What is the scope of this privacy policy?

Intergalactic Network Inc is strongly committed to your privacy. We respect the privacy of our website visitors and our Click app users.

With this Privacy Policy, we (meaning Intergalactic Network Inc International and our subsidiaries; hereafter “Intergalactic Network Inc,” “we,” “us,” “our”) want to inform you why and how we may process your personal information, when and why we could share your personal data, and your rights and choices to control your personal data in accordance with the applicable laws. We collect your data through our Click application, our websites (hereinafter “Sites”) and our online services (collectively hereinafter referred to as our “Services”) and when you contact us, you communicate with us via our online or social media channels.

Who we are?

Intergalactic Network Inc is a wireless network connecting and securing the next trillion Internet of Things using smartphones and Bluetooth Low Energy (BLE).

We also provide Click that is the world’s first digital trust network to authenticate content and combat misinformation plus fake news. Click confirms content is real and actually happened at a specific location, time, and via a specific device and camera. Click leverages the blockchain to create a unique cryptographic signature. The blockchain’s immutability ensures that once data is recorded, it cannot be altered or tampered with. This makes it a secure and reliable way to store content and its credentials. By signing content with Click and recording it on the blockchain, a public record is created that can be verified by anyone. Only signed content can be publicly shared, anyone viewing the content can verify the content’s authenticity easily via Click’s public website and mobile app.

Click supports The Coalition for Content Provenance and Authenticity (C2PA) which addresses the prevalence of misleading information online through the development of technical standards for certifying the source and history (or provenance) of media content.

What information do we collect?

We can collect “Personal Data” (or “Data”) that identifies you:

• either directly, such as your email address (if you provide us your email address or if you log in with Twitter account) or your name (if you log in with Twitter account) ;

• or indirectly, your location data, timestamp, a cookie or another identifier if you use our Click application or our website.

When do we collect your personal data and for what purpose?

We may collect your Data:

1. You use our Services:
   We can collect some Data to provide you with our Services, to improve and personalize your online experience, understand and analyze how you use our Services and develop new services, features, and functionality, analyze trends, prevent fraud and improve the security of our Services.
   
   When you visit our website, we may collect the following types of information:

   • Contact Details: this includes information such as your email address when you subscribe to a newsletter (hereinafter your “Contact Details”).

   • Technical information: your browsing data and technical Information, to access to our Services and security of our Services, such as: visited pages, identifier of your connection (IP address), dates and times, information about the browser and the operating system you use.

   
   When you use our Click application, we may process the following types of information:
   • Email Address: optionally provided by you or if you log in with your Apple or Twitter account. Additionally, when logging in with Apple, you can utilize the “Hide My Email” feature, generating a unique, random email address that forwards to your personal account, ensuring the privacy of your real email address.
   • Twitter Information: We collect your public Twitter information for waitlist registration, that includes Name, Number of followers, Profile description, and Location if available on Twitter.
   • Location Data: The location data is collected when a photo is taken, then recorded in file metadata, and signed with C2PA and NFT metadata if minted as an NFT.
   • Content Metadata: This metadata Includes date, time, camera settings, and image settings, location, certified with C2PA.
   • Photo: when you take a photo, the file that includes the photo and its metadata stays locally accessible on your phone and can be deleted without any remnants. You can sign the file with your key, which involves uploading the file to the distributed file system IPFS and pushing file details onto the chain as an NFT. Once minted as an NFT, the file becomes publicly accessible, cannot be deleted, and persists even if the app is uninstalled. You do not incur any fees for NFT minting. All associated costs are covered by Intergalactic Network Inc.
   • Technical Information: This includes IP address, MAC address, and browsing data and any other usage data. We use our SDK and various types of technologies such as cookies (hereinafter ”Cookies”) to collect such Data when you use our Services. We allow some of our partners to set and access their Cookies on your device. These partners' use of Cookies is subject to their own privacy policies and not this Privacy policy. To refuse Cookies or request their deletion as well as obtain the list of partners who are permitted to store and/or access these Cookies, please visit the Cookies policy or the “How do you exercise your rights?” section below.


2. You accept to receive push notification, or you sign up to our newsletters, ask to be contacted by us or our partners.
   
   Push Notifications. If you have opted-in to receive push notification on your device, we can process your data to push you some personalized notifications on your device. You can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
   
   Emails and Newsletters. We collect your email address and other contact details when you sign up to our newsletters or ask to be contacted by us or our partners. You can unsubscribe at any time by clicking on the unsubscribe link available at the end of each newsletter.
   
   You cannot opt-out of push notifications or non-promotional emails, such as those about your account, transactions or servicing.


3. You contact us via our customer support or social media.
   If you contact us via our customer support, we collect Data such as your first name, your last name, your username, your email address, your date of birth, your postal address, depending on your questions or requests. We will record the content of our correspondence with you (such as feedback and questions to customer support).
   
   This data could be used to monitor service quality and compliance, prevent fraud, or provide training for our staff and customer service teams.
   
   If you contact us via social media, we collect some of the Data included on your profile.


4. You take part in a survey
   
   We could organize surveys within our application or our community (discord channels, telegram channels), and collect Data for administering the survey, analytics, statistics and marketing purposes (e.g. sending you promotional offers).


5. You do not comply with our terms and conditions.
   
   When you use our Services, we ask that you comply with our terms and conditions which are intended to protect our users, employees, and our rights.
   
   If you do not abide by these rules, you may be blocked your account including in the event of inappropriate conduct. We will keep your Data for the time needed to apply these exclusions. This Data may include for example your username, your IP address, and the identifier of your device.

How long do we keep your Personal Data?

Unless the law specifies a different retention period (e.g. for complying with legal, accounting, tax requirements and for managing your rights and/or our rights), we will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected. At the end of this data retention period, your personal data will be erased or anonymized.

Due to the nature of blockchain, the retention period of the personal data embedded to manage the file uploaded to IFPS (e.g. the Photo and its metadata) is aligned with the duration of the blockchain.

In which situation your data could be shared?

We may share your Data with:

• The competent Administrative or judicial authorities or any other authorized third party, in compliance with applicable laws. We always verify the legitimacy of the request. We may share Data to establish, exercise or defend our and/or your legal rights (this includes providing Data to our professional advisors).

• We share information with our related entities, including our parent, sister, and subsidiaries for business purposes such as customer support, marketing, product development, technical operations and administering the Services.

• Subsidiaries and Affiliates: In connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets, including in the unlikely event of a bankruptcy, we may transfer your Data to service providers, advisors, potential transactional partners, or other third parties. If the transfer or sale goes ahead, the companies receiving your Data can use your Data in the same way as us. The use of your Data following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

We can work with some partners who use your usage data to help us make our services better via Cookies: to consult the list of these partners, please visit the Cookies page. These third-parties (except our subsidiaries) have their own privacy policies which you may refer to for information about how they process your information and how to exercise your data subjects' rights as provided under applicable laws. We do not accept any responsibility or liability for the policies of other organizations.

When you decide to share a photo and its metadata, this data is uploaded to the IFPS and is publicly available and cannot be altered or deleted. Please, ensure you have obtained the consent of the individuals before taking the picture of them and uploaded them to the IFPS.

We may process or transfer some Data with partners who have servers or who are based outside EEA. In such cases, the European Data may be transferred to countries located outside the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of this Data is specially ensured by the signature of standard contractual clauses approved by the European Commission or equivalent legal mechanisms such as those defined in chapter V of the Regulation (UE) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter ”GDPR”).

What are your rights?

Due to the nature of blockchain, your privacy rights (e.g. rectification, object and erasure rights) are not extended to the data embedded in the blockchain. This personal data stored on the blockchain is limited to the photo and its metadata you have decided to sign with your private key.

• Obtain a copy of your Data - “Right of access and data portability”: You have a right to see the personal data we hold about you and you can request a copy of this data. You also have the right to request a copy, in an interoperable format (right to your data “portability”), of the personal data that you have provided to us for the performance of a contract with us or under your consent. You may also use it yourself or transfer it to another service provider. If you have been excluded in relation to our Services, we will not be able to give you access to the Data regarding your sanction to maintain our ability to detect or act against such behavior.
• Correct your Data - “Right to rectification”: If you believe we hold inaccurate or missing information, please let us know and we will correct it.
• Object to our use of your personal data (Right to object): We will consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it. At any time, you can unsubscribe of the reception of newsletters (please use the unsubscribe link available in our newsletters). You can also opt-out at any time of the marketing Push Notifications on your device by adjusting the permissions in your device or uninstalling our app.
• Give and withdraw your consent (Right to consent):At any time, you may withdraw your consent or object to:
• Correct your Data - “Right to rectification”: If you believe we hold inaccurate or missing information, please let us know and we will correct it.
  
  
  • Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
  • Location Sharing: The Click App needs permission to capture device location. You can stop collection of precise location data from the Click App by withdrawing your consent through your device settings. You can also stop all collection of information via any app by uninstalling it.
• Right to erasure (Right to be forgotten): You can request the deletion of your data when:
  
  
  • We no longer need to keep your personal data.
  • You have successfully made a general objection.
  • You have withdrawn your consent to us using your personal data (where we have relied on consent as the lawful basis for doing so).
  • We have unlawfully processed your personal data.
  
  If you have been sanctioned in relation to our Services, we cannot delete the Data regarding your sanction as to allow us to maintain your sanction.
  
  PLEASE REMINDER, DUE TO THE INHERENT TECHNOLOGY OF BLOCKCHAIN (I.E., ITS IMMUTABLE NATURE), YOUR PRIVACY RIGHTS TO BE FORGOTTEN ARE NOT APPLICABLE TO ANYTHING THAT IS PUBLISHED ON THE BLOCKCHAIN.
  
  
• Limit the use of your data (Right to restriction of processing): you can restrict our use of your personal data (if you do not want us to delete it), if you have successfully made a general objection, you are challenging the accuracy of the personal data we hold, or we have used your personal data unlawfully.
  If you object to the processing or withdraw your consent or ask for the deletion of your personal data by us, we will stop processing your personal data or erase it from our IT systems, except where we have legitimate and compelling grounds for processing, or for the purpose of ascertaining, exercising, or defending its legal rights in accordance with the applicable laws and regulations.

How do you exercise your rights?

To exercise your rights,you can also contact us. But before we can facilitate these rights, we will first need to be able to identify you based on the information that we have about you.

We will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We'd like the chance to resolve any complaints you have. However, if you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the regulatory authority in your country.

How do we secure your personal data?

To ensure the security and confidentiality of your Data, we implement appropriate physical, electronic and organizational procedures to safeguard and secure Data throughout our Services, in particularly, to prevent your Data from being distorted, damaged or communicated to unauthorized third parties, by ensuring an appropriate level of security with regards to the risks associated with the processing and the nature of Data to be protected.

Where you use a password for registering with our Services, you are responsible for keeping this password confidential. We ask you not to share your username and/or password and/or your private key with anyone.

We cannot guarantee the security of Data that you transfer over the internet or a telecommunication network to us; however, we do take appropriate technical and organizational measures to safeguard your personal data.

What is the lawfulness of processing?

The lawfulnesses of the data processings are:

• A contract between you and us to provide you with Services
• A legitimate interest: offering you the best possible user experience (including understanding our product – strengths, weaknesses, opportunities and threats, testing and developing new products and services as well as improve existing ones, understanding and keeping abreast of current, new and emerging trends in our industry), administering and protecting our Services (maintaining the integrity of our IT services and network security, troubleshooting, system maintenance, support, reporting and hosting of data), responding to your requests and questions or sending you our newsletters, keeping our records up to date.
• Complying with a legal obligation: responding to complaints and queries from competent administrative or judicial authorities or any other authorized third party, in compliance with applicable laws

Children’s Privacy

Our Services are not intended for use by or directed towards children. Accordingly, we do not knowingly collect and maintain the information of anyone under the age of 18. Where we discover that the user is a child, we will promptly delete the associated user account and any personal data linked to this account, except where that data is part of the blockchain, in which case it is immutable and cannot be deleted.

Update of our Privacy policy Policy Updates

Please note that we may update or change this privacy policy. If we update our privacy policy, we will post those changes to other appropriate places. You are deemed to have accepted the new terms of the privacy policy when you first use the Services.

To let you know when we make changes to this Privacy Notice, we will amend the revision date at the top of this page. The new modified or amended Privacy Notice will apply from that revision date. Please check back periodically to see changes and additions.

Contact

If you have any questions about this privacy policy, please contact our Data Protection Officer by using this contact form or by mail: Data Protection Officer, Intergalactic Network Inc, 2443 Fillmore Street #287, San Francisco, CA 94115

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us by using this contact form.

Your Californian privacy rights

This privacy notice for California Residents supplements the information contained in this Privacy Policy and applies to visitors, users, and others who reside in the State of California. Consumers residing in California have certain rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”).

• Notice of Collection and Use
  In the preceding 12 months, we could collect the following categories of Data: identifiers, personal information categories listed in the California Customer Records statute, commercial information, internet or other similar network activity, and geolocation data. For examples of more specific information, we collect and the sources of such collection, please see Section “When do we collect your Personal Data and for what purpose?” in the Privacy Policy. We collect your Data for the business and commercial purposes described in the dedicated section.
  
  
  • The categories of personal information we have collected about you.
  • The categories of sources from which the personal information was collected.
  • The categories of personal information about you we disclosed for a business purpose or sold.
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold.
  • The business or commercial purpose for collecting or selling the personal information.
  • The specific pieces of personal information we have collected about you.
  
  
  To exercise any of these rights, please contact us by using our contact form. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
  
  
• Right to Opt-Out
  To the extent Intergalactic Network Inc sells and shares your personal information as the terms “sell” and “share” are defined under CCPA and CPRA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by using our contact form.


• Authorized Agent
  You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and will verify your identity directly.


• Right to Non-Discrimination
  You have the right not to receive discriminatory treatment by us for the exercise of any your rights.


• California Shine the Light Law
  California Civil Code Section 1798.83 permits users of services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit a verifiable consumer request to us by writing to us at:
  
  Intergalactic Network Inc
  2443 Fillmore Street #287
  San Francisco, CA 94115
  
  We may still retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements.
  
  California Do Not Track Disclosures: “Do Not Track” is an internet browser setting regarding tracking and your browser may allow you to set a DNT signal indicating that you do not wish your online activity to be tracked. As there are currently no agreed upon standards for the DNT signals or how to respond to them, our system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.

Data Subject Request

Please use the form below if you want to make a request regarding your data. Your email address will be used as the point of contact for our privacy team to answer your requests.