What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, phone number, credit card information or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, place an order, subscribe to a newsletter, open a Support Ticket or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To allow us to better service you in responding to your customer service requests.
- To quickly process your transactions.
- To send periodic emails regarding your order or other products and services.
- To follow up with them after correspondence (live chat, email or phone inquiries)
How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
What personal Identifiable Information do we collect and why?
ITR collects Personal Identifiable information (PII) data from clients as needed. This information includes contact information: name, address, phone, and email, payment information, and computer IP addresses. This information is collected and needed so that we can maintain a business professional relationship with our clients. For a more in-depth definition of what is collected, the types, why and the sensitivity classification please see the 'Categorize all PII data' section.
How do we permanently erase your information completely and accurately?
- Customer Care will receive notification by email or phone with the request from a customer to delete their PII data. Once the request has been received, ITR will notify internally all parties necessary of the request and all internal parties will cease using their personal data.
- A confirmation email is sent to client (see template) confirming the removal process from all databases (internal and third party) their data is stored at has begun.
- Customer Care will notify IT of request and together they will locate all inhouse PII data.
- The following internal databases will be searched; CRMs, ITR website, and accounting softwares.
- Upon finding PII in our database from the said user, the information will be deleted permanently from our databases. No retrieval of information will be possible. The request is final and not reversible.
- ITR can provide records of deletion via logs upon request.
- IT will notify our 3rd party vendors with what information must be deleted from their databases. Confirmation of deletion from 3rd party vendors is required to authenticate the successful removal of PII from their inventory per the user's request. Written communication to ITR will suffice due to the agreements in place between ITR and the 3rd party vendor with the additional clause stating they are GDPR compliant.
- Once completed an email is sent to client confirming removal of all PII data from location data is being used (see template).
- All employees will be required to take the GDPR course through ITR's Learning Management System annually to educate them on the proper policy.
Do we use 'cookies'?
- Help remember and process the items in the shopping cart.
- Understand and save user's preferences for future visits.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If users disable cookies in their browser:
If you turn cookies off, some of the features that make your site experience more efficient may not function properly.Some of the features, like logging in, may not function properly.
- Remember whether a user is logged in
- Google Analytics (also GetResponse which uses Analytics) to keep track of a user as they browse
- Adaptive image is an image resizing plugin for responsive images, the cookie keeps track of screen resolution and expires after session close
- Login history is a plugin we use and the cookie is likely similar to analytics where it keeps track of the user as they browse. I also noticed that it logs the user's IP, which we will need to anonymize for the GDPR
- DataCast sends user data such as ID, Email, Username, roles from our website to DataCast server in order to validate user and provide features such as completion email. It also stores ASP.NET session data. Both of these are encrypted, I cannot see them.
- Drupal uses a cookie, has_js to store whether the user is using JS or not (most likely to save on load times if they don't). This expires on session
- Hotjar stores several session cookies that I found, which isn't even the full scope. More about that here: https://www.hotjar.com/legal/policies/cookie-information
- Twitter gathers information from our widget in the footer. Information on that can be found: https://twitter.com/en/privacy
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Freshdesk Chat & Authorize.net Support Sites
- Freshdesk GDPR Complience - https://freshdesk.com/gdpr
We do not include or offer third-party products or services on our website.
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have implemented the following:
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) to compile data regarding user interactions with page views and other information as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- You can change your personal information: By logging in to your account
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It's also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify you via email within 7 business days
- We will notify the users via in-site notification within 7 business days
- We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to your product and/or service
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at
- Follow the instructions at the bottom of each email to be removed from that mailing list.
77 Sundial Ave
Manchester, New Hampshire 03103
Last Edited on 2017-10-04