Privacy Notice

Personal information you disclose to us. We collect personal information that you voluntarily provide when you express interest in obtaining information about us, our products, and our Services, or when you otherwise contact us.

The personal information we collect may include:

• Names
• Email addresses

Sensitive information. We do not process sensitive personal information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected. This website does not use cookies, analytics tracking, or other automated data collection technologies. We do not automatically collect any information about your device, browsing behavior, or usage patterns when you visit our website.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To respond to inquiries and provide support. We process your information to respond to your requests, questions, and communications regarding our products and Services.
• To send administrative and marketing communications. We may use your information to send you information about our products, Services, and events that may be of interest to you.
• To fulfill contractual obligations. We may process your information as necessary to perform our obligations under any contracts entered into with you.
• To comply with legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as responding to lawful requests and court orders.
• To protect our interests and prevent fraud. We may process your information as necessary to protect our legitimate business interests and to detect and prevent fraudulent or illegal activity.

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law. Depending on the circumstances, we may rely on the following legal bases:

• Consent. We may process your information if you have given us express permission to use your personal information for a specific purpose. You may withdraw your consent at any time.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your rights and freedoms.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Contractual obligations. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.

We may share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Sub-processors. We may share your information with third-party sub-processors who perform services on our behalf. For a current list of our sub-processors, please visit our Sub-Processors page.
• Legal requirements. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal process.

We do not sell your personal information to third parties. We do not share your personal information with third parties for their direct marketing purposes.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information. If deletion is not immediately possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include encryption, access controls, and secure infrastructure practices.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@itva.com.

Depending on your state of residence in the United States, you may have certain rights regarding your personal information, including:

• Right to access. You may have the right to request access to the personal information we collect from you, including details about the nature, processing, and disclosure of that information.
• Right to rectification. You may have the right to request that we correct any inaccurate personal information we maintain about you.
• Right to erasure. You may have the right to request that we delete your personal information, subject to certain exceptions provided by law.
• Right to withdraw consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

If you have questions or comments about your privacy rights, please email us at legal@itva.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

California law requires us to inform you how we respond to web browser DNT signals. Because no industry or legal standard currently exists for recognizing or honoring DNT signals, we do not respond to them at this time. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

If you are a resident of certain U.S. states, including but not limited to California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia, you may have additional rights regarding your personal information under applicable state privacy laws.

Your Rights

Depending on your state, you may have the right to:

• Access, correct, delete, or obtain a portable copy of your personal data
• Opt out of targeted advertising, the sale of your personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects
• Limit the use and disclosure of your sensitive personal information

How to Exercise Your Rights

You may submit a data subject access request by emailing us at legal@itva.com. We may request specific information from you to help us confirm your identity and process your request. You may also designate an authorized agent to submit a request on your behalf, provided we receive proper verification of authorization.

Appeals

If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please email us at legal@itva.com. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

Under California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents may request information regarding the disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

Yes, we will update this Privacy Notice as needed to stay compliant with relevant laws. The updated version will be indicated by a revised “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to stay informed about how we are protecting your information.

If you have questions or comments about this notice, you may email us at legal@itva.com or contact us by mail at:

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To submit a data subject access request, please contact us at legal@itva.com. We will respond to your request in accordance with applicable data protection laws.