information to IVM?

When interacting with IVM, you choose what personal information and how much information to provide to us. Your choice may affect our ability to provide you with our products or services.

What about my personal data that was provided by my employer to IVM?

For information that your employer-provided to IVM in order to use our services, we do not own this data. Our services are used by our clients for internal distribution of products. Those clients are the owners (controllers) of the data that you provided to them. If you have provided personal data to one of our clients, you should contact that client to access, correct or delete your personal data.

For personal data provided to us by our clients, we consider that information to be private and owned by the client. We allow access to the client account and any reports therein to the person with the authorized user name and password login information for that account.

If you are an individual who interacts with a client using our services (such as an employee of one of our clients) and would either like to amend your contact information or no longer wish to be contacted by one of our clients that use our Services, please contact the client that you interact with directly.

How does IVM protect my personal data?

IVM takes reasonable precautions to protect personal data in its possession from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

CCPA Notice

This Privacy Notice for California Residents supplements the information contained in IVM’s Privacy Policy at https://ivminc.com/privacy/and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:

• • • Publicly available information from government records.
    • De-identified or aggregated consumer information.
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• • • Directly from you when you contract to use IVM’s services, when you contact us via our website contact form, or when you submit an online support ticket.
    • Indirectly from you, like most companies, we collect limited personal information from visitors to our website and users of our products and services.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• • • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
    • To provide, support, personalize, and develop our Website, products, and services.
    • To process your requests.
    • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
    • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
    • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected from you for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• • • Service providers.
    • Data Aggregators.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• • • The categories of personal information we’ve collected about you.
    • The categories of sources for the personal information we’ve collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we’ve collected about you (also called a data portability request).
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales, identifying the personal information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• • • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• • • Calling us at (866) 271-9680
    • Emailing us at Privacy@IVMinc.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• • • Provide sufficient information that allows us to reasonably verify you are the person about whom we’ve collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

Non-Discrimination

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.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Privacy@IVMinc.com. or write to us at 5155 Technology Way Indianapolis, IN 46268, USA.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (866) 271-9680

Website: www.IVMInc.com

Email: Privacy@IVMinc.com.