EU-U.S.

Ineo, LLC (“Ineo”, “we”, “us”) complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Ineo has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Ineo has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

This Notice explains our data practices and commitments in connection with our customer’s data and for business contact data.

Information Management Practices

Ineo collects personal data from a variety of sources, including through our website. This personal data may include names, postal addresses, email addresses, financial information, and other details relevant to the services we provide. We may obtain personal data directly from customers, or indirectly from business partners or other third parties. In addition, certain information that incorporates personal data may be developed as a function of providing a product or service to a customer. Ineo processes its personal data for purposes of providing a product or service or communicating with its customers or potential customers regarding its offerings.

We limit the collection and use of personal data about our customers to that which is necessary to administer our business and provide superior service. We may disclose personal data to our service providers, business partners, and others who assist us in providing our products and services. Ineo may be liable with respect to the onward transfer to third parties of EU, UK (including Gibraltar) and Swiss data subjects’ personal data received pursuant to the EU-U.S. DPF, UK extension to the EU-U.S. DPF, and Swiss-U.S. DPF.

Please note that in certain situations Ineo may be required to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Security

We are committed to the security of our customers’ personal data and financial information. Our operational and data processing systems are maintained in a secure environment, with appropriate administrative, technical, and physical safeguards to protect the personal data we maintain from unauthorized access.

Your Access and Limitation Rights

EU, UK and Swiss data subjects have the right to access personal data maintained about them and to impose certain limits on the use and disclosure of such personal data. Ineo has committed to uphold these Data Privacy Framework Principles, but our ability to access certain personal data of individuals directly may be restricted depending on our services. We do not share personal data with unaffiliated third parties. If we were to share personal data in this manner, we would provide EU, UK (including Gibraltar) and Swiss data subjects with appropriate means to opt out of such sharing as required by law, and will request opt-in consent prior to using EU, UK (including Gibraltar) or Swiss personal data for a purpose other than the purpose for which it was originally collected.

If you wish to access your personal data or make a request regarding the use or disclosure of your personal data, please contact us using the contact information below.

Questions, Complaints, Recourse, and Contact Information

EU-U.S. DPF, UK Extension or Swiss-U.S. DPF Complaints

In compliance with the EU-U.S. DPF Principles, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, Ineo commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles.  European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Ineo at: Privacy@ineomobility.com, by phone at (303)308-1801, or by postal mail sent to:

Ineo, LLC
Attn: DATA PRIVACY FRAMEWORK INQUIRY
7340 E. Caley Ave.
Suite 350
Centennial, CO 80111
USA

Ineo has further committed to refer unresolved privacy complaints under the Data Privacy Framework program to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers  for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction

Jurisdiction

The Federal Trade Commission has jurisdiction over Ineo’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.