Privacy Policy


Last updated: 2/7/21

This Privacy Policy applies to InnovaSystems International, LLC (“InnovaSystems,” “Innova,” “We”, “Our”, “Us”). This Privacy Policy explains how we collect, use, and share the personal information that we gather on (“Websites”) or through your use of our recruiting software services (the “Services”). By continuing to use our Websites or the Services, you agree to the terms of this Privacy Policy.



InnovaSystems provides software and technology services to the United States Federal Government, Department of Defense (DoD), non-profits, partnerships, and other organizations (“Customers”). As part of recruiting for employment or other uses of our company website, our Customers may store personal information in the process of applying for employment or as an independent contractor. We recommend that you read this Privacy Policy in full to ensure that you are fully informed.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact information provided at the end of this Privacy Policy.



This section applies to personal information that we collect and process through our Websites and in the usual course of our business, such as in connection with our sales and marketing activities, recruitment, and events.

2.1 Information We Collect.

The personal information that we collect falls into the following categories:

2.1.1 Information You Give Us.

You may provide us information in the following ways:

  • By contacting us directly through a webform, email, social media message, or
  • By attending our events or other business interactions and providing your contact
  • By entering into our sweepstakes or
  • By applying for a job or other role with

The categories of information include:

  • Identifiers such as real name, address, email address, job title, company, or phone number.
  • Your public profile on social media accounts – depending on your privacy setting for your social media account, this includes your profile picture, social media handle, number of followers, bio, if you’re verified and your location by city and
  • Employment information and job history for individuals who apply for a role with
2.1.2 Information We Automatically Collect.

Like many website operators, we collect information that your browser sends whenever you visit our Websites or Services. We use cookies and other tracking technologies to collect some of this information.

The categories of information include:

  • Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and
  • Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our
  • Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the

We generally collect this information in the aggregate to improve the performance of our Websites. We do not associate this information with you or your computer, unless we need to investigate a violation of our Terms.


2.2 How We Use the Personal Information

We may use the personal information we collect for a range of reasons, including:

  • To share your cookie data with third-party marketing platforms (e.g. Google Ads, Facebook Ads, HotJar) to provide tailored advertising on our Websites and other websites that you may
  • To market our products and/or services to
  • To analyze Websites usage and improve the services
  • For market research, project planning, troubleshooting
  • For detecting and protecting against error, fraud or other criminal
  • To enforce compliance with our Terms and applicable


2.3 How We Share the Personal Information.


2.3.1 Affiliates and Service Providers.

We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. These service providers are under a duty of confidentiality.

2.3.2 Third Party Marketing and Advertising Organizations.

We share your information with third party marketing and advertising partners, such as Google, Facebook, Instagram, and YouTube to provide tailored advertising on our Websites and other websites that you may visit.

2.3.3 Third Party Links and Websites.

Our Websites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

2.3.4 Social Media.

Our Websites may include social media buttons or widgets (“social media elements”). These social media elements may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media elements are governed by the privacy policy of the social media company providing the feature and/or widget.

2.3.5 Disclosures Required by Law.

We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

2.3.6 Aggregate and De-Identified Information.

We reserve the right to share aggregate or de-identified information about its users with third parties for marketing, advertising, research, product development or similar purposes


2.4 Legal Bases for Processing (EEA and UK Individuals).

If you are from the European Economic Area or the United Kingdom, our legal bases for collecting and using your personal information is as follows:

  • Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our
  • Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatary retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such
  • Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any
  • In some limited cases, we may also have a legal obligation to collect Personal Information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How Do We Share Personal Information?”

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Contact Information” section below.




3.1 General

3.1.1 Marketing Opt-Out:

We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send. You will still continue to receive service-related messages concerning our Services.

3.1.2 Exercising Your Privacy Rights:

We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws and may remove or update your information within a reasonable time and (where applicable) after providing notice to the Customer of your request. We may ask you to verify your identity in order to help us respond efficiently to your request.


3.2 California Residents

3.2.1 Third Party Marketing.

California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the Contact Information below.

3.2.2 California Consumer Privacy Act.

If you are a California consumer, you have the following rights beginning on January 1, 2020:

  • The right to know what Personal Information is being collected about
  • The right to know whether your Personal Information is sold or disclosed and to
  • The right to say no to the sale of Personal
  • The right to access your Personal
  • The right, in certain circumstances, to delete the information you have provided to
  • The right to equal service and price, even if you exercise your privacy rights, unless the difference in service and/or price is reasonably related to the value provided to the you by your Personal
3.2.3 Requests for Deletion and Information.

In certain circumstances, California consumers have the right to request that we delete their information. In addition, California consumers have the right to request, up to twice in a 12- month period, that a business that collects Personal Information about the consumer disclose to the consumer the information listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information.

  • The categories of Personal Information it has collected about that
  • The categories of sources from which the Personal Information is
  • The business or commercial purpose for collecting or selling Personal
  • The categories of third parties with whom the business shares Personal
  • The categories of Personal Information that the business sold about the consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was
  • The categories of Personal Information that the business disclosed about the consumer for a business
  • The specific pieces of Personal Information it has collected about that

To make such a request, please contact us at the contact information below.

Do Not Sell My Personal Information. California consumers have the right to opt out of the sale of the consumer’s personal information. To make such a request, please contact us at the contact information below or submit a request online.



3.3 EEA and UK Residents

3.3.1 EEA and UK Privacy Rights.

If you are from the European Economic Area or United Kingdom, you have the right, under certain circumstances, to:

  • Access your Personal Information;
  • Correct inaccurate Personal Information;
  • Request erasure of your Personal Information without undue delay;
  • Request the restricted processing of your Personal Information;
  • Request portability of the Personal Information that you have given us; and
  • To object to the processing of your Personal Information, including the ability to object to automated processing and/or

If you are from the European Economic Area or United Kingdom, you also have the right to lodge a complaint with a supervisory authority, under certain circumstances.

You may contact us at the contact information below for more information, or to exercise your rights.




Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States and abroad, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail a transfer of your Personal Information across international borders, including, but not limited to, transfers from within the European Economic Area (the “EEA”) or the United Kingdom to the United States. The data protections standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any Personal Information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.

If you are a Customer and wish to upload the personal information of individuals residing in the European Economic Area or the United Kingdom, please contact us for a copy of our Data Processing Addendum using the contact details provided in the “Contact Information” section below.




Our Websites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us at the Contact Information below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.




Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.




To make our Websites and Services work properly, and to provide tailored advertising, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy.




Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.




For Customers, we retain the information we receive for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws.



We take appropriate and reasonable technical and organizational measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

However, please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, keeping your log-in and password private. You agree that we are not responsible for lost, stolen, or compromised passwords or for any activity via unauthorized password activity.




This policy is reviewed and updated annually. We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. This policy is implemented under the supervision of the organization’s appointed Data Protection Officer (DPO). The DPO works closely with the organization to ensure that privacy principles and required privacy controls are implemented and maintained on an ongoing basis. The DPO negotiates a budget for privacy operations and implementation with CIO/CISO annually.

We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Websites.




If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us at:


Data Protection Officer:

Robin Evans, CPO/DPO InnovaSystems Int’l, LLC 619-955-5800