Last Updated: July 10, 2023.
For purposes of data protection laws, International Training and Exchange, Inc., 600 California Street, 10th Floor, San Francisco, CA 94108, is the “data controller” of your information.
The information we collect may include data you explicitly provide to us, data we obtain automatically from your interactions with our Services, and data we obtain from other sources.
a. Information You Provide Us
We may collect information directly from you when you complete an Information Request form, register for a public event, initiate an Intrax program application, or otherwise communicate or interact with us. The types of information we may collect from you directly include:
Calls/Electronic Communications. In the regular course of our business, Intrax may monitor and record phone conversations or email communications between you and Intrax employees for training and quality assurance purposes. We may receive a confirmation when you open or click on content in an email from us, which helps us make our communications to you more useful and interesting.
b. Information We Collect Automatically
Log Data. When you use the Services, we may collect information such as your Internet Protocol (IP) address and/or domain, the type and version of your Internet browser software and operating system you use, the date, time, and duration of your use of the Services, the specific pages, buttons, images, links, and forms that you access while visiting the Services, the type of device you use to access the Services, and your mobile carrier and/or internet service provider.
We may also embed web beacons, tags, and pixels in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email.
Location Information. When you use the Service, we may collect general location information (such as general location inferred from an IP address).
c. Information We Collect from Third Parties
We may gather information, including background check information, from third parties, such as business partners, marketers, researchers, and analysts. We may also receive information about you if you are referred by another user. We use this information to improve our records, support administrative operations or market Intrax and the Services.
Generally, information you provide to us will be used to provide the Services or to help us deliver a better website experience to you on all our websites and to enhance our business efficiency and effectiveness with you. We may also use your personal information to:
We may combine information that we collect from you through the Services with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.
We may disclose your personal information as follows:
We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information We Collect Automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page.
Do Not Track. We do not recognize or respond to browser initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control browser choice referenced below.
Marketing emails: at any time, you can tell us to stop sending you promotional communications for one, several or all of our Intrax programs by (a) utilizing the opt-out or unsubscribe links found in the trailer of email messages, newsletters and other electronic forms of communication, (b) logging in to your personal account with us and change your privacy settings to your desired level of communication, or (c) contacting us using the information in the “Contact Us” section below. After you have told us to stop communicating with you, certain actions you take may be interpreted by us as a change to this request. For example, if you subsequently visit an Intrax website and take some action that re-initiates contact with us, we will assume that you have changed your mind and are again interested in one or more Intrax website program(s) and/or service(s). When you do this, we may initiate various website and off-website forms of communication with you. Generally, you may not opt-out of service-related or transactional communications, which are not promotional.
Text messages: If you are receiving text messages from us and wish to opt out of these messages, you may do so by replying “STOP” to the message. You acknowledge that our text message platform may not recognize and respond to unsubscribe requests that do not include the STOP keyword command and agree that Intrax and its service providers will have no liability for failing to honor such requests. If you unsubscribe from one of our text message programs, you may continue to receive text messages from Intrax through any other programs you have joined until you separately unsubscribe from those programs.
Cookies: Most web browsers are set to accept Cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. The method for disabling Cookies may vary by device and browser but can usually be found in your device or browser preferences or security settings. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Portal.
Online Advertising Networks: You may opt out of receiving targeted ads based on the information we collect from you by following the instructions in the “Advertising & Analytics” section above.
Google Analytics: To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
Applicable law (such as the Virginia Consumer Data Protection Act (“VCDPA")) may give you various rights regarding your information. If these rights apply to you, they may permit you to request that we:
You can exercise those rights by submitting a Data Subject Access Request or emailing us using the information in the “Contact Us” section below. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services. You will be required to verify your identity before we fulfill your request.
Applicable law may also permit you to appeal any denials of your rights requests; to do so, contact us at using the information in the “Contact Us” section below and describe in detail why you believe the denial was in error. Your description must include your full name and the email address to obtain the Services from us, along with a copy of the denial notice you received from us.
You may also have the right to opt out of the use of your information for targeted advertising. Targeted advertising (as defined by applicable law) is advertising based on a consumer’s personal data obtained from the consumer’s activity across websites to predict the consumer’s preferences or interests. To opt out of targeted advertising, please visit this link: Do Not Sell or Share My Personal Information.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
Our legal grounds for processing your information are as follows:
If you’re a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties to whom we disclose personal information.
Throughout this Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the "categories" of personal information and sensitive personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by applicable law). The categories of personal information are identifiers (such as name, address, and email address); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address and browsing history); geolocation information (general location); inference data about you; audio and visual information (such as when you speak with a program advisor); professional or employment related data; education data; inference data about you; legally protected classifications (such as gender); insurance (including health insurance) information; and other information that identifies or can be reasonably associated with you. The categories of sensitive personal information are account log-in and password, financial data, or other credentials allowing access to your account, as well as health information.
We or our service providers collect and disclose the above categories of personal information for the purposes described in our Policy. This includes the following business and commercial purposes (as those terms are defined in applicable law):
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) third parties such as other users and analytics or attribution partners.
We describe our information disclosure practices in the Policy above. We may disclose certain categories of personal information to third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose your name, contact information, financial information, and professional and employment information to your host family, school, or US employer, depending on which program you are participating in.
Rights of California Consumers
If you’re a California resident, you may have certain rights. California law may permit you to request that we:
You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Service to you. If you ask us to delete it, you may no longer be able to access or use the Service.
If would like to exercise any of these rights, please submit a request by submitting a Data Subject Access Request or emailing us at email@example.com or calling 1-800-777-7766. You will be required to verify your identity before we fulfill your request. To do so, you will be required to provide us with your name, email address, and Intrax ID. We may request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
The CCPA requires businesses that “sell” personal information, as the term “sell” is defined under the CCPA, to provide an opt-out from such sales. Some people have taken the position that when a website uses third parties’ cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. As part of these analytics and advertising services, these technologies may access identifiers (like IP addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Services), and commercial information (like the fact that a browser visited a page directed to people who are considering the use of our Services) to those sorts of companies. While Intrax does not believe these are “sales” as that term is defined under the CCPA, you can opt out of this activity. You can opt out of these activities by visiting this link: Do Not Sell or Share My Personal Information.
The CCPA also requires businesses that "share“ personal information to provide an opt out from such sharing. Under the CCPA,” sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites. We “share” information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may "share“ identifiers (like IP addresses and email addresses), internet or other electronic network activity information (like information regarding an individual’s browsing interactions on our Site), and commercial information (like the fact that a browser visited a page directed to people who are considering a beauty purchase) with advertising platforms and advertising networks. To opt out of such “sharing,” please visit this link: Do Not Sell or Share My Personal Information.
Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.
We do not knowingly “sell” or “share” the personal information of children under 16.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.
Retention of Your Personal Information
Please see the “Data Retention” section below.
Notice of Financial Incentive
We provide certain rewards or incentives for providing your email address, referring friends and contacts, or leaving a review, and may occasionally run sweepstakes and contests where participants may provide personal information in return for a chance to win or compete to win certain prizes. You can opt into these incentives, sweepstakes, or contests by taking the requested action. Your participation is completely voluntary, and you have a right to withdraw from these incentives at any time. If you decide you don’t want to participate in these financial incentives, you can refrain from taking the requested actions.
The specific reward or incentive offered, if any, is made available to you when you provide the information requested or submit a review. The monetary value of the reward or incentive is a reasonable approximation of the monetary value of the information you provide us. We have arrived at this estimate based on consideration of multiple factors, including the following: (1) revenue generated by Intrax in developing insights on our customers; (2) expenses incurred by Intrax in operating the incentives; and (3) our reasonable assessment of revenue we may generate as a result of the referrals provided to us by our customers.
Shine the Light
Under California Civil Code Section 1798.83 (also known as the “Shine the Light” law), users who are residents of California may request information regarding the disclosure of our personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us using the information in Section 16 below.
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to another person. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the information in the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
In general, Intrax will retain collected information for the length of time needed to fulfill the purposes outlined in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is permitted by law.
Intrax maintains administrative, technical, and physical safeguards that are designed to protect the security of personal information. The safeguards include tools and technologies including firewalls, data encryption techniques, passwords and security certificates. In addition, Intrax uses security protocols and security processes, such as periodic monitoring of our infrastructure and servers, implementation of physical access restrictions, and authorization controls for information access. Intrax allows internal users to use data on as needed basis to ensure a high level of information security.
However, no security measures are perfect, so we cannot ensure or warranty the security of any information transmitted to or generated by Intrax in connection with the Services. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.
Only persons 13 years of age or older may use the Services. We do not knowingly collect personal information from individuals under 13 years of age. If we discover that an individual under 13 has provided us with personal information, we will delete the personal information to the extent required by law.
Intrax operates as a global business. Therefore, information that you provide to us may be transferred to countries outside of the country in which you live, which may not offer a level of protection equivalent to that required by your jurisdiction.
Where required, we will use appropriate safeguards for transferring data outside of your jurisdiction. This includes signing Standard Contractual Clauses that govern the transfers of such data, which may be used in conjunction with additional safeguards. For more information about these transfer mechanisms, please contact us as detailed in the “Contact us” section below.
We may change this Policy to reflect changes in the law, our information practices, or the features of the Services. At the top of our Policy, we will indicate the date of the most recent update. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.
Please address any questions, concerns or comments you have about this policy to:
mail: Intrax, Inc.
Attn: Privacy Officer
600 California Street, 10th Floor
San Francisco, California 94108
United States of America
To contact Intrax’s Data Protection Officer with any question or complaints, please use the following email address: DPO@intraxinc.com.