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Inworks Privacy Policy

Updated January 22, 2019

Effective January 22, 2019, Inworks Servicing, LLC (“Inworks” or “we” or “us” or “our”) have updated our Privacy Policy (“Policy”).

PLEASE READ THIS POLICY CAREFULLY. IT IS YOUR CHOICE WHETHER OR NOT TO PROVIDE PERSONAL INFORMATION TO US. IF YOU CHOOSE TO DO SO, YOU ARE GIVING US YOUR EXPRESS CONSENT TO USE, PROCESS, AND DISCLOSE YOUR PERSONAL INFORMATION AS SET FORTH IN THIS POLICY. IF YOU CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION TO US, YOU MAY NOT BE ABLE TO USE OUR SERVICES.

1. Introduction

This Policy details our commitment to protecting the privacy of individuals who visit our Websites, who register to use our services, and who provide personal information to us online or offline. We explain what personal information we collect, how we use it, and other relevant information. We encourage you to read the summaries below and to click on “Learn More” if you would like more information on a particular topic.

2. Scope of This Policy

This Policy applies to the Websites that link to this Policy.

For the purposes of this Policy, the term “Websites” shall refer collectively to www.inworks.com and well as to the other websites that Inworks operates and that link to this Policy.

In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.

Personal information is required for us to be able to provide the services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to companies that help us to provide our services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use our services.

Our Websites may contain links to other websites, and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of such other websites to understand their information practices.

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of third parties. We encourage you to review each such third party's privacy statement and to otherwise understand its privacy practices, before providing personal information directly to it.

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3. Personal Information We Collect

We collect personal information to operate effectively and provide you with the best experiences with our services. You provide some of this information directly, such as when you create an account or contact us for support. We get some of the information, such as your IP address, by recording how you interact with our services. We may also get information about you from third parties.

Information That Your Provide To Us

We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and electronic payment information when you register for an account to access or when you use one or more of our services.

We ask for and may collect personal information from you when you start or submit web forms on our Websites, via email, or as you use interactive features of the Websites, request customer support, or otherwise communicate with us. This personal information may include non-text components such as images and videos.

Third party intermediaries are used to manage electronic payment processing. These intermediaries are not permitted to store, retain, or use your cardholder data for any purpose except for electronic payment processing on our behalf.

By voluntarily providing us with your personal information, you represent that the personal data is accurate and that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

Information That We Collect From You On Our Websites

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and services. In such case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use our Websites or our mobile applications to help us improve them. We may also share anonymous data about your actions on our Websites and our mobile applications with third party service providers of analytics services. We do not link analytics information to your personal information.

Information Collected From Other Sources

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third party authentication service if you log into our services through such a service or otherwise provide us with access to information from the service.

Any access that we may have to such information from a third party service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.

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4. How We Use Personal Information

We use the personal information we collect for a variety of purposes. We will retain personal information for as long as it is needed.

General Uses

We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to: (a) provide, operate, maintain, and improve our services and develop new services; (b) enable you to access and use our services; (c) process and complete transactions and send you related information; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) monitor and analyze trends, usage, and activities in connection with the Websites and services; (f) investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities; (g) personalize the Websites and services, including by providing features or advertisements that match your interests and preferences; and (h) for other purposes for which we obtain your consent, such as marketing communications. You can revoke your consent to receive marketing communications from us by following the unsubscribe instructions included in our marketing communications.

How Long We Retain Your Personal Information

We will retain your personal information for as long as is needed to fulfill the purposes set forth in this Policy, 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 it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

For personal information that we process on behalf of a client institution, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.

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5. Sharing Of Information Collected

We share your personal information as necessary to provide the services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.

To Provide the Services Your Request

Personal information is required for us to be able to provide the services to you. You are required to provide personal information in order to create an account with us. When you use our services to submit a form that we host for a client institution, the information you entered into that form will be disclosed to that client institution. In addition, please note that when you enter information into a form that we host for a client institution, the information you enter into that form will be disclosed to that client institution regardless of whether or not you ever complete the form and submit it. You may access a form that is “in progress” and modify the information you have entered into it by following the instructions on the form. After you submit the form, you will not be able to access or modify the information submitted on that form without assistance from Inworks. Once your personal information has been disclosed to a client institution, the privacy statements and information practices of that institution will govern the institution’s use of the information disclosed.

Third Party Service Providers

We share information, including personal information, with our third party service providers that we use to provide hosting for and maintenance of our Websites, application development, backup, storage, payment processing, analytics, and other services for us. These third party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third party service providers to use the personal information that we share with them for their marketing purposes or for any purpose other than in connection with the services they provide to us.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or Terms of Service, or as otherwise required by law.

With Your Consent

We share personal information with third parties when we have your consent to do so.

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6. Transfer of Information

Personal information we collect will be processed in the United States and possibly transferred to entities in other jurisdictions. BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU CONSENT TO ANY TRANSFER AND PROCESSING IN ACCORDANCE WITH THIS POLICY.

7. Your Privacy Rights

You have certain rights regarding your personal information, as set forth in this Policy and applicable law.

Right to Access and Right to Delete

If you provide us with personal information in connection with your use of our Websites or services, you have the right to access this information and the right to have this information deleted, subject to certain limitations. For some of our services, you have the ability to access, change, and delete the information in your account. Some of our services require you to contact us to request access or deletion.

We will not deny you access to your personal information unless applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. Notwithstanding a request to delete information, we may retain information for as long as you maintain an account for our services, as needed to provide you with the services you requested, to comply with our legal obligations, resolve disputes, and enforce our agreements.

To make a request to delete your personal information maintained by us, please contact us at privacy@inworks.com. We will respond to your request to delete your information within thirty (30) days. To protect your privacy and security, we may take steps to verify your identity before taking action on your request. Please note that we cannot change or delete information that you provided in a form that has already been submitted. If you want to update or delete information on such a form, you must contact the client institution to which the form was submitted.

If you request access to or deletion of personal information that we store and process on behalf of a client institution, we will direct you to submit your request to the client institution. Upon receipt of a request from one of our client institutions for us to provide or delete your personal information, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our client institutions for as long as needed to provide the services to our client institutions. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@inworks.com.

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8. Children’s Personal Information

We do not knowingly collect any personal information from children under the age of 18. If you are under the age of 18, please do not submit any personal information through our Websites or services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy.

9. Other Important Privacy Information

Below you will find additional privacy information you may find important.

Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information provided to us, both during transmission and once it is received.

Passwords

Your account information, if you create an account, is accessible online through the use of a password. To protect the confidentiality of personal information that you provide in connection with a user account, you must keep your password confidential and not disclose it to any other person. We are not responsible for the consequences of any passwords that you disclose or which are lost or stolen. Please advise us immediately if you believe your password has been misused or otherwise misappropriated.

Cookies

We may use cookies, Web beacons, or other technologies to identify users, to collect information about their preferences and history, and to customize their experiences. We use cookies to prevent you from having to repeatedly enter your login information, to save searches temporarily, to administer our Websites and help us understand how visitors use them, and to improve our Websites and our services.

We may use third parties, including network advertisers and other third party ad servers, to deliver ads or other functionality to you. These third parties may use cookies, Web beacons, or other technology to collect information about your visits to our Websites and may use that information to present news and advertisements that may be of interest to you (including while you are no longer on our Websites) or to integrate with social networking sites. This Policy does not apply to, and we are not responsible for, cookies, Web beacons, or similar technologies in third party services, and we encourage you to check the privacy policies of such third parties to learn about their use of cookies and other technology.

You may refuse to accept cookies by following the procedures specific to your Web browser. If you do so, your browser may react strangely, and you may not be able to complete, save, or submit a form or use some services on our Websites.

P3P

Some of our Websites may support the Platform for Privacy Preferences ("P3P"). P3P allows website operators to convey their privacy policies, to the extent possible, in standardized, machine-readable code. This allows P3P-enabled browsers like Internet Explorer to "interpret" the code and automatically compare it to privacy preferences selected by the user in the browser's settings. In some cases, users may not have selected privacy preferences but instead rely on the default settings in the browser. A P3P-enabled browser automatically informs the user if the website's privacy practices do not meet the browser's settings. The user may use this information to decide whether or not to view the website.

Even if our Website supports P3P, the resulting code does not convey all of our privacy practices. There are certain inherent limitations in trying to explain human concepts about privacy in machine-readable code. For example, P3P is not capable of coding policies with regard to the collection of children's information and parental consent. Moreover, different browsers may interpret our P3P code in different and, at times, conflicting ways. Because of these limitations, P3P does not fully, and may not accurately express all of our data practices. Accordingly, P3P results obtained through use of your browser should only be considered as a shorthand expression of our privacy practices, whereas this Policy is the primary source of information and will take precedence over P3P for all purposes.

Business Transactions

We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.

Statement Changes

We will modify this Policy if our privacy practices materially change in the future. We will notify you of any such modification by posting the modified Policy on our Websites and indicating at the top of the Policy the date it was last updated. We may also notify you of modification or changes by sending you an email or other notification. We encourage you to review the Policy each time you visit one of our Websites, to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.

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10. Contact Us

If you have questions regarding this Policy or about our privacy practices, please contact us by email at privacy@inworks.com

Inworks Servicing, LLC
Attn: Privacy Officer
805 SW Broadway, Suite 1600
Portland, Oregon 97205
United States

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