PRIVACY POLICY AND NOTICE

Last modified: November 6, 2023

1.Introduction

ITMH Corp. (“ITMH”) respects your privacy and is committed to protecting it through ITMH’s compliance with this ITMH Privacy Policy and Notice (the “Policy” or “Privacy Policy”).

This Policy describes the types of information ITMH may collect from you or that you may provide when you visit or use, whether as a guest or a registered use www.itmhcorp.com and any other ITMH website or client portal related to ITMH (collectively, the “Websites”), ITMH’s LU application and any other ITMH mobile or desktop apps (the “Apps”), and any content, data, information, functionality, technology solutions and services offered on or through the Websites or Apps (collectively, the “Services”), and ITMH’s practices for collecting, using, maintaining, protecting, and disclosing that information. The Websites, Apps and Services are collectively referred to as the “Platform.” Capitalized terms not defined in this Privacy Policy shall have the meanings attributed to them in the ITMH Platform Terms of Use located at www.itmhcorp-terms-of-use

This Policy applies to information ITMH collects:

On the Platform.
In email, text, and other electronic messages, contacts, or calls between you, ITMH, and/or the Platform.
When you interact with ITMH’s advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
Through the provision of ITMH Services.

It does not apply to information collected by any third party that gets access to the information, including through any application or content (including advertising) that may link to or be accessible from, on or through the Platform or any information you provide to or is collected by any third party, including any organizations.

Please read this Policy carefully to understand ITMH’s policies and practices regarding your information and how ITMH will treat it. If you do not agree with this Policy, your choice is not to use the Platform or ITMH’s Services. By accessing or using this Platform you agree to this Privacy Policy. This Policy may change from time to time (see Changes to the ITMH Privacy Policy below). Your continued use of the Platform and after ITMH makes changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2.Children Under the Age of 16

The Platform is not intended for individuals under 16 years of age. No one under age 16 may provide any information to or on the Platform. ITMH does not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Platform, or through any of its features, register on the Platform, or provide any information about yourself to ITMH, including your name, address, telephone number, email address, or any screen name or username you may use. If ITMH learns that it has collected or received personal information from a child under 16 without verification of parental consent, ITMH will delete that information. If you believe ITMH might have any information from or about a child under 16, please contact us by sending an email to support@itmhcorp.com.

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights section below for more information.

3.Information ITMH Collects About You and How ITMH Collects It

ITMH collects several types of information from and about users of the Platform:

Directly from you when you provide it to ITMH, including as part of the Services.
Automatically when you visit or use any portions of the Platform.

Information You Provide to ITMH

When you register with or use the Platform, including the Services, ITMH may ask that you provide information:

By which you may be personally identified, such as name, postal address, e-mail address, telephone number, age, gender, online profile (such as LinkedIn, Facebook, VK, OK, Yandex etc.), photos, media, or other identifier by which you may be contacted online or offline (“personal information”).
That is about you but individually does not identify you.

The information ITMH collects on or through the Platform, including the Services, may include:

Information that you provide by filling in forms on the Platform or submitting requests or questions. This includes information provided at the time of registering to use the Platform, subscribing to any service, posting material, and requesting further services. ITMH may also ask you for information when you enter a promotion sponsored by ITMH, and when you report a problem with the Platform.
Records and copies of your correspondence (including email addresses and phone numbers) if you contact ITMH.
Records of your requests or questions submitted through the Platform as part of the Services.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the Platform.
Your search queries on the Platform.
Other information you provide to ITMH as part of the Services.
Access to media (photos and videos on the device).

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, ITMH cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, ITMH cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information ITMH Collects Through Automatic Data Collection Technologies

When you access, use, navigate through and interact with portions of the Platform, ITMH may use technology to automatically collect:

Usage Details. When you access and use the Platform, ITMH may automatically collect certain details of your access to and use of the Platform, including location data, logs, and other communication data and the resources that you access and use on or through the Platform.
Device Information. ITMH may collect information about your mobile device, computer and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, device name, operating system version, configuration of your device when utilizing the Services, the device’s telephone number, the time and date of your use of the Services, and other information.

If you do not want ITMH to collect this information do not visit or use the Platform.

The technologies ITMH uses for this automatic data collection may include:

Cookies (or mobile/browser cookies). A cookie is a small file placed on the hard drive of your computer or other device. You may be able to refuse to accept mobile or browser cookies by activating the appropriate setting on your device or browser. However, if you select this setting, you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, ITMH’s system will issue cookies when you direct your browser to the Platform.
Local Storage Objects. ITMH may elect to use Local Storage Objects (LSOs) such as HTML5 to store blog user preferences and information such as email address.
Social Media Widgets. The Platform includes social media features, such as the Facebook “Like” button, and other widgets, such as the “Share” button or interactive mini programs provided by third parties. These third parties collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. You can control your interactions with these widgets through the relevant social media network.
Google Analytics. We use a tool called “Google Analytics” to collect some information we listed above about your use of the Platform. We use the information we get from Google Analytics to improve the Platform. In order to collect this information, Google Analytics may set cookies on your browser or mobile device or read cookies that are already there. See “Cookies” and Other Tracking Technologies.” Google Analytics may also receive information about you from apps you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Platform to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here https://tools.google.com/dlpage/gaoptout/.
Firebase Storage and Crashlytics. ITMH uses Firebase Database and Storage for storing application and user data and content, and Firebase Crashlytics as a real time crash reporter that helps us track, prioritize, and fix stability issues that erode app quality.

ITMH does not collect personal information automatically, but ITMH may tie this information to personal information about you that ITMH collects from other sources or that you provide to ITMH.

4.Third-Party Use of Cookies and Other Tracking Technologies

When you use the Platform, or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

Advertisers, ad networks, and ad servers.
Analytics companies.
Your mobile device manufacturer.

The applicable payment processor, including credit card companies, Apple Pay, Google Play, etc.

ITMH may also partner with other third parties to either display advertising on the Platform or to manage ITMH’s advertising on other websites. ITMH’s third-party partners may use technologies such as cookies to gather information about your activities on the Platform in order to provide you advertising based upon your browsing activities and interests. If you wish not to have this information used for interest-based ads, you may opt-out by sending an email to support@itmhcorp.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different platforms, apps, and other online services platforms. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

ITMH does not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see below.

Below are some of the third-party providers that may be used and links to their privacy policies:

Google Play. ITMH uses Google Play to provide access to the content of the App on Android-certified devices. https://policies.google.com/privacy?hl=en.
Google Analytics. ITMH uses Google Analytics for collection, storage and processing of user data and their actions in the App. https://developer.apple.com/app-store/app-privacy-details/.
Apple Pay and Google Pay. ITMH works with Apple Pay and Google Pay to process payments. By accessing or using the Platform, You expressly agree to and grant Apple Pay and Google Pay the right to use Your personal information in accordance with the privacy policies located at https://www.apple.com/legal/applepayments/privacy-notice/and https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB

5.How ITMH Uses Your Information

ITMH uses information that ITMH collects about you or that you provide to ITMH, including any personal information:

To provide you with the Platform, and its contents, and any other information, products or other Services that you request from ITMH.
For analytics purposes related to compensation programs and trends.
To carry out ITMH’s obligations and enforce ITMH’s rights arising from any contracts entered into between you and ITMH, including for billing and collection.
To notify you about changes to the Platform or any Services ITMH offers or provides though it.
To allow you to participate in interactive features on the Platform.
To understand and set your communication preferences.
To analyze the User’s behavior, as well as identify the User’s preferences for a certain type of content.
For the prompt and correct operation of the Platform, improving the functioning of the Platform, improving the content of the Platform, improving the internal architecture and functionality of the Platform, providing technical support
To identify the User.
To send personalized advertising and marketing materials to the specified email address and/or mobile phone of the User.
To comply with legal requirements.
To track orders/purchases made by the User through the Platform.
To conduct statistical research.
In any other way ITMH may describe when you provide the information.
To fulfill any other purpose for which you provide it.
For any other purpose with your consent.

The information ITMH collects helps ITMH to improve the Platform and to deliver a better and more personalized service, including by enabling ITMH to:

Estimate ITMH’s audience size and usage patterns.
Store information about your preferences, allowing ITMH to customize the Platform according to your individual interests.
Speed up your searches.
Recognize you when you return to the Platform.

ITMH may also use your information to contact you about ITMH’s own and third parties’ goods and services that may be of interest to you. If you do not want ITMH to use your information in this way, please send an email to ITMH at support@itmhcorp.com. For more information, see below.

ITMH may use the information it has collected from you to enable ITMH to display advertisements to ITMH’s advertisers’ target audiences. Even though ITMH does not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

6.Is Your Information Transferred Internationally?

The ITMH servers are located in the United States. If you are accessing the Platform, including the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information as set forth in this Privacy Policy.

7.Disclosure of Your Information

ITMH may share Your personal information with service providers that perform services for ITMH that are necessary for the orderly operation of the Platform, such as providing marketing assistance, analyzing User Content, and processing payment card information Personal information handled by these service providers is subject to their terms and privacy policies. Please review the service provider’s terms and privacy policies to better understand how they manage your data.

ITMH may also disclose personal information that ITMH collects, or you provide, as described in this Privacy Policy:

To ITMH’s subsidiaries and affiliates.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ITMH’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ITMH about Platform users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How ITMH Uses and Discloses Your Information below.
To fulfill the purpose for which you provide it. For example, if you give ITMH an email address to use the “email a friend” feature of the Platform, ITMH will transmit the contents of that email and your email address to the recipients.
For any other purpose disclosed by ITMH when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply the Platform Terms of Use at https://www.itmhcorp.com/terms-of-use, the Terms of Service at https://www.itmhcorp.com/terms-of-service, and other agreements, including for billing and collection purposes.
If ITMH believes disclosure is necessary or appropriate to protect the rights, property, or safety of ITMH, ITMH’s customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

8.Choices About How ITMH Uses and Discloses Your Information

ITMH strives to provide you with choices regarding the personal information you provide to ITMH. This section describes mechanisms ITMH provides for you to control certain uses and disclosures of your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, or block use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the Platform to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Platform may become inaccessible or not function properly.
Promotion by ITMH. If you do not want ITMH to use your email address or other contact information to promote ITMH’s own or third parties’ products or services, you can opt-out by sending an email stating your request to support@itmhcorp.com.
Targeted Advertising by ITMH. If you do not want ITMH to use information that we collect or that you provide to ITMH to deliver advertisements according to ITMH’s advertisers’ target-audience preferences, you can opt-out by sending ITMH an email stating your request to support@itmhcorp.com.
Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending us an email stating your request to support@itmhcorp.com.

ITMH does not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads or cookies from members of the Network Advertising Initiative (“NAI”) on the NAI’s opt out page http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance website (http://www.aboutads.info/choices/), or if you are in the EU, the EDAA (http://www.youronlinechoices.eu/).

Advertising platforms. To edit your information and ad preferences on major marketing platforms, you will need to visit each platform.

California, Colorado, Connecticut, Utah, Virginia residents, and residents of other countries may have additional personal information rights and choices. Please see below for more information.

9.Accessing and Correcting Your Information

You can review and change your personal information by logging into the Platform and visiting your account profile page, if applicable.

You may also send ITMH an email to support@itmhcorp.com to request access to, correct or delete any personal information that you have provided to ITMH. ITMH cannot delete your personal information except by also deleting your user account. ITMH may not accommodate a request to change information if ITMH believes the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by the Platform Terms of Use located at https://www.ITMH.com/platform-terms-of-use.

Residents of some states and countries may have additional personal information rights and choices. Please below for more information.

10.Your California Privacy Rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law may permit Users who are California residents to request and obtain from ITMH, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below. The California Code of Regulations defines a “residents” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a business purpose;

the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, ITMH is not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

We will not discriminate against you if you exercise your privacy rights.

We do not process consumer's sensitive personal information.

Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights.

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

You can opt out from the selling or sharing of your personal information as otherwise set forth in the Privacy Policy or on the Platform.

To exercise these rights, you can contact us by submitting a data subject access request, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11.Rights of Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email support@itmhcorp.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@itmhcorp.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

12.Rights of Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email support@itmhcorp.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at support@itmhcorp.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

13.Rights of Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data.

Right to access your personal data.

Right to request deletion of your personal data.

Right to obtain a copy of the personal data you previously shared with us.

Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data or targeted advertising by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email support@itmhcorp.com or submit a data subject access request.

14.Rights of Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. Your rights with respect to your personal data.

Right to be informed whether or not we are processing your personal data.

Right to access your personal data.

Right to correct inaccuracies in your personal data.

Right to request deletion of your personal data.

Right to obtain a copy of the personal data you previously shared with us.

We sell personal data to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.

Exercise your rights provided under the Virginia VCDPA

You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email support@itmhcorp.com or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at support@itmhcorp.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

15.Rights of Residents in the European Union (EU), UK

If you use the Platform and reside in the EU or UK, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply. To exercise these rights please contact ITMH at support. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. In the event that we refuse a request under rights of access, we will provide you a reason as to why.

The right to access: You have the right to ask ITMH for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process. When making a request, please provide an accurate description of the data you want access to.
The right to rectification: You have the right to ask ITMH to rectify information you think is inaccurate. You also have the right to ask ITMH to complete information you think is incomplete.
The right to erasure: You have the right to ask ITMH to erase your personal information in certain circumstances, including (i) when your personal information is no longer necessary for the purposes for which it was collected or processed or (ii) your information must be erased to comply with a legal obligation in EU Union or Member State law.
The right to restrict processing: You have the right to ask ITMH to restrict the processing of your information in certain circumstances, including (i) when the accuracy of the information is brought into question or (ii) when we no longer need the information for purposes of the processing but you require such information for the establishment, exercise, or defense of a legal claim. See “choices about your information” for some ways you can restrict processing.
The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in ITMH’s legitimate interests. See “choices about your information” for some ways you can object to processing.
The right to data portability: This only applies to information you have given ITMH. You have the right to ask that we transfer the information you gave ITMH from one organization to another, or give it to you.
The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

16.Rights of Canadian Residents

If you are located in Canada, we may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

For investigations and fraud detection and prevention.

For business transactions provided certain conditions are met.

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

If the collection is solely for journalistic, artistic, or literary purposes.

If the information is publicly available and is specified by the regulations.

17.Residents of Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Policy and Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

offer you the products or services that you want

respond to or help with your requests

manage your account with us

confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us as set forth in this Privacy Policy.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

18.Residents of the Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us as set forth in this Privacy Policy.

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

19.How Long Do We Keep Your Information

Unless otherwise requested in writing, ITMH will retain your personal information until the later of (i) the information is no longer necessary to accomplish the purpose for which it was provided, (ii) there is no ongoing business reason to keep the information, or (iii) until you request that your account be deleted.

We retain your information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect ITMH’s legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. More specifically, we would retain some data for longer periods of time for the following reasons:

Security, fraud, and abuse prevention: i.e., to protect you, other people, and ITMH from fraud, abuse, and unauthorized access.
Financial recordkeeping: When you make a payment to ITMH we are often required to retain this information for long period of time for purposes of accounting, dispute resolution, and compliance with tax, anti-money laundering, and other financial regulations.
Complying with legal or regulatory requirements: To meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce ITMH’s Terms of Use or other terms of service, including investigation of potential violations.
Direct communications with ITMH: If you have directly communicated with ITMH, through a support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

Even if you delete your account, keep in mind that the deletion by ITMH’s third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to support@itmhcorp.com.

20.Data Security

ITMH has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where ITMH has given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. ITMH asks that you not share your password with anyone. ITMH urges you to be careful about giving out information in public areas of the Platform or the sharing of information with third parties.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although ITMH takes reasonable steps to protect your personal information, ITMH cannot guarantee the security of your personal information transmitted to or through the Platform. Any transmission of personal information is at your own risk. ITMH is not responsible for circumvention of any privacy settings or security measures contained on the Platform.

21.Changes to ITMH’s Privacy Policy

ITMH may update the Privacy Policy from time to time. If ITMH makes material changes to how it treats its users’ personal information, ITMH will post the new Privacy Policy on this page with a notice that the Privacy Policy has been updated. The date the Privacy Policy was last revised is identified at the top of the page. If we make changes that materially affect your privacy rights we will notify you of the changes by posting a prominent notice on our Platform or using other methods that we select, such as sending you an email.

21.Contact Information

To ask questions or comment about this Privacy Policy and ITMH’s privacy practices, contact ITMH at: support@itmhcorp.com.