Privacy Policy

Last updated September, 09 2019

Last updated 9/10/19

At Ntirety, Inc. (“Ntirety”) we respect your privacy. We know that you care about how your personal information is collected and used, and we encourage you to read through our information handling practices as described below so you understand our commitment to your privacy and how you can participate in the handling of your information.

ABOUT THIS PRIVACY NOTICE

This Privacy Notice discusses how Ntirety collects, maintains, uses, and discloses the information that is collected from you, our customers, the visitors to our website, and any individual who contacts us directly (altogether, “Users”). The purpose of this Privacy Notice is to provide Users with an understanding of what types of information we collect, how it is stored, why we use it, and the choices that Users have related to this information. We want to ensure that you understand how we will and will not use the information you entrust to us.

If you are a Ntirety customer (“Client”), this Privacy Notice is incorporated into and subject to the Master Services Agreement (“MSA”) (available online at https://www.ntirety.com/MSA or as otherwise executed between yourself and Ntirety), and should also be read in conjunction with the Acceptable Use Policy (“AUP”) (available online at https://www.ntirety.com/AUP).

If you are only visiting our website, you will not be required to identify yourself or reveal any personal information as you browse online. However, if you wish to initiate any communications with Ntirety via our website, such as using the online form to request a sales quote or using the live chat function to speak with a customer service agent, you may be asked to first provide certain personal information to identify yourself to us. If you do not wish to provide this personal information, you may continue to browse our website, but we will not be able to contact you. Once you choose to provide us with your personal information (or any other information by which you can be identified), you can be assured that it will only be used to support your relationship with Ntirety as detailed herein this Privacy Notice.

We reserve the right to change this Privacy Notice at any time. To stay updated on our most current Privacy Notice, please visit this page often. If you have a question about how a certain type of information is handled, please e-mail us at: privacy@ntirety.com. If you have requests in regards to GDPR as it pertains to the Rights of a Data Subject (see further details below) please email privacy@ntirety.com. 

EU GENERAL DATA PROTECTION REGULATION (GDPR)

Ntirety complies with the EU General Data Protection Regulation 2016/679 (“GDPR”) in the Processing of all Personal Data received from European Union (“EU”) member countries. For the purposes of this section of the Privacy Notice, the terms, “Processing” and “Personal Data” will have the same meaning as in GDPR. The nature and purpose of the Processing will be solely as described in this Privacy Notice. The scope of the Processing will be limited to the Personal Data that you have provided to Ntirety. You determine the type and categories of Personal Data that are held by Ntirety. We will not collect any Personal Data without your knowledge. Your rights and obligations in relation to the Processing of Personal Data will be as set out in GDPR, this Privacy Notice, and, if you are a customer, the MSA.

To ensure our compliance with GDPR, Ntirety engages a trusted independent third party provider to review our GDPR readiness, which is in addition to our standard SOC1, SOC2, and PCI-DSS audits. If, after you conduct a data protection impact assessment or consultation with a supervisory authority you determine that continuing with our Services would be in breach of GDPR, then you must notify Ntirety immediately and we will work together with you to reach a mutually agreeable solution. 

Data Protection Officer

If at any time you have any questions or concerns about Ntirety’s GDPR compliance, please contact our Data Protection Officer directly at: privacy@ntirety.com.

Supervisory Authority

Notwithstanding anything herein or in the MSA, if you have a good faith belief that the Processing of your Personal Data infringes GDPR, you have the right to lodge a complaint with a supervisory authority in the EU member country of your place of residence or work, or in which the alleged infringement occurred. Ntirety will provide reasonable cooperation with any supervisory authority consultation.

NORTH AMERICA DATA PROTECTION REGULATIONS

Ntirety complies with all state/provincial and federal data privacy laws and regulations of the United States of America and Canada, as applicable, with respect to the collection and storage of personally identifying information in the course of our business.  If you have a good faith belief that your personally identifying information has been collected or disclosed without your authorization, you have the right to register your concerns with the following authorities:

USA

            Your local or state consumer protection agency: https://www.usa.gov/privacy

            Canada

The Office of the Privacy Commission of Canada: https://www.priv.gc.ca/en

The Office of the Information and Privacy Commissioner of British Columbia: https://www.oipc.bc.ca/

  

WHAT TYPE OF INFORMATION DO WE COLLECT?

 

Statistical Information. When you visit the Ntirety website, our servers collect basic user information about you such as your ISP’s domain, your IP address, your operating system and web browser, the date and time you accessed our website, and the pages from within our website that you visit (“Statistical Information”). This Statistical Information does not include names, contact information, or any other information by which Users can be personally identified.

 

User Contact Information. When you initiate any communications with Ntirety either through our website or any other means, we may ask you to provide us with certain personal information such as your name, email address, phone number, company name, job title, and geographical location (“User Contact Information”).  User Contact Information contains information by which Users can be personally identified.

 

Client Information. When you sign up as a Client, you will be required to provide us with the User Contact Information described above as well as your payment information, such as your credit card number, wire information, or other banking information (altogether, “Client Information”). The term “Client Information” will also include information maintained by Ntirety with regard to your customer account status, choice of Services, and access logs. In addition, we may store your electronic mail and other communications as a part of the transmission and delivery of those communications as a part of your Client Information. Client Information contains information by which Users can be personally identified.

 

HOW DO WE COLLECT YOUR INFORMATION?

By Asking You Directly.

If you indicate to us that you would like to receive communications from Ntirety, we will ask you to provide us with your User Contact Information.  If you sign up as a Client, we will ask you to provide us with your Client Information.  You will be provided the opportunity to actively consent to Ntirety’s use of this information to communicate with you, and to consent to the purpose(s) for which Ntirety may contact you or otherwise use your information.  You may withdraw this consent at any time.

By Using Cookies

Our website uses cookies. These data files are read by our server to determine whether Users have visited our site before, how often, the length of time and which pages Users view. The Systems we use to provide Services to Users may also place cookies on their computers. You may stop the use of tracking cookies by clicking the Opt-out button below. However, even after opting-out, some cookies are still required for basic website functionality (for example, hiding notifications that have already been acknowledged). These basic cookies contain no identifying information and do not track visit data in any way.

To allow cookies, click Opt-in.

Cookies used on the Ntirety.com website are:

  • Google Analytics: Tracks page visitation data using a client ID Google Analytics tracks Client number and internal IDs for the user and session.
  • BrightInfo: Tracks user activity on our webpages to provide more targeted content through advertising pop-ups.
  • Marketo: Tracks all individuals who visit Ntirety’s website to associate web visits with our automated marketing campaigns. Visitors IP addressed and other information are tracked by Marketo.
  • Pendo: Tracks page visitation data using a visitor ID. Pendo tracks customer number, customer name, user email, user name and internal IDs for the user and session.

By Using Tracking Software

We may use software designed to track responses to our advertisements, other promotional activity, and movement throughout our site (“Tracking Software”). Tracking Software includes software such as web beacons and software used by our advertising partners.

By Log Files

Our website gathers Statistical Information automatically and stores it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you.

WHERE DO WE KEEP YOUR INFORMATION?

Ntirety may store or access your personal information from any of our office locations, and therefore your personal information may be transferred, processed, or stored outside the jurisdiction in which it was collected. Where Ntirety must transfer your personal information from an EU member country to one of our office locations outside of the EU, Ntirety will ensure that the recipient is also GDPR compliant or otherwise certified under an approved alternative mechanism. If your personal information is governed by GDPR, and you wish to obtain further details regarding the physical location of your information, you may contact Ntirety’s Data Protection Officer at privacy@ntirety.com.

HOW DO WE USE YOUR INFORMATION?

Automatically Collected Information

We use Statistical Information automatically collected by our website servers to help us analyze Web traffic, improve the content of our website and improve your experience on our website. Statistical Information is also used to operate our hardware and software, diagnose problems and administer our website. We may use aggregate Statistical Information to modify the products and services we offer based on who is visiting our website and what they are purchasing.  Statistical Information alone will not enable us to identify a User personally.

Information Collected by Cookies

We use the information provided by cookies to change the way our website looks to Users, to keep Users logged in to certain areas of our website, to ensure continued connection to the Systems, and to collect demographic data about where Users go on our website and how they behave. Cookies used by our Systems are used to track and log activities on the Systems and our network for security, network maintenance and other related activities. Information about Users collected by cookies may be combined with Statistical Information collected from Tracking Software, User Contact Information collected from sales or support inquiries, and other additional information collected in order to identify a User personally.

Information Collected by Tracking Software

We use the information collected by Tracking Software to determine the effectiveness of our marketing programs, improve the functionality of our website, and to collect demographic data about where Users go on our website and how they behave. Tracking Software may collect information about Users that, when combined with other Statistical or User Contact Information we have collected, will enable us to identify Users personally.

Information Provided by Users for Communications

We use the User Contact Information provided by you to send you general information about Ntirety, details about our products and Services, publications related to our industry, and other promotional materials in which you have indicated an interest.  You may opt out of receiving any such promotional communications from Ntirety at any time by sending a request to newsletter-unsubscribe@ntirety.com, by using the unsubscribe instructions included in each promotional communication, or, if you are a Client, by changing your email preferences in the Client Portal.

Information Provided by Clients for Services

If you are a Client, we use your Client Information to establish our Services for you.  This includes creating and maintaining your Client Account and your choice of Services, contacting you for customer and technical support purposes, and processing payment for the Services. We may also create and maintain Client logs in the normal course of providing Services to you. While you may opt out of receiving promotional communications from Ntirety at any time, Clients may not opt out of receiving communications that are essential to your use of the Services, including communications from technical support, security and compliance, billing and account management, and system and network updates.

Payment Processing

Ntirety uses third party providers to provide credit card processing services through our online Client Portal. If you choose payment by credit card when you purchase our Services, we will share your Client Information as necessary for the third party processor to provide the payment processing services. Please be assured that these third parties are prohibited from using your personal information for any other purpose including their own marketing services. These companies are authorized to use your personal information only as necessary to provide their services to us.

In response to a Subpoena or Other Legal Demand for Information

Ntirety is required to comply with demands for information as required by state/provincial and federal law. Examples of these demands include subpoenas, warrants, and civil discovery demands. Information covered by our Privacy Notice may be disclosed following such a request if we determine, in our sole discretion, that such a disclosure is necessary or required. We may also disclose this information if (a) it is a matter or public safety or policy; (b) it is necessary to provide to a law enforcement agency when the contents are inadvertently obtained by Ntirety and appear to pertain to the commission of a crime; or (c) it is necessary or required to protect our interests or the interests of our other customers. We may not be able to notify you prior to any such disclosures.

CHILDREN’S PRIVACY

Ntirety does not sell products or services for purchase by children. Clients must be at least 18 years of age. If you have reason to believe that a child under the age of 18 has provided personal information to us without the consent of their parent or guardian, please contact us immediately, and we will endeavor to delete that information and terminate the child’s account from our databases.

THIRD PARTY VENDORS AND PROVIDERS

We offer certain products and services that are provided by third party vendors as a part of our Services, and we also use certain third party providers ourselves in the course of our business (such as auditors, communications providers, customer relationship management providers, marketing agencies, and social media providers). This includes third party widgets or other interactive mini-programs that run on our website that may set a cookie to enable that feature to function properly. These third parties may collect and use your information in ways that differ from those set out in this Privacy Notice.  We have no responsibility for how these third parties treat your information; however, if we have access to their privacy notices, we will provide them to you on your request.  If you choose to interact directly with any third party by clicking on a widget or feature on our website, your interactions will be governed by such third party’s own privacy policy.

If you are a Client, your Client Information will only be shared with third parties if it is necessary to provide the Services to you. Information in the Client Information related to payments, such as a User’s credit card number, is only used to ensure we receive payment for services rendered.  Your User Contact Information may be shared with third parties only to the minimum extent necessary for the third parties to provide their services, either to you or the Ntirety (as applicable). The third party vendors and providers that are incorporated as a part of our Services are not authorized to use any of your information for purposes beyond those specified by us, and they are required to preserve the confidentiality with which we treat such information.

TESTIMONIALS

Ntirety displays personal testimonials of satisfied Clients on our Website in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@ntirety.com. 

REFERRALS

If you choose to use our referral service to tell a friend about our website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website. Ntirety stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us at privacy@ntirety.com to request that we remove this information from our database.

BLOG

Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at privacy@ntirety.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. 

SURVEYS OR CONTESTS

From time-to-time, we may provide you the opportunity to participate in contests or surveys on our website. If you participate, we will request certain User Contact Information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code).  We use this information to notify contest winners and award prizes, to monitor website traffic or personalize the website (in the case of anonymous information collected in surveys), or to send participants an email newsletter.  We may use a third party service provider to conduct these surveys or contests, and that company will be prohibited from using our Users’ personal information for any other purpose including their own marketing. User Contact Information collected from surveys or contents is not shared with third parties in ways that identify Users personally. To the extent we share Survey Information with third parties, it is done in aggregate.

CHAT FUNCTION

Our website may allow for a chat function. Chat functions allow you to participate in “live” online conversations with us on our Website. Although the transcripts from the chats may be stored internally on in-house servers for our records only, we collect no personal information about you when you participate unless you choose to provide that information to us.

HOW CAN YOU ACCESS OR DELETE YOUR PERSONAL INFORMATION?

If you have consented to Ntirety processing your personal information by signing up for our newsletter or requesting a sales quote, but you are not a Client, you can withdraw your consent and request the deletion of your data at any time by emailing privacy@ntirety.com.

If you are a Client, you can access your personal information, such as your address and contact information, at any time to correct, change or delete any of the data shared with us when you became a Client. To access your personal information stored in your Client Account, please click on the “Log In” link on the header of the Website. Your account information is secure and is accessible by using a password that you select. If you need assistance or have questions about correcting information you can contact us via email at customers@ntirety.com. Ntirety will respond to access requests within 30 days.

Upon written request Ntirety will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at customers@ntirety.com.

DATA RETENTION AND SECURITY

Information collected by the technologies described in this Privacy Notice is protected by SSL 128 bit encryption technology during transmission. Information kept by us in our business is protected using industry standard security measures. Though we reserve the right to keep the information covered in this Privacy Notice indefinitely, our employees are required to keep this information confidential – unless disclosure is authorized in this Privacy Notice or by Users. No means of communication, information transmission, or storage is totally secure. Because of this we are not responsible for loss corruption or unauthorized acquisition and use of information covered by this Privacy Notice, or for any resulting damages, including unauthorized acquisition and use.

If you have any questions about security on our Website, you can send email us at privacy@ntirety.com.

CHANGES TO OUR POLICY

We reserve the right to modify this Privacy Notice at any time, so please review it frequently. If we make material changes to this Privacy Notice, we will notify you here on this webpage, by email, through the Client Portal, or by means of a prominent notice on the home page of our website.

LINKS

Our website provides links to other websites that may be maintained by companies that are not affiliates of ours. We are not responsible for the privacy practices or the content of such websites and we encourage you to use caution. In particular, we recommend that you view the privacy policy posted on each site to confirm the sites policies are acceptable to you. This Privacy Notice applies solely to information collected by this website.

CONTACT US

If you have questions or concerns regarding this Privacy Notice, you should contact us by email at privacy@ntirety.com. 

Ntirety, Inc.
2901 Via Fortuna, Suite 175
Austin, Texas 78746