Privacy Policy and Data Protection

Introduction

This Privacy Policy outlines our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by International Insights Pte Ltd (“II”, or “we” and cognate words). It also outlines the methods by which we and our Service Providers may (subject to necessary consents) monitor your online behaviour to tailor our services. This Privacy Policy also tells you how you can verify the accuracy of your personal data and how you can request that we delete or update it.

This Privacy Policy applies to all visitors to the International Tax Bytes by Steve Towers (“ITB”) Website (www.itbstevetowers.com) and/or App, regardless of whether the visitors are Subscribers or Subscription Permitted Users or otherwise.

By visiting and/or using the ITB Website and/or App, you are agreeing to the terms of this Privacy Policy. If you have questions about this Privacy Policy, or our use of your personal information, cookies or similar technologies, please contact us by email at privacy@internationaltaxbytes.com.

Please note that some terms which are used in this Privacy Policy, are defined in our Terms & Conditions (“T&C”). Those same definitions apply to those terms as used in this Privacy Policy. You can view the most current version of our T&C on the ITB Website and App.

Information Collection

We receive and store information about you such as:

• Information you provide to us: We collect information you provide to us which includes:
  • your name, email address, job title, company name, country, and Payment Method. We collect this information in several ways, including when you enter it while using our service, interact with our Customer Service personnel, etc.;
  • information which you choose to provide in account settings or preferences in My Account, or otherwise provide information to us through our service or otherwise.
• Information we collect automatically: We collect information about you and your use of the ITB Service, your interactions with us, as well as information regarding your computer or other device(s) used to access the ITB Service. This information includes:
  • your activity regarding the ITB Service, such as watch history, search queries, etc;
  • details of your interactions with our Customer Service personnel, such as the date, time and reason for contacting us, notes of any conversations, and if you call us, your telephone number.
  • device IDs or other unique identifiers, device and software characteristics (such as type and configuration), connection information, statistics on page views, referral URLs, IP address (which may tell us your general location), browser and standard web server log information;
  • information collected via the use of cookies, web beacons and other technologies. Please see the “Cookies” section of this Privacy Policy for more details.
• Information from other sources: We might supplement the information described above with information we obtain from other sources, including from both online and offline data providers. Such supplemental information could include demographic data, interest-based data, and internet browsing behaviour.

Use of Information

We use information to provide, analyse, administer, enhance and personalise our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to:

• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our T&C (such as determining Free Trial eligibility);
• analyse and understand our audience, and improve our service (including our user interface experiences, delivery, etc.);
• communicate with you concerning the ITB Service (for example, by email, push notifications text messaging, and online messaging channels), so that we can send you news about ITB, details about new features, and special offers, promotional announcements, and customer surveys, and to assist you with operational requests such as password reset requests. Please see the “Your Choices” section of this Privacy Policy to learn how to set or change your communication preferences.

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

• Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, communications, infrastructure and IT services, to personalise and optimise the ITB Service, to process credit card transactions, to provide customer service, to analyse and enhance data (including data about customers’ interactions with the ITB Service), and to process and administer customer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We prohibit them from using or disclosing your personal information except in connection with providing their services.
• Protection of II: II and our Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce our T&C, including investigation of potential breaches thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of II, the users of the ITB Service or the public, as required or permitted by law.
• Business transfers: In connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, we may transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy.

Whenever in the course of sharing information we transfer personal information to countries or regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.

You may also choose to disclose your information in the following ways:

• Certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the applications on your smart device;
• Social plugins (including those offered by Facebook, Twitter, and LinkedIn) allow you to share information on those platforms.

Social plugins and social applications are operated by the social networks themselves and are subject to their terms of use and privacy policies.

Access to Your Account and Profiles

To provide you with highly secured access to your account and to help administer the ITB Service, you are required to log in with your own-created password and the One-Time Password (OTP) authentication. In addition, our system will permit you to make only one login at one time.

To remove access to your ITB account from your device, (a) visit “My Account” and choose “Log off” or (b) delete your ITB settings from your device (steps vary by device and the option is not available on all devices). Where possible, users of public or shared devices should log out at the completion of each visit. In any case, if a login session has no action for one hour, it will be automatically logged off.

If you allow others to have access to your account, they will be able to see your information (including in some cases personal information) such as your watch history, account information (including your email address or other information in My Account), etc.

Please also be aware of the limitations on use of the ITB Content, as set out in section 6 of the T&C.

Your Choices

If you no longer want to receive certain communications from us via email, simply click the “unsubscribe” button available in our emails. Please note that you cannot unsubscribe from certain email correspondence from us, such as messages relating to your account transactions.

To exercise choices regarding cookies set through the ITB Website and/or App, as well as other types of online tracking, see the “Cookies” section of this Privacy Policy.

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You can do so by visiting the “My Account” portion of the ITB Website and/or App, where you can access and update a broad range of information about your account, including your contact information, your Payment Method, and various related information about your account (such as your favourite video podcasts and your watch history). You must be signed in to access “My Account”.   You may also request that we delete personal information that we hold about you.

To make requests, or if you have questions regarding our Privacy Policy, please contact us at privacy@internationaltaxbytes.com.  Please also see the “Your Choices”section of this Privacy Policy for additional choices regarding your information.

We may reject requests that are unreasonable or not required by law, including those that would be impractical, could require disproportionate technical effort, or could expose us to operational risks such as Free Trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honour your choices, for our billing or records purposes and to fulfil the purposes described in this Privacy Policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information.

Other Websites, Platforms, and Applications

The ITB Service may be provided through and/or utilise features operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access the ITB Service through platforms such as computers, mobile devices, and several other internet connected devices. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully. In addition, you may encounter third party applications that interact with the ITB Service.

Changes to this Privacy Policy

We will update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. The most current version of the Privacy Policy, showing the most recent updates and the effective date of such updates, can be viewed on the ITB Website and App. Your continued use of the ITB Service after such updates take effect will constitute your acceptance of those changes. If you do not accept any updates to this Privacy Policy, you may cancel your use of the ITB Service. To see when this Privacy Policy was last updated, please see the “Last Updated” section of this Privacy Policy.

Cookies

We and our Service Providers use cookies and other technologies for various reasons. For example, we use cookies and other technologies to make it easy to access our services by remembering you when you return, to provide and analyse our services, and to learn more about our users and their likely interests. We want you to be informed about our use of these technologies, so this notice explains the types of technologies we use, what they do and your choices regarding their use.

1. What are cookies?

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are uniquely assigned to your device and are sent back to the originating website on each subsequent visit or to another website that recognises that cookie. Some of the cookies used by the ITB Website and App are set by us, and some are set by third parties who are delivering services (such as web analytics) on our behalf.

2. Why does ITB use cookies?

We and our Service Providers may use the following types of cookies:

• Essential cookies: These cookies are strictly necessary to provide our Website and App service. For example, we or our Service Providers may use these cookies to authenticate and identify our subscribers when they use the ITB Website or App, so that we can provide our service to them. They also help us to enforce our T&C, prevent fraud and maintain the security of our service.
• Performance and functionality cookies: These cookies are not essential, but they help us to personalise and enhance your online experience with ITB. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during subscription registration). We also use these cookies to collect information (such as popular pages, viewing patterns, click-through and other information) about our customers’ use of the ITB Service so that we can enhance and personalise the ITB Website and App and conduct market research. Deletion of these types of cookies will result in limited functionality of the ITB Service.

3. How can I exercise choice regarding cookies and other types of online tracking?

• By using the ITB Website and/or App, you agree that we can place cookies on your computer or device as explained above. However, you can control and manage cookies in various ways. Please bear in mind that removing or blocking cookies can impact on your user experience and parts of the ITB Website and/or App may no longer be fully accessible.
• Browser controls
  • Most browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. For more information on how to modify your browser settings to block or filter cookies, seehttp://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.
• Managing Analytics cookies
  • You can opt-out of having your anonymised browsing activity recorded by analytics cookies. We use the following service providers and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the following links:
    • Adobe: http://www.adobe.com/privacy/opt-out.html
    • Google Analytics: http://www.google.com/analytics/learn/privacy.html
• Managing Local Shared Objects or Flash Cookies
  • A local shared object or flash cookie is like most other browser cookies except that it can store additional types of information. These cookies cannot be controlled using the mechanisms listed above. Some parts of the ITB Website and/or App use these types of cookies to store user preferences for media player functionality and without them some video content may not play properly. These cookies can be controlled manually by visiting the Adobe website:
    http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Data Protection

We have appointed a Data Protection Officer, and contact details are as follows:

Last Updated: 15 June 2023 (effective immediately)